Tax Audit Schedule 2026: Who Was Affected by the March Update

On 26 March 2026, the State Tax Service published an updated schedule of documentary audits, which in practice is one of the key indicators of tax risk for businesses. It is not just a “list of the unlucky”, but a snapshot of the sectors, transactions and behaviour patterns that the tax authorities currently regard as the most risky, so reading the schedule correctly helps companies and sole proprietors both assess their chances of an inspection and understand the overall logic of control in 2026.

What the audit schedule is and how it is updated
The schedule of documentary audits is an official list of taxpayers the STS plans to audit during the year, compiled according to risk criteria and periodically updated as a “roadmap” for control. The update of 26 March 2026 is no longer the initial version but a revised list that takes into account new data, returns and previous audit results, so a business that was absent from the January version may well appear in the updated list now.

Trends to expect in the update
Although the specific lists of taxpayers depend on information‑system data, the STS’s general focus areas are usually predictable. In the 2026 schedule we can reasonably expect a stronger focus on:

• sectors with a high share of cash payments – retail, HoReCa and household services, where cash registers, chains of sole proprietors and “grey” turnover remain sensitive issues;
• participants in risky VAT chains – companies that show up in analytical cross‑checks related to blocked tax invoices, “carousel” schemes, imports with overstated/understated values or purely formal exports;
• exporters and importers with atypical indicators – for example, low profitability with large volumes, or mismatches between customs and tax data;
• companies with complex group structures – particularly where there are risks of business splitting among several sole proprietors and legal entities, artificial profit shifting or under‑declared VAT.

A separate group consists of taxpayers that have already been subject to unscheduled actions, additional assessments or invoice blocking. For the STS, such cases are a signal to “dig deeper”, so they more often end up in the annual plan.

How to check whether your company is on the list
Formally it is simple: the schedule is published in open access, and a taxpayer can check their EDRPOU/Tax ID code in the relevant sections. In practice, businesses often perform a single check at the beginning of the year and miss spring or summer updates when they may already have been added. Therefore, in 2026 it is advisable to monitor the schedule regularly, at least after each official update.

If you find yourself in the schedule, you should look at:

• the type of audit (planned documentary audit, VAT‑only or covering other taxes as well);
• the period to be audited;
• the approximate start date of the audit.

This information gives you time to review your reporting, turnovers, primary documents and internal policies before the inspectors arrive “on site”.

What inclusion in the schedule means for real risks
Being listed in the schedule does not guarantee that an audit will take place on the exact stated date, but it is a clear signal that your business has been classified as higher risk. It usually implies greater attention from analytical departments to your transactions, a higher probability of additional information requests and cross‑checks, and a wider range of issues during the audit (from corporate income tax to VAT, personal income tax, social contributions, transfer pricing and the reality of transactions). For management, this is not a “sentence” but it is also not a mere formality: it is cheaper to conduct an internal audit in advance than to respond in crisis mode to audit reports with additional assessments.

How to prepare for an audit under the updated schedule
The preparation algorithm depends on the size of the business, but the basic steps are similar:

1. Analyse risk areas. Assess which taxes, periods and transactions are likely to attract inspectors’ attention. If you have had blocked invoices, unusual transactions with non‑residents, high payments to sole proprietors or large losses, these areas should be reviewed first.
2. Check the completeness of primary documents. Review contracts, acts, invoices, CMR/waybills, internal orders and policies. Pay special attention to complex or “non‑standard” deals, transactions with related parties and counterparties from the “grey‑risk zone”.
3. Assess potentially contentious positions. Where transactions have ambiguous tax treatment (business purpose, reality of services, expense classification, VAT credits), prepare your arguments, legal references, individual tax rulings or court practice in advance.
4. Set internal procedures and responsibilities. Decide who will communicate with inspectors, how requests will be registered, how quickly responses will be prepared, and who makes decisions on admitting/denying entry, appealing findings, etc.
5. Consider preventive steps. Sometimes it is reasonable to correct specific errors via amended returns or voluntary top‑up payments before the audit starts, which reduces penalties and simplifies negotiations with the STS.

What businesses should focus on in 2026
The updated 2026 schedule should be viewed in a broader context. The STS continues to rely on analytical taxpayer selection based on electronic data and focuses on businesses’ historical behaviour – indicator dynamics, participation in risky chains and reaction to past comments. This means that:

• one‑off “cosmetic” adjustments in accounting will no longer hide systemic issues – trends over several years are visible;
• companies with aggressive tax models (large chains of sole proprietors, unusual compensations, quasi‑dividends) will increasingly fall within the scope of not only unscheduled actions but also annual audits;
• compliant businesses that respond to comments in a timely manner, adjust risky practices and communicate transparently with the tax service are more likely either to avoid the schedule altogether or to pass audits with minimal consequences.

In these circumstances, the schedule becomes not only a control tool but also a kind of “feedback” from the state. If your business appears in the updated list as of 26 March 2026, this is a signal that the tax service already views certain aspects of your activity as risky, and the earlier you address them, the lower the chances of a conflict scenario during the audit.

If you have questions or issues related to being included in the audit schedule, preparing for an STS visit, analysing risky transactions or building an audit‑defence strategy, you should seek professional advice to assess your specific situation and minimise potential additional tax assessments.

Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm.