STS approved the “white list” of companies: what does it mean for business?

In September 2025, the State Tax Service of Ukraine (STS) announced the approval of a new list of so-called “white businesses” — a register of companies and economic entities that have demonstrated a transparent tax history, proper fulfillment of budget obligations, and compliance with integrity criteria. The introduction of this list is another step in reforming the tax administration system, strengthening trust between the state and responsible businesses, and reducing pressure on entrepreneurs who operate legally.
The initiative immediately drew the attention of experts, as it represents a kind of “institutionalization of trust”: instead of treating all taxpayers with suspicion, the tax authorities are shaping a selective approach, recognizing those who consistently provide honest reporting, comply with the rules, and avoid shadow schemes.

What is “white business”?
In tax terminology, a “white business” refers to companies or sole proprietors that operate fully legally, regularly pay taxes, maintain transparent reporting, and do not use artificial minimization tools. At different times, tax authorities have tried to encourage such enterprises by reducing the number of inspections, simplifying interaction procedures, or accelerating VAT refunds.

The new STS list systematizes this approach at a new level: businesses included in the register receive official “white” status and thus a range of guaranteed advantages in dealing with the tax service.

Preconditions for creating the register
The establishment of the list was driven by several factors:

• A large shadow economy, estimated at around 30% of GDP in 2024.
• Business distrust of the STS, with audits historically used as a tool of pressure.
• EU integration commitments, requiring Ukraine to implement compliance-based mechanisms.
• The demand of society, with business associations advocating for the rewarding of transparent companies.

Key criteria for inclusion
The STS defined several criteria for businesses eligible for the list:

• flawless tax history over the past three years,
• absence of tax debt and penalties,
• no pending criminal cases concerning tax crimes,
• transparent ownership structure and disclosure of final beneficiaries,
• confirmation of real economic activity (no signs of fictitiousness),
• adequate wage levels, not lower than the industry average.

Thus, the criteria go beyond formal compliance, emphasizing fair pay and the avoidance of fictitious schemes.

What benefits does business receive?
Inclusion in the “white business” list provides:

• reduced risk of inspections,
• expedited VAT refunds,
• priority in public tenders,
• reduced bureaucracy and simplified procedures,
• enhanced business reputation.

Potential risks and threats
Despite the positive effects, concerns remain, such as:

• subjective application of criteria,
• risk of corruption or abuses,
• creation of a “two-tier” business environment,
• possible political manipulation.

Impact on the business climate
The “white registry” could foster a culture of voluntary tax compliance, improve competitiveness, and attract foreign investment. However, if applied unfairly, it could undermine trust in the initiative itself.

Reaction of the business community
The European Business Association and the American Chamber of Commerce praised the idea but stressed the importance of clear and equal procedures. Tax consultants recommend transparent rules for inclusion.

Future perspectives
The STS announced that the list will be regularly updated, integrated with tax ratings, and linked to electronic services. In the future, “white business” may form part of a broader tax trust framework, including real-time data exchange and reduced bureaucracy.

Thus, the new “white business” register approved by the STS marks a key step toward developing a healthier economic environment in Ukraine. Its success will depend on the transparency, fairness, and accessibility of its administration.

Author: Ihor Yas’ko, Managing Partner at “Winner Law Firm”, PhD in Law.