The National Securities and Stock Market Commission of Ukraine (NSSMC) has provided a response to a request from the Ukrainian Association of Investment Business regarding the practical application of the updated Requirements for audit and review of financial statements, approved by Decision No. 3398 dated December 19, 2025.
The clarification is important for companies operating in capital markets, including asset management companies (AMC), non-state pension funds (NPF), collective investment institutions (CII), and other market participants, as it defines the practical approach to preparing audit documentation in 2026.
When the new requirements entered into force
The updated version of the audit requirements came into force on February 1, 2026, with certain exceptions.
In particular, Chapters 4–10 of Section II will only become effective from July 1, 2026.
Is an assurance report mandatory?
A key question for the market concerned the requirement to submit an assurance report.
The NSSMC noted that:
- assurance reports are required only in cases explicitly предусмотренных by law;
- such cases are defined in Chapters 2–10 of Section II of Requirements No. 555.
This means that the requirement is not universal for all types of audits or reviews of financial statements.
Audit for 2025: what documents must be submitted
The Commission’s response effectively confirms the market’s position:
- for audits of financial statements for 2025 conducted after February 1, 2026, an audit report alone is sufficient;
- similarly, for reviews of financial statements for Q1 2026, a review report is sufficient.
A mandatory condition is the inclusion of additional information in accordance with paragraph 9 of Section I of the Requirements.
Transitional period until July 1, 2026
The NSSMC also outlined specific features of the transition period. Until July 1, 2026:
- for most administrative procedures (Chapters 4–10), only an audit report and/or review report must be submitted;
- assurance reports are not required.
Exceptions apply to:
- licensing procedures;
- approval of significant ownership,
where a full set of documents, including an assurance report, is required starting from February 1, 2026.
Practical implications for business
The clarification significantly reduces regulatory uncertainty for market participants.
Key takeaways:
- in most cases, during the first half of 2026, a standard audit report is sufficient;
- the additional burden of assurance reports is limited;
- companies must carefully assess whether their situation falls under Chapters 2–3 of the Requirements.
At the same time, risks remain related to:
- misinterpretation of regulatory requirements;
- ignoring the transitional period;
- errors in audit documentation.
Link to audit digitalization (SAF-T UA)
The update of audit approaches is taking place in parallel with the implementation of electronic audit (SAF-T UA) in Ukraine, which предусматривает standardization and digitalization of financial data.
In this context, companies should assess in advance:
- readiness of accounting systems;
- quality of financial reporting data;
- compliance of internal processes with new control requirements.
Conclusion
The NSSMC clarification confirms that a phased approach to implementing new audit requirements will apply in 2026.
Until July 1, 2026, a simplified regime is in place for most procedures, giving businesses time to adapt and prepare for full compliance.
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This material was prepared by experts at Kreston Ukraine, an international audit and consulting firm specializing in statutory audit, tax consulting, accounting, and support of tax audits.
The information is based on the requirements of Ukrainian legislation, OECD recommendations, and electronic audit practices applied in the European Union.
Do you need clarification on how the new audit requirements apply to your specific situation?
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