A non-profit organization (a public association or charitable foundation) that applies NP(S)BO 25 prepares a balance sheet and a statement of financial results in simplified form every year. Under clause 46.2 of Article 46 of the Tax Code of Ukraine, the financial statements are an appendix and an integral part of the tax Report on the Use of Income (Profit) of a Non-Profit Organization. In practice this does not mean both documents must be submitted as a single package: the financial statements can be submitted earlier than the Report itself.
In our article on accounting in a non-profit organization, we covered record-keeping during the year. This article covers the year-end reporting for the calendar year. Below we look at how financial statements differ from the Report on the Use of Income, which forms to prepare, and what happens if the deadline is missed.
Two documents in one package
The “Report on the Use of Income (Profit) of a Non-Profit Organization” and the “financial statements” are not synonyms, although they are partly addressed to the same recipient.
Report on the Use of Income (Profit)
- What it shows: the income and expenses the foundation or organization had during the year.
- Form approved by: Order of the Ministry of Finance of 17.06.2016 No. 553.
- Role in the package: the main tax report.
- Deadline: 60 calendar days after the end of the reporting year (to the State Tax Service).
Financial statements (balance sheet and statement of financial results)
- What they show: the financial position at year-end (balance sheet) and the financial result for the year (statement of financial results).
- Forms approved by: NP(S)BO 25 “Simplified Financial Statements” (Order of the Ministry of Finance of 25.02.2000 No. 39).
- Role in the package: an appendix and integral part of the tax report (clause 46.2, Article 46 of the Tax Code), as well as the organization’s own financial statements.
- Deadline: to the State Tax Service, the same deadline, and they may be submitted earlier than the Report; to the statistics authorities, no later than 28 February.
Although the tax report and the financial statements are components of one reporting package, they do not have to be sent to the supervisory authority at the same time. The financial statements can be registered several days or even weeks before the Report. The supervisory authority takes both forms into account for the relevant period. A problem arises if either document is not submitted at all by the deadline, because the package is then considered incomplete. It is also important that the supervisory authority registers the financial statements before the Report on the Use of Income is submitted.
Which financial statements a non-profit organization prepares
NP(S)BO 25 applies to microenterprises, small enterprises, and non-entrepreneurial companies. Non-entrepreneurial companies are companies that do not aim to make a profit for distribution among their participants (Article 85 of the Civil Code of Ukraine). In practice, this category includes public associations, charitable foundations, and other non-profit entities. Tax legislation (subparagraph 133.4.1 of clause 133.4 of Article 133 of the Tax Code) contains a specific requirement for such organizations: their founding documents must prohibit the distribution of income among founders, participants, members of the organization, employees, or related persons.
Non-entrepreneurial companies are a separate category of entities that prepare simplified financial statements. The forms they use therefore do not depend on the actual size of their balance sheet figures. Charitable foundations and public associations report on forms No. 1-ms (balance sheet) and No. 2-ms (statement of financial results), regardless of whether they meet the criteria for a micro or small enterprise. Forms No. 1-m and No. 2-m are intended for small enterprises. A non-entrepreneurial company, even with “small” figures, prepares No. 1-ms and No. 2-ms and does not choose a form based on its size.
There are, however, exceptions to this rule. Simplified forms are not used by organizations that are required to apply International Financial Reporting Standards (IFRS), that keep records under IFRS voluntarily, or that have independently chosen to prepare financial statements on the forms under NP(S)BO 1. Whether these restrictions apply to a specific foundation or organization should be checked separately, so such cases are not covered in this article.
Where and when to submit
Deadline and method of submission to the State Tax Service
The Report on the Use of Income (Profit) of a Non-Profit Organization and the financial statements are submitted to the State Tax Service at the organization’s main place of registration. The deadline is 60 calendar days after the end of the reporting (tax) year (subparagraph 49.18.3 of clause 49.18 of Article 49 of the Tax Code, for taxpayers whose reporting period equals the calendar year).
For 2026, the calculation is as follows: 31 days of January plus 28 days of February plus 1 day of March gives exactly 60 days, i.e. 1 March 2027. If that date falls on a weekend, then under clause 49.20 of Article 49 of the Tax Code the last day of the deadline is the operating (banking) day following the weekend.
The taxpayer chooses the method of submission, paper or electronic, independently (clause 49.3 of Article 49 of the Tax Code). Electronic submission 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 submits its tax reporting electronically, it must also submit its financial statements under clause 46.2 only electronically. In practice, this is the main option for NGOs. Through electronic submission, the financial statements reach two recipients at once.
Submission of financial statements to the statistics authorities
The second recipient of the same financial statements is the state statistics authorities. For non-entrepreneurial companies, this requirement follows from Article 14 of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” of 16.07.1999 No. 996-XIV. The procedure and deadline are set by the Procedure for Submission of Financial Statements approved by Resolution of the Cabinet of Ministers of Ukraine of 28.02.2000 No. 419, under which annual statements are submitted to the statistics authorities no later than 28 February of the following year. The rule on moving the deadline to the nearest working day if it falls on a weekend also applies to reporting to the statistics authorities.
There is no need to submit the financial statements twice. Electronic financial statements on forms with the identifier “S” go through the “single window” and reach both the State Tax Service and the State Statistics Service. Forms with the identifier “J” do not reach the statistics authorities. Therefore, after submission, you should wait for the acceptance receipt from the statistics authority, not just from the tax authority.
Sequence of electronic submission
Because the financial statements are an appendix and an integral part of the Report on the Use of Income, it is important to follow the correct sequence when submitting electronically. The financial statements should be submitted before the Report, and you should wait for confirmation that they have been accepted. Only then is the Report on the Use of Income submitted, indicating the relevant forms of financial statements.
The recommended sequence for electronic submission is therefore:
- Submit the financial statements.
- Wait for receipt No. 2 confirming their acceptance.
- Submit the Report on the Use of Income with the relevant marks regarding the submitted financial statements.
- Check receipt No. 2 confirming acceptance of the Report.
This sequence matters because, during the automatic check of the Report, the supervisory authority verifies that submitted and registered financial statements exist. If the Report is submitted first and the financial statements later, the Report may be rejected. Submitting the financial statements afterwards does not automatically lead to acceptance of the previously rejected Report. In that case, the Report must be submitted again.
What happens if you don’t submit on time
For failure to submit, or late submission of, the Report on the Use of Income (Profit) of a Non-Profit Organization as a tax report, clause 120.1 of Article 120 of the Tax Code of Ukraine provides for a fine of UAH 340 for each such violation (sanction amounts are stated as of September 2026). If such a fine has already been imposed on the organization during the year, a repeat violation results in a fine of UAH 1,020. At the same time, subparagraph 69.1 of clause 69 of subsection 10 of Section XX “Transitional Provisions” of the Tax Code provides for exemption from liability where it is impossible to meet reporting deadlines, provided the procedure for confirming such circumstances has been followed.
Failure to submit tax reporting on time is an independent ground for an unscheduled documentary audit under subparagraph 78.1.2 of Article 78 of the Tax Code.
Keep in mind that the Report itself neither confirms nor grants the organization’s non-profit status. It only reflects how the organization used its income during the year. Non-profit status depends on compliance with founding-document and statutory requirements and on inclusion in the Register of Non-Profit Institutions and Organizations. If the supervisory authority removes an organization from that register, it becomes a corporate income tax payer with separate rules for determining the tax base and the date of transition, so in a disputed situation the consequences should be analyzed with a specialist rather than under the general rule.
How to prepare in advance
The figures in the financial statements and in the Report on the Use of Income should be reconciled before submission to the supervisory authorities, not after. These five steps reduce the risk of discrepancies and a missed deadline:
- Determine whether the organization is a non-entrepreneurial company under NP(S)BO 25 and whether it is subject to mandatory IFRS, keeps records under IFRS voluntarily, or has chosen reporting forms under NP(S)BO 1. This determines which forms of financial statements to prepare.
- Reconcile the amounts of targeted and non-targeted funding in the accounting records 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 the lines and amounts must match literally.
- Prepare the balance sheet and statement of financial results in advance and submit them on the “S” forms no later than 28 February, but before the Report itself. This way the financial statements meet both the statistics deadline and the tax deadline, and a technical failure on the last day will not derail the submission.
- Submit the Report to the tax authority within 60 days, taking into account the shift to an operating day, with a mark indicating the attached financial statements.
- Keep the acceptance receipts (from the State Tax Service and from the statistics authority) as proof that deadlines were met; for paper submission, obtain a receipt stamp or the relevant postal documents.
UHY Prostir provides accounting support for non-profit organizations, from recording targeted receipts and expenses during the year to preparing the Report on the Use of Income and the financial statements. The benefits of an independent audit specifically for a non-profit organization are covered in our article on the importance of audit for trust in NGO activities. If you need an audit of a non-profit organization before submission, or you have doubts about reporting for previous periods, please contact our team.
Oksana Koliada (Auditor)
Frequently Asked Questions
Does a non-profit organization need to submit financial statements if it had no income during the year?
Yes. The obligation to submit the Report on the Use of Income and the financial statements does not depend on whether there were receipts during the reporting year. The absence of current transactions does not exempt the organization from submitting: the balance sheet still shows assets, liabilities, and capital as of year-end, not just the movement of funds during the period.
Can financial statements be submitted before the Report on the Use of Income?
Yes. The financial statements are an appendix to the Report, but this does not mean both documents must be submitted as a single package. The supervisory authority accepts the financial statements separately. The main thing is that they are submitted within the deadline, for the same reporting period, and before the Report is submitted.
How do the financial statements of a non-profit organization differ from the Report on the Use of Income?
Financial statements are accounting reports. They show the financial position at year-end and the financial result of activities for the year. The Report on the Use of Income is a tax reporting form. Based on the same accounting data, it shows the organization’s income and expenses for the year, as well as the directions in which the income received was used, in accordance with the requirements established for non-profit organizations. The latter document does not by itself confirm the organization’s non-profit status, because that is a matter of meeting the criteria and being included in the relevant register, not of having submitted the report.
By what date must a non-profit organization submit its report for 2026?
The Report must be submitted to the State Tax Service by 1 March 2027 inclusive. The basic deadline is 60 calendar days after the end of the reporting year under subparagraph 49.18.3 of clause 49.18 of Article 49 of the Tax Code. If the 60th day falls on a weekend, under clause 49.20 of the same article the last day of the deadline is the operating (banking) day following the weekend. For reporting to the statistics authorities, the basic deadline for submitting financial statements is no later than 28 February. Because in 2027 this date falls on a Sunday, the final deadline will be Monday, 1 March.
Is an audit of a non-profit organization’s financial statements required before submission?
There is no general statutory requirement for a mandatory audit based on the volume of receipts for a typical charitable foundation or public association. In practice, whether an audit is mandatory is most often determined by the terms of a specific grant agreement with a donor, by the organization’s own charter, or by the criteria of the Law on Accounting for medium-sized and large enterprises (this should be checked for each organization separately). The subject of an audit is usually the financial statements themselves, not the tax Report on the Use of Income. Consistency between the financial statements and the Report is a matter for a separate reconciliation, either internal or with an external consultant, and should be done before the reports are submitted.
