White Business Club in Ukraine: Criteria, Benefits, and Rules for Sole Proprietors and Companies

The term «White Business Club» refers to the List of Taxpayers with a High Level of Voluntary Compliance with Tax Legislation. The State Tax Service of Ukraine (STS) compiles this list automatically using data from tax returns, state registers, and its own information systems. There is no need to submit a separate application to join. To be included, a business must simultaneously meet the general requirements of the Tax Code and the specific criteria established for its taxation system. For Sole Proprietorships, this mechanism is available to entrepreneurs under the general taxation system and Group III single-tax payers.

Inclusion in the List does not exempt businesses from taxes, reporting, ECR/PECR requirements, inventory accounting, licensing, or other obligations. The main benefits concern tax administration: taxpayers are assigned a compliance manager, the initiation of certain types of tax audits is restricted, VAT budget refund audits are subject to shorter deadlines, and individual tax consultations are provided within a special timeframe. Inclusion in the List does not provide a complete moratorium on tax audits.

What Is the «White Business Club» Under the Law?

The legal framework was introduced by Law of Ukraine No. 3813-IX, which added Subparagraph 69.41 to Paragraph 69 of Subsection 10, Section XX of the Tax Code. Its official name is the List of Taxpayers with a High Level of Voluntary Compliance with Tax Legislation.

The special regime applies throughout martial law and until December 31 of the year in which martial law is terminated or canceled. In 2026, the rules for inclusion in the List apply subject to the amendments introduced by Law No. 4698-IX and changes to the procedure approved by Ministry of Finance Order No. 495.

The following taxpayers may qualify for inclusion in the List:

• legal entities under the general taxation system;

• Diia City residents;

• legal entities paying Group III single tax;

• legal entities paying Group IV single tax;

• Sole Proprietorships under the general taxation system;

• Sole Proprietorships paying Group III single tax.

For Sole Proprietorships in Groups I, II, and IV, Subparagraphs 69.41.2.1–69.41.2.6 of the Tax Code do not establish separate eligibility criteria.

At the same time, producers and sellers of excisable goods, gambling operators, and providers of financial or payment services are not automatically excluded from eligibility for the List. However, broader possibilities for conducting documentary tax audits remain applicable to them.

General Requirements for Inclusion in the List

A legal entity or Sole Proprietorship must meet all general requirements simultaneously.

1. Tax Debt Must Be Limited in Amount and Duration

Tax debt and other arrears collected under the supervision of the STS must not exceed 3,000 non-taxable minimum incomes of citizens, and no more than 30 days must have passed since the debt arose.

For this calculation, one non-taxable minimum equals UAH 17, so 3,000 non-taxable minimums amount to UAH 51,000.

This means that even a small debt outstanding for more than 30 days prevents compliance with this requirement.

2. There Must Be No Outstanding Unified Social Contribution Debt

Arrears, unpaid fines, or penalties related to the unified social contribution are not permitted.

3. Only a Limited Amount of Reporting-Related Fines Is Permitted

Over the last three consecutive calendar months, the total fines imposed for violations of obligations to submit tax returns, documents, or notifications must not exceed one minimum monthly wage established on January 1 of the relevant year. These fines must have been paid, except for amounts under appeal.

In 2026, the minimum monthly wage as of January 1 is UAH 8,647, which is the maximum amount permitted under this criterion.

Therefore, the mere existence of a small reporting-related fine that has already been paid does not automatically disqualify a business from inclusion in the List.

4. There Must Be No Violations of Foreign Exchange Settlement Deadlines for Exports and Imports

During the previous 12 months, the taxpayer must not have received tax notices-decisions concerning violations of statutory settlement deadlines for export or import transactions.

5. The Taxpayer Must Not Be Classified as a Risky VAT Payer

The STS must not have an active decision classifying the taxpayer as meeting the criteria for a risky VAT payer under Paragraph 201.16 of the Tax Code.

6. The Business Must Not Be Undergoing Termination

A legal entity must not be subject to an initiated termination procedure, and a Sole Proprietorship must not have initiated the termination of its business activities.

7. There Must Be No Bankruptcy or Insolvency Proceedings

Initiated bankruptcy or insolvency proceedings prevent inclusion in the List.

8. Sanctions Must Not Apply

There must be no decision imposing sanctions under the Law of Ukraine «On Sanctions» against the taxpayer, its founders, shareholders, participants, or ultimate beneficial owners.

9. Restrictions Apply to Connections with an Aggressor State

The taxpayer, its founders, participants, and ultimate beneficial owners must not hold citizenship of a state conducting armed aggression against Ukraine. An exception applies to citizens of such a state who obtained combatant status after April 14, 2014.

Founders, participants, and ultimate beneficial owners must also not include persons whose place of residence or registered location is in the aggressor state.

10. The Primary Economic Activity Code Must Remain Unchanged for 12 Months

The Unified State Register must show no changes to the primary type of economic activity specifically during the last 12 consecutive calendar months. The law does not impose the same restriction on every change to additional economic activity codes (KVED).

For calculating industry averages, the industry is determined by the primary KVED code at the class level under DK 009:2010.

11. Legal Entities Must Have Proper Beneficial Ownership Information

For a legal entity, the Unified State Register must contain information about the ultimate beneficial owner and must not contain a notation indicating that information about the beneficial owner or ownership structure may be unreliable.

A justified explanation for the absence of an ultimate beneficial owner in the ownership structure is permitted.

Eligibility Criteria Depend on the Taxation System

In addition to the general requirements, a business must meet the indicators established for its particular category. The STS calculates these indicators using tax returns whose submission deadlines have already passed by the date the List is compiled. The STS publishes average industry indicators separately.

An additional restriction applies to newly registered legal entities and Sole Proprietorships: they may be included in the List no earlier than one calendar year after registration with the STS.

How to Get Included in the List

The STS independently determines whether a taxpayer meets the requirements and criteria. The Tax Code does not require a special document package or an application for «membership».

The List is compiled and approved no later than the last working day of March, May, August, and November. It is published on the STS web portal on the 15th working day after approval. The STS publishes the average values of the eligibility indicators within five working days after approval.

The private section of the Electronic Cabinet contains a menu called «Voluntary Tax Compliance Criteria», which separately displays:

• compliance with the general requirements;

• compliance with the criteria for the applicable taxation system;

• indicators showing why the taxpayer does not reach the required average level.

The STS notifies taxpayers of inclusion or exclusion through the Electronic Cabinet.

Is Publication of Information About a Company or Sole Proprietorship Mandatory?

The public section of the List includes the legal entity's name or the Sole Proprietorship owner's full name and tax identification number, or, in cases prescribed by law, passport details.

A taxpayer has the right to opt out specifically of the public disclosure of their information without losing their status as a participant in the List. The following electronic notifications are used for this purpose:

• J1325402 — for legal entities;

• F1325402 — for individuals.

If an opt-out request is submitted after the List has been published, the STS must remove the taxpayer's information from the public version within five working days. The taxpayer remains included in the List.

What Benefits Does a Business Receive?

A Dedicated Compliance Manager

A taxpayer is assigned an official from the territorial STS office — a compliance manager. This person is not an employee of the business but a representative of the tax authority responsible for communicating with the taxpayer.

Communication is available verbally or remotely, including through video conferencing. The compliance manager provides guidance on meeting tax obligations and may notify taxpayers about upcoming deadlines for submitting returns, registering tax invoices, paying taxes, and the emergence of tax debt.

At the taxpayer's request, the compliance manager may provide information available to the STS indicating tax risks and advise on how to address them. A five-day response period applies to such requests.

Individual Tax Consultations Within 15 Days

Individual tax consultations for taxpayers included in the List are provided by the central STS office within 15 calendar days following receipt of the request. This deadline cannot be extended.

Shorter Audit Periods for VAT Budget Refunds

Participants in the List benefit from shorter audit periods for claimed VAT budget refunds:

• desk audit — 5 working days;

• documentary audit — 10 working days.

The STS has confirmed the practical application of this rule. For example, in the Lviv region, VAT refund claims submitted by taxpayers on the List were reviewed within five days, or within ten days when a documentary audit was required.

Which Audits Are Not Initiated for Participants in the List?

The restrictions take effect on the day following publication of the List. They do not apply to audits for which an order had already been sent or delivered to the taxpayer before publication of the new List.

The STS does not initiate:

1. On-site inspections concerning licensing of fuel storage where fuel is stored exclusively for own consumption and/or industrial processing.

2. Unscheduled documentary audits, except in cases specifically provided for by law.

3. Scheduled documentary audits, except audits of businesses that:

   •    produce or sell excisable goods;

   •    organize and conduct gambling activities;

   •    provide financial or payment services.

Which Unscheduled Audits Remain Possible?

Having the status of a taxpayer with a high level of voluntary compliance does not prevent unscheduled documentary audits:

• at the taxpayer's own request;

• on the grounds provided by Subparagraph 78.1.1 of the Tax Code concerning taxation of Ukrainian-source income of nonresidents and transfer pricing control;

• under Subparagraph 78.1.2 concerning transfer pricing;

• under Subparagraphs 78.1.3, 78.1.5, 78.1.7, 78.1.8, 78.1.9, 78.1.12, 78.1.14, 78.1.15, 78.1.16, 78.1.19, 78.1.21, and 78.1.22 of the Tax Code;

• when tax information indicates violations of foreign exchange legislation concerning deadlines for receiving imported goods or export proceeds in foreign currency;

• concerning taxpayers who produce or sell excisable goods, operate in the gambling industry, or provide financial or payment services.

Therefore, inclusion in the List should not be interpreted as a complete moratorium on tax audits.

Does the List Protect Businesses from On-Site ECR/PECR Inspections?

No. Among on-site inspections, Subparagraph 69.41.3 of the Tax Code expressly prohibits the initiation of only one narrowly defined category — inspections concerning the licensing of fuel storage exclusively for own needs or industrial processing.

Therefore, for retail businesses, inclusion in the List does not eliminate the possibility of on-site inspections for compliance with ECR/PECR legislation where there are lawful grounds for such inspections.

Likewise, inclusion in the List does not exempt an entrepreneur from:

• using an ECR or PECR where required by law;

• generating and issuing a valid payment receipt;

• complying with inventory accounting requirements where they apply to a particular Sole Proprietorship;

• retaining primary accounting documents;

• filing tax returns and paying taxes on time;

• obtaining licenses and complying with their conditions when the business activity requires licensing. The ECR Law remains in force and applies regardless of whether the taxpayer is included in the «White» List.

For Sole Proprietorships required to maintain inventory records under the ECR Law, Ministry of Finance Procedure No. 496 applies. Goods received and dispatched must be recorded in the inventory accounting form based on primary documents. If a Sole Proprietorship operates several sales locations, records must be maintained separately for each location.

Does the «White Business Club» Automatically Entitle Businesses to Reserve 25% of Their Employees from Military Mobilization?

Inclusion in the List alone does not automatically grant the right to reserve 25% of employees liable for military service from mobilization.

In the final provisions of Law No. 3813-IX, the Verkhovna Rada merely recommended that the Cabinet of Ministers amend the employee reservation procedure to allow such taxpayers to reserve up to 25% of their employees automatically. This is a recommendation to the government, not a right directly granted to participants in the List under the Tax Code.

Therefore, inclusion in the List should not be used as an independent legal basis for reserving employees from mobilization.

When Does a Business Lose Its Status?

The List is regularly compiled anew. Compliance with the general requirements and specific criteria is reviewed as of each new compilation date. If the required indicators are no longer met, the taxpayer does not qualify for inclusion in the new List.

Accelerated removal is provided for three types of violations. If the STS identifies noncompliance with requirements concerning:

• sanctions against the taxpayer, founders, participants, or beneficial owners;

• citizenship of an aggressor state;

• the residence or registered location of founders, participants, or beneficial owners in an aggressor state,

the taxpayer is removed from the List within three working days of discovering the violation. A notification is sent to the Electronic Cabinet.

Failure to be included in the List or removal from it is not, in itself, a separate tax offense, and Subparagraph 69.41 of the Tax Code does not establish a special fine or automatic license cancellation for this. However, the violation that caused a business to lose eligibility may have its own tax, licensing, or other legal consequences.

What Should Entrepreneurs Monitor?

To remain eligible for inclusion in the List, businesses should regularly check not only whether taxes have been paid but also all the indicators the STS uses for its automatic assessment:

• tax debt and the date it arose;

• the status of unified social contribution payments;

• fines related to reporting and document submission;

• risky VAT payer status;

• the primary KVED economic activity code;

• ultimate beneficial ownership information in the Unified State Register;

• average salaries and employee numbers, where the relevant criterion applies;

• VAT, corporate income tax, personal income tax, or consolidated budget tax payment rates — depending on the taxation system;

• for Group III Sole Proprietorships — declared income;

• notifications and indicators in the private section of the Electronic Cabinet.

Importantly, the STS uses data from tax returns whose submission deadlines have already passed by the date the List is compiled. Therefore, errors in tax returns, delayed corrections, or discrepancies in state register information may directly affect the results of the automatic assessment.

How the List Is Compiled in Practice

For example, the List compiled for May 2026 included 9,251 business entities: 8,673 legal entities and 578 Sole Proprietorships. Among the Sole Proprietorships, 71 entrepreneurs operated under the general taxation system, while 507 were Group III single-tax payers. A total of 7,603 taxpayers, or 82% of this List, had also been included in the previous version.

This example also demonstrates that the status is not granted indefinitely: the composition of the List is reviewed regularly based on taxpayers' current indicators.

How Torgsoft Helps Monitor PECR Operations, Inventory Accounting, and Document Changes

The software itself does not determine an entrepreneur's eligibility for inclusion in the List — the STS makes that determination based on the criteria established by the Tax Code. However, Torgsoft provides retail businesses with tools that support systematic operational accounting and help reduce the risk of documentation errors. Torgsoft supports software ECR operations: since version 2022.0.16, business units, PECRs, and cashiers can be registered directly through the software. It also provides settings for fiscal goods, receipt printing, linking PECRs to companies, and transaction analytics.

For Sole Proprietorships subject to Ministry of Finance Procedure No. 496, Torgsoft offers an additional feature, «Inventory Accounting». It is designed to record goods received and dispatched based on primary documents, including incoming invoices, sales, and write-offs. This makes it possible to link goods movements to the documents underlying inventory accounting.

For internal control, the software provides the «User Activity Log», change logs in editing forms, and the «Document Change Log». The Document Change Log can record changes to inventory and financial documents, including goods receipts, sales, and returns. These tools allow business owners to track who performed specific operations in the system and identify the causes of data discrepancies more quickly.

Key Takeaways for Entrepreneurs

The List of Taxpayers with a High Level of Voluntary Compliance is not a separate taxation system or an exemption from tax control. Its main value lies in a special framework for interacting with the STS, available to businesses that consistently meet tax obligations and maintain tax payment and salary indicators at or above the established thresholds.

Retail entrepreneurs should remember that this status does not replace ECR/PECR requirements, primary documents, or inventory accounting, and does not protect them from all on-site inspections. The safest approach is to ensure that actual goods movements and financial transactions match accounting records, fiscal receipts, tax returns, and state registers.

Official Sources

1. Tax Code of Ukraine dated December 2, 2010, No. 2755-VI — Subparagraph 69.41 of Paragraph 69, Subsection 10, Section XX; Articles 52, 78, 201, and other provisions referenced in Subparagraph 69.41. Tax Code of Ukraine on the Verkhovna Rada website

2. Law of Ukraine dated June 18, 2024, No. 3813-IX «On Amendments to the Tax Code of Ukraine Regarding Special Tax Administration Rules During Martial Law for Taxpayers with a High Level of Voluntary Compliance with Tax Legislation» — introduced Subparagraph 69.41 of the Tax Code; Paragraph 5 of the Final Provisions contains a recommendation to the Cabinet of Ministers concerning employee reservations from mobilization. Law No. 3813-IX on the Verkhovna Rada website

3. Law of Ukraine dated December 3, 2025, No. 4698-IX — amendments to the requirements and criteria for the List applicable in 2026. Law No. 4698-IX on the Verkhovna Rada website

4. Order of the Ministry of Finance of Ukraine dated October 7, 2024, No. 495 «On Approval of the Procedure for Compiling and Publishing the List of Taxpayers with a High Level of Voluntary Compliance with Tax Legislation» — governs the calculation, compilation, notification, and publication of the List; the current version incorporates the 2026 amendments. Ministry of Finance Order No. 495 on the Verkhovna Rada website

5. Law of Ukraine «On the State Budget of Ukraine for 2026» No. 4695-IX, Article 8 — minimum monthly wage from January 1, 2026: UAH 8,647. Law on the State Budget of Ukraine for 2026

6. Law of Ukraine dated July 6, 1995, No. 265/95-VR «On the Use of Registrars of Settlement Operations in Trade, Catering, and Services» — rules for using ECRs/PECRs and recording settlement transactions. ECR Law on the Verkhovna Rada website

7. Order of the Ministry of Finance of Ukraine dated September 3, 2021, No. 496 «On Approval of the Procedure for Maintaining Inventory Records by Individual Entrepreneurs, Including Single-Tax Payers» — inventory accounting rules for Sole Proprietorships subject to the relevant requirement. Ministry of Finance Order No. 496 on the Verkhovna Rada website

8. STS Public Information and Reference Resource «Tax Trust Territory» — official explanations concerning eligibility criteria, audits, compliance managers, and compilation of the List. STS Tax Trust Territory