The regulator has recently updated the rules governing the disclosure of financial statements in XBRL format for capital market participants and professional participants of organized commodity markets. Some of the changes clarify procedural aspects, while others affect the scope of information that must be disclosed in financial reports. Therefore, reporting entities should take these updates into account when preparing their financial statements for 2026. Below, we outline the key changes that deserve particular attention.
On 1 May 2026, Decision No. 36/21/4172/К03 of the National Securities and Stock Market Commission (NSSMC), dated 16 April 2026 (registered with the Ministry of Justice on 29 April 2026, under No. 585/45979), came into force. The document introduces amendments to the Requirements for the Disclosure of Financial Statement Indicators in XBRL Format, approved by the Commission’s decision dated 6 June 2025, No. 36/21/2383/К03. The updates apply to capital market participants and professional participants of organized commodity markets that file their reports with the Financial Reporting Collection Centre (FRCC).
Reporting for non-standard periods — a clearly defined procedure
The Requirements formally establish a mechanism for submitting financial statements for periods other than annual or interim ones (e.g., liquidation reports or statements prepared for obtaining administrative services).A reporting entity must submit a reasoned application to the FRCC via email at xbrl.registration@nssmc.gov.ua, using the form provided in Appendix 2 to the Requirements. The application should include the date as of which the financial statements are prepared, the deadline by which they must be submitted, the grounds for submission, contact details of the responsible person, information on whether an audit has been conducted. The NSSMC reviews the application within three business days and creates a corresponding reporting request. After that, the reporting file is submitted through the personal account in accordance with the standard procedure.
Submission deadlines
The provision on submission deadlines has been revised: annual (including consolidated) financial statements must be submitted no later than April 30 of the following year; interim financial statements — no later than the last day of the month following the reporting period; interim consolidated financial statements — no later than the last day of the second month following the reporting period.Deadlines for submitting financial statements for non-standard periods are determined in accordance with applicable legal requirements.
Expanded disclosure requirements
The updated Appendix 1 to the Requirements establishes a list of additional indicators that must be disclosed in the specified fields of the taxonomy.All reporting entities are required to disclose, among other things:
- management’s professional judgments regarding materiality; analysis of income and expenses; subclassifications of assets, liabilities, and equity;
- the amount of cash and cash equivalents broken down by account types (current, deposit accounts, as well as accounts held with banks under temporary administration or in liquidation);
- total liabilities;
- unpaid share capital;
- dividends accrued or paid to related parties, or received from them;
- results of independent valuations.
In addition, if the carrying amount of financial investments or accounts receivable exceeds 10% of total assets, a detailed breakdown must be disclosed regarding:
- the five largest issuers (by the amount of financial investments); and
- the five largest counterparties (by the amount of accounts receivable).
Threshold values are calculated based on the data from the statement of financial position as of the end of the relevant reporting period, unless otherwise provided by law.
Professional participants are further required to disclose the material terms of agreements related to granted and received loans, repayable and non-repayable financial assistance, as well as certain categories of income and expenses (including training, consulting, advertising and marketing, assignment of claims or debts), if the total volume of transactions in the relevant category during the reporting period exceeds 25% of total assets. They must also disclose information on financial assets that are subject to seizure, blocking, or any encumbrance imposed by a court decision or within enforcement proceedings. Investment firms are required to separately disclose funds and liabilities under client agreements.
Important: The updated submission deadlines and the requirements set out in Appendix 1 apply starting from the nine-month reporting period of 2026 and the annual financial statements for 2026. Therefore, reporting entities still have time to prepare.
Other changes
All indicators must be disclosed exclusively in the fields designated for them within the reporting file. Text blocks for additional information may only be used for data for which no separate fields are provided.The reporting file must include an auditor’s report (for annual financial statements) or a review report (for interim financial statements, where required by law). In addition, issuers of securities (except for collective investment institution securities) must also include a management report. Micro and small enterprises that are not issuers are not required to submit a management report, except where such a report is requested by the Commission if it has not been previously disclosed.
The procedure for resubmission has also been clarified: once the relevant request is approved, previously submitted financial statements are deemed not to have been submitted until the entity uploads a revised file — therefore, entities are advised not to delay the submission.
The procedure for using the personal account has been revised: the “one email address — one user” rule now applies, and authentication is carried out via id.gov.ua using a qualified electronic signature (QES). The deactivation of user accounts has also been specifically regulated — either upon request of the reporting entity or in the event of the termination of a legal entity. In the first case, deactivation is only possible if all of the following three conditions are met simultaneously: the entity has transitioned to national accounting standards; the entity is not subject to the requirements of Article 12-1 of the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” and the Procedure for Submitting Financial Statements approved by Resolution of the Cabinet of Ministers of Ukraine No. 419 dated 28 February 2000; and the entity has submitted financial statements for all periods during which it was required to do so.
Reporting entities are encouraged to review their internal XBRL reporting processes in advance and assess which of the new indicators will need to be disclosed in their 2026 financial statements.
The BDO in Ukraine team supports companies in assessing the impact of the new XBRL reporting requirements, adapting internal processes, and preparing for the disclosure of additional indicators in financial statements. If this topic is relevant for your business, we would be pleased to support you in identifying practical steps and guiding your reporting preparation. Feel free to contact us.
