Top 5 Reporting Mistakes Made by Diia City Resident Companies: Let’s Analyze with «Global Audit»
IT ClusterBeing a resident of Diia.City means lower taxes, more investor trust, and official freelancer cooperation. But reporting errors can cost you this status — and money.
Together with «Global Audit», a partner of Kharkiv IT Cluster, we have collected 5 typical mistakes that even experienced companies make. And to illustrate practical aspects, we will use the real experience of Diia.City resident companies.
1. Incorrect Calculation of Average Remuneration
Mistake: Companies often divide the total amount of remuneration by the average number of employees — this is incorrect.
Correct approach: Only individuals who received payments are counted. If a specialist worked only part of the month but received remuneration, they are counted as a full unit.
Law No. 1667-IX clearly states: only the number of people who received payments should be included, with no partial coefficients.
Let’s look at an example:
Imagine a company with 20 team members, including both full-time employees and gig specialists. Each receives a monthly remuneration of €1,200. On May 16, staffing changes occurred:
- 5 new hires joined
- 3 employees left
Total remuneration for May: €25,200.
Actual remuneration breakdown:
17 people worked the full month:
1200 × 17 = €20,400
5 newcomers worked from May 16 (half a month):
1200 / 22 × 11 × 5 = €3,000
(22 – average working days per month; 11 – actual days worked)
3 resignations also worked half a month:
1200 / 22 × 11 × 3 = €1,800
Total: €20,400 + €3,000 + €1,800 = €25,200 — aligns with reality.
Total number of employees who received remuneration:
17 + 5 – 3 = 25
Calculation of average remuneration:
25,200 / 25 = 1,008 euros, which is below the minimum set by Law No. 1667-IX
Thus, in cases where employees are hired or dismissed not at the beginning of the month, there is a real risk of non-compliance with the requirements of Law No. 1667-IX.
Case study from Amazing Drones LLC:
In practice, 1200 euros is an acceptable level for IT companies. However, for companies with manufacturing processes, such as Amazing Drones LLC, this can significantly increase the cost of production.
2. How to Count Freelancers?
The law requires that starting from the month after receiving Diia City residency, a company must employ at least 9 people.
Issue: The law requires that gig specialists be included in the calculation, but does not specify how to do so. Instruction No. 286 does not classify gig specialists as part of the average headcount, since they operate under civil law contracts, which are accounted for separately and not included in the average number of employees.
Solution from «Global Audit»: Develop an internal methodology for calculating the average number of employees including gig specialists, and approve it through an internal policy document. This approach helps ensure greater confidence during audits.
3. Rounding Employee Counts — Not as Simple as It Seems
The State Statistics Service clarified how to apply Instruction No. 286 on rounding: use the “even number” rule to avoid systematic errors in staff counts.
Rounding rules:
- if the last digit is 1–4, round down (e.g., 12.3 → 12);
- if it’s 6–9, round up (e.g. 12.7 → 13);
- if it’s 5, round to the nearest even number: if the preceding digit is odd, round up (e.g., 13.5 → 14), if even, leave it (e.g., 12.5 → 12)
4. Friday Dismissals and Reporting Traps
Scenario: an employee resigns on a Friday, but is still counted in staffing figures until the first working day after the weekend — i.e., Monday.
Key rules:
- An employee is excluded from reports on the first day they no longer work.
- On weekends or holidays, the employee count is taken from the last working day.
- Thus, a dismissed employee is still counted until the first working day post-resignation.
Example: An employee resigned on Friday, December 31. They are excluded from the official headcount starting from the following Monday — January 3 (the first working day of the new year). Therefore, in the calculation of the average headcount for December, the employee is counted in full. In the same calculation for January, they are included only for the first two days — January 1 and 2.
Recommendation: ensure HR accurately reflects these changes. Otherwise, your reports may not match official records.
5. Qualified Income: What Counts and What Doesn’t
Frequent error: calculating qualified income based on all company income (entire Class 7 of the Chart of Accounts).
Only include:
- net revenue from sales (Account 70),
- royalties (Account 719) — only if not included in Account 70.
All other income sources are not counted as qualified income. Misreporting here may result in loss of Diia City residency.
How to Avoid Mistakes?
- Don’t leave report preparation to the last minute.
- Work as a team: accountant + lawyer + HR. Only coordinated collaboration ensures accuracy.
- Use audit support — this is a legal requirement under Law No. 1667-IX.
- Document internal methodologies — this is your shield during inspections.
It’s important to know: during martial law, the requirements for Diia.City residents remain in force. Amazing Drones LLC shared that this is precisely why they continue to comply with all regulations — to be fully prepared for the post-war realities.
Reporting within Diia.City isn’t intimidating if handled consistently. The key is not to leave it until the last minute and to follow a clear action plan. The accountant, lawyer, and HR specialist must work together — that’s when everything runs smoothly.
«Global Audit» is a team of auditors and consultants with years of experience supporting the IT business sector. The company is a trusted partner of Kharkiv IT Cluster and specializes in audit and tax consulting services tailored for Diia City residents.
Work with professionals — so you can focus on scaling, not fixing mistakes.
