What an LLC has to do about NACE 2.1-UA: when to check the codes, when to convene a meeting, and why the tax authority is a separate step.
On 1 January 2027 Ukraine moves to a new classification of economic activities — NACE 2.1-UA. It was approved by State Statistics Service Order No. 191 of 28 October 2025 and replaces the current classifier DK 009:2010, which everyone knows as KVED. This is not another edition of the same directory: the classification is aligned with the European NACE Rev. 2.1, and some familiar codes disappear, split, or change meaning.
The first thing to say plainly: there is no reason to rush to a registrar today. There is still no technical mechanism for replacing codes across the state registers, and 2026 is set aside for preparation. But checking your codes is worth doing now — so that January does not reveal that your primary activity has split into three new ones.
Step 1. Check the codes you hold
Open your extract from the Unified State Register and write out every code you hold — the primary one and all the secondary ones. Each has to be located in the KVED-2010 to NACE 2.1-UA correspondence table.
Step 2. Identify the type of change
Next to every code the correspondence table shows a type of change. That is what tells you whether you have work ahead:
| Type | What it means |
|---|---|
| 1:1 | the old code carries over unchanged — nothing to do |
| 1:n | one old code splits into several new ones — you choose the one that matches what you actually do |
| n:1 | several old codes merge into one — usually a technical change |
| n:m | complex mapping: parts of the activity move to different new codes — this one needs analysis |
Step 3. A decision by the participants
For a company the procedure starts inside the company, not at the registrar. You need minutes of the general meeting of participants — or a decision of the sole participant — listing the codes to be added, changed or removed, and naming the person authorised to file.
Check the charter separately. If it lists the company's activities, changing the codes drags the charter along with it, and that is a different registration action with a different set of documents. If the charter uses general wording, the decision alone is enough.
Step 4. Registering the change
You file application form 2 — on state registration of changes to the information held about a legal entity. With it go the participants' decision and proof of payment of the administrative fee. Filing is possible with a state registrar, through an Administrative Service Centre, or with a notary who holds registrar powers.
- Form 2 with the box for a change of economic activity ticked
- The participants' decision — signatures notarised where required
- Administrative fee — 0.3 of the subsistence minimum for able-bodied persons
- Proof of authority for the representative, if the director is not filing in person
Step 5. The tax authority is a separate step
Code data flows from the state register to the tax service automatically. But if the company is on the single tax, third group, that is not enough: activity types are also held in the Register of Single Tax Payers, and changes get there through a separate application for the simplified tax system (the form approved by Ministry of Finance Order No. 308 of 16 July 2019), marked as an amendment.
What else to check
- Licences and permits — they are tied to specific activities
- Your bank — compliance matches payment descriptions against the codes in the register
- Contracts and primary documents — the subject matter has to match the declared activity
- Statistical reporting — the forms will be updated for the new classification
What not to do right now
- Re-registering codes in bulk just in case — the correspondence tables are still being refined
- Picking a new code by the closest number without reading the description of the activities
- Leaving the check until December 2026: if your codes are type n:m, the decision will take time
Do I need to change my LLC codes to NACE 2.1-UA right now?+
No. NACE 2.1-UA becomes binding on 1 January 2027. 2026 is set aside for preparation, and there is still no technical mechanism for a bulk replacement of codes in the state registers. But it is worth checking your current codes now.
Is filing form 2 with the state register enough?+
For most companies — yes. But single-tax group 3 payers have to file an additional application for the simplified tax system (Ministry of Finance Order No. 308 of 16 July 2019) marked as an amendment; otherwise the new codes will not reach the Register of Single Tax Payers.
Do I need to amend the charter when the codes change?+
Only if the charter lists the company's specific activities. If it uses a general wording (e.g. 'other activities not prohibited by law'), the participants' decision and form 2 are enough.
How much does changing the codes cost for an LLC?+
The administrative fee for registering changes in the state register is 0.3 of the subsistence minimum for able-bodied persons. Notary fees (if signatures on the decision need to be notarised) and legal support are additional.
Which way suits you better?
Do it yourself with a step-by-step guide — or hand it over to us and save the time.
LLC registration
Charter, founders and shares, choosing the tax regime and KVEDs, opening a bank account — without legal traps on day one.
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- Model charter vs custom — when each one wins
- Share capital, non-resident founders
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