What is SAF-T UA?
This is not reporting in the usual sense. According to the State Tax Service's clarification, the SAF-T UA file does not belong to tax reporting but is an electronic document. It is not submitted quarterly along with the declaration. The tax authority requests the file when conducting a documentary audit.
In general, the file has four substantive blocks:
Block | What’s inside |
|---|---|
Header | Metadata: who, for which period, in which system the file was generated |
MasterFiles | Directories: counterparties, nomenclature, chart of accounts, units of measurement, taxes, fixed assets |
General Ledger Entries | General ledger entries |
Source Documents | Primary documents: sales, purchases, payments, inventory movement, transactions with fixed assets |
The Ukrainian scheme is more detailed than the basic OECD standard. It includes inventories, goods movement, and fixed assets. Therefore, inventory and fixed asset accounting must also be aligned with accounting.
How the State Tax Service works with files in e-audit
Previously, the tax office requested paper or scanned documents, and inspectors checked them manually. This was time-consuming, and the outcome depended on what was decided to be shown.
The e-audit by the State Tax Service was launched on January 1, 2026. Now the process looks like this:
- The taxpayer receives a request in the Electronic Cabinet.
- Forms a file separately for each period specified in the request and uploads it as an archive.
- The system checks the file for compliance with the XSD schema.
- The taxpayer receives a second receipt: the file is accepted or not accepted, with a list of errors.
The State Tax Service has already reported the first submissions of files during audits. This has three implications for businesses.
Speed.Two working days are given for submission after receiving the request.
Transparency.Data comes in a unified structure. Gaps between directories, entries, and documents become visible to anyone analyzing the file.
The cost of error.There is no separate fine specifically for SAF-T in the Tax Code. The State Tax Service applies the general rule of paragraph 121.2 of Article 121 of the Tax Code. For failure to submit or for incomplete submission, the fine amounts to one minimum wage established on January 1 of the reporting year for each instance. In 2026, this is 8,647 UAH. A file that the system did not accept is considered not submitted. Payment of the fine does not cancel the obligation to submit the file.
Who needs to prepare SAF-T UA in 2026–2027?
The file is generated upon request during a documentary audit. The circle of taxpayers depends on who you are.
Large taxpayers
The requirement is already in effect for them. A large taxpayer is a legal entity whose income over four consecutive quarters exceeds 50 million euros in equivalent. The second criterion: the amount of taxes paid during this period exceeds 1.5 million euros. As of 2026, 1,647 companies are included in the Register of Large Taxpayers.
Two important clarifications from the State Tax Service:
- The submission deadline is two working days following the day of receipt of the request (Article 85 of the Tax Code).
- The file must be submitted only for those periods when the taxpayer was in the Register of Large Taxpayers.
Other VAT taxpayers
In the clarifications from the State Tax Service (ZIR, category 130.01), it is stated that the National Revenue Strategy provides for IT solutions for processing SAF-T UA for all VAT taxpayers starting in 2027. But these are plans, not a legal norm.
Bill No. 6255, which was supposed to establish the procedure, was withdrawn by the Verkhovna Rada in July 2025. No new bill has been submitted according to open sources for the fall of 2026. Therefore, the procedure, deadlines, and responsibilities for the mass segment are not definitively established.
Individual entrepreneurs on a simplified system
There is no automatic obligation solely based on the status of an individual entrepreneur. At the same time, the Ministry of Finance proposed to introduce mandatory VAT registration for a portion of individual entrepreneurs with an income of over 4 million UAH, starting from 2027. As of October 2026, this regulation has not yet been adopted. If you are an individual entrepreneur with high turnover, keep an eye on the changes.
Why you shouldn't wait for the law
The date may shift. However, data preparation takes from two weeks to several months depending on the quality of accounting. If you wait for the final law, there will be no time left for preparation.
The problem is with the data, not with XML
The file is generated by the program. But it takes what is in the accounting. If a counterparty is entered in three different spellings, there will be three counterparties in the file. If a transaction does not have a primary document, the gap will end up in the export.
Accountants most often encounter the following problems:
- duplicates of counterparties and nomenclature;
- empty mandatory fields in directories;
- transactions without documents and documents without transactions;
- accounting in several programs that are reconciled manually;
- backdated corrections without a change history.
When accounting is scattered, preparing the file turns into a data collection project. When everything is in one database, it becomes a reconciliation project. It is much simpler.
How Odoo ERP helps prepare accounting for SAF-T UA
File block | What is needed | What Odoo ERP provides |
|---|---|---|
Header | Company details, period, source system | Company data, currency, and periods are stored in the settings |
MasterFiles | Counterparties, nomenclature, chart of accounts, fixed assets | One partner and product card for the entire company. Duplicates are visible and can be merged for export. |
General Ledger Entries | General ledger entries | Each entry is recorded in the journal with a date, account, and partner. The period lock date prevents retroactive changes. |
Source Documents | Primary documents, inventory movement | Invoices, waybills, warehouse movements, and payments in one database. The entry shows the document, and the document shows the entry. |
In addition to the data structure, three more things help.
Regulated accounting.
Odoo supports P(С)BO, VAT, and payroll calculations with taxes.For more details, see the Accounting page.
LabelAudit Trail.
LabelThe system records who, when, and what was changed. This answers the question "who edited the document," which will inevitably arise during an audit.Details can be found in the article about Audit Trail in Odoo.
Open API and open source.
LabelData can be transferred to a solution that compiles the file according to the tax service scheme. Open source allows you to adapt the export to your accounting requirements.
From practice.SAF-T UA requires consistent data. Clients who have switched to a unified system notice this effect in daily processes. The closing of the accounting month has been reduced from 10 days to 2. The number of errors in accounting has decreased by 85%. These are not cases about SAF-T UA. These are indicators that accounting can be maintained in a state where responses to tax inquiries are given in days, not weeks.
What Odoo will not do
Honestly about limitations. They affect timelines and budget.
It will not correct the data itself. Odoo will not fix a counterparty that has been manually entered in various spellings for years. But it will help consolidate existing cards and reduce the risk of new duplicates.
It does not generate XML according to the tax authority's schema "out of the box".Odoo provides clean and consistent data. The XML itself is generated by a separate tool: a module or connector. It is tailored to your accounting and tested on a copy of your database.
Не очистить історію під час міграції автоматично. Якщо ви перейшли з іншої системи, старі помилки переїжджають разом із даними. Їх треба чистити під час міграції, а не після. Про це — на сторінці міграції з 1С на Odoo.
How we prepare accounting for SAF-T UA
- Data audit.We look for duplicates, empty mandatory fields, and entries without documents.
- Cleaning directories.We consolidate counterparties and nomenclature into a single card. If you are migrating from 1C, we do this as part of the migration.
- Accounting setup.We adjust the chart of accounts and journals, check VAT codes, enable period locking and Audit Trail.
- Selecting a solution for file generation.We check on a copy of your database whether it covers your documents.
- Test export.We generate a file for one month and address all comments from the audit.
- Training.We show the accountant how to generate and verify the file in two working days.
Checklist for readiness for SAF-T UA
Check yourself against five points:
- Directories.Are there any duplicates of counterparties and goods? Are the codes required by the standard filled in?
- Connections.Does each transaction have a primary document, and does each document have a transaction?
- Unified system.Is all accounting in one database? If not, who and how consolidates the data?
- Change history.Can you show who and when edited the document?
- Speed.Will you be able to generate a file for the audit period within two working days?
If the answer to at least two questions is "no," it's time to diagnose the accounting now.
Common mistakes in preparation
- Wait for the final law.The date may change, but the quality of the data will not improve in a week.
- Buy a tool for file generation and consider the issue closed.It does not fix duplicates and gaps in accounting.
- Hand everything over to the IT department.The file is an accounting product. Without the chief accountant in the project, substantive errors cannot be found.
- Test immediately over the entire period.First one month, then scale up.
SAF-T UA is not about XML. It's about whether your accounting can pass the data structure audit. The law may change the date, but it will not change the state of directories and the connections between transactions and documents.
What should be done right now:
- check directories and connections between transactions and documents;
- consolidate accounting into one system;
- enable change control;
- make a trial export for one month.