Legal updates (21.05.2026)
The Forvis Mazars team has prepared for you a list of recent Legal updates in Ukraine.
Below, you will learn about:
- Martial law and mobilization: prolonged until 2 August 2026;
- Diia.city residents: the 2025 compliance report must be submitted by 1 June;
- Business digitalization report: new form No. 1 ICT effective 1 January 2027;
- Foreign economic activity for defense enterprises: list of transactions not requiring separate approval by the Cabinet of Ministers expanded;
- State supervision: businesses gain new tools to protect against inspections;
- Military levy: payment extended for 3 years following the lifting of martial law;
- By 20 June 2026 – submission of transport data to the territorial recruitment centers.
Martial law and mobilization: prolonged until 2 August 2026
On 30 April 2026, the President signed laws extending martial law and general mobilization.
Key aspects:
- the term has been extended from 4 May to 2 August 2026;
- current rules for reserving employees remain in effect;
- restrictions on the travel of men subject to military service remain in effect;
- the legal regime remains the basis for businesses’ regulatory, tax, and labor decisions.
Diia.city residents: the 2025 compliance report must be submitted by 1 June
In accordance with the requirements of Law No. 1167-IX, Diia.City residents are required to submit a compliance report and an independent auditor’s opinion annually by 1 June at the latest.
The report is submitted to the Ministry of Digital Transformation via the Diia portal.
Please be reminded that with this report, a Diia.City resident confirms compliance during the reporting year with the requirements set forth in Law No. 1667-IX:
- the absence of any negative circumstances that would prevent them from being a Diia.City resident;
- compliance with numerical criteria:
- the average monthly salary and gig remuneration must be at least the equivalent of 1 200 euros (does not apply to Diia.City residents with “startup” status during the first 2 years of operating under such status);
- the average number of employees and gig specialists must be at least 9 people (does not apply to Diia.City residents with “startup” status during the first 2 years of operating under such status);
- the share of qualified income (revenue) in total income (revenue) must be at least 90%.
Failure to submit a compliance report, late submission, or submission without an audit opinion constitutes grounds for the Ministry of Digital Transformation to remove a Diia.City resident from the registry and revoke the legal and tax benefits granted by this status (including a preferential personal income tax rate, minimum unified social tax, the ability to work with sole proprietors under gig contracts, critical enterprise status, and employee reservation rights).
Business digitalization report: new form No. 1 ICT effective 1 January 2027
The State Statistics Service, by Order No. 111 dated 29 April 2026, approved the new Form No. 1 ICT (annual) statistical report – a report on the use of IT, e-commerce, and digital technologies in business, which will be introduced effective 1 January 2027.
Key aspects:
- the form is annual and must be submitted by 10 April of the year following the reporting year;
- it is submitted by legal entities in accordance with the sampling established by the State Statistics Service;
- as of 1 January 2027, the previous Form No. 1 ICT will be invalid.
What Form No. 1 ICT covers:
- the level of IT use in the company;
- e-commerce;
- the use of business systems and software solutions;
- the use of cloud services (email, accounting, data storage, computing);
- the application of artificial intelligence.
Foreign economic activity for defense enterprises: list of transactions not requiring separate approval by the Cabinet of Ministers expanded
On 29 April 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 541, which expands the list of transactions involving military goods that may be conducted without a separate approval from the CMU.
Key aspects:
- the list of cases of imports without a separate CMU approval has been clarified:
- spare parts, components, materials, and equipment for the repair, modernization, and extension of the service life of military-purpose goods;
- domestic supplies to defense forces:
- supplies by manufacturers of goods to security and defense forces without being exported outside Ukraine are carried out without a separate approval from the CMU;
- exports by manufacturers with a certified internal export control system (IECS):
- enterprises with a valid certified internal export control system may export without a decision by the CMU, provided they have the relevant authorization from the State Export Control Service;
- provided that the goods are used for manufacturing military-purpose products for security and defense forces;
- re-export of substandard products:
- the re-export or return of goods that do not meet quality requirements or contract terms is permitted without a separate approval from the CMU for the purpose of fulfilling warranty obligations.
State supervision: businesses gain new tools to protect against inspections
On 25 April 026, Law No. 4840-IX entered into force and will become effective on the date when martial law in Ukraine is terminated or lifted. The law updates the system of state supervision (control) (excluding tax, customs, and currency control) and introduces new rules for business interaction with regulatory authorities.
Key aspects:
- video recording of inspections is now mandatory:
- the inspection must be recorded on video from start to finish;
- in the absence of a video recording or if it is incomplete, the results of the inspection may be called into question and are more difficult to use as evidence;
- inspection durations are limited:
- scheduled inspection: no more than 5 business days;
- unscheduled inspection: no more than 2 business days;
- a risk-based approach has been introduced:
- each business entity is assigned a risk level;
- the frequency of inspections depends on this (the lower the risk, the less frequent the inspections);
- voluntary audits without penalties have been introduced:
- businesses may voluntarily initiate an audit of their operations;
- no sanctions are imposed based on the results, but the findings are considered when determining the risk level and may reduce the frequency of future inspections;
- procedural requirements for inspections have been strengthened:
- stricter rules have been established regarding the preparation of documents and the conduct of inspections;
- a procedural violation by the regulatory authority may serve as grounds for cancellation of the inspection results;
- a Council on State Supervision has been established, with the following characteristics:
- at least 50% of its members are business representatives;
- it will participate in shaping approaches to inspections and regulatory policy.
Military levy: payment extended for 3 years following the lifting of martial law
On 15 April 2026, Law No. 4835-IX came into effect, extending the military levy for three years following the year in which martial law is terminated or lifted.
Key aspects:
- rate for individuals: 5% of income;
- sole proprietors in Groups I, II, and IV: 10% of the monthly minimum wage;
- sole proprietors and legal entities in Group III: 1% of income;
By 20 June 2026 – submission of transport data to the territorial recruitment centers
Enterprises are required to submit to the territorial recruitment centers a report on their vehicles, their technical condition, and employees subject to military transport obligations; the next deadline is 20 June 2026.
Key aspects:
- the report must be submitted by all legal entities;
- deadlines: twice a year, by 20 June and by 20 December;
- includes data on vehicles and the employees who operate them;
- requirement to submit a “zero” report (given certain court precedents, it is advisable to submit a report even in the absence of transport).
Our experts:
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| Denys Shendryk Partner, Head of Tax & Legal Department | Tetiana Levkivska Head of Legal Practice | Vladyslav Kovtunenko Legal Manager |
