Author: Viktoriia Staryk, lawyer at F&P
On March 31, 2026, the annual declaration campaign ends. By this date, every declarant – from a village council member to a deputy minister – must submit an annual declaration for 2025 through the Unified State Register of Declarations. There are less than three weeks left.
At first glance, the procedure is routine: open your account, fill in the sections, click “submit.” But it is this apparent simplicity that creates problems. Every year, the NACP finds thousands of declarations with errors, and some of them are subject to full audits that end in administrative or criminal proceedings. In 2024, the NACP resumed full audits in full, and this trend is growing.
This article is not a retelling of instructions from the NACP website. We will analyze specific mistakes in practice that actually lead to declarants being audited and explain where the line between inaccuracy and unreliability lies.
Mistake #1: “Not mine, but my mother-in-law’s” – ignoring the property of family members
One of the most common and dangerous mistakes. The declarant fails to indicate real estate, vehicles or bank accounts registered in the name of his/her spouse or persons with whom he/she lives together. In this case, a “family member” within the meaning of the Law “On Prevention of Corruption” is not only a registered spouse, but also a person who lives together, is bound by common life and has mutual rights and obligations (part 1 of Article 1 of the Law). A civil partner with whom you live together and run a common household is a family member for declaration purposes.
Practical advice: before filling out the declaration, make a list of all property, accounts, securities, and corporate rights of each family member. Ask them to provide bank statements. It is better to spend an hour on this than to explain yourself to the NACP later.
Mistake #2: Rounding and “approximate” amounts
The NACP distinguishes between “inaccurate” and “unreliable” information, and the line between them is 100 subsistence minimums for able-bodied persons. In 2026, this is UAH 332,800 (one subsistence minimum is UAH 3,328). If the discrepancy between the declared and the actual amount does not exceed this amount, it is an inaccuracy that can result in disciplinary liability at most. If it does, it is already inaccurate information, and a completely different story begins.
The problem is that “rounding” tends to add up. One bank account with a balance of UAH 50,000 was omitted, the cost of a car was rounded up by UAH 100,000, and income from renting an apartment was forgotten by UAH 80,000 – and the total discrepancy already exceeds the threshold of UAH 332,800. And if the amount reaches 500 subsistence minimums (UAH 1,664,000), this is already criminal liability under Article 366-2 of the Criminal Code.
Misconception #3: Cryptocurrencies and digital assets
This is an increasingly relevant topic every year. If the declarant or a member of his or her family owns cryptocurrency, it must be indicated in the Securities section (subsection “Other corporate rights”). The problem is that many people believe: “crypto is not regulated, so there is no need to declare it”. This is not the case. The NACP clearly states in its explanations that virtual assets are subject to declaration.
An additional difficulty is determining the value. The NACP recommends using the market rate as of December 31 of the reporting year. But which rate, from which exchange? There is no clear answer here, and this is a risk area: The NACP may estimate the value differently than you do.
Mistake #4: Income that has been “forgotten”
The “Income” section should include ALL income, including those that have already been taxed. A common mistake: the declarant does not indicate the salary, believing that “it is already in the tax office”. Or they do not indicate income from the sale of movable property, gifts, inheritance, interest on deposits.
Separately, there are cashback, bonuses, cashback from banks, and payments from insurance companies. These are also income, and they need to be reported. Yes, this applies even to the National Cashback if the amount exceeds the threshold for notification.
Mistake #5: Failure to submit a notice of significant changes
This is a separate obligation that is most often forgotten. If during the year you or a member of your family received income or acquired property in an amount equivalent to or greater than 50 subsistence minimums (UAH 166,400 in 2026), you must report significant changes in your property status within 10 days.
We bought a car for UAH 200,000 in August – the notification had to be submitted by the end of August. Failure to do so is a separate violation, regardless of whether you fill out the annual declaration correctly.
Error #6: Ignoring the “Data for the declaration” function
The NACP provides a tool that many people ignore – the Data for Declaration certificate. It is generated in the personal account and contains information that
The NACP already has information from the registers: real estate, vehicles, corporate rights, bank accounts. In fact, this is a cheat sheet from the NACP itself: they show what they already know about you.
If your declaration differs from this data, it is an automatic reason for attention during the audit. Therefore, I advise you to generate the certificate BEFORE filling out the declaration and compare it with what you plan to declare. Please note: the certificate can be generated only once per reporting period.
What to do if you have already filed a declaration with an error
The law provides for the possibility to submit a corrected declaration within 30 days after submission. This is important: if you notice a mistake, do not wait for an audit, correct it yourself. Timely correction significantly reduces risks. When conducting a full audit, the NACP takes into account the explanations submitted before the audit.
If the 30-day period has expired, you can send a letter to the NACP via your personal email account, explaining the reasons for the error and attaching supporting documents. This is not a guarantee, but it is much better than waiting for the NACP to identify the discrepancy on its own.
Scale of responsibility: from a warning to prison
A practical checklist before submission
- Make a complete list of property, accounts, and income of all family members
- Generate the “Data for the declaration” certificate and compare it with your data
- Check whether all notifications of material changes were submitted during the year
- Specify crypto assets, if any
- Don’t round up: provide exact amounts from bank statements
- Use auto-complete in the draft – it reduces technical errors
- After submission, read the declaration again. You have 30 days to make corrections
If you have a complicated situation – many objects, foreign assets, questions about identifying family members, or you have already received a notice of a full audit – contact a lawyer before filing, not after. It is much cheaper to correct a mistake than to defend against its consequences.
Need help with declaration or protection during NACP inspection? Don’t hesitate to contact us.
Phone: +38 093 722 56 33
Email: fo@fedoryshyn.com
