In accordance with the decision of the National Security and Defense Council of Ukraine dated July 21, 2025, put into effect by Decree of the President of Ukraine No. 538/2025, the Government has been instructed to take measures to increase the efficiency of the implementation of tax and customs control mechanisms. In particular, it is envisaged to establish restrictions on inspections of business entities that have AEO status, as well as enterprises with a low degree of risk, with the exception of those that carry out activities related to the circulation of excisable goods.
In this context, the pre-inspection analysis tool, which is a component of post-customs control, acquires particular importance. Such analysis is carried out after the completion of customs clearance of goods based on customs declaration data and other information characterizing the activities of the enterprise. This includes, in particular, the history of tax obligations, available analytical information, and the results of the risk management system. It is the pre-verification analysis that allows you to identify potential violations without the need for an inspection.
The pre-verification analysis mechanism has already been implemented in the work of customs authorities. Based on its results, enterprises receive notifications from customs offices stating the facts of possible violations of customs or tax legislation. This allows foreign economic activity entities to independently eliminate the identified inconsistencies even before the start of a documentary inspection. During the first half of 2025, enterprises voluntarily paid UAH 40.1 million in customs payments precisely as a result of such preventive work.
In the context of implementing the NSDC decision, the main emphasis during post-customs control is on conducting a pre-verification analysis, timely informing enterprises about detected violations, and conducting explanatory work regarding the possibility of independently eliminating the detected violations without applying penalties and conducting documentary inspections.
The risk assessment conducted by customs takes into account a wide range of indicators. In particular, the volume of imports or exports of goods, their commodity nomenclature, the number of errors made in customs declarations or violations of customs legislation and the timeliness of their correction, the availability of information from the customs authorities of the contracting countries about the forgery of documents submitted to the customs authority or about the unreliability of information entered into the customs declaration during customs clearance of goods imported into Ukraine.
An important factor is also the practice of interaction with customs authorities when acquiring AEO status or other simplifications, the timeliness of submission of reporting specified by customs legislation, provision of complete and reliable information to customs authorities during customs clearance of goods, as well as the results of customs formalities during customs clearance of goods. The presence or absence of facts of violations of customs legislation in the past is separately taken into account, in particular the presence of protocols on violations of customs rules, decisions on adjustment of customs value, classification decisions, etc.
Thus, the decision to conduct a documentary audit is preceded by painstaking work on assessing the enterprise's risk and explanatory work on the possibility of eliminatingof detected violations before conducting a documentary audit.
Therefore, documentary audits will not be conducted for:
- enterprises that have received AEO status, since such enterprises already have a high level of trust;
- enterprises that have independently eliminated the violations detected during the pre-audit analysis;
- enterprises that operate systematically and have low risks of violations of customs legislation, enterprises that have recently started foreign economic activity;
- enterprises that are located in temporarily occupied territories or territories where hostilities are underway/possible hostilities are possible;
- enterprises that import goods recognized as humanitarian aid into the customs territory of Ukraine.
At the same time, tax control of the results of customs clearance of such enterprises is carried out by conducting a pre-audit analysis, the results of which are brought to them for independent elimination of detected violations and are taken into account when determining the set of customs formalities that will need to be carried out during customs clearance of goods of such entities of foreign economic activity in the future.
During the first half of 2025, customs authorities conducted 648 documentary inspections. Of these, 37 were on-site (scheduled or unscheduled), which is 6% of the total. The remaining 611 inspections (94%) were carried out in a non-on-site format. The total amount of additional monetary obligations accrued as a result of inspections amounted to almost UAH 1.35 billion, of which UAH 575.2 million (43%) were on-site inspections, and UAH 773.4 million (57%) were on-site inspections.
Given that the average annual number of enterprises registered with customs authorities and carrying out export-import operations is about 35 thousand (and taking into account citizen importers - about 130 thousand payers), in the first half of 2025, only 1.7% of such entities were covered by inspections.