Expansion of Tax Service Requests Concerning Individuals’ Income: New Control Rules from October 2025

How the criterion of insufficient labor resources works
Inspectors analyze the company’s staff schedule, 1DF report data, and transparency of accounting and reporting for employees. If an enterprise employs only a director, an accountant, and a few people, while the documents show large production or trade operations, this may arouse suspicions of fictitious or unreal business. The main signs are:

• the number of staff does not match the declared scope of activity;
• lack of confirmation of engaging contractors, outsourcers, or services for performing work;
• non-compliance with industry standards (for example, in construction or production, there should be more employees than in an intermediary or IT company).

What happens in the SMKOR system
The payer automatically receives “risky” status.
Almost all TI/AC submitted by a risky payer are blocked until the status is lifted.
The data table that justifies the nomenclature and turnover is often disregarded—precisely due to insufficient labor resources.
The reason for blocking is specified in the receipt: “insufficient number of labor resources required to carry out operations.”

When TIs/ACs are blocked
Blocking by this criterion occurs if all these conditions are met:

• TIs or ACs are submitted for large amounts for items requiring significant human resources (production, construction, agribusiness);
• company staff is not sufficient to actually perform such operations;
• no confirmation of outsourcing, specialized work, or involvement of other companies as contractors;
• no documents proving real operations—completion certificates, contracts with contractors, production reports, etc.

How to avoid blocking tax invoices
Promptly update employee information in reporting forms (1DF, ESC), in company registers;
In the data table (for TI), always specify the list of services, contractors, actual engagement of external labor resources;
For complex operations (production, construction, service), provide additional documents—completion certificates, contracts, payment documents;
Explain the actual workflow in responses to tax authority requests.

Appeals and unblocking
If TIs/ACs are blocked because of insufficient labor resources:

• Submit explanations and copies of documents confirming real operations to the tax authority via the electronic cabinet;
• Attach certificates of employee engagement, contracts with external contractors, commercial proposals;
• If the data table is disregarded—you can appeal to the tax commission or go to an administrative court;
• Practice shows that proper documentation and explanations often lead to positive decisions, but the process may take time.

New trends in 2025
Since September 27, 2025, blocking criteria have been optimized, but insufficient labor resources remains one of the key reasons for assigning risky status.
Already now, there is a trend toward mass blocking of TIs/ACs in manufacturing, construction, and agricultural companies with a “weak” staff;
Risky status can only be removed by adjusting personnel policies, confirming actual operations, and continually submitting additional explanations to the tax authority.

Conclusion
Insufficient labor resources is a formal criterion for blocking tax invoices and adjustment calculations under SMKOR since 2025, which applies regardless of the scope of business activity or industry. To avoid problems, companies should ensure that staff matches operational volumes, document external resource engagements, and submit detailed explanations to the tax authority in advance. Confirmation of actual execution of operations is the basis for automatic TI/AC registration in the current risk system.

Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”.