Tax audits 2026

Regulatory framework of tax control 2026
In 2026, tax audits are conducted under the general rules of the Tax Code, taking into account the amendments that entered into force at the end of 2025 and on 1 January 2026. The updates concern a more precise risk‑based approach, the impact of taxpayers’ participation in “good‑faith business clubs”, and the consequences of procedural violations by the controlling authorities.
The earlier anti‑crisis moratoria and restrictions on scheduled audits applied in 2024–2025 are transformed in 2026 into more targeted mechanisms instead of a general ban on audits. At the same time, the rules on limitation periods, renewal of postponed audits and the possibility of additional assessments after the end of moratoria remain among the most contentious issues in relations with the tax authorities.

Audit schedule 2026: whom and how they select
The State Tax Service published the schedule of documentary scheduled audits for 2026 in December 2025, complying with the Tax Code requirements on publication deadlines and the limited number of updates. The schedule includes about 4.6 thousand taxpayers: legal entities, individual entrepreneurs, financial institutions and taxpayers for whom personal income tax, military levy and unified social contribution are controlled separately.
The main criterion for inclusion in the schedule is a high risk of tax underpayment or violation of legislation, determined according to criteria approved by the Ministry of Finance and the methodology of the State Tax Service. Typical risk indicators include significant potential underpayments of corporate income tax, VAT, personal income tax/military levy and social contribution, belonging to “risky” sectors (construction, fuel trade, agriculture, financial services), non‑standard supply chains and abnormal market indicators.

Risk‑based approach and new philosophy of control
From 2026, the State Tax Service moves from mass scheduled audits to targeted control focused on high‑risk taxpayers, using sectoral and industry analysis, financial indicators, history of interaction with the tax authorities, and analytical data on supply chains and counterparties.
A two‑tier system is being formed: compliant business receives minimal interference (including through participation in “white business” programmes), while companies with “red flags” are subject to enhanced monitoring and audits. This encourages taxpayers to restructure risky transactions, revise their counterparty policies and strengthen documentary evidence of the reality of business operations.

Types of tax audits and 2026 priorities
In 2026, the division of audits into desk, documentary (scheduled and unscheduled; on‑site and off‑site) and factual audits is preserved. Desk audits are automatically based on submitted returns and information system data, and their intensity increases along with the development of analytical tools of the State Tax Service.
Documentary scheduled audits are carried out according to the schedule, whereas unscheduled audits are usually related to discrepancies in reporting, tax risks, VAT refund claims, reorganisation or liquidation, as well as information from law‑enforcement bodies. Factual audits remain a tool for rapid response in relation to cash settlements, cash registers, circulation of excisable goods and labour relations, and their activity may intensify after general moratoria expire.

Moratoria, reliefs and their echo in 2026
In 2024–2025, moratoria and other restrictions on the powers of controlling authorities to conduct scheduled business audits were introduced, in particular on the basis of NSDC decisions and the President’s 2025 decree; they were temporary, allowed selective audits in high‑risk areas and were aimed at supporting economic activity and reducing administrative pressure.
In 2026, the key consequence is the “effect of postponed audits”: audits that were suspended or not started due to the moratorium may be resumed after it ends within the limitation periods, which creates a risk of accumulated claims for several tax periods and substantial additional tax assessments, fines and interest.

“White business club” and benefits for compliant taxpayers
One of the key trends in tax control is the development of “voluntary compliance” instruments, in particular the White Business Club, participation in which reduces the likelihood of audits and softens the reaction of the tax authorities, provided the taxpayer behaves transparently.
At the same time, from 2026 the benefits are clearly limited: audits that have not yet started in respect of Club members may be cancelled only from the date of official publication of the participants’ list, while already scheduled audits are not revoked by the member status, which motivates businesses to meet the integrity criteria in substance rather than formally.

Preparing for audits: practical focus for business
In 2026, the State Tax Service will focus mainly on taxpayers combining high tax risks, non‑standard business models and significant transaction volumes, so preventive audits of tax positions, inventory of problematic areas (VAT credit, transfer pricing, dealings with risky counterparties, transactions with non‑residents) and regular updates of accounting policies become the key defence.
Process compliance is equally important: timely and complete reporting, correct registration of tax invoices, internal regulations for interaction with the tax authorities and training of responsible persons for communication during on‑site and factual audits. For company groups, a unified defence strategy and a coordinated position on contentious issues during simultaneous audits of related entities are critical.

If you have questions or issues related to tax audits in 2026, challenging their results, preparing for inclusion in the audit schedule or developing a tax‑security strategy, it is advisable to seek professional legal support in advance to minimise financial risks, avoid procedural mistakes and protect your interests in relations with the controlling authorities.

Author: Ihor Yasko, Managing Partner of “WINNER Law Firm”, PhD in Law.