NACE 2.1-UA from 2027: which activity codes Ukrainian NGOs should check

From 1 January 2027 Ukraine introduces a new classification of economic activities, NACE 2.1-UA, which will replace the national KVED-2010. Most NGOs will not need to do anything if their code has a direct one-to-one match. Organisations whose old code has been split into several new ones, or has an indirect match, should check their codes and may need to update their registration data.

KVED-2010 will not disappear at once: according to the State Statistics Service, it will be used at least until the end of 2027, and during 2027 both classifications will apply in parallel. There is no need to rush, but it is worth looking at the correspondence tables now. Below we explain what changes for NGOs, charitable foundations and religious organisations.

What has changed

State Statistics Service Order No. 191 of 28.10.2025 approved the NACE 2.1-UA classification, effective from 1 January 2027. The explanation: State Statistics Service of Ukraine.

• NACE 2.1-UA is harmonised with the European NACE Rev. 2.1, which the EU introduced in statistics from 2025. It replaces the national classifier DK 009:2010.
• The new classification has 22 sections, 87 divisions, 287 groups and 651 classes.
• The transition follows an Action Plan approved by State Statistics Service Order No. 244 of 25.12.2025: correspondence tables were developed in 2025; methodological guidance and digital tools for choosing codes are being prepared in 2026; in 2027 NACE 2.1-UA is used in statistics and statistical registers are recoded; the transition is completed in 2028.
• On 30 September 2026 the Sumy regional office of the State Tax Service (STS) reported that the preparatory stage runs until 31 December 2026, that correspondence tables are already published on the State Statistics Service page “Implementation of NACE 2.1-UA”, and that the STS has drafted a law amending the Tax Code to replace references to KVED-2010.

Where civil society organisations sit in the new classification

In NACE 2.1-UA, division 94 “Activities of membership organisations” belongs to section T “Other service activities”. Section S is now “Arts, sports and recreation”. The classes most relevant to NGOs are:

The State Statistics Service correspondence tables show exactly how your old code maps to the new one. According to the State Statistics Service, it will itself determine the final level of correspondence.

Who is affected

• NGOs, charitable foundations, religious organisations, trade unions and associations registered as legal entities;
• NGOs that carry out business activities and have several codes in their registration data;
• organisations bidding in donor tenders or state programmes that require a specific activity code;
• accountants who prepare NGO statistical reports.

What to do and by when

1. Obtain a current extract of the organisation’s registration data and list all activity codes, primary and secondary.
2. Look up each code in the correspondence tables on the State Statistics Service page “Implementation of NACE 2.1-UA”.
3. Mark codes with a direct one-to-one match: according to the State Statistics Service, these will change automatically.
4. For codes that were split or have an indirect match, choose the new code that reflects actual activity and prepare to update the registration data once the correspondence table is published.
5. Check whether internal documents refer to old codes: accounting policy, regulations on business activity, donor applications.
6. Follow amendments to the Tax Code: the STS has drafted a law replacing references to KVED-2010.

Common mistakes and risks

• Re-registering in a hurry. Re-registration is needed only where a code was split or has an indirect match. For codes with a direct match the State Statistics Service expects an automatic change.
• Treating the code as proof of status. The classification states that an activity code creates no rights or obligations and, in agreements, can be regarded only as an assumption, not as evidence. Non-profit status is determined by the charter and paragraph 133.4 of the Tax Code, not by the code.
• A code that does not match the charter. If an organisation actually provides social services but the register shows only 94.99, compare the codes with the activities in the charter when updating.
• Forgetting statistics. NACE 2.1-UA is primarily a statistical classification. From 2027 it will be used in statistical registers and from 2028 in state statistical surveys.

What the auditor and the donor will check

In an audit we compare the organisation’s registration data with its charter and actual activities. A mismatch between the codes in the register and the work an NGO presents to a donor is not a breach in itself, but it raises questions in partner capacity assessments and tenders. A donor may ask for a register extract, so it is better if the codes in it reflect what the organisation really does.

FAQ

How we help

We keep the books of NGOs and help align activity codes with the charter, the accounting policy and donor requirements. See accounting for NGOs, NGO audit and grant audit. For NGO accountants and managers we run free webinars for NGOs.

Prepared by the MK Audit team