Vadym Lozytskyi ,
Auditor at Audit Invest
Table of Contents
In 2026, a campaign to “catch up” on financial transparency is unfolding in Ukraine: companies are en masse preparing and publishing financial statements, auditors are struggling under the workload, and state regulatory authorities are introducing new rules. This “deferred audit syndrome” is the result of a combination of factors, specifically wartime legislative relaxations, the complexity of new regulatory requirements, standards, and digital formats (XBRL, SAF-T UA), staff shortages, economic volatility, and several others. The year 2026 is becoming decisive, as the expiration of wartime exemptions and the introduction of new compliance requirements mean that accumulated developments and legislative changes have converged at the same time. Concrete statutory requirements have emerged (NSSMC Resolution No. 3398 of December 19, 20251, the digital XBRL mandate, tax-focused SAF-T UA, and others, as previously discussed in our article “SAF-T vs. iXBRL: Complex Made Simple” of January 14, 2026). As a result, audit delays placed pressure on the capital market: investors, government authorities (regulators), and other stakeholders demanded financial disclosures, while slow publication of statements temporarily undermined trust in them.
It is crucial to recognize that without timely audits and public disclosures, a business cannot prove its reliability to investors, counterparties, government bodies (regulators), and most importantly, to society.
Public Value of an Audit:
The utility of an audit lies not in its consumer value for executive management and controlling majority shareholders, but in its value for a broader network of owners, creditors, government authorities, and others. The primary purpose of an audit is its value to society. Once those tasked with commissioning audits acknowledge this, audits will provide tangible value to every participant in the process.
A Brief History (2021–2026)
In 2021–2022, Ukraine began preparing for European standards: introducing IFRS for large enterprises, modernizing accounting practices, and preparing digital reporting formats (XBRL, SAF-T UA). In February 2022, full-scale war erupted, prompting the state to temporarily ease reporting requirements. Specifically, starting in March 2022, Law No. 2115-IX2 permitted the submission of accounting and financial statements within three months following the termination of martial law for the entire missing period. Consequently, for 2022–2024, many companies bypassed the need for timely audits and financial disclosures, relying on this postponement. In June 2022, another statute was adopted — Law No. 2285-IX3 — to support audit activity during the war and post-war recovery. These changes formally kept the audit market operating, but effectively postponed audits until later.
Simultaneously, digitalization accelerated throughout 2022–2024. Under an agreed memorandum between the NSSMC and the NBU, the Ministry of Finance progressively rolled out a single electronic reporting format based on IFRS taxonomies. At the end of 2023, the 2022 IFRS XBRL taxonomy was approved (for 2022 annual and 2023 interim statements); in December 2024, the 2023 taxonomy (for 2023 annual and 2024 interim); in July 2025, the 2024 taxonomy (for 2024 annual and 2025 interim); and on December 2, 2025, the 2025 taxonomy (for 2025 annual and 2026 interim statements).
In parallel, donors and the international community insisted on financial accountability. Donor representatives repeatedly emphasized that audits form the foundation of international trust in Ukraine.
Thus, across 2021–2025, numerous prerequisites accumulated regarding corporate financial transparency (Table). The transition from wartime exemptions back to the regular regime marked the culmination. Amendments to Law No. 2115-IX2 changed the situation.. As a result, after May 9, 2025, most entities falling under the regulatory purview of the NSSMC and NBU were required to publish statements for 2022–2024 by August 2025 to avoid penalties. Many of them focused on this during the autumn of 2025.
Chronology of Key Events and Documents 2021–2026
New statutes, standards, and regulatory requirements:
| Year | Event, Document | Source |
|---|---|---|
| 2021 | Initial rules on the application of IFRS by banks and key entities took effect (based on NBU regulations and Ukrainian laws); a digital reporting committee was established (2017 memorandum). | NBU, Ministry of Finance, Memorandum No. 102/15 |
| 2022 | February 24 – outbreak of full-scale war. March 3 – Law No. 2115-IX: publication of statements permitted within 3 months following the end of martial law. May 31 – Law No. 2285-IX: amendments to the audit law ensuring audit activity during the war. | Laws of Ukraine No. 2115-IX, No. 2285-IX |
| 2023 | December 19 – approval of the 2022 IFRS XBRL taxonomy (for 2022 reporting). Donors stepped up transparency requirements (cost tracking, independent audits of international programs). | NSSMC, Ministry of Finance, donor reports |
| 2024 | December 27 – approval of the 2023 IFRS XBRL taxonomy (for 2023 reporting). Warnings of a critical workforce shortage: deficit of accountants and auditors due to mobilization and migration. | NSSMC, IAA Analytics |
| 2025 | July 11 – approval of the 2024 IFRS XBRL taxonomy (for 2024 reporting). September 23 – State Tax Service announces SAF-T UA (electronic audit for tax inspections) as a transparency tool. Commencement of “deferred” 2022–2024 report submissions and publication of 2025 reports. | NSSMC, STS, IMF |
| 2026 | December 19, 2025 – NSSMC Resolution No. 3398 updates “Audit Requirements,” effective February 1, 2026. February 1, 2026 – entry into force of new rules for audit and review of financial statements. July 3, 2026 – expiration of the transitional period (scope of additional requirements). Consequently, accumulated backlogs of audits must be completed in 2026. | NSSMC, regulations, press releases |
Analysis of the Causes of “Deferred Audits”
Regulatory Factors
Legislation provided the opportunity to defer audits, and companies took full advantage. During wartime, the government waived penalties for late audit reports. Law No. 2115-IX, and subsequent amendments under Law No. 2285-IX, effectively removed pressure from businesses, allowing them to “postpone” filing and publishing statements without sanctions until three months after the end of the war. At the same time, standards for both auditing and reporting remained high, resulting in an accumulation of unperformed audits. New regulations (e.g., NSSMC Decision No. 3398 of December 19, 2025) introduced additional procedures, and as of February 1, 2026, established specific requirements for review and audit reports. These factors made conducting audits and selecting audit firms significantly more complex.
Technological Factors
During the same period, digital reporting standards were actively introduced, creating new technical challenges. The rollout of XBRL for IFRS filings and SAF-T UA for tax “electronic audits” requires specialized IT tools, fundamentally altering the preparation and verification of financial statements. Enterprises and audit firms had to invest time and capital into new systems and staff training. As a result, the digital transition created bottlenecks and placed additional burdens on auditors, especially in 2025 and 2026, when historical statements were restored concurrently with preparing new filings in updated digital formats.
Staffing Factors
The war profoundly disrupted the labor market. According to the Institute of Analytics and Advocacy4, by October 2023, the shortage of qualified specialists had worsened significantly following the displacement of a substantial portion of the population. This deficit is felt acutely in specialized domains — notably “bookkeeping and accounting” (where vacancy demand substantially exceeds supply). A shortage of accountants and auditors translates directly into delayed report preparation and extended audit timelines. Auditors were also subject to military mobilization or relocated abroad, complicating traditional on-site audit field visits. Furthermore, the audit sector faces an aging professional demographic alongside low inflows of new talent.
Economic and Political Factors
Economic volatility and ongoing uncertainty complicate the calculation and disclosure of financial figures. Currency fluctuations, inflation, and financial unpredictability force enterprises to conduct multi-layered assessments (wartime impacts on sudden or material asset impairments, expected credit loss provisions, etc.), adding significant complexity to the audit. Simultaneously, international sanctions enforcement requires restructuring certain cross-border transactions, contracts, or liabilities, requiring auditors to establish detailed procedures in response to assessed risks and ask difficult questions.
Pandemic Legacy
Although COVID-19 in 2020 and 2021 is in the past, its impact persists in remote work arrangements and procedural shifts in audit execution. The experience gained with remote auditing transitioned into standard practice, and today a substantial part of audit work takes place remotely. While this can be viewed positively, it has placed even greater demand on IT systems, requiring teams to request, verify, and process voluminous remote data packages.
Regulatory and wartime provisions enabled companies to defer audits, while digitalization and the staffing crisis represent the true operational causes of delays
Why 2026 Became the Turning Point
The year 2026 is a turning point because a vast portion of the postponed changes and regulatory requirements from 2022–2025 must now be implemented simultaneously.
- First, legislative relaxations have expired. The reporting moratorium introduced due to martial law ended in May 2025, giving companies until August 2025 to catch up on three years of skipped filings — an effort that largely extended through autumn 2025. Consequently, many delayed audits must be concluded in 2026.
- Second, 2026 marks the first operational year under updated regulatory requirements, auditing standards, and procedures. NSSMC Resolution No. 3398 of December 19, 2025, introduces new requirements for audits and reviews of financial statements effective February 1, 2026, fundamentally altering filing logic. A transitional regime runs until July 1, 2026, mandating supplementary reporting and verification for companies seeking public capital access or regulatory approvals from the NSSMC and NBU.
- Third, the structural framework and reporting formats have changed. The year 2026 sees not only advanced XBRL taxonomies, but also the rollout of the initial SAF-T UA architecture. Across 2025 and 2026, pilot testing of SAF-T was scheduled across the tax landscape. Regulators now require financial reporting strictly in standardized digital taxonomy formats, rejecting paper filings outright.
- Fourth, widespread public and stakeholder concern has accumulated by 2026. Investors and regulatory bodies are challenging businesses over prolonged gaps in operational transparency, demanding verified statements and formal accountability. While businesses could previously cite wartime disruptions, by 2026 this explanation is no longer readily accepted, creating pressure for all participants to deliver timely, audited financial results.
Implications for Investors, Capital Markets, and Trust
The consequences of “deferred audits” for investors and the capital market are significant, though not irreversible. Delayed financial reporting restricts the verified intelligence upon which investors base capital allocation decisions. Outdated financial disclosures amplify uncertainty and perceived risks, reducing capital market appeal. Investors may demand higher risk premiums or avoid markets characterized by insufficient transparency. Under wartime conditions, this dynamic is amplified by generally constrained inbound investment.
For domestic stakeholders and regulatory authorities, market skepticism prompts intensified scrutiny. In the banking sector, for instance, all independent audit reports undergo close review by the National Bank of Ukraine. When a regulated entity fails to present an audit report on time, it signals potential systemic weaknesses, compelling regulators to escalate formal enforcement measures. Similarly, in the securities market, delayed filings can trigger trading suspensions in corporate equities and bonds or revocation of investment fund trading permits.
Conversely, overcoming this backlog of deferred reporting can steadily restore institutional credibility. When enterprises widely publish verified financial audits demonstrating compliance with statutory standards, investment transparency improves. Over time, rigorous regulatory requirements and corporate adherence will elevate financial reporting quality, reinforcing broader capital market trust.
What Needs to Be Done Right Now
Recommendations for Key Process Stakeholders:
- For regulators and government bodies: it is vital to strike a balance between enforcement and business enablement. Continuing active consultations with industry associations regarding the rollout of new regulatory rules and standards, issuing clear implementation guidance to prevent administrative confusion, aligning realistic submission schedules for accumulated audit files, and maintaining dedicated supervisory resources. Furthermore, supporting professional workforce development — such as streamlining auditor certification and expanding professional training programs in financial analysis, ISAs, and IFRS — will help rebuild the specialist talent pool.
- For audit professionals: firms must master modern digital toolsets (training on SAF-T UA schema and XBRL analytics, strengthening remote auditing methodologies, and enhancing cybersecurity protocols) to effectively audit automated financial data. Developing clear operational workflows for processing large volumes of accumulated financial statements using risk-based sampling is essential: prioritizing key balances and material transactions that shifted under wartime operations. Fundamentally, audit corporate culture must adapt toward continuous auditing to uphold institutional trust.
- For commercial enterprises:, above all, stop postponing statement compilation and statutory audits. Completing audits as early as possible in 2026 avoids statutory penalties and preserves corporate reputation among stakeholders. Internal accounting workflows should be modernized to embed transparent operational record-keeping. Use transitional frameworks and seasonal windows to train finance personnel on XBRL and SAF-T formats. During reporting preparation, pay particular attention to comprehensive disclosure of wartime operating impacts. Facilitate remote collaboration with auditors where on-site visits are unfeasible. Most importantly, view the audit not as an administrative burden, but as a pillar of public confidence in the company: all financial reporting must be complete, accurate, and cleared through overdue audits.
Conclusion
The 2021–2026 period in Ukraine has been defined by a cumulative elevation of financial transparency demands. While audit verifications were temporarily deferred due to force majeure circumstances (the pandemic, war), by 2026, accumulated financial statements must be independently audited and presented to the public. This positions 2026 as a year of acceleration across the audit profession. We are witnessing both heightened market demand for disclosures and reinforced institutional mandates (new statutory requirements, standards, and digital formats). For investors and capital markets, this represents an opportunity to gauge the genuine commitment of businesses to transparent operations. If the “deferred audit syndrome” is successfully overcome through coordinated collaboration between regulators, auditors, and corporations, the country will secure a stronger foundation for post-war reconstruction and economic expansion. Conversely, setbacks in this transition threaten institutional trust and macroeconomic stability, whereas the timely publication of true, audited records will restore long-term confidence in the Ukrainian market. Audit firm Audit Invest stands ready to facilitate these processes and communicate verified information regarding the financial position, financial results, cash flows, and equity of Ukrainian businesses to society.
Sources
- NSSMC Resolution of December 19, 2025 No. 09/21/3398/K03 “On Amendments to the Resolution of the National Securities and Stock Market Commission of July 22, 2021 No. 555.”
- Law of Ukraine “On Protection of the Interests of Reporting Entities and Other Documents During Martial Law or State of War” of March 3, 2022 No. 2115-IX.
- Law of Ukraine “On Amendments to the Law of Ukraine ‘On Audit of Financial Statements and Auditing Activities’ Regarding the Provision of Auditing Activities for the Period of Martial Law and Post-War Economic Recovery” of May 31, 2022 No. 2285-IX.
- Article “War and the Shortage of Workers: Dynamics of Human Resources in Ukraine” dated October 13, 2023, Institute of Analytics and Advocacy.
