EBA calls for clearer accounting rules for assets lost due to the war

03/ 07/ 2026

The European Business Association has approached the Ministry of Finance of Ukraine with a proposal to amend the Regulation on the Inventory of Assets and Liabilities in order to establish clear procedures for documenting and accounting for assets that have been lost, destroyed, or placed beyond the control of businesses as a result of the temporary occupation of territories or hostilities. Today, a significant number of companies are facing situations where goods and other assets have remained in temporarily occupied territories or have been destroyed during military operations. According to the Association’s member companies, many businesses possess sufficient documentary evidence confirming such losses, including reports issued by the State Emergency Service of Ukraine, military administrations, materials from criminal proceedings, force majeure certificates, and other official documents. However, under the current Regulation, such assets can effectively be written off only after an inventory has been conducted, which is possible solely where safe and unrestricted access to the property exists. In practice, this means that companies are unable to reflect confirmed losses in their accounting records in a timely manner until the relevant territories are de-occupied or access to the assets is restored. Furthermore, during tax audits, the tax authorities often refuse to recognise write-offs that have not been supported by an inventory, resulting in disputes and creating legal uncertainty for businesses. In light of these challenges, the Association proposes supplementing the Regulation with provisions allowing companies to recognise the loss, destruction, or loss of control over assets located in temporarily occupied territories or areas affected by hostilities on the basis of official documents issued by the competent authorities, without having to wait until physical access to the property is restored. According to the Association’s experts, these amendments would eliminate legal uncertainty surrounding the accounting treatment of assets under martial law, improve the reliability of companies’ financial reporting, and align accounting rules with the realities in which Ukrainian businesses are currently operating. The European Business Association stands ready to contribute to the development of the proposed amendments in cooperation with the Ministry of Finance of Ukraine.

Today, a significant number of companies are facing situations where goods and other assets have remained in temporarily occupied territories or have been destroyed during military operations. According to the Association’s member companies, many businesses possess sufficient documentary evidence confirming such losses, including reports issued by the State Emergency Service of Ukraine, military administrations, materials from criminal proceedings, force majeure certificates, and other official documents. However, under the current Regulation, such assets can effectively be written off only after an inventory has been conducted, which is possible solely where safe and unrestricted access to the property exists.

In practice, this means that companies are unable to reflect confirmed losses in their accounting records in a timely manner until the relevant territories are de-occupied or access to the assets is restored. Furthermore, during tax audits, the tax authorities often refuse to recognise write-offs that have not been supported by an inventory, resulting in disputes and creating legal uncertainty for businesses.

In light of these challenges, the Association proposes supplementing the Regulation with provisions allowing companies to recognise the loss, destruction, or loss of control over assets located in temporarily occupied territories or areas affected by hostilities on the basis of official documents issued by the competent authorities, without having to wait until physical access to the property is restored.

According to the Association’s experts, these amendments would eliminate legal uncertainty surrounding the accounting treatment of assets under martial law, improve the reliability of companies’ financial reporting, and align accounting rules with the realities in which Ukrainian businesses are currently operating.

The European Business Association stands ready to contribute to the development of the proposed amendments in cooperation with the Ministry of Finance of Ukraine.