Amendments to the Procedure for the Exchange of Electronic Documents with Supervisory Authorities Effective from 24 May

On 24 May 2026, Order of the Ministry of Finance of Ukraine No. 169 dated 25 March 2026 entered into force, introducing amendments to the Procedure for the Exchange of Electronic Documents with Supervisory Authorities. One of the key changes clarifies the mechanism for acquiring the status of an electronic document exchange entity through accession to the relevant agreement.

From now on, accession to the Agreement on the Recognition of Electronic Documents is carried out by submitting the first electronic document in the prescribed XML format to the supervisory authority. Confirmation of acquiring the status of an electronic document exchange entity is the receipt of an acceptance receipt for such document. For self-employed individuals who are required by law to submit reports in electronic form, a separate procedure has been introduced for the use of a personal qualified electronic signature. In particular, the public key certificate must be submitted to the supervisory authority together with the first electronic document or via a separate notification.

The updated Procedure also contains a number of practical aspects requiring particular attention from businesses and their advisors. In particular, the Agreement is automatically terminated in the event of a change of the company’s director in the Unified State Register, expiry of the qualified electronic signature certificate, or termination of the taxpayer’s activities. Accordingly, businesses are advised to continuously monitor the validity of their electronic keys and registration data, as the tax authorities’ systems will automatically reject documents signed with invalid or expired certificates.