Deadlines for publishing financial statements with the auditor’s report in Ukraine

A statutory audit only serves its purpose when the auditor’s report is published together with the financial statements by the legal deadline. Missing the date produces the same result as not being audited at all. Below we explain who publishes by which date, where, what the package must contain and how to plan the audit backwards from that date. Who is required to be audited in the first place is explained in statutory audit criteria in Ukraine.

Two key dates

The Ukrainian Accounting and Financial Reporting Act sets two deadlines depending on the category of the entity.

• By 30 April of the year following the reporting year: public interest entities, public joint stock companies, natural monopolies on the national market and extractive companies. They publish the annual financial statements and, where applicable, consolidated statements together with the auditor’s report.
• By 1 June of the following year: large enterprises that are not issuers of securities, medium enterprises, and other financial institutions classified as micro or small.

During martial law the publication deadlines have been changed several times by separate laws. That is why every year, before planning the audit, we check the current wording and tell clients the applicable date. Relying on last year’s dates without checking is not advisable.

Where the statements are published

The statements and the auditor’s report are placed on the entity’s own website. Issuers are additionally subject to the securities regulator’s disclosure rules. Uploading to the taxpayer’s electronic cabinet or filing with the statistics office does not count as publication: the law requires public access.

What the package contains

• the statement of financial position, income statement, cash flow statement, statement of changes in equity and the notes;
• consolidated financial statements, if the entity has subsidiaries and is required to consolidate;
• the independent auditor’s report with an opinion on the statements;
• for certain categories, the management report.

The auditor’s report must relate to the exact version of the statements that is published. If the statements are changed after the report is signed, the auditor has to revisit the report. This is a frequent cause of delay, so adjustments should be finalised before signing.

The audit calendar, counted back from the deadline

We count backwards from the publication date. For a medium enterprise with a 1 June deadline a realistic plan looks like this.

• January. Year-end closing, inventory count, reconciliations with counterparties. The auditor observes the count where the engagement provides for it.
• February. Engagement letter, document checklist, handover of the package. The earlier the documents arrive, the fewer questions at the end.
• March. Fieldwork: two to four weeks. Findings are raised as the work goes, not at the end, so the books can be corrected in parallel.
• April. Adjustments to the statements, discussion of the management letter, signing of the auditor’s report.
• May. Approval of the statements by the general meeting and publication on the website by 1 June.

For entities with a 30 April deadline every stage moves a month earlier, which means the engagement letter should be signed in December or January.

Typical reasons for being late

• The auditor is engaged in April, when the market is overloaded and no slots are free.
• Documents arrive in pieces and the auditor waits.
• Findings are corrected after the report is signed, and the report has to be revised.
• The general meeting is scheduled for the last week before the deadline with no buffer.

Who approves the statements before publication

The annual statements of an LLC are approved by the general meeting of participants, those of a joint stock company by the general meeting of shareholders. The auditor’s report is considered at the same meeting, so the meeting date should sit in the calendar at least a week before the publication date. Where the company has a supervisory board or an audit committee, the report goes through them first. This is often forgotten, the meeting is set for the last day, and any late adjustment to the statements breaks the deadline.

Consolidated statements of groups

If the entity controls subsidiaries, it also prepares and publishes consolidated statements, and the auditor issues a separate report on them. The deadline is the same, but the work is larger: a group audit includes auditing the subsidiaries or obtaining their auditors’ reports. For groups we recommend adding two to three weeks and starting with the subsidiaries so that the parent statements are not held up.

What happens if you miss the date

Failure to publish the statements with the auditor’s report on time leads to administrative liability for officers and to practical consequences: banks ask for the auditor’s report when lending, buyers in transactions, donors in grant applications. Issuers also face regulator sanctions. The most expensive consequence is deferred: next year the auditor will have to confirm the opening balances as well, in effect auditing two years.

MK Audit has operated since 2000, is listed in the Ukrainian audit register under No. 4624 and belongs to DFK International. We plan the audit backwards from the publication date, remind clients of the deadlines and support the publication itself. More about the service: statutory audit of financial statements in Ukraine. Request a proposal: we quote after reviewing the assignment and reply within one working day.