The State Tax Service will audit 1016 individuals in 2026

The State Tax Service of Ukraine has published an updated schedule of documentary audits for 2026, which includes 1,016 individuals. For wealthy citizens and active sole proprietors this is a clear signal of tighter tax control and increased attention to their income in 2026.

What is a schedule of documentary audits
A schedule of documentary audits is the official list of taxpayers that the tax authority plans to audit during the year. It is formed using a risk‑based approach: it includes taxpayers with increased risks of tax non‑payment or abuse (high income volumes, sharp financial fluctuations, transactions with non‑residents, work with “risky” counterparties, tax debts, etc.).
Planned documentary audits of individuals involve a detailed review of primary documents, contracts, bank statements, asset and income declarations and data from state registers. They are carried out at the taxpayer’s place of registration and usually cover several tax periods.

Why individuals are in focus
The fact that the State Tax Service separately plans to audit 1,016 individuals shows growing attention to citizens’ income that does not always pass through the classic business segment. This primarily concerns:

• individuals with high declared or actual income (rent, sale of real estate, investments, securities transactions);
• sole proprietors with significant turnover who may be audited both as entrepreneurs and as private individuals;
• persons whose expenses (purchase of property, cars, luxury assets) significantly exceed their officially declared income;
• persons involved in other audits or criminal proceedings where potential tax violations have been identified.

In recent years the state has been moving towards a model where an individual’s financial behaviour is analysed comprehensively: through tax reporting, banking data, information from public registers (real estate, vehicles) and international tax information exchange (CRS/EOIR for certain jurisdictions).

How individuals are selected for audit
Inclusion in the schedule is not random. Individuals are added to the list of potential audit targets mainly on the basis of:

• analysis of filed tax returns: mismatch between income and type of activity, unusual or sharp year‑to‑year changes;
• data on major assets: purchase of expensive housing, cars or business assets with relatively modest declared income;
• information from banks and other institutions: significant movements of funds on accounts, regular inflows from abroad, securities and derivatives transactions;
• results of audits of counterparties: if a corporate audit reveals suspicious transactions with an individual, this may trigger their inclusion in the schedule;
• participation in risky schemes, such as splitting business across several sole proprietors, sham civil contracts instead of employment contracts, etc.

Thus, the updated 2026 schedule should be seen as the result of prior risk analysis rather than a “random sample”.

What will be audited for individuals
· Declaration of income from rental of residential and commercial property and land.
· Timeliness and completeness of payment of personal income tax, military levy and social contributions (for sole proprietors).
· Real estate transactions: frequency of sales, market‑level prices, use of tax exemptions.
· Foreign income and transactions: salaries, dividends, interest, royalties, crypto transactions and foreign accounts.
· Investments: transactions with shares, bonds, corporate rights and startups.
· Consistency of lifestyle with officially declared income (major purchases, travel, expenses).

Potential consequences for taxpayers
For individuals included in the schedule, an audit may lead to:

• additional tax assessments (personal income tax, military levy, social contributions) if underreporting or concealment of income is found;
• fines and late‑payment interest for incomplete or late tax payments;
• initiation of criminal proceedings where the amount of tax evasion is significant or deliberate schemes are detected;
• blocking of certain transactions, freezing of bank accounts or assets as part of criminal or enforcement procedures.

At the same time, for compliant taxpayers an audit may end without negative consequences, but it will still require time, document collection and professional support.

Risks of informal activity and “cash” schemes
The updated 2026 schedule targets informal economic activity by individuals who earn systematically but do not register as entrepreneurs and do not declare income. This includes:
· unofficial provision of services (consulting, IT, creative, educational);
· continuous rental of housing or commercial premises without formal contracts;
· systematic online trading without registering as a sole proprietor;
· use of cryptocurrencies and electronic payment systems to “anonymise” income.

As digitalisation and data exchange grow, the belief that cash and online payments will remain invisible is increasingly unrealistic: the tax service builds risk profiles and analyses taxpayer behaviour.

How to prepare for possible audits
Review your tax history for the last 3–5 years: completeness of income declaration and payment of personal income tax and the military levy.
Check rental, sale‑purchase and investment contracts and ensure you have supporting documents for all major transactions.
Organise bank statements and primary documents (acts, invoices, delivery notes, certificates, receipts).
If you are self‑employed or a sole proprietor, make sure your tax regime matches your real turnover and types of activity.
If you have foreign income or accounts, assess your tax obligations in Ukraine, considering double‑tax treaties.
If you are a business beneficiary, analyse risks of transactions with related companies, intra‑group loans, dividends and financial assistance.

What this trend means for 2026
The updated schedule and explicit number of individuals planned for audits show a clear trend: the state is shifting from focusing only on businesses to deep monitoring of private finances. This aligns with global practice, where the fight against shadow income, money laundering and aggressive tax planning targets not only companies but also ultimate beneficial owners — individuals.

For citizens this means that “personal” financial behaviour will increasingly be viewed through the lens of tax transparency. Those who proactively organise their documents, declare income and think in terms of tax planning rather than “minimisation at any cost” will be in a better position.

If you have questions or issues related to audits by the State Tax Service, additional tax assessments, legalisation of income or preparation of documents for tax control, it is advisable to consult tax law and advisory professionals to minimise risks and protect your interests.

Author: Ihor Yasko, Managing Partner at WINNER Law Firm, PhD in Law.