STS tax card for Ukrainian NGOs 2026: auditor comments and 1,825-day retention
The State Tax Service (STS) information tax card for non-profits gives a short overview of how to get into the Register, what to report and which financial statement formats to choose. It is a useful checklist, but one point needs a correction: the document retention period. For non-profit organisations the Tax Code now requires primary documents, accounting registers and financial statements to be kept for at least 1,825 days, not 3 years.
The STS published the same card text in Volyn region on 10 June 2026 and in Sumy region on 17 June 2026. Below we go through it point by point and add what an auditor looks at when auditing an NGO or a charitable foundation.
What has changed
The card does not create new rules; it brings existing rules together in one memo. The text: STS Main Office in Volyn region. A table of the main reports for public associations is attached as a separate file on the STS website.
The key points of the card:
- NGOs, charities and other organisations included in the Register of Non-Profit Institutions and Organisations do not pay corporate income tax as long as they comply with paragraph 133.4 of the Tax Code.
- To be included, they file application form 1-RN (form code J1310502) and copies of the founding documents certified by the director’s signature and seal, except documents published on the e-services portal.
- The application can be filed in person, by registered mail with acknowledgement of receipt and a list of contents, or electronically if the founding documents are published on the portal.
- Non-profits file three kinds of reports: tax, financial and statistical.
- The report on the use of income is prepared from the accounting records, that is, on an accrual basis (Article 4 of the Law on Accounting and Financial Reporting).
- Where there are humanitarian aid transactions, annex GD to the report is mandatory for both receipts and spending. Information on annexes is a mandatory element of the report (paragraph 48.3 of the Tax Code).
- Failing to file the report or the financial statements attached to it costs UAH 340 under paragraph 120.1 of the Tax Code, or UAH 1,020 for a repeat within a year.
Who is affected
- NGOs and unions, charitable foundations, religious and other organisations with non-profit status;
- organisations not yet in the Register or that have amended their founding documents;
- NGOs receiving humanitarian aid that must complete annex GD;
- accountants choosing the financial statement format for next year.
Auditor’s comment: document retention
The card says non-profits keep documents for at least 3 years after filing, and public associations for at least 5 years, citing Article 23 of the Law on Public Associations. We checked both rules in their current versions on zakon.rada.gov.ua.
- Subparagraph 44.3.2 of the Tax Code sets 1,825 days for primary documents, accounting registers, financial statements and other tax-related documents prepared by entities defined in paragraph 133.4, that is, non-profits. The 1,095-day period now applies only to other documents not covered by the 1,825-day rule.
- The period runs from the day the report based on those documents was filed, or, if it was not filed, from the filing deadline.
- Article 23 of the Law on Public Associations (Law No. 4572-VI of 22.03.2012, version of 03.09.2024) requires accounting and reporting but contains no separate retention period. The card also gives a different date and number for the law than zakon.rada.
In practice: treat 1,825 days from filing as the minimum under the Tax Code for a non-profit. If the grant agreement requires a longer period, the longer period applies.
What to do and by when
- Check that the organisation is in the Register of Non-Profit Institutions and that the Register data match the current charter.
- Update the accounting policy order: retention of at least 1,825 days, a person responsible for the archive, rules for storing electronic documents.
- Choose the financial statement format for the year before preparing it (see the table).
- If the organisation receives humanitarian aid, keep separate records of receipts and spending to complete annex GD.
- File the report on the use of income together with the financial statements where they are attached to it, to avoid the UAH 340 penalty for non-filing.
| Financial statement format | For whom, per the STS card | What to consider |
|---|---|---|
| Simplified micro-entity statements (forms 1-ms, 2-ms) under Accounting Standard 25 | Organisations that qualify as micro-entities by income and headcount | The right of non-profits to use abridged forms is set out in Article 11(3) of the Law on Accounting |
| Small entity statements (forms 1-m, 2-m) under Accounting Standard 25 | Organisations that qualify as small entities | The same balance sheet and income statement, with more detail |
| Full financial statements under National Accounting Standard 1 | At the choice of the organisation, its founders or donors; the STS recommends them for organisations with medium or large business activity | Balance sheet, income statement, cash flow statement, statement of changes in equity and notes |
According to the card, organisations without business activity keep their books using the simplified Chart of Accounts approved by Ministry of Finance Order No. 186 of 19.04.2001. We wrote more about the formats in financial statement forms for non-profit organisations.
Common mistakes and risks
- Documents destroyed after 3 years. For non-profits the Tax Code requires 1,825 days. If documents are missing during an inspection, they are treated as not having existed when the report was prepared (paragraph 44.6 of the Tax Code).
- A cash-basis report. The card expressly refers to the accrual method. A report based on cash movements will not agree with the financial statements.
- Humanitarian aid without annex GD. The annex is mandatory if such transactions took place, for both receipts and spending.
- Simplified forms when the donor expects a full set. The law allows simplified forms, but a donor may require a cash flow statement and notes. Check the grant agreement before the year is closed.
- Financial statements not filed with the report. The paragraph 120.1 penalty applies to both the report and the financial statements attached to it.
FAQ
How long must a Ukrainian NGO keep accounting documents?
Under subparagraph 44.3.2 of the Tax Code, non-profits keep primary documents, accounting registers and financial statements for at least 1,825 days from filing the report they were used for. If the grant agreement sets a longer period, apply it.
Which financial statements does a Ukrainian NGO file?
According to the STS card, these may be the simplified forms 1-ms and 2-ms, the small entity forms 1-m and 2-m under Accounting Standard 25, or full statements under National Accounting Standard 1. The choice depends on the organisation’s size and donor requirements.
When does an NGO complete annex GD to the income report?
When there were humanitarian aid transactions during the reporting period. The annex covers both the aid received and its use.
How we help
We keep the books of NGOs, help choose a financial statement format that meets donor requirements and set up a document archive within the Tax Code periods. See accounting for NGOs, NGO audit and audit of NGO annual statements. For NGO accountants we run free webinars for NGOs.
Prepared by the MK Audit team