Getting Ready for E-Audit: A Guide to SAF-T Implementation

Although the legislative framework in Ukraine is still being finalized, more and more large corporations and major taxpayers are taking steps to implement the SAF-T standard into their tax and financial reporting processes. 

At IT-Enterprise, we are receiving an increasing number of requests from users of our ERP system and providing guidance on how to use the SAF-T module, which reflects the harmonization of Ukrainian tax procedures with international transparency practices.

 

What is SAF-T and Why is it Needed?

SAF-T (Standard Audit File for Tax) is an international standard developed by the OECD that allows accounting and tax data to be transferred in a unified electronic format. Its goal is to ensure transparency, simplify audits, and improve analytics — both for businesses and governments.

SAF-T performs two main functions:

• Audit — fast access to accurate information for supervisory authorities.
• Analytics — standardized analysis of business data, risk detection, and combating the shadow economy.

 

What Reporting Elements Does SAF-T UA Include?

The SAF-T UA file contains:

• General details of the company and accounting system.
• Chart of accounts and reference data.
• Information on business transactions.
• Primary documents and their attributes.
• Data on inventories and movement of fixed assets.
• Income, expense, and tax calculation records.

According to the Tax Code of Ukraine, the SAF-T UA file must be submitted within two working days upon request from the State Tax Service (STS).

 

SAF-T UA in Ukraine: Progress and Outlook

SAF-T UA was formalized by Order No. 561 of the Ministry of Finance and draft law No. 6255, which envisioned:

• From January 1, 2025 — mandatory submission for large taxpayers.
• From January 1, 2027 — mandatory submission for all VAT payers.

However, on July 17, 2025, the Cabinet of Ministers of Ukraine withdrew the draft law following numerous proposals for improvement and feedback from business associations (European Business Association, American Chamber of Commerce, NABU). The private sector’s strong position prompted a review of the implementation approach, without dismissing the need to adopt e-audit standards in Ukraine.

Ukraine continues to align its processes with European practices across many areas. Moreover, many Ukrainian companies already operate within the EU and are familiar with SAF-T as part of their reporting.

 

SAF-T Implementation in Europe

 

Country	Status	Start / Mandatory
🇵🇹 Portugal	Implemented, mandatory	2009 / monthly
🇦🇹 Austria	Implemented, on demand	2009
🇱🇺 Luxembourg	Implemented, on demand	2011
🇫🇷 France	Implemented, on demand	2014
🇵🇱 Poland	Implemented, mandatory	2016 / replaced VAT in 2020
🇱🇹 Lithuania	Implemented, on demand	2019 / > €30,000
🇳🇴 Norway	Implemented, mandatory	2020 / replaced VAT in 2022
🇷🇴 Romania	Implemented, mandatory	2022 / monthly
🇩🇰 Denmark	Phased implementation	2024
🇧🇬 Bulgaria	Planned, phased	2026
🇨🇿 Czechia	Implemented	2024
🇺🇦 Ukraine	Suspended	Planned 2025

 

SAF-T UA Pilot Project

Our experience with ERP users aligns with STS data: in 2025, over 40 companies participated in the SAF-T UA pilot project, submitting more than 80 SAF-T UA files. Participants included large manufacturing, trade, and IT companies.

 

In September, the STS called on banks to actively adopt SAF-T reporting. To streamline communication with banks regarding SAF-T UA, a dedicated Google Chat channel (“Google Chat Bank”) was created.

The Role of IT-Enterprise in SAF-T UA Implementation

Our team continuously monitors global trends in financial reporting and transparency and responds quickly to legislative changes in Ukraine. This agility is our advantage as a Ukrainian product company that can adapt and create solutions aligned with local regulations.

Back in 2021, IT-Enterprise developed a SAF-T UA module within our ERP system, which includes:

• Data mapping — over 1,000 attributes automatically linked to the SAF-T structure.
• Flexible configuration — generation by company or business unit.
• Validation — error checks before submission.
• Integration — accounting modules automatically generate SAF-T files.

 

This enables clients to prepare SAF-T UA reports in just one click. For companies already using IT-Enterprise ERP or MASTER products, the transition is faster. Still, implementing SAF-T requires significant adjustments in accounting methodology and data transformation, which can take 6–12 months. That’s why we provide training and comprehensive consulting support.

 

What Does a Company Need to Implement SAF-T?

The scope of implementation depends on whether the company already has an ERP system. Typical costs include:

• Audit of IT systems, data, and processes.
• SAF-T integration into ERP.
• Development or purchase of software.
• Staff training.
• Internal controls implementation.

 

For example, Deloitte estimates that SAF-T adoption costs could be:

• Small companies: €5,000–€20,000
• Medium companies: €20,000–€50,000
• Large companies: €50,000–€250,000+

The main burden falls on accountants, financial analysts, IT specialists, and department managers. Additional training is required for staff working with accounting, reporting, and ERP systems.

 

What Should Executives Do?

1. Audit systems, data, and processes.
2. Integrate SAF-T into ERP.
3. Train staff.
4. Implement internal controls.
5. Engage in professional associations.
6. Work with lawmakers on regulations and transition timelines.

 

What Kind of Investment is This?

While any change may seem like a burden, companies are making an investment that can bring benefits far beyond compliance. Based on our work with businesses implementing SAF-T, large enterprises expect:

• Stronger internal controls.
• Increased investor confidence.
• Alignment with European standards.
• Strategic advantages in international markets.

 

Importantly, SAF-T adoption in Ukraine considers the position of the business community, ensuring that legislative frameworks and transition periods are balanced between state interests and those of the private sector — which remains the driving force of the economy even in wartime.

As the leader of a tech company working daily on digital transformations, I see e-audit as a gateway to new opportunities and a new level of transparency. It is not just a technical requirement but a tool for companies to become more open, efficient, and ready for international cooperation.

Companies that prepare early, join the pilot, or plan to implement SAF-T soon will gain future advantages — and we already observe tangible benefits: from stronger internal controls to higher trust among investors.