Diia City audit for IT companies: independent assurance report for residents<\/h1>\n
Every Diia City resident needs a Diia City audit: the annual compliance report filed with the Ministry of Digital Transformation by 1 June must come with an independent auditor’s report. The audit for IT companies in Diia City covers three indicators: the share of qualified income, the average monthly pay of employees and gig specialists, and their average headcount. We review revenue structure, contracts, payroll and the annual financial statements, work remotely across Ukraine and issue the report in English and Ukrainian.<\/p>\n
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<\/div>\nEach year by 1 June a Diia City resident files an annual compliance report with the Ministry of Digital Transformation, together with an independent auditor’s report. The auditor checks the company’s statements on the share of qualified income (at least 90%), average monthly pay (at least the equivalent of EUR 1,200) and the headcount of employees and gig specialists (at least nine). MK Audit has worked since 2000 and is a full member of the international association DFK International, based in Kyiv.<\/p>\n
Why a resident needs an independent auditor<\/h2>\n<\/div>\n\nProof for the Ministry<\/b><\/p>\nA 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.<\/p>\n<\/div>\n
Indicators with their own rules<\/b><\/p>\nThe 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.<\/p>\n<\/div>\n
The cost of an error<\/b><\/p>\nIf 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.<\/p>\n<\/div>\n<\/div>\n<\/section>\n\n\nLegal requirements<\/div>\nDiia City criteria the auditor checks<\/h2>\n<\/div>\n\nQualified income of at least 90%<\/b><\/p>\nThe 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)).<\/p>\n<\/div>\n
Pay of at least EUR 1,200<\/b><\/p>\nAverage 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)).<\/p>\n<\/div>\n
At least nine people<\/b><\/p>\nAverage 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)).<\/p>\n<\/div>\n<\/div>\n
New companies follow a separate path: a legal entity registered no more than 24 months before applying, with income within the single tax group 3 limit, may hold the status until 31 December of the following year without meeting the pay and headcount requirements. The activity and qualified income requirements still apply (Art. 5(3)). Source: Law of Ukraine No. 1667-IX on Stimulating the Development of the Digital Economy in Ukraine<\/a>.<\/p>\n<\/section>\n\n\nReporting<\/div>\nWhich reports a resident needs<\/h2>\n<\/div>\n\nAnnual compliance report and independent conclusion<\/b><\/p>\nEvery 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.<\/p>\n<\/div>\n
Audit of the annual financial statements<\/b><\/p>\nThe 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>.<\/p>\n<\/div>\nInitial report and conclusion on request<\/b><\/p>\nA 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.<\/p>\n<\/div>\n<\/div>\n<\/section>\n\n\nDeadlines<\/div>\nDiia City resident reporting deadlines<\/h2>\n<\/div>\n\nSixth month after the status<\/b><\/p>\nThe 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)).<\/p>\n<\/div>\n
1 June<\/b><\/p>\nAnnual compliance report for the previous calendar year with the independent conclusion. For 2026: no later than 1 June 2027 (Art. 13(3)).<\/p>\n<\/div>\n
60 days<\/b><\/p>\nDeadline 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)).<\/p>\n<\/div>\n
20 business days<\/b><\/p>\nFiling 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)).<\/p>\n<\/div>\n<\/div>\n<\/section>\n\n\nScope<\/div>\nWhat the auditor checks<\/h2>\n<\/div>\n\nRevenue by type of activity<\/b><\/p>\nWe 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.<\/p>\n<\/div>\n
Gig contracts<\/b><\/p>\nWe 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.<\/p>\n<\/div>\n
Employment contracts and HR records<\/b><\/p>\nWe 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<\/a>.<\/p>\n<\/div>\nAverage pay calculation<\/b><\/p>\nWe 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.<\/p>\n<\/div>\n
Average headcount<\/b><\/p>\nWe 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.<\/p>\n<\/div>\n
Tax accounting under the special regime<\/b><\/p>\nWe 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<\/a>.<\/p>\n<\/div>\n<\/div>\n<\/section>\n\n\nIn practice<\/div>\nCommon mistakes of residents<\/h2>\n<\/div>\n\nAll receipts treated as qualified<\/b><\/p>\nThe 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.<\/p>\n<\/div>\n
No split by business line<\/b><\/p>\nIncome 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.<\/p>\n<\/div>\n
Gig contract on paper only<\/b><\/p>\nThe 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.<\/p>\n<\/div>\n
Pay calculated on the wrong base<\/b><\/p>\nNot 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.<\/p>\n<\/div>\n
Headcount taken at a date, not on average<\/b><\/p>\nThe figure is taken at month end and ignores movements during the month. The result differs from the average headcount the law requires.<\/p>\n<\/div>\n
The audit is remembered in late May<\/b><\/p>\nDocuments are collected in a rush before 1 June while the accountant closes other reports. Starting in winter leaves time to fix what turns up.<\/p>\n<\/div>\n<\/div>\n<\/section>\n\n\n\nHow we work<\/div>\nFour steps from request to report<\/h2>\n<\/div>\n\n01<\/b>Understanding the engagement<\/strong><\/p>\nWe find out when the status started, which activities the company runs, who works under employment contracts and who under gig contracts. We reply within 1 business day.<\/p>\n<\/div>\n
02<\/b>Document request and plan<\/strong><\/p>\nWe send the list of documents and access we need and agree the timeline and your contact people. We point out at once where questions usually arise.<\/p>\n<\/div>\n
03<\/b>Audit work<\/strong><\/p>\nWe analyse revenue, contracts, payroll, indicator calculations and the financial statements. Open points are discussed with your accountants as we go, not at the end.<\/p>\n<\/div>\n
04<\/b>Report and findings<\/strong><\/p>\nWe deliver the independent conclusion for the compliance report in Ukrainian and, if needed, in English, plus a separate list of what to fix in the books for the next period.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/section>\n\n\n\n\n\nQuestions<\/div>\nFrequently asked questions<\/h2>\n<\/div>\n\n\nDoes a Diia City resident need an independent audit<\/summary>\nYes. The law requires an independent auditor’s conclusion to be attached to the annual compliance report (Art. 13(3) of Law No. 1667-IX). Without it the report is incomplete, and filing more than 20 business days late is a ground for losing the status.<\/p>\n<\/details>\n\nIs it the same as a statutory audit of financial statements<\/summary>\nNo. The independent conclusion covers the statements in the compliance report: income, pay and headcount. A company may also fall under a statutory audit of financial statements<\/a>, so at the start we check the statutory audit criteria<\/a> and avoid doing the same work twice.<\/p>\n<\/details>\n\nWhen is the best time to start<\/summary>\nThe calmest option is before year end, while revenue analytics and HR records can still be corrected. The annual report is due by 1 June, so starting after March is risky. If the year is already closed, we work with what there is and list what to change going forward.<\/p>\n<\/details>\n\nWhat if the indicators are close to the threshold<\/summary>\nWe show the calculation and the points where it may change once the data is refined. The company decides what to do next; our job is to give an honest picture before anyone else sees it.<\/p>\n<\/details>\n\nDoes a company that joined as a new entity (Art. 5(3)) need a conclusion<\/summary>\nSuch a company files its initial report without an independent conclusion, but the Ministry may request one if the data differs from the financial statements; there are 60 days to provide it. Every resident attaches an independent conclusion to the annual compliance report.<\/p>\n<\/details>\n\nDo you work remotely and will the report be in English<\/summary>\nYes, we work remotely across Ukraine and accept documents electronically. The report is prepared in Ukrainian and English; the English version is what founders and partners abroad need. Other services are listed under audit services<\/a>.<\/p>\n<\/details>\n\nHow much does it cost<\/summary>\nThe fee depends on the number of business lines, transaction volume, the number of specialists and the state of the books. Commercial proposal after we review the engagement.<\/p>\n<\/details>\n<\/div>\n<\/div>\n
\nOrder a Diia City audit<\/h3>\n
Describe your situation, we reply within 1 business day.<\/p>\n\n
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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.<\/p>\n<\/div>\n
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.<\/p>\n<\/div>\n
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.<\/p>\n<\/div>\n<\/div>\n<\/section>\n 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)).<\/p>\n<\/div>\n 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)).<\/p>\n<\/div>\n 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)).<\/p>\n<\/div>\n<\/div>\n New companies follow a separate path: a legal entity registered no more than 24 months before applying, with income within the single tax group 3 limit, may hold the status until 31 December of the following year without meeting the pay and headcount requirements. The activity and qualified income requirements still apply (Art. 5(3)). Source: Law of Ukraine No. 1667-IX on Stimulating the Development of the Digital Economy in Ukraine<\/a>.<\/p>\n<\/section>\n 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.<\/p>\n<\/div>\n 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>.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n<\/div>\n<\/section>\n 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)).<\/p>\n<\/div>\n Annual compliance report for the previous calendar year with the independent conclusion. For 2026: no later than 1 June 2027 (Art. 13(3)).<\/p>\n<\/div>\n 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)).<\/p>\n<\/div>\n 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)).<\/p>\n<\/div>\n<\/div>\n<\/section>\n 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.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n 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<\/a>.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n 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<\/a>.<\/p>\n<\/div>\n<\/div>\n<\/section>\n 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.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n The figure is taken at month end and ignores movements during the month. The result differs from the average headcount the law requires.<\/p>\n<\/div>\n 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.<\/p>\n<\/div>\n<\/div>\n<\/section>\n We find out when the status started, which activities the company runs, who works under employment contracts and who under gig contracts. We reply within 1 business day.<\/p>\n<\/div>\n We send the list of documents and access we need and agree the timeline and your contact people. We point out at once where questions usually arise.<\/p>\n<\/div>\n We analyse revenue, contracts, payroll, indicator calculations and the financial statements. Open points are discussed with your accountants as we go, not at the end.<\/p>\n<\/div>\n We deliver the independent conclusion for the compliance report in Ukrainian and, if needed, in English, plus a separate list of what to fix in the books for the next period.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/section>\n Yes. The law requires an independent auditor’s conclusion to be attached to the annual compliance report (Art. 13(3) of Law No. 1667-IX). Without it the report is incomplete, and filing more than 20 business days late is a ground for losing the status.<\/p>\n<\/details>\n No. The independent conclusion covers the statements in the compliance report: income, pay and headcount. A company may also fall under a statutory audit of financial statements<\/a>, so at the start we check the statutory audit criteria<\/a> and avoid doing the same work twice.<\/p>\n<\/details>\n The calmest option is before year end, while revenue analytics and HR records can still be corrected. The annual report is due by 1 June, so starting after March is risky. If the year is already closed, we work with what there is and list what to change going forward.<\/p>\n<\/details>\n We show the calculation and the points where it may change once the data is refined. The company decides what to do next; our job is to give an honest picture before anyone else sees it.<\/p>\n<\/details>\n Such a company files its initial report without an independent conclusion, but the Ministry may request one if the data differs from the financial statements; there are 60 days to provide it. Every resident attaches an independent conclusion to the annual compliance report.<\/p>\n<\/details>\n Yes, we work remotely across Ukraine and accept documents electronically. The report is prepared in Ukrainian and English; the English version is what founders and partners abroad need. Other services are listed under audit services<\/a>.<\/p>\n<\/details>\n The fee depends on the number of business lines, transaction volume, the number of specialists and the state of the books. Commercial proposal after we review the engagement.<\/p>\n<\/details>\n<\/div>\n<\/div>\n Describe your situation, we reply within 1 business day.<\/p>\n\n <\/p> Diia City criteria the auditor checks<\/h2>\n<\/div>\n
Which reports a resident needs<\/h2>\n<\/div>\n
Diia City resident reporting deadlines<\/h2>\n<\/div>\n
What the auditor checks<\/h2>\n<\/div>\n
Common mistakes of residents<\/h2>\n<\/div>\n
Four steps from request to report<\/h2>\n<\/div>\n
Frequently asked questions<\/h2>\n<\/div>\n
Does a Diia City resident need an independent audit<\/summary>\n
Is it the same as a statutory audit of financial statements<\/summary>\n
When is the best time to start<\/summary>\n
What if the indicators are close to the threshold<\/summary>\n
Does a company that joined as a new entity (Art. 5(3)) need a conclusion<\/summary>\n
Do you work remotely and will the report be in English<\/summary>\n
How much does it cost<\/summary>\n
Order a Diia City audit<\/h3>\n
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