The Committee on Accounting, Auditing, and Taxation of the Association of Ukrainian Banks (AUB) reviewed, together with AUB members from the National Financial Institutions Association (NFIA), a draft of the NBU’s Methodological Recommendations on Accounting Policies for Non-Bank Financial Institutions. The participants identified a key issue requiring further coordination with the regulator: the timing of recording source documents in the context of NBU Resolutions No. 192 and No. 143. The Committee agreed to formulate a consolidated market position on this issue.
“Source documents are not always received on time, and the Accounting Act requires that transactions be recorded in the period to which they actually belong. Our task is to find a solution that will be unambiguous for the market and, at the same time, will not contradict current legislation,” explained Committee Chairman Bohdan Lukashevych.
The Issue at Hand: Timing of Recording Source Documents
The draft Methodological Guidelines propose recording source documents (acts, invoices, and other supporting documents) as of the date they are actually received. Committee members noted that, in practice, such documents are often received late—after the end of the reporting period to which they actually pertain.
This provision conflicts with the requirements of Resolution No. 192, which mandates the daily calculation of capital and leverage ratios: figures calculated as of the reporting date may subsequently change once information for the prior period is received. The Committee believes that this issue should be clearly addressed in the recommendations themselves so that the procedure for recording documents is unambiguous and predictable for all market participants.
Next Steps
The Committee will continue its dialogue with the National Bank regarding Resolutions No. 192 and No. 143 to present a coordinated market position. All interested parties—banks, payment institutions, insurers, and other non-bank financial institutions—are invited to contribute to the development of proposals.
The Association encourages the submission of practical case studies and proposals to office@aub.org.ua: the more comprehensive the market’s position is, the greater the likelihood that the regulator will take it into account during the final approval of the Methodological Recommendations.
