Ukraine's SAF-T UA: Building Digital Tax Infrastructure in Extraordinary Times

Ukraine’s journey toward a SAF-T-based digital tax infrastructure has been shaped by ambition, pragmatism, and extraordinary circumstances. Since Draft Law 6255 was introduced on November 2, 2021, establishing the legal foundation for SAF-T UA, the country has continued through full-scale conflict while continuing to develop one of the most forward-looking digital tax frameworks outside the European Union. The result is a system that blends international best practice with hard-won operational realism, culminating in the launch of the E-Audit system on January 1, 2026.

SAF-T UA: The Development Path

The legislative basis for SAF-T UA was laid by Draft Law 6255, registered with the Verkhovna Rada on November 2, 2021. The law introduced the concept of a standardised audit file for taxation, modelled on the OECD’s SAF-T framework, and empowered the State Tax Service (DPS) to define the technical specifications. From January 2023, SAF-T UA became available on a voluntary basis, allowing businesses and ERP vendors to begin generating compliant XML exports without facing enforcement penalties.

The original roadmap was ambitious. Large taxpayers were to begin mandatory SAF-T UA filing from January 2025, with the requirement extending to all VAT-registered taxpayers by January 2027. However, the ongoing martial law context (extended repeatedly, most recently through at least February 2026) made a phased, pragmatic approach the only responsible course. On July 17, 2025, the Ministry of Finance formally withdrew the mandatory filing timeline, preserving the on-demand obligation while redirecting resources toward the E-Audit platform.

Version 2.0: The 2024 Update

In November 2024, the DPS published SAF-T UA 2.0, a significant revision of the original schema. The update reflected lessons learned during the voluntary adoption period and feedback from the business community. Key changes included:

• •Simplified XML structure: Redundant elements were removed and the overall schema was streamlined to reduce the technical burden on smaller businesses and ERP vendors.
• •Fewer mandatory fields: Version 2.0 reduced the number of required data points, focusing on the information most relevant to audit and analytics use cases.
• •Alignment with national accounting standards: The updated schema was brought into closer alignment with Ukrainian accounting standards, reducing the mapping effort for domestic businesses.
• •E-Audit readiness: Version 2.0 was designed with the E-Audit system in mind, ensuring that the data structure would support automated risk analysis and cross-referencing.

Timeline

• •November 2, 2021: Draft Law 6255 registered, establishing the legal framework for SAF-T UA.
• •January 2023: SAF-T UA becomes available on a voluntary basis for all taxpayers.
• •November 2024: SAF-T UA 2.0 published with simplified schema, fewer mandatory fields, and national accounting alignment.
• •July 17, 2025: Ministry of Finance formally withdraws mandatory SAF-T UA filing plans.
• •January 1, 2026: E-Audit system launched, using SAF-T UA as its data format for risk-based tax control.

The E-Audit System

On January 1, 2026, Ukraine’s State Tax Service launched the E-Audit system, a platform designed to modernise how tax audits are conducted. Rather than requiring periodic SAF-T submissions from all businesses, E-Audit uses the SAF-T UA format as the standard data interchange when the DPS requests information during a tax audit or risk assessment.

The system’s core capabilities include risk-based taxpayer selection, automated data analytics, and cross-referencing of SAF-T data against other government databases. The intent is to reduce manual intervention in routine audits, allow tax inspectors to focus on high-risk cases, and provide businesses with a more predictable and transparent audit experience. For large taxpayers, the practical effect is clear: when the DPS initiates an audit, the business must be able to generate and submit a SAF-T UA 2.0 compliant XML file within the requested timeframe.

SAF-T UA specifications are published by the State Tax Service of Ukraine (DPS).

Ukraine in the European Context

Ukraine is not an EU member state, but its digital tax strategy is explicitly aligned with EU and OECD standards as part of its broader EU accession path. The adoption of SAF-T, an OECD-originated framework, is one of several measures designed to bring Ukrainian tax administration into line with European norms. This alignment serves both a diplomatic purpose (demonstrating institutional readiness for EU membership) and a practical one (enabling Ukrainian businesses to operate more smoothly in European supply chains).

Ukraine’s current on-demand model is structurally similar to those in Norway and Austria, where businesses must be able to produce SAF-T files on request rather than filing them on a fixed schedule. The E-Audit platform adds an analytical layer that goes beyond what most on-demand regimes currently offer, reflecting the DPS’s ambition to use structured data for proactive risk management rather than purely retrospective audit.

As the EU ViDA initiative reshapes digital reporting requirements across the Union, Ukraine’s SAF-T UA framework positions it to adopt future EU standards with less friction than countries starting from scratch. For a broader view of how SAF-T is evolving across the continent, see our SAF-T adoption across Europe in 2026 overview.