Finally: the New Combined Reporting Forms Approved

Businesses have been awaiting the issuance of this Order since the beginning of the year, as Law No. 4536 established that IEs must submit quarterly reporting on personal income tax, military levy, and the unified social contribution, while legal entities would continue reporting monthly. Order No. 243 has updated the reporting forms not only for IEs but also for legal entities. With the entry into force of Order No. 243, it is important to determine the reporting period when the new forms must be applied for the first time.

As regards legal entities, the Order specifies that they must submit their first reports using the updated forms for the month in which the Order enters into force. Since Order No. 243 enters into force in July, the new forms must first be used to report for July 2026. Monthly reporting must be submitted within 20 days following the last day of the reporting month. Accordingly, legal entities must submit reporting using the new forms by August 20 this year.

As regards IEs, the situation remains uncertain. The Order stipulates that the first quarter of 2026 should be the first reporting period. However, all IEs that are employers have already submitted reports for the first quarter using the previous forms for each month within the quarterly reporting deadline, following the recommendations of the tax authorities. Whether these reports will need to be resubmitted using the new forms is yet to be clarified in future official guidance. Most likely, this will not be required. What is already clear, however, is that the new forms must be used to file reports for Q2 2026.

It should be noted that quarterly reporting must be submitted within 40 calendar days following the last day of the reporting period (quarter). Therefore, the deadline for submitting reporting for Q2 2026 is August 10, 2026.

If the number of employees is more than five persons, the reporting must be submitted electronically. The new reporting forms are already available in the taxpayer's electronic cabinet under the following identifiers: J0500110 for legal entities; F0500110 for individual entrepreneurs.

The reporting package for legal entities consists of the Tax Calculation and six appendices:

·       Appendix D1 – information on accrued Unified Social Contribution (USC);

·       Appendix D2 – information on sick leave benefits;

·       Appendix D3 – information on maternity benefits;

·       Appendix 4DF – data on individuals’ income, personal income tax, and the military levy;

·       Appendix D5 – information on employment relationships;

·       Appendix D6 – data on employees’ special service record.

As a general rule, reporting is submitted to the tax authority at the taxpayer’s principal place of registration. However, amendments have been introduced concerning enterprises whose employees permanently work within the territory of a territorial community other than that in which the head office is registered. Based on the amendments,   not only registration at a secondary place of tax registration and payment of personal income tax to the budget of the respective territorial community is required, but reports have to be submitted there too.  However, the military levy and unified social contribution for all employees continue to be paid at the taxpayer’s principal place of registration.

Under the updated procedure for submitting unified reporting, the first Tax Calculation must be filed for the head office and must include all appendices (D1, 4DF, D5, and D6), together with the introductory section covering all employees, regardless of their place of work.

After receiving Receipt No. 2, confirming successful submission of the reporting package, the taxpayer must submit separate calculations for each territorial community in which employees work. Such calculations must indicate the Code of the Administrative-Territorial Unit and Territorial Community (CATOTTG) of the relevant territorial community, as well as information on the business facility concerned, such as a store, warehouse, kiosk, or other subdivision, including its address.

Appendices D1, D5, and D6 are not required to be submitted with these separate calculations. Only Appendix 4DF must be filed, as it contains information on employees working within the respective territorial community and the amounts of accrued salary, personal income tax, and military levy.

As regards the reporting forms for IEs, the scope of the Tax Calculation has been reduced, as sections applicable exclusively to legal entities have been removed. The revised form now contains only the introductory section and a table reflecting accrued income and USC amounts broken down by the reporting months of the quarter. The number of appendices has also been reduced to four:

·       FIZ-D1  - information on accrued USC;

·       FIZ-4DF  – data on individuals’ income, personal income tax, and military levy;

·       FIZ-D5  – information on employment relationships;

·       FIZ-D6  – data on employees’ special service record.

Although the reporting is submitted on a quarterly basis, Appendices FIZ-D1, FIZ-4DF, and FIZ-D6 must be completed separately for each month within the reporting quarter. This requirement does not apply to Appendix FIZ-D5. As before, it must be submitted only if hires, terminations, transfers to another position, or transfers to another department took place during the reporting quarter.

The changes affect not only the reporting forms themselves but also the procedure for correcting errors. If an error is identified before the filing deadline expires, a calculation with the reporting type "New Reporting" must be submitted. If the error is discovered after the filing deadline, a Tax Calculation with the reporting type "Amending" must be filed. In such cases, only those appendices containing the error being corrected need to be submitted together with the calculation.

Where an error is contained in Appendix D1 (FIZ-D1), the completion depends on the type of report being filed. In a New Reporting filing, the principle of excluding and adding entries using indicators “1” and “0” applies. In an Amending filing, special accrual-type codes are used to increase or decrease the amounts of salary and USC.

To correct erroneous entries in Appendix 4DF, the standard correction mechanism continues to apply: the incorrect line is cancelled using indicator "1", while the corrected line is added using indicator "0".

Natalia Shcherbak
Accounting and Tax Consultant