Diia City audit for IT companies: independent assurance report for residents

A resident must meet the legal requirements continuously for the whole period of residency. The company’s own calculations are not enough: an independent auditor checks the statements in the compliance report.

The share of qualified income, average pay and the average headcount of employees and gig specialists follow the rules of Law No. 1667-IX. They are not balance sheet lines; they have to be built from contracts, payroll and revenue analytics.

If the report or the auditor’s conclusion shows non-compliance, the Ministry decides to withdraw the status and, with it, the special tax regime (Art. 9 of Law No. 1667-IX). Finding a gap after a quarter costs less than reading about it in the annual report.

The share of qualified income in total income for the first three calendar months after the month the status was granted and for each calendar year of residency. Qualified income is net revenue and royalties from the activities listed in Art. 5(4) of the Law (Art. 5(1)(4), Art. 1(1)(5)).

Average monthly pay of employees and gig specialists in every calendar month from the month after the status was granted, at least the equivalent of EUR 1,200 at the NBU rate on the first day of the month. All payments before taxes and levies are included (Art. 5(1)(2), Art. 1(1)(12)).

Average headcount of employees and gig specialists for each calendar month from the month after the status was granted, at least nine people (Art. 5(1)(3)).

Every year for 1 January to 31 December. The report is accompanied by an independent conclusion: an assurance report the auditor issues after checking the resident’s statements on pay, headcount and the share of qualified income (Art. 13(3) and (4), Art. 1(1)(8)). The first annual report covers the period from the month after the status was granted to 31 December.

The Diia City law does not require a separate audit of the financial statements. It is mandatory if the company is medium or large or falls into another category under Law No. 996-XIV. In that case it makes sense to plan both engagements together, since they use the same data. More: statutory audit of financial statements.

A new resident files an initial compliance report for the first three full months after the status was granted, together with an independent conclusion. A company that obtained the status under Art. 5(3) files the initial report without a conclusion, but the Ministry may request one if it sees discrepancies with the financial statements (Art. 13(2)). The law sets no other mandatory interim checks; we prepare an interim calculation of the indicators if the company wants one.

The initial compliance report and the independent conclusion are due by the last day of the sixth calendar month after the month the status was granted. Status granted in March: report due by 30 September (Art. 13(2)).

Annual compliance report for the previous calendar year with the independent conclusion. For 2026: no later than 1 June 2027 (Art. 13(3)).

Deadline for an independent conclusion requested by the Ministry from residents that obtained the status under Art. 5(3). The request arrives by email within 15 business days after the initial report or the financial statements are filed (Art. 13(2)).

Filing the report or the conclusion more than 20 business days late, or repeated consecutive late filing, is a ground for losing resident status (Art. 9(1)(4) and (5)).

We split revenue by activity and see which receipts the company treated as qualified. We check that contracts, acts and source documents support this and that the accounting analytics are set up correctly.

We read the gig contracts: scope, engagement terms, pay, evidence of work done. We check whether the contract matches what actually happens and whether payments are backed by documents.

We review orders, staffing schedules, timesheets and changes in pay terms. HR records affect both headcount and the pay calculation, so we treat them as carefully as in an HR audit.

We check who was included, for which month and which payments were counted. Most differences arise at the border between employment and gig relations and on payments that were accrued but left out of the calculation base.

We look at how the company calculates the average headcount of employees and gig specialists: for which period, who is included, and how people who joined or left mid-month are counted.

We check how the chosen tax regime is applied, withholdings from payments to specialists, tax returns and deadlines. Where needed, this part becomes a separate tax audit.

The company runs several lines of business but counts all revenue as qualified income. The review starts with contracts and ends with reworking the analytics, sometimes after the year is closed.

Income and expenses sit in one pot, so the indicators are calculated by hand in spreadsheets. Such a calculation is hard to support with documents and impossible to repeat quickly.

The contract is signed, but no acts are issued and the volume of work is not recorded anywhere. This is a weak point both for confirming the status and for any inspection.

Not everyone who should be is included, or the wrong payments are. The error looks technical, but it changes the figure for the month, and the pay requirement applies every month.

The figure is taken at month end and ignores movements during the month. The result differs from the average headcount the law requires.

Documents are collected in a rush before 1 June while the accountant closes other reports. Starting in winter leaves time to fix what turns up.