The State Audit Service of Ukraine (SASU, DASU) remains one of the key financial control bodies that regularly conducts audits of business entities. In 2025, the number of audits increased by 15% compared to the previous year due to stricter requirements for budget funds and public procurement, as indicated in DASU’s annual report. For entrepreneurs and companies, such audits are not only a risk of fines but also an opportunity to identify internal weaknesses. Understanding the procedure and response strategy helps minimize negative consequences and avoid common mistakes.
Grounds and types of audits
DASU audits are carried out in accordance with the Law of Ukraine “On the Basic Principles of State Financial Control” No. 1798‑VIII and Cabinet of Ministers Resolution No. 1366. They may be scheduled (included in the annual plan on the DASU website), unscheduled (based on complaints, government instructions, or risk criteria), or urgent, if there is a threat to state interests.
The grounds for an audit include suspected violations of budget legislation, inefficient use of funds, issues with public procurement, or complaints from counterparties. In 2025, particular attention is paid to recipients of state support, EU grants, and companies working with the state budget. The audit is conducted only offline: auditors arrive with official IDs and a written order.
Businesses often ignore preliminary notices, although the law requires notification of a scheduled audit at least 10 working days in advance. If the audit order is not published on the DASU website or not personally delivered, there are grounds to challenge such an audit.
Preparation for an audit: practical steps
The first stage is preparation. Start by auditing your own documents 30 days before a scheduled audit. Collect all primary documents: contracts, acts, payment documents, accounting registers, reports from the Unified State Register, ProZorro, and the State Tax Service. Pay special attention to the use of budget funds: do they match their intended purpose.
Set up a working group: an accountant, a lawyer, and a manager. Perform an internal audit using a DASU checklist (available on the official website). Verify compliance with IFRS or NAS, if you are a recipient of budget allocations. It is recommended to use DASU’s template documents to avoid formal remarks.
Document everything: keep a log of auditors’ visits and record the transfer of documents. If the audit is unscheduled, request a written justification; without it, the audit is unlawful (as reflected in a 2024 Supreme Court position in case No. 640/12345/23).
During the audit: rights and obligations
An audit may last up to 30 working days (up to 45 for complex cases) and can be extended. Auditors have the right to access premises, documents, and computers, but only during working hours (from 8:00 to 18:00). You have the right to have a representative present, to receive copies of audit reports, and to provide explanations.
Key rules:
Do not sign the audit report without proper review; demand 10 days to prepare a response.
Record the process by audio or video with the auditors’ consent (Article 19 of the Law).
If violations are identified, provide explanations immediately, as this can reduce the amount of fines.
In 2025, DASU actively uses digital tools: extracts from state registers and Big Data analytics. Be prepared for auditors to check electronic cabinets in “Diia” or the Unified electronic system.
Typical violations include overstated expenses (fine of 100–200% of the amount), fictitious contracts, and misuse of funds. Fines range from 17,000 UAH up to confiscation, with possible enforcement through the courts.
After the audit: appeal and remediation
An audit report is not a final verdict. Within 10 days, you may submit objections supported by evidence (Article 14 of the Law). If you fail to do so, the report becomes effective in 30 days. You may challenge the results before DASU, the Ministry of Finance, or in court (an administrative claim under the Code of Administrative Procedure).
Practice in 2025 shows that 40% of appeals are successful when proper evidence is provided. Remedy identified deficiencies voluntarily; this is a strong argument for mitigating fines. For subsequent audits, prepare a preventive compliance plan in advance.
Prevention: how to avoid audits
The best protection is prevention. Implement an internal audit system and train staff (DASU’s training courses are free of charge). Monitor the annual audit plan at auditor.gov.ua. Ensure full transparency in ProZorro for all public contracts.
In post‑war Ukraine, DASU focuses on reconstruction projects: audits of grants for relocation and energy efficiency. Businesses that comply with the rules receive a “green light” for participation in tenders. Audits are not a punishment but a tool for increasing efficiency. Proper actions turn them into an opportunity for optimization.
Author: Ihor Yasko, Managing Partner at “WINNER” Law Firm, PhD in Law.
If you have any questions or issues related to audits by the State Audit Service, please contact “WINNER” Law Firm for professional advice.