SAF-T UA: Digital Audit as a Challenge and an Opportunity for Business in 2025

The 2025 tax reform opens a new stage of digitalization of financial processes in Ukraine. At the heart of the changes is the SAF-T UA (Standard Audit File for Tax) system — an electronic format that allows the tax authority to receive company data in a structured way. This is not just a technical innovation but a complete shift in how businesses and the state interact.

What is SAF-T UA and Why Does It Matter

SAF-T UA is a “digital snapshot” of a company’s accounting. The file contains information about transactions, revenues, expenses, counterparties, and primary documents. The tax authority receives it in a standardized format, enabling automatic data analysis, detection of inconsistencies, and building of risk profiles.

For the first time, this tool was applied in September 2025 during a tax inspection. According to the State Tax Service (STS), data processing was much faster than in the traditional mode. The STS website now has a dedicated “SAF-T UA” section with technical descriptions, XSD schemes, and clarifications. In July 2025, the Audit Department even published new answers to taxpayers’ questions about forming and submitting these files.

Current Status and Implementation Plans

Initially, Draft Law No. 6255 envisaged mandatory SAF-T submission:

• from 2025 — for large taxpayers;
• from 2027 — for all VAT payers.

However, the bill was withdrawn, so for now SAF-T UA is being introduced in a pilot format. At the same time, businesses and the STS are actively discussing a possible launch of full-scale e-audit in 2026. This means companies should start preparing in advance: testing software, adapting internal processes, and training staff.

Risks and Opportunities for Business

The introduction of SAF-T UA brings both challenges and benefits.

Risks:

• additional costs for upgrading accounting software;
• risk of technical errors that the tax authority may treat as violations;
• greater responsibility for the quality of data submitted to the state.

Opportunities:

• fewer traditional inspections and reconciliations;
• more predictable relations with tax authorities;
• competitive advantages for companies that operate transparently and are ready for digital standards.

What to Avoid

The biggest danger is treating SAF-T as just “another file for the tax office.” A formal approach increases the likelihood of mistakes and penalties. Without proper testing, accounting systems may generate incorrect data, which could look like an attempt to conceal income. Underestimating staff training is also risky: accountants and lawyers must clearly understand what data goes into the file and how it can be interpreted.

What to Do Today

The right strategy includes conducting an internal audit, reviewing transactions with counterparties, and investing in modern accounting software. Legal preparation is equally important: a lawyer can help develop an action plan in case the tax authority identifies discrepancies or automatically generates claims.

Conclusion

SAF-T UA is not a distant future but a reality already operating in test mode. For businesses, it is both a challenge and an opportunity: those who prepare in advance will reduce risks and strengthen their reputation. At this stage, a lawyer and financial advisor become key partners — helping not only to avoid penalties but also to turn digital audit into a tool for growth.