Statutory audit criteria in Ukraine in 2026: how to check your company

“Is an audit mandatory for us?” is a question we hear from owners of Ukrainian companies every week, and the answer is rarely obvious. The law does not give a single list; it combines three separate grounds: the size of the company, its legal form and its line of business. Below we set out each ground and give a simple test. The service itself is described on the page statutory audit of financial statements in Ukraine.

Ground one: the size of the enterprise

The Ukrainian Accounting and Financial Reporting Act divides enterprises into micro, small, medium and large by three indicators at the reporting date: balance sheet total, net revenue and average headcount. An enterprise belongs to a category if it meets at least two of the three criteria.

• Micro: assets up to 350 thousand euro, revenue up to 700 thousand euro, up to 10 employees.
• Small: assets up to 4 million euro, revenue up to 8 million euro, up to 50 employees.
• Medium: assets up to 20 million euro, revenue up to 40 million euro, up to 250 employees.
• Large: at least two of the medium thresholds exceeded.

Hryvnia figures are converted into euro at the National Bank’s average annual rate. The obligation to publish annual statements together with an auditor’s report applies to large and medium enterprises. Small and micro enterprises are outside it by size, unless another ground applies.

The two-year rule

This is the most common mistake in self-assessment. An enterprise changes category only when it fails the criteria of its previous category for two consecutive years. Example: a small enterprise exceeded the small thresholds for revenue and assets in 2025. It has not yet become medium. If the thresholds are exceeded again in 2026, from 2027 it is medium, and the audit of the 2027 statements becomes mandatory. Companies often either audit a year too early or, worse, a year too late.

Ground two: legal form

Regardless of size, an audit is mandatory for public joint stock companies and for public interest entities: issuers of listed securities, banks, insurers, private pension funds and other financial institutions other than micro and small ones. For private joint stock companies the requirements follow the Joint Stock Companies Act and the charter; in most cases the annual statements are also confirmed by an auditor before the general meeting.

Ground three: line of business

Certain activities trigger a mandatory audit irrespective of size: natural monopolies on the national market, extractive companies and financial institutions on the regulator’s list. For non-profit organisations the law sets no size-based audit requirement, but donors, the charter or the board require one, and in scope such an engagement is no different. More on that separately: mandatory audit of NGOs and foundations.

A ten-minute test

• Step 1. Are you a public joint stock company, an issuer, a bank, an insurer, a financial institution, a natural monopoly or an extractive company? If yes, the audit is mandatory and you can stop reading.
• Step 2. Take the balance sheet and income statement for the last two years. Convert assets and revenue into euro at each year’s average rate.
• Step 3. For each year check whether two of the three small enterprise thresholds (4 million assets, 8 million revenue, 50 employees) were exceeded. If so in both years, you are a medium enterprise and the audit is mandatory.
• Step 4. If only one year is exceeded, set a reminder: next year decides.
• Step 5. If nothing is exceeded, the audit is not required by law. But check the loan agreements and the charter: the bank or the shareholder may require it separately.

What to do if the audit is mandatory

The audit timeline runs back from the publication deadline, not from New Year. Large enterprises and public interest entities publish the statements with the auditor’s report by 30 April, medium enterprises by 1 June of the following year. The audit itself takes two to four weeks, and correcting the books after the findings takes another two to three. So the work should start no later than February, and ideally right after the year end. More on dates and sequence: deadlines for publishing statements with the auditor’s report.

What happens if you do not

Failure to publish the financial statements with the auditor’s report leads to administrative liability for officers and, more painfully in practice, to questions from the bank when borrowing, from the buyer when selling the business and from the donor when applying for a grant. In addition, next year the auditor will have to test opening balances, in effect auditing the prior year too, which costs more than auditing on time.

MK Audit has operated since 2000, is listed in the Ukrainian audit register under No. 4624 and belongs to DFK International. Send us two years of statements and we will tell you free of charge whether the audit is mandatory for your company and from which year. Request a proposal: we quote after reviewing the assignment and reply within one working day.