The National Securities and Stock Market Commission (NCSSFR) issued a letter on 30 December 2025, No. 16/22882, addressed to industry associations of capital market participants with recommendations on certain aspects of submitting financial and consolidated financial statements prepared under International Financial Reporting Standards (IFRS) in a single electronic XBRL format.
The Commission reminds that, in accordance with the Law of Ukraine “On Accounting and Financial Reporting in Ukraine,” financial and consolidated financial statements under IFRS must be prepared exclusively based on the official IFRS taxonomy, published in the state language, and submitted to the Financial Reporting Collection Center, operationally managed by the NCSSFR.
The letter pays special attention to the audit report. In cases of mandatory audit, the XBRL electronic file of the financial statements must include the full audit report submitted together with the financial statements. This requirement is provided, in particular, by the Law of Ukraine “On Audit of Financial Statements and Audit Activity,” the Procedure for the Operation of the Financial Reporting Collection Center, and the Requirements for Disclosing Financial Statement Indicators in XBRL for Capital Market Participants.
The NCSSFR also emphasizes that the auditor confirms the compliance, in all material respects, of the information contained in financial statements submitted in the single electronic XBRL format with legislation and IFRS. Accordingly, capital market participants are recommended to clearly define the format of the financial statements subject to audit when concluding audit agreements.
These recommendations aim to ensure proper compliance with legislation in the field of accounting and auditing, as well as to foster a unified practice of preparing, submitting, and auditing financial statements in XBRL format, providing users with access to complete and reliable audited financial information.
Key Takeaways
The NCSSFR’s position indicates a strengthened regulatory focus not only on the formal submission of financial statements in XBRL format but also on their quality, completeness, and consistency of audited information available to users. For companies reporting under IFRS, this requires careful application of the IFRS taxonomy and coordination of the financial statement format with the auditor during audit planning.
For auditors, it is critically important to recognize that the object of assurance is specifically the financial statements in the single electronic XBRL format, not alternative submissions. This approach will help establish a unified practice for auditing XBRL reports and reduce regulatory and reputational risks for all market participants.
