Starting January 1, 2027, the new Classification of Economic Activities NACE 2.1-UA will be implemented in Ukraine. It is harmonized with the European NACE Rev. 2.1 and will eventually replace the business-familiar NACE DK 009:2010.
Activity codes are not just a line in the extract from the Unified State Register. The right to a simplified taxation system, the risks of tax invoice blocking, and bank audits depend on them.
In this article, we will examine what has already been established by regulations, what is not yet in place, and how to check your own codes using the correspondence table. For clarity, we will analyze our company's codes.
What is established by regulations?
By the order of the State Statistics Service dated October 28, 2025, No. 191, the Classification of Economic Activities (NACE 2.1-UA) was approved and put it into effect from 01.01.2027. Preparatory measures defined by the plan approved by the State Statistics Service order No. 244 of December 25, 2025, shall continue until December 31, 2026.
It is important to understand the nature of these acts. These are departmental orders in the field of statistics. They do not cancel NACE DK 009:2010 (KVED DK 009:2010), do not change the procedure for state registration, and do not establish deadlines for businesses to change codes in the EDR.
State Statistics Service only states that NACE 2.1-UA will eventually replace NACE-2010.
Instead, it has already been determined statistical duties legal entities. By the State Statistics Service order dated 13.08.2026 No. 201, questionnaires were approved in which the enterprise itself indicates its types of activities according to KVED-2010 and their equivalents according to NACE 2.1-UA. They apply starting from reporting in 2027:
- No. 1-SBR (NACE), one-time – no later than September 20;
- №1-SBR (annually), no later than August 20;
- №1-SBR (active), annual – by September 20.
Questionnaires are submitted to the territorial body of the State Statistics Service via the «Respondent's Cabinet».
Please note: Questionnaires serve to recode the statistical business register (SBR) and do not replace the application for changing types of activities in the EDR.
How to read the correspondence table?
21.05.2026 Derzhstat published the correspondence table between NACE-2010 and NACE 2.1-UA. It contains 972 mapping lines and allows checking the code in both directions: from old to new and vice versa.
For each pair of codes, the table indicates the type of change:
- 1:1 – the type of activity is transferred entirely. The code and name may remain the same or change;
- 1:n – one old code is distributed among several new ones;
- n:1 – several old codes are combined into one new one;
- n:m – part of the activity is transferred to other codes.
For 1:n and n:m types, the table contains a column with a description of the redistributed activities. It is this description that needs to be matched against the actual activity of the enterprise in order to select the correct new code.
Example: Bargen law firm codes
Let's check the eight NACE-2010 codes registered to our company against the correspondence table. The result is as follows: only three codes do not change at all, two change their numbers, and another three require an analysis of actual operations.
Thus, even for a law firm, the transition does not boil down to a mechanical replacement of numbers. In three out of eight cases, the new code requires analysis and selection depending on the actual activity.
Will there be an automatic replacement, and what is the liability?
State registration is based on applicant principle. Therefore, the state will automatically recode only the statistical register SBR. In the EDR, codes will be changed only upon the application of the business entity.
Simultaneously The procedure for changing codes in the USR and tax registers has not yet been approved.. The registration system currently does not technically allow selecting a code according to NACE 2.1-UA, so it is impossible to submit such an application today.
Regarding liability, current legislation does not yet contain a specific sanction for failure to submit an application for a change of types of activity.
However, the absence of a penalty does not mean the absence of consequences. Risks arise indirectly—through tax and other regimes where activity code types have legal significance.
Single tax payers. Types of activities are entered into the single tax payers register, and the application for choosing the simplified system contains codes according to the NACE DK 009:2010 (KVED DK 009:2010). Pursuant to subclause 7 of subparagraph 298.2.3 of paragraph 298.2 of Article 298 of the Tax Code of Ukraine, a taxpayer is obliged to switch to the general system in case of carrying out types of activities not specified in the single tax payers register. How the State Tax Service will compare the old codes in the register with the new ones is not yet determined by the Tax Code of Ukraine.
VAT payers. Discrepancies between operations and registered activities can become grounds for additional inquiries and the suspension of tax invoice registration.
Banks. As part of customer due diligence, banks monitor the compliance of financial operations with available information about the client and their activities, so up-to-date information on types of activities in the Unified State Register remains important.
Statute. If the charter explicitly states the NACE-2010 codes or the list of types of activities, it will have to be brought into compliance, which requires a decision of the participants and state registration of changes to the constituent documents.
How to prepare right now?
While the procedure for changing codes in the EDR has not yet been approved, there is no need to submit registration applications. At the same time, you can prepare in advance, namely:
- compare each code with the mapping table and determine the type of change;
- for codes 1:n and n:m, map the description to the actual activity and select a new code;
- check whether the codes include the charter, client agreements, and bank questionnaires;
- check with the statistics authorities whether the enterprise submits questionnaire No. 1-SBR in 2027.
Thus, the transition to NACE 2.1-UA is already defined in time, but the rules for business are still being formed. As the example of the Bargen law firm shows, even a routine set of codes requires analysis.
Bargen law firm is ready to help with the audit of activity codes, preparation of corporate resolutions, and registration documents for the transition to NACE 2.1-UA.
