What Financial Statements a Non-Profit Organization Files in Ukraine

A non-profit organization in Ukraine (a civic organization or a charitable foundation) that applies National Accounting Standard 25 (NP(S)BO 25) prepares a balance sheet and an income statement every year using simplified forms. Under clause 46.2 of Article 46 of the Tax Code of Ukraine, these financial statements are an annex to, and an integral part of, the tax Report on the Use of Income (Profits) of a Non-Profit Organization. In practice this does not mean both documents have to be filed as a single package: the financial statements can be filed before the Report itself.

In our article on accounting in a non-profit organization we covered bookkeeping during the year. This one is about the year-end reporting for the calendar year. Below we look at how the financial statements differ from the Report on the Use of Income, which forms to prepare and what happens if you miss the deadline.

Two documents in one package

The "Report on the Use of Income (Profits) of a Non-Profit Organization" and the "financial statements" are not synonyms, even though their recipients partly overlap.

Criterion	Report on the Use of Income (Profits)	Financial statements (balance sheet + income statement)
What it shows	What income and expenses the foundation or organization had during the year	Assets and liabilities at year end (balance sheet) and the financial result for the year (income statement)
Form approved by	Order of the Ministry of Finance No. 553 of 17 June 2016	NP(S)BO 25 "Simplified Financial Statements" (Order of the Ministry of Finance No. 39 of 25 February 2000)
Relationship between the documents	The principal tax report	An annex to, and an integral part of, the tax Report (clause 46.2 of Article 46 of the Tax Code), and at the same time the organization's own financial statements
Filing deadline	To the State Tax Service (STS): 60 calendar days after the end of the reporting year	To the STS: the same deadline, and it may be filed before the Report; to the statistics authorities: no later than 28 February

Although the tax Report and the financial statements form one reporting package, this does not mean they have to be sent to the tax authority at the same time. The financial statements can be registered days or even weeks before the Report. The tax authority matches both sets of forms for the relevant period. A problem arises when one of the two documents is not filed within the deadline at all, because the package is then considered incomplete. It also matters that the tax authority registers the financial statements before the Report on the Use of Income is filed.

Which financial statements a non-profit organization prepares

NP(S)BO 25 applies to micro-enterprises, small enterprises and non-entrepreneurial companies. Non-entrepreneurial companies are a category of entities that do not aim to earn a profit for distribution among their members (Article 85 of the Civil Code of Ukraine); in practice it covers civic organizations, charitable foundations and other non-profit entities. Tax law (sub-clause 133.4.1 of Article 133 of the Tax Code) adds one specific requirement for such organizations: the founding documents must prohibit any distribution of income among founders, members, employees or their related parties.

Non-entrepreneurial companies are a separate category of entities that prepare simplified financial statements. That is why the forms they use do not depend on the actual size of their balance sheet figures. Charitable foundations and civic organizations report on Form No. 1-ms (balance sheet) and Form No. 2-ms (income statement) regardless of whether they meet the micro- or small-enterprise criteria. Forms No. 1-m and No. 2-m are meant for small enterprises. A non-entrepreneurial company with "small" figures still prepares Forms No. 1-ms and No. 2-ms; it does not pick a form by its size. There are exceptions, however: organizations that are required to apply International Financial Reporting Standards (IFRS), keep their books under IFRS voluntarily, or have chosen to prepare financial statements on the forms set by NP(S)BO 1. Such organizations do not use the simplified forms. Whether these restrictions apply to a particular foundation or organization should be checked separately, so such cases are outside the scope of this article.

Where and when to file

The Report on the Use of Income (Profits) of a Non-Profit Organization and the financial statements are filed with the State Tax Service at the organization's principal place of registration. The filing deadline is 60 calendar days after the end of the reporting (tax) year (sub-clause 49.18.3 of Article 49 of the Tax Code, for taxpayers whose reporting period is the calendar year).

For 2026 the calculation runs as follows: the 31 days of January plus the 28 days of February plus 1 day of March add up to exactly 60 days, which lands on 1 March 2027. If that date falls on a day off, under clause 49.20 of Article 49 of the Tax Code the last day of the deadline is the operating (banking) day following the day off.

The taxpayer chooses the filing method, on paper or electronically (clause 49.3 of Article 49 of the Tax Code). Electronic filing is mandatory for large and medium-sized enterprises (clause 49.4 of the Tax Code). The same clause 49.4 contains a separate rule for financial statements: if a non-profit organization files its tax returns electronically, it must also file the financial statements under clause 46.2 electronically only. In practice this is the main route for non-profits. Electronic filing delivers the financial statements to both recipients at once.

The second recipient of the same financial statements is the state statistics authorities. For non-entrepreneurial companies this requirement stems from Article 14 of the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" No. 996-XIV of 16 July 1999, while the procedure and the deadline are set by the Procedure for Filing Financial Statements approved by Cabinet of Ministers Resolution No. 419 of 28 February 2000, under which annual statements go to the statistics authorities no later than 28 February of the following year, which is earlier than the tax deadline. The same rule applies to statistics filings: if the deadline falls on a day off, it moves to the next working day. There is no need to file the financial statements twice. Electronic financial statements on forms with an "S" identifier pass through the "single window" and reach both the STS and the State Statistics Service. Forms with a "J" identifier never reach the statistics authorities. So after filing, wait for the receipt confirming that the statistics authority has accepted the financial statements, not just the receipt from the tax office.

Because the financial statements are an annex to, and an integral part of, the Report on the Use of Income, the order of electronic filing matters. File the financial statements before the Report and wait for confirmation that they have been accepted. Only then file the Report on the Use of Income, indicating the financial statement forms attached. The recommended sequence for electronic filing is:

1. File the financial statements.
2. Wait for Receipt No. 2 confirming their acceptance.
3. File the Report on the Use of Income with the relevant boxes ticked for the financial statements already filed.
4. Check Receipt No. 2 confirming acceptance of the Report.

This sequence matters because, during the automated check of the Report, the tax authority verifies that the financial statements have been filed and registered. If the Report goes first and the financial statements later, the Report may be rejected. Filing the financial statements afterwards does not automatically get the rejected Report accepted. In that case the Report has to be filed again.

What happens if you file late

Failing to file the Report on the Use of Income (Profits) of a Non-Profit Organization, which counts as tax reporting, or filing it late carries a fine under clause 120.1 of Article 120 of the Tax Code of UAH 340 for each such violation (amounts as of September 2026). If the organization has already been fined for the same violation during the year, a repeat violation costs UAH 1,020. At the same time, sub-clause 69.1 of clause 69 of sub-section 10 of section XX of the Tax Code exempts taxpayers from liability where they were unable to meet the filing deadline, provided the prescribed procedure for confirming those circumstances is followed, for example when the reporting could not be filed on time because of a power outage caused by missile strikes (STS clarification in the ZIR knowledge base).

Failure to file tax reporting on time is a standalone ground for an unscheduled documentary tax audit under sub-clause 78.1.2 of Article 78 of the Tax Code. Keep in mind that the Report itself neither confirms nor grants an organization non-profit status. It only shows how the organization used its income during the year. Non-profit status depends on meeting the requirements in the founding documents and in law, and on inclusion in the Register of Non-Profit Institutions and Organizations. If the tax authority removes an organization from that Register, it becomes a corporate income tax payer, with separate rules for determining the tax base and the transition date, so in a contested situation it is worth analyzing the consequences with a professional rather than relying on the general rule.

How to prepare in advance

Reconcile the figures in the financial statements and in the Report on the Use of Income before filing them with the authorities, not after. Five steps reduce the risk of discrepancies and of a missed deadline:

1. Establish whether the organization is a non-entrepreneurial company under NP(S)BO 25 and whether it is subject to mandatory IFRS, applies IFRS voluntarily, or has voluntarily chosen the NP(S)BO 1 forms. This determines which financial statement forms to prepare.
2. Reconcile the amounts of restricted and unrestricted funding in the accounts and in the reporting. The figures in the Report on the Use of Income and in the financial statements must be consistent, although this does not mean a literal line-by-line and amount-by-amount match.
3. Prepare the balance sheet and the income statement in advance and file them on the "S" forms no later than 28 February, and in any case before the Report itself. That way the financial statements meet both the deadline for the statistics authorities and the deadline for the tax authority, and a technical failure on the last day will not derail the filing.
4. File the Report with the tax authority within 60 days, allowing for the shift to the next operating day, and tick the box confirming which financial statement forms are attached.
5. Keep the acceptance receipts (from the STS and from the statistics authority) as proof that the deadlines were met; for paper filing, obtain a receipt stamp or the relevant postal documents.

UHY Prostir supports accounting for non-profit organizations, from accounting for restricted funding and its use during the year to preparing the Report on the Use of Income and the financial statements. Our article on the importance of auditing for trust in NGO activities explains what an independent review gives a non-profit. If you need such a review before filing, or have doubts about reporting for earlier periods, contact our team.

Oksana Koliada (Auditor)