Viktoriia Kharchenko,
Head of Marketing Department
Table of Contents
In our previous article, we analyzed in detail why it is critically advantageous for engineering and architecture firms working with Building Information Modeling (BIM) technologies to become Diia City residents. However, while opening doors to ultra-low tax rates and flexible Gig contracts, the state imposes a strict reciprocal requirement — absolute financial transparency.
Resident status is not a perpetual gift. It is a privilege that must be periodically reconfirmed through an independent auditor’s report.
In this article, we examine the audit specifics tailored specifically to the BIM sector, the critical deadlines to maintain, and how to steer clear of pitfalls that could cost your company its resident status.
Legal Foundation: What Does the Law State?
The obligation of residents to undergo an independent audit is clearly governed by Article 13 of the Law of Ukraine No. 1667-IX “On Stimulating the Development of the Digital Economy in Ukraine.”
The state does not take internal management reports at face value — every key metric of the company must be certified by a licensed external auditor.
BIM companies that have recently obtained resident status are subject to two primary compliance stages:
- Initial (Compliance Report): Submitted based on the results of the first three full months of residency. The auditor’s task is to verify whether the company established the correct operational model from day one. The Ministry of Digital Transformation must receive this report together with the independent auditor’s report no later than the last day of the sixth month following the month resident status was acquired.
- Annual (Annual Report): A regular financial check-up. Subsequently, the company must undergo this audit on an annual basis. The report for the preceding calendar year must be submitted within a strictly defined window — from January 1 to June 1 of the year following the reporting period.
Audit Specifics for BIM: What Does the Auditor Look For?
For traditional IT businesses, Diia City audits have already become standard practice. However, for engineering and architectural practices transitioning into BIM residents, there are unique nuances where errors most often occur.
The audit firm verifies the business’s compliance against three “golden” criteria:
1. Qualifying Revenue (The 90% Threshold)
The share of company income derived from qualified activities must account for no less than 90% of total revenue.
The trap for BIM: In addition to authoring 3D models and structural drawings (covered by NACE/KVED 71.12), design practices frequently provide author supervision, general contracting, or even software license reselling. If an accountant misclassifies these income streams and the qualifying engineering share drops to 89.9%, the company risks losing its resident status. We strongly advise paying close attention to this issue. As part of the audit, a specialist will analyze your revenue classification methodology and confirm or refute its compliance with Diia City statutory criteria, giving the company clarity before the regulator.
2. Remuneration Level (EUR 1,200 Equivalent)
The average monthly remuneration of employees and Gig specialists must be no less than EUR 1,200 (at the official National Bank of Ukraine exchange rate).
The trap for BIM: Architecture studios often engage freelance subcontractors or project-based compensation structures (tied to project milestones). The auditor will strictly calculate the average amount across all personnel on a monthly basis. Irregular disbursement schedules can pull this metric below the threshold during months with few closed acceptance certificates.
3. Team Size (Minimum 9 Individuals)
The average headcount of employees and Gig specialists at the end of each calendar month must be at least 9 persons. These must be officially engaged staff (under standard labor contracts or Gig contracts), rather than standard Group 3 individual entrepreneurs (FOPs).
The Cost of an Error: What Risks Does the Business Face?
Diia City regulations are uncompromising. If a company misses the deadline for submitting the independent audit report, or if the audit uncovers a failure to meet even one of the three criteria, the Ministry of Digital Transformation initiates the procedure to revoke resident status.
Loss of status does not imply retroactive tax recalculations for prior compliant months; however, it nullifies all tax privileges moving forward. The enterprise will be forced to revert to the general taxation system: pay 18% corporate income tax instead of the 9% exit tax (DIT), 18% personal income tax instead of 5%, and charge 22% unified social contribution (USC) on the entire payroll instead of the fixed minimum contribution.
For multi-year BIM projects where operating margins were budgeted around Diia City tax incentives, this represents an immediate hit to financial stability and market competitiveness.
Audit Invest — Your Trusted Guide in the World of BIM and Diia City
Adopting BIM methodologies and transitioning into Diia City is a complex milestone requiring high-level expertise across both modern technologies and tax law. You do not have to navigate this path alone through trial and error.
Audit Invest is actively expanding in this innovative domain and possesses industry-leading experience in the Ukrainian market.
Why Residents Trust Us:
- Extensive Track Record: Over the past 3 years, we have successfully managed and supported over 250 Diia City projects. We know every potential issue, every ministry guideline, and the precise nuances of criteria verification.
- BIM Sector Expertise: The Diia City regime functions under unified rules for all technological sectors. Our deep audit background with IT businesses enables us to support the BIM industry with equal precision, as statutory financial criteria and reporting standards remain aligned.
- Synergy with Market Leaders: We serve as active participants and expert partners in events organized by the Kharkiv IT Cluster, Dnipro IT Cluster, and contribute as speakers at initiatives held in partnership with the Ministry of Digital Transformation covering Diia City and BIM implementation. Together, we cultivate the ecosystem for advanced high-tech, architectural, and engineering businesses.
Do not postpone verifying the financial health of your BIM business until the final deadline. Entrust the preparation of your independent audit report to professionals who will help safeguard your resident status, legally optimize your accounting, and confidently scale your business globally.
Contact Audit Invest today — and we will conduct a preliminary expert diagnostic of your readiness for the Diia City audit!
