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SAF-T UA: A temporary deferral for large taxpayers or a strategic comeback? What does the withdrawal of draft law No. 6255 mean?

19 August, 2025 Newsletters

The issue of introducing electronic audits (e-audits) in Ukraine remains a subject of active debate among the business community and experts. Both this and last year, numerous proposals were submitted to improve the Draft Law on Amendments to the Tax Code of Ukraine regarding the Introduction of Electronic Audits as of November 02, 2021, No. 6255 (Draft Law No. 6255), which, among other things, became the basis for reviewing the relevance of this law and its subsequent withdrawal and removal from consideration.

Worth remembering that the European Business Association, the American Chamber of Commerce in Ukraine, and other representatives of the business community have officially expressed their comments and suggestions on this issue. The main emphasis was placed on the need for proper regulation of issues related to the introduction of the standard audit file (SAF-T UA).

Business associations have repeatedly stressed the need to prioritise changes aimed at avoiding excessive administrative burdens on taxpayers and, in particular, ensuring the effective implementation of the reform, including taking into account the transition period for businesses following the adoption of Draft Law No. 6255.

On July 17, 2025, Verkhovna Rada withdrew and removed from consideration Draft Law No. 6255, which provided for amendments to the Tax Code of Ukraine (the Tax Code) introducing e-audits.

Notably, this decision formally suspended the legislative enactment of the SAF-T UA. At the same time, practice shows that electronic auditing in the SAF-T UA format has not only remained relevant but is also gradually gaining momentum.

Hence, is the pullback of Draft Law No. 6255 the final curtain for e-audits in Ukraine, or the start of something bigger?

First of all, it should be noted that, in accordance with Articles 104-105 of the Law of Ukraine “On the Regulations of the Verkhovna Rada of Ukraine”, a draft law may be withdrawn by its initiator or considered withdrawn in the event of the termination of the powers of the legislative initiative entity. Thus, in the case of Draft Law No. 6255, we are referring to its voluntary withdrawal by the Cabinet of Ministers of Ukraine, which does not mean that it automatically loses its validity; rather, the feasibility of its implementation in its current form is being reviewed. As of today, this draft law has been withdrawn and removed from consideration.

This means that Draft Law No. 6255 will never appear on the agenda again. At the same time, this does not mean that the state has abandoned the idea of e-audits altogether. Most likely, the initiative may be reintroduced in the near future as a new draft law from the Cabinet of Ministers of Ukraine or another legislative body.

Thus, the withdrawal and removal of Draft Law No. 6255 from consideration is not tantamount to abandoning the very concept of introducing e-audits in Ukraine.

Moreover, this opens up space for updating and adapting to modern challenges, taking into account proposals put forward by the business community, and preparing a more refined draft law under a new number.

At the same time, despite the lack of a legislative basis and the absence of any amendments to the Tax Code, the State Tax Service of Ukraine continues to actively promote the SAF-T UA pilot project.

It should be noted that according to information from the State Tax Service website as of July 23, 2025: “41 taxpayers have already joined the E-audit testing. They have generated and submitted 415 SAF-T files”.

At the same time, the State Tax Service notes that the purpose of such testing is:

“…

to check the format’s performance in real conditions;
to identify methodological, technical, and accounting features;
to collect practical comments from businesses”.

The above demonstrates that businesses are gradually adapting to the new data exchange format, and the withdrawal of Draft Law No. 6255 can be interpreted as a kind of temporary reprieve for taxpayers. Although the legislative implementation of e-auditing has been postponed, the system itself is already operating in test mode.

This pilot project allows the State Tax Service to gain practical experience, test technical solutions, and prepare businesses for future changes that are not so far off.

In the near future, the government is likely to introduce a new, improved draft law, which, we hope, will take into account the results of the pilot implementation and proposals from business associations.

Thus, the strategy does not appear to be a rejection, but rather preparation for a strong and more reasonable “return” of the SAF-T UA to the legislative field.

What’s next?

We assume that until the government adopts a more refined draft law on e-audits, the following steps are possible:

Businesses will decide for themselves whether to voluntarily participate in testing the pilot project for the implementation of the SAF-T UA.
Legislative consolidation may take place in a new format with refined procedures and deadlines.
The transition to mandatory use (most likely starting with large taxpayers and later extending to all others); however, this is possible only after the adoption of a new law.

Therefore, we believe that the withdrawal and removal of Draft Law No. 6255 from consideration is not the end of the implementation of the SAF-T UA, but, on the contrary, it provides an opportunity to incorporate the necessary relevant changes and to establish the transition period for businesses after the adoption of the new law.

In addition, e-audits are likely to be resubmitted to the Verkhovna Rada for consideration in a new version, and the transition from “paper-based” tax audits to digital ones will constitute an inevitable step in the modernisation of Ukraine’s tax system.

For now, we can only wait for the new draft law and hope that the proposals of the business community will be taken into account.

The above commentary presents the general statement for information purposes only and as such may not be practically used in specific cases without professional advice.

Kind regards,

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