On May 20, 2026, Ukraine's Verkhovna Rada adopted in first reading draft law No. 15111-d, the long-awaited statute aligning the country with the EU's DAC7 model for taxing income earned through digital platforms. The bill passed with 234 votes and now returns to the Committee on Finance, Tax and Customs Policy for a second reading. According to the official bill card, it amends the Tax Code to implement automatic international exchange of information on platform income — but it does more than mirror Brussels. Where DAC7 (EU Directive 2021/514) stops at reporting, Kyiv designates platform operators, including some non-residents, as full tax agents that must withhold and remit on sellers' behalf.
What the bill actually does
Under the framework, operators of marketplaces, ride-hail apps, delivery services and short-term rental platforms — names like OLX, Glovo, Bolt, Uklon and Uber appear repeatedly in the Ukrainian coverage — must register with the State Tax Service by November 1, 2026, conduct due diligence to identify their sellers, and report seller income annually. Most operative provisions, including the headline 5% rate, take effect January 1, 2027, with the first information exchange covering 2027 activity due in early 2028 (regfollower, VATupdate).
The carrot is real. Qualifying individuals pay a preferential 5% personal income tax instead of the standard 18%, on top of the wartime 5% military levy that has applied to most income since December 2024. That yields an effective ~10% rate versus 23% for ordinary self-employment income. To qualify, a seller must be a Ukrainian tax resident, use a designated Ukrainian account, employ no staff for the activity, and avoid excisable goods. The relief is capped: it applies to annual income up to 834 minimum wages — roughly Hr 7.2 million, about $163,000 — above which standard rates resume.
Crucially, the version that cleared first reading is narrower and less intrusive than the government's original draft. Per dev.ua, lawmakers stripped out provisions granting access to banking secrecy and mandatory special accounts, and exempted sales of used personal goods entirely. A separate de minimis floor exempts goods sales under €2,000 per year. This is the so-called "OLX tax" that, in practice, leaves ordinary citizens selling a second-hand sofa untouched.
The case for it
The strongest argument for 15111-d is straightforward and serious. Ukraine has a large informal economy, a war to finance, and an $8.1 billion IMF Extended Fund Facility whose structural benchmarks explicitly require this law. Platform income has been a visible blind spot: full-time couriers and gig drivers earning real money alongside salaried workers who cannot opt out of withholding. DAC7 alignment is also an EU-accession deliverable — Ukraine cannot credibly pursue membership while leaving cross-border platform income outside the automatic-exchange perimeter. A low 5% rate paired with generous exemptions is a defensible bet that formalization is better achieved by making compliance cheap than by threatening audits.
On its own terms, the bill is well-calibrated. Dropping banking-secrecy access and special accounts removed the most disproportionate surveillance features, and the used-goods and €2,000 carve-outs target the law at genuine commercial activity rather than household clear-outs.
Where proportionality strains
The concern is not the rate — 5% is pro-innovation by any measure — but the architecture. DAC7 deliberately makes platforms reporters, not collectors. The information flows to tax authorities, who assess and collect. Ukraine instead conscripts platforms as withholding tax agents that must calculate, withhold and remit monthly, with penalties reaching 100 minimum wages for a missing report. For a domestic operator this is burdensome; for a non-resident platform serving a mid-sized, war-affected market, it is a live question whether the compliance cost justifies staying. Reporting obligations can be automated against existing data; acting as a withholding agent against Ukrainian residency, account-type and headcount criteria — facts platforms do not natively hold — pushes tax administration onto private intermediaries that are poorly positioned to verify it.
That matters because platform competition in Ukraine is thin and fragile. Every marginal operator that declines to register by November 1 narrows the choices available to the couriers and small sellers the preferential rate is meant to help. The risk is a familiar one: a withholding mandate that looks costless on paper because the state offloads collection, while the real cost lands on market entry and platform diversity.
The fix is within reach
None of this requires abandoning the bill — it requires the second reading to lean toward the DAC7 reporting model rather than past it. Lawmakers could let qualifying sellers self-assess at the 5% rate while platforms merely report, reserving withholding for clear-cut high-volume cases. They could also give non-resident operators a longer registration runway than the compressed November deadline and a genuine safe harbour for good-faith due-diligence errors. The committee has already shown it listens: it removed the banking-secrecy and special-account provisions once. Trimming the withholding-agent mandate to match the EU template it claims to follow would keep the formalization gains while sparing a small market the burden of turning every platform into a tax collector.