Diia.City is a special legal and tax regime for technology companies operating in Ukraine. It does not require a company to change its legal form: an existing Ukrainian LLC, JSC or other eligible entity can obtain Diia.City resident status and operate under its specific tax and employment rules.
The regime was introduced under the Law of Ukraine “On Stimulating the Development of the Digital Economy in Ukraine”. It covers various technology-related activities, including software development, SaaS, cybersecurity, IT R&D, robotics, gaming, hosting and other qualifying digital services.
An established resident must generally meet three key requirements:
* at least 90% of income must come from qualifying activities;
* the average number of employees and/or gig specialists must be at least nine;
* their average monthly remuneration must be at least the equivalent of EUR 1,200.
Startups have separate rules and may receive temporary exemptions from some of these requirements.
No. The existing Ukrainian legal entity remains in place. Diia.City is a special status granted to an eligible company.
The application is submitted electronically. There are no separate licences required for Diia.City status, and the application is generally reviewed within 10 working days.
Taxation
One of the main advantages of the regime is the treatment of employee and gig-specialist remuneration.
For employees and gig specialists of Diia.City residents, the main rates are:
* 5% personal income tax;
* 5% military levy;
* Unified Social Contribution of 22% of the minimum wage rather than 22% of the employee’s actual salary.
This can significantly reduce the payroll tax burden for companies with highly paid IT specialists.
A Diia.City resident can choose between two corporate taxation models:
* 18% corporate income tax; or
* 9% tax on distributed capital under the alternative model.
The appropriate option depends on how the company generates, retains and distributes its profits.
GIG contracts
A GIG contract is a special contractual arrangement available to Diia.City residents for engaging IT specialists. It is separate from both a traditional employment agreement and an ordinary civil-law services contract.
Companies can continue using conventional employment contracts and, where appropriate, cooperate with individual entrepreneurs (FOPs). The GIG contract provides an additional legally defined option for structuring relationships with specialists.
The tax advantages are conditional on continued compliance with the regime. Residents must maintain the relevant requirements concerning qualifying activities, income, personnel, remuneration and tax compliance.
Residents are also subject to annual reporting confirming compliance with the residency requirements, including an independent auditor’s report where required by law. The Diia.City register records resident companies and decisions concerning their status.
Yes. The framework contains specific rules concerning intellectual property created by employees and gig specialists, as well as contractual mechanisms relevant to investment and financing. Proper documentation of IP rights is therefore an important part of operating under the regime.
Not necessarily. Before applying, a company should assess whether its activities qualify, whether at least 90% of its revenue can remain within the permitted activities, and whether it can maintain the personnel and remuneration requirements.
For a genuine technology business with predominantly qualifying revenue, a sufficiently large professional workforce and competitive salaries, Diia.City can provide substantial tax and operational advantages.
As of 2026, Diia.City is an established framework rather than an experimental regime. For Ukrainian technology companies that meet the requirements, it has become an important option for structuring both taxation and relationships with employees and contractors.
Considering Diia.City residency for your company?
Qualifying for Diia.City involves more than reaching the 90% income threshold, it also means meeting personnel and remuneration requirements and staying compliant on an ongoing basis. Leinonen Ukraine can assess your company’s eligibility, advise on the tax and payroll implications of GIG contracts versus standard employment, and support your annual compliance reporting. Contact our Ukraine team to discuss your specific situation.



