SMKOR updates in 2025: key changes and clarifications from the State Tax Service

In 2025, the Risk Assessment Criteria Monitoring System (SMKOR) underwent significant changes, with a series of official explanations provided by the State Tax Service. The main goal is to optimize the mechanism for automatic blocking of tax invoices (TI) and adjustment calculations (AC), reduce the number of accidental blockings of bona fide taxpayers, and increase procedural transparency and the stability of VAT administration.

Key Directions of Changes in SMKOR
As of September 27, 2025, amendments to CMU Resolution No. 1165 came into force. These include a number of innovations:

• Increased thresholds for unconditional registration of TI and AC: the limit for one TI has been increased from 5 to 10 thousand UAH, and the monthly supply volume—from 500 thousand to 3 million UAH.
• Updated criteria for unconditional registration now include expanded requirements for a positive tax history (turnover per counterparty, the number of companies in which a director can hold a similar position, etc.).
• The automatic unblocking mechanism for TI and AC has been improved: if the risky status is removed or when considering data tables, a positive tax history is also taken into account—this allows for a faster and simpler return to normal operations.

Risk Mechanism Updates

• Separate clarification of the criteria for risky taxpayers and signs of risky operations, particularly regarding adjustments for returns of goods by non-VAT payers (the time limit has been increased from 30 to 90 days).
• The formula for evaluating transaction volumes has been changed to reduce the number of incorrect blockings of TIs and to identify specifically risky taxpayers.
• Enterprises from areas with increased security risks are granted additional concessions and simplified access to unconditional TI registration.

Tax Service Efficiency and Openness
The STS emphasized the transition to a “one-click tax” model and the enhancement of dialogue with business. Regional consulting centers have been established, where entrepreneurs can promptly obtain advice on unblocking and completing data tables. All changes are being developed in close cooperation with business associations and expert communities.

Clarifications on the Taxpayer’s Data Table
The new data table consideration mechanism is automated. Now, after submission, supporting documents are not always required—the system recognizes repeated submissions and resolves issues automatically. There is also a complaints procedure allowing for decisions to be canceled through the accumulation of a positive taxpayer history.

Impact on Reliable Taxpayers
The changes have significantly reduced administrative burdens for those constantly confirming the legality of their operations and demonstrating business transparency. According to STS forecasts, the share of blocked invoices in 2025 has halved—from 0.76% to 0.39% of the total. Substantiating taxpayer data and unblocking has become less bureaucratic and faster.

Negative Phenomena and Actual Challenges
Alongside positive innovations, there is an increase in the total amount of blocked VAT. Meeting risk criteria has become more difficult for companies with large turnovers or non-standard delivery practices.
One continuing problem is the lack of proper automation of interaction with the tax authority on contentious issues. Companies still risk being placed in the “risky segment” due to one-off discrepancies or technical system errors.

Prospects and Next Steps
The STS announces expanded analytics, audit digitalization, and integration with government digital services (Diia). The aim is to simplify operations for companies conducting transparent business flows, while strengthening control over abnormal or suspicious fiscal transactions.
The decisive factor for the effectiveness of these changes will be the balance between control and service, as well as the broad involvement of business in the development of new rules through open dialogue.

Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”.

If you have any additional questions or need expert advice on issues related to the blocking of invoices, feel free to request a consultation!