On December 25, 2025, the Ministry of Finance of Ukraine adopted Order No. 654 amending Order of the Ministry of Finance No. 422 dated December 9, 2022. The amendments are aimed at simplifying and further automating reporting by primary financial monitoring entities (PFMEs).
Principal amendments
1. Electronic reporting form
The annual report in Form No. 2-finmon is submitted exclusively in electronic form through a special section of the unified web portal for the use of public funds: https://spending.gov.ua/aml/
In the event of an official notification to the Ministry of Finance about the technical impossibility of submitting reporting via the web portal, it is allowed to submit the report in electronic Excel format to the Ministry of Finance’s email address: infomf@minfin.gov.ua.
2. Extension of the deadline for submitting annual reports
The deadline for submitting annual reports in Form No. 2-finmon has been extended to January 25 of the year following the reporting year (instead of January 11).
3. New deadline for submitting an adjusted report
In the case of submitting corrected reports, a new deadline has been established – no later than January 30 of the year following the reporting year.
4. Cover letter cancellation
Cover letter cancelled. Instead, the report is accompanied by an explanation that is consistent with approaches to digitalization and document flow simplification.
Practical significance of the amendments
The introduced amendments are designed to reduce the administrative burden on PFMEs, unify the procedure for submitting reports, and increase the efficiency of its processing within the framework of state financial monitoring.
Recommendations
Kreston Ukraine’s experts advise primary financial monitoring entities to check in advance their readiness to submit reports exclusively in electronic format, as well as the relevance of access of responsible persons to the spending.gov.ua web portal.
Particular attention should be paid to meeting the updated deadlines for submitting annual and adjusted reports, as well as preparing explanations instead of cover letters, which are now a mandatory element of report submission.
If necessary, Kreston Ukraine’s experts are ready to provide consulting support on the proper Form No. 2-finmon filling and the organization of internal financial monitoring procedures in accordance with the updated legislative requirements.
Note. As of January 5, 2026, the text of Order No. 654 of the Ministry of Finance of Ukraine is missing from the official websites of the Verkhovna Rada of Ukraine and the Ministry of Finance of Ukraine. Also, the updated reporting forms have not yet been published on the official website of the Ministry of Finance.
