The White Business Club is a special register of legal entities and individual entrepreneurs (FOPs) that benefit from a simplified tax control regime.
As of January 1, 2026, updated criteria for membership in Ukraine’s White Business Club have come into force. These changes were introduced by Law No. 4698, which amended tax legislation and significantly affected requirements related to beneficiary transparency, salary levels, and tax performance. The new rules apply when forming the Club’s membership list based on the results of the fourth quarter of 2025. Below are the seven key changes businesses should be aware of in order to maintain their “white” taxpayer status.
1. More Lenient Reporting Requirements
Previously, any violation of reporting or documentation rules within a 12-month period resulted in automatic exclusion from the Club. Under the new rules, a taxpayer may remain a member if all penalties are paid in full. However, the total amount of fines imposed over the last three months must not exceed the minimum wage set as of January 1 of the reporting year.
Practical advice: Pay penalties promptly and closely monitor reporting deadlines.
2. Mandatory Accuracy of Beneficial Ownership Information
Accurate information about ultimate beneficial owners must now be recorded in the Unified State Register (USR). Entries marked as unreliable or missing will disqualify a taxpayer from Club membership. Transparency regarding beneficial ownership has become a strict and non-negotiable criterion.
Practical advice: Regularly verify and update beneficiary information in the USR.
3. Improved Procedure for Removal from the Club
If a beneficiary is found to hold citizenship or reside in an aggressor state, the taxpayer will no longer be removed immediately. Instead, the tax authorities will exclude the business within three working days after identifying the issue, giving the taxpayer a short window to respond.
Practical advice: Monitor any changes in beneficiaries’ citizenship or residency status.
4. Clarified Industry Classification and Salary Criteria
Industry affiliation is now determined based on the primary KVED code at the class level. For certain unique industries, the minimum average salary requirement is set at double the statutory minimum wage as of the beginning of the year.
Practical advice: Ensure your primary KVED code is correct and that salary levels meet the updated standards.
5. Stricter Rules for Corporate Income Taxpayers
Legal entities paying corporate income tax must now meet two conditions simultaneously: pay income tax at least at the average industry level and report a positive taxable profit for the most recent reporting quarter. Companies that show quarterly losses will not qualify.
Practical advice: Plan financial activities carefully to avoid quarterly losses.
6. Higher Average Salary Requirements
The average salary for the last 12 months must be no lower than:
- the industry average multiplied by a coefficient of 1.1; and
- the statutory minimum wage as of January 1.
For legal entities, this requirement applies only if they employ at least five workers.
Practical advice: Monitor both salary levels and employee headcount to remain compliant.
7. Limitations on Tax Audit Privileges
Protection from tax audits applies only after the official publication of the White Business Club membership list. If a tax authority issues an audit order before the list is published, it will not be canceled, even if the taxpayer is later included in the Club.
Practical advice: Plan interactions with tax authorities with the publication timeline in mind.
