In July–September 2025, the Business Ombudsman Council (the Council) continued helping entrepreneurs in countering cases of unfair treatment by state authorities.
In the reporting quarter, the Council focused its work on resolving business tax-related complaints, the practical implementation of the administrative procedure, and impacting policy in the recovery sphere. A special emphasis of the quarterly report is the largest category within tax-related complaints — inspections, to which a separate section of the report is dedicated.
Achievements and investigation results
The Council received 225 complaints and closed 116 cases. Investigations in 67 cases are ongoing. The Council ensured a significant financial impact for businesses for the quarter — UAH 2.7 bn. Since 2015, the total amount of funds saved for entrepreneurs has reached UAH 31 bn.
The leading categories in the complaint “anti-rating” in the third quarter are tax issues (48%), law enforcement agencies (20%), state regulators (10%), customs issues (7%), and local government bodies (5%).
Focus of the quarterly report: tax inspections
The Council systematically analyzes tax inspection practices and promotes the “Consult First” approach, transparent data and KPIs, and fair law enforcement that reflects the realities of the judicial system. During the reporting period, the Council observed progress in implementing the recommendations issued in its own-initiative investigation report, particularly in implementing the “Consulting First” approach.
At the same time, based on complainants’ cases, the Council emphasizes the problems of delayed approval of inspection results and inefficient repeated “additional inspections,” which create excessive pressure on taxpayers and complicate business planning.
VAT and SMKOR: monitoring the implementation of recommendations
Monitoring changes in SMKOR, the Council noted stabilization trends in the blocking of tax invoices during July–September. According to the tax service, the percentage of suspended invoices decreased from 0.35% in July and August to 0.29% in September 2025. These trends indicate a gradual alignment of the control process and a reduction in cases of unjustified blocking.
Administrative procedure: steps towards implementation
The Council moved from advocacy to active work on the practical application of the Law “On Administrative Procedure” (LAP).
Together with EU4PAR2 and the Lviv City Council, the pilot project “Lviv: Implementing LAP” (Zaprovadzhennia) was launched to standardize administrative acts, introduce effective administrative appeals, and promote pre-trial dispute resolution and mediation. Next steps include shaping the workflow of the city Appeals Commission and conducting training activities.
From analytics to action: Policy & Recovery
The Policy & Recovery unit transforms the Council’s systemic findings into practical tools for reconstruction. The team works with critical infrastructure (energy, transport, social facilities) and focuses on developing recommendations that make recovery projects coordinated, transparent, and rapid, increasing predictability for business and attracting private capital.
For more details please download the quarterly report here.
