Vadym Lozytskyi ,
Auditor at LLC AF “AUDIT-INVEST”
Table of Contents
What Changed in 2026?
As of January 1, 2026, Ukraine has implemented significant changes to the liability regime and requirements for the submission and disclosure of regulated information. This includes both general regulated data and regular information provided by issuers and capital market participants. These changes are primarily driven by the introduction of new, stringent financial sanctions for non-compliance.
The new regulatory landscape is based on the following legislative acts:
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The Law of Ukraine “On State Regulation of Capital Markets and Organized Commodity Markets” (No. 448/96-VR, as amended effective 01.01.2026). This law radically expands the financial liability regime (sanctions) for violations related to financial reporting and disclosure of regulated information. Specifically, it introduces Article 50 (via Law No. 3585-IX), which details much harsher penalties and the procedures for their application.
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Law No. 3585-IX dated February 22, 2024. This act mandates the temporary application (from January 1, 2026, to January 1, 2030) of the maximum financial sanctions (fines) provided for under Article 50 of the Law “On State Regulation of Capital Markets and Organized Commodity Markets.”
The Law of Ukraine “On Capital Markets and Organized Commodity Markets” (as amended by Law No. 738-IX). This law governs relationships within capital markets and defines the obligations of issuers regarding the disclosure of regulated information, including regular information (annual and interim) and financial statements.
Regular information about an issuer is a core component of regulated information in capital and organized commodity markets. We will focus specifically on the disclosure of annual regular information, as this process directly involves mandatory auditing activities.
What exactly is changing in reporting and information disclosure?
The full obligation to disclose regulated information has been restored. Following a period of temporary exemptions, disclosure requirements for securities issuers are now fully back in effect:
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Regular (annual and interim) and special information must be submitted in strict accordance with the legislation and NSSMC (National Securities and Stock Market Commission) regulations.
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Qualified requirements regarding the format, deadlines, and content of submissions are defined by the “Regulation on Information Disclosure” approved by the NSSMC.
In practice, this means that issuers must be prepared for the regular disclosure of data concerning their operations, including financial statements, corporate events, and changes in management structure.
New Regime of Financial Sanctions (Fines):
A new regime of financial sanctions is being introduced, significantly increasing the potential fines. Starting January 1, 2026, new financial penalties for violations in the field of financial reporting and regular information disclosure (as stipulated by Article 126 of the Law “On Capital Markets and Organized Commodity Markets”) will come into force:
- Up to UAH 22 million for officials (individuals).
- Up to UAH 110 million for legal entities (not to exceed 5% of annual turnover).
The maximum financial sanctions (fines) provided for in parts one through six of Article 50 of the Law of Ukraine “On State Regulation of Capital Markets and Organized Commodity Markets” shall be applied temporarily from January 1, 2026, to January 1, 2030. These maximum sanction amounts are implemented incrementally according to the following schedule:
- In 2026: Applied with a coefficient of 0.2 (20% of the maximum fine);
- In 2027: Applied with a coefficient of 0.4 (40% of the maximum fine);
- In 2028: Applied with a coefficient of 0.6 (60% of the maximum fine);
- In 2029: Applied with a coefficient of 0.8 (80% of the maximum fine);
- From January 1, 2030: 100% of the maximum sanction amounts shall apply.
This approach creates a gradual increase in liability, allowing market participants time to adapt their internal processes to the new, more rigorous requirements.
What regular information must be reported and disclosed, and what are the deadlines?
Regular information about an issuer is a core component of regulated data. It primarily includes annual and interim reporting on the financial and business performance of the issuer. This information is disclosed within capital and organized commodity markets and must include, among other things, annual financial statements (as well as consolidated financial statements) verified by an independent audit entity.
According to the requirements of Article 126 of the Law of Ukraine “On Capital Markets and Organized Commodity Markets,” this information must be disclosed by the issuer no later than the following deadlines:
- Annual Information: No later than April 30 of the year following the reporting year;
- Interim (Q1): No later than April 30;
- Interim (Q2): No later than July 31;
- Interim (Q3): No later than October 31;
- Interim (Q4): No later than January 31 of the following year.
- *Information regarding interim consolidated financial statements must be disclosed no later than the last day of the second month following the reporting period.
Consequently, the Annual Information of the issuer for 2025 must be disclosed no later than April 30, 2026. The Report on Payments to Governments for 2025 must be disclosed by the issuer no later than June 30, 2026. This information about the issuer must be posted on its official website and remain publicly accessible for at least 10 years after its initial disclosure.
Is it necessary to submit the Financial Reporting Taxonomy along with the Auditor’s Report, and by what date?
According to the requirements of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine,” enterprises that use International Standards for preparing financial statements must prepare and submit both individual and consolidated financial statements to state authorities and other users upon request. This must be done in a unified electronic format based on the International Financial Reporting Standards (IFRS) Taxonomy.
The submission of the financial reporting taxonomy along with the auditor’s report is a mandatory legislative requirement when filing financial statements to the Financial Reporting System (FRS), administered by the NSSMC in the XBRL/iXBRL format. This submission consists of an XBRL file constructed on the basis of the official UA IFRS XBRL Taxonomy published by the regulator.
Regarding the deadlines: the Law of Ukraine “On Capital Markets and Organized Commodity Markets” establishes the deadline for disclosing annual regular information as no later than April 30 of the year following the reporting year. In our professional opinion, submitting financial statements through the FRS in XBRL/iXBRL format is the specific method prescribed by the NSSMC to fulfill this obligation and does not create a separate deadline distinct from the legally established disclosure date.
Important Reminders:
The full set of annual financial statements of the issuer under IFRS, together with the auditor’s report for 2025, must be disclosed no later than April 30, 2026. For issuers, submitting this information through the Financial Reporting System (FRS) in XBRL/iXBRL format is the official method established by the NSSMC to fulfill this obligation.
It is possible (as many market participants hope) that for the annual issuer information for the 2025 financial year to be disclosed in 2026, the deadlines for submission and disclosure through the FRS in XBRL/iXBRL format may be revised. However, any such change must be officially approved by a separate decision of the NSSMC or the FRS regulations.
Interested in financial reporting in the UA iXBRL IFRS Taxonomy format?Audit Invest is ready to provide expert assistance with the preparation, verification, and submission of your reports, as well as consult on all current regulatory matters.
