On 19 September 2025, the National Securities and Stock Market Commission (further — the Commission) adopted Resolution No. 09/21/2902/K03 “On the Approval of Amendments to Certain Regulatory Acts of the National Securities and Stock Market Commission Regarding the Procedure for Submitting Financial Statements” (further — the Resolution).
The changes will take effect on 01 November 2025.
Under the latest amendments, the requirement to submit financial statements in XML format has been abolished, and a single mandatory format has been established: financial statements prepared in accordance with international standards must now be submitted exclusively in XBRL format via the Financial Reporting Collection Center (FRCC).
Thus, the Commission has aligned its regulatory acts with the requirements of current legislation, specifically the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” and Resolutions of the Cabinet of Ministers of Ukraine No. 419 dated 28.02.2000, and No. 845 dated 11.08.2023.
The changes apply to both professional participants in the capital and organized commodity markets, as well as to securities issuers who disclose regulated information in accordance with Regulation No. 608 on the disclosure of information by securities issuers, and to persons providing guarantees for such securities, as approved by the Commission’s resolution of 06 June 2023 (hereinafter — Regulation No. 608).
In particular, paragraph 25 of Chapter 1, Section II of Regulation No. 608 clarifies that issuers who prepare their financial statements (annual or interim) in accordance with International Financial Reporting Standards must prepare their financial statements and management report (management commentary) / consolidated financial statements and consolidated management report (consolidated management commentary, if consolidated financial statements are prepared) based on the International Financial Reporting Standards taxonomy in the unified electronic format (XBRL format).
This paragraph has also been amended to include requirements regarding the content of the electronic file containing financial statements in XBRL format, which must include:
- the auditor’s report submitted by the issuer together with the annual financial statements / annual consolidated financial statements (if consolidated financial statements are prepared);
- the review report on the interim financial statements / interim consolidated financial statements (if consolidated financial statements are prepared), in cases provided for by law and the Commission’s regulations.
Annexes 7 and 10 to Regulation No. 608 have been amended with a requirement to indicate the URL of the Financial Reporting Collection Center where the issuer’s financial statements are published, in cases where annual financial statements are prepared in XBRL format and submitted to the FRCC.
It is also appropriate to note that, for its reporting entities (securities issuers, professional participants in the capital markets, and professional participants in organized commodity markets), the Commission has set a deadline of 31 October 2025, for submitting annual and interim financial statements in XBRL format via the Financial Reporting Collection Center (FRCC) for the entire period during which such statements were not submitted.
Other reporting entities that did not submit financial statements during martial law must do so by 05 October 2025, in accordance with the requirements of the Law of Ukraine “On Protection of the Interests of Reporting Entities and Other Documents During Martial Law or State of War”.
Thus, the amendments adopted by the Commission ensure the unification of the procedure for submitting financial statements in accordance with current legislation, abolishing the use of the XML format and establishing XBRL as the sole mandatory format via the Financial Reporting Collection Center. This enhances the transparency and standardization of reporting by professional participants in the capital markets and securities issuers, and also clarifies the requirements for the content of electronic files and information disclosure by issuers.
The team of BDO in Ukraine has deep expertise in IFRS and XBRL and is ready to provide comprehensive support to companies required to submit financial statements in the new format. We assist at every stage: from preparing iXBRL files to advising on taxonomy and regulatory requirements.
Contact us today to ensure full compliance with the Commission’s requirements — without risks and with confidence.
