Most foreign founders arrive in Belarus with an audit rule of thumb borrowed from home. In the EU, small companies are usually exempt, while in some jurisdictions every subsidiary is audited. Neither assumption holds in Minsk.
Belarusian law decides who needs a statutory audit by status, size and a handful of specific events — not by who owns the shares. A foreign-owned software house with modest revenue may never need one. A three-person startup that joins the Hi-Tech Park (HTP) needs one every year from its first reporting period.
This guide explains where the obligation comes from, how the revenue threshold works for 2026 and 2027, why HTP residency changes everything, and which other events can put an auditor on your calendar. It closes with deadlines, a checklist and answers to the questions foreign shareholders ask most often.
The core rule sits in Article 22 of Law No. 56-Z of 12 July 2013 “On Auditing Activities”. It defines a mandatory audit as one required by that law or by other legislative acts. It covers annual individual and consolidated statements prepared under Belarusian accounting rules.
Article 22 contains a closed list of entities that must be audited every year. For a typical IT business, three entries matter:
The rest of the list covers the National Bank, commercial banks and banking groups, exchanges, insurers and insurance brokers, and professional securities market participants. It also includes joint-stock investment funds and their management companies, special financial organisations and the deposit guarantee agency. Few IT subsidiaries fall into these categories, although fintech projects should check them carefully.
The audit of a given year’s statements must be completed no later than 30 June of the following year. That date applies to every entity on the list, whatever triggered the obligation.
The size test is simple on paper. If a company’s revenue for the previous year exceeded 500,000 base units, its statements for the current year must be audited. The base unit is taken as of 31 December of that previous year.
Because the government resets the base unit almost every January, the threshold in rubles rises with it. The base unit was BYN 40 in 2024 and BYN 42 in 2025, and it was raised to BYN 45 from 1 January 2026. Here is how that translates into audit obligations:
| Revenue earned in | Base unit on 31 December | Revenue threshold | Statements to audit | Audit deadline |
| 2024 | BYN 40 | BYN 20,000,000 | 2025 | 30 June 2026 |
| 2025 | BYN 42 | BYN 21,000,000 | 2026 | 30 June 2027 |
| 2026 | BYN 45* | BYN 22,500,000* | 2027 | 30 June 2028 |
*Assumes the base unit is still BYN 45 on 31 December 2026.
In other words, a company that booked more than BYN 21 million of revenue in 2025 is already inside the audit net for its 2026 statements. It needs an audit contract in place well before the June 2027 deadline.
The Ministry of Finance has clarified that the test uses sales revenue recorded on the credit of sub-account 90-1, the account for revenue from goods, works and services. Revenue of branches and representative offices is included, and the total is converted into base units at the rate in force on 31 December.
Two practical consequences follow for IT exporters. First, the figure is sales revenue as booked in Belarusian accounts — practitioners read it as gross, including VAT and other taxes charged on sales. Profit is irrelevant, and other income such as interest or exchange gains is left out.
Second, revenue is measured in Belarusian rubles. A contract priced in US dollars or euros can push you over the threshold simply because the ruble weakened, even if your dollar income stayed flat.
Consider a software company that is not an HTP resident and is owned by a Cyprus holding company; in 2025 it recorded sales of BYN 21.4 million on sub-account 90-1. Since this amount is more than BYN 21,000,000, the company is required to have its 2026 financial statements audited by 30 June 2027, even if its 2026 revenue turns out to be lower.
Now imagine the same company had joined the Hi-Tech Park. The revenue figure would stop mattering altogether, for the reason explained further below.
No. Nothing in Article 22 refers to foreign shareholders, foreign investment or the nationality of the ultimate owner. A limited liability company owned by a parent in Cyprus, the UAE or the US is tested exactly like one owned by Belarusian residents.
That surprises founders who assume a foreign-owned subsidiary automatically attracts extra scrutiny. In practice, the only questions are whether the entity is an HTP resident, whether it crossed the revenue line, and whether it belongs to one of the regulated categories.
Foreign ownership does, however, create demand for an audit from other directions. The auditor of the parent company might request audited figures from each subsidiary, occasionally requiring them to be restated in accordance with IFRS, even though Belarus requires IFRS statements mainly from listed companies and financial institutions. Investors include audit covenants in their shareholder agreements and lenders do the same in their loan agreements. Although none of these requirements constitutes a statutory audit, each of them can be just as binding.
For the majority of foreign-owned IT companies, it is this section that makes the decision. All residents of Hi-Tech Park are required to have their annual accounting statements audited each year, no matter what their revenue, number of employees, or length of time in operation is. A startup that earns BYN 500,000 in its first year needs an audit just as much as a resident earning BYN 50 million.
The HTP audit consists of two components: the auditor has to verify that the annual statements are reliable and must also check that the resident has correctly calculated and paid its contribution to the HTP administration—1% of revenue. The audit report must be submitted to the HTP administration no later than 1 July in the year following the reporting year.
The time at which admission is made has no effect on the scope; a company which became a resident in December still prepares a single set of annual statements, and therefore the entire year is subject to an audit, including the months prior to its entry into the Park.
Errors relating to revenue recognition, currency conversion or the allocation between permitted and non-permitted activities come to light quickly since the auditor examines the revenue base for the 1% contribution. Residents who maintain their accounts using accounting support designed for HTP residents generally experience a shorter and less expensive audit simply because there is less for the auditor to amend. Many of them also opt for a staged audit, with an interim visit after the first nine months of the year, so that problems can be corrected before the end of the year.
Beyond the annual list, several situations bring an auditor in, either by law or in practice.
Consolidated statements. If a Belarusian company within Article 22 prepares consolidated statements under national rules, those are audited too. The law exempts them for a given year when the group’s IFRS consolidated statements for that year have been audited.
Dividends. Paying a dividend does not by itself require an audit. Distributions are, however, restricted when net assets fall below the charter capital, and banks handling cross-border payments may ask for the financial statements behind them. Audited figures make both checks easier, which matters when you are planning dividends to a foreign parent and relying on treaty rates.
The charter and shareholders. A company’s charter or a general meeting decision can make an annual audit compulsory for that entity alone. Foreign parents sometimes add this clause at incorporation and later forget it exists.
Deals and financing. Loan agreements, investment rounds and M&A due diligence routinely call for audited accounts. These are contractual obligations, but missing them can stall a transaction just as surely as a regulatory breach.
Voluntary liquidation. A company that decides to wind up can commission an auditor’s independent assessment instead of waiting for a tax inspection. This route, set out in Decree No. 1 of 16 January 2009 and Council of Ministers Resolution No. 500 of 4 July 2017, is usually much faster. Liquidation rules have been under revision, so confirm the current procedure first. Park residents also have to coordinate the exit with the HTP administration, which turns liquidating an HTP company into a multi-step project.
Once you know an audit is required, the calendar is fixed.
| Step | Deadline |
| Reporting year closes | 31 December |
| Mandatory audit completed | 30 June of the following year |
| HTP residents file the audit report with the HTP administration | 1 July of the following year |
| Information about the audit submitted to the Ministry of Finance | Within one month of receiving the audit report, and no later than 15 July |
The Ministry of Finance filing is an online questionnaire on the ministry’s website, not a copy of the report; companies have not had to send the audit report to the tax inspectorate since 2020.
In practice, the audit should be contracted by autumn of the reporting year, with the auditors planning their spring around those clients who had booked their work early and a staged audit requiring its first visit before the end of the year. These dates should therefore be included on the subsidiary’s reporting calendar together with the tax returns and the statistical filings so that nobody at head office is surprised in May.
Select an audit firm or individual auditor who is entitled to practise in Belarus and has actual experience of dealing with IT exporters and HTP residents. Find out if the audit includes the HTP contribution check, whether the team communicates in English, and how the findings will be reported to the head office.
One consequence follows another rather than arriving as a single fine. Officials of the company may be held liable administratively for reporting breaches, and the duty to carry out an audit does not cease when the deadline has gone by; the year which has not been audited simply remains as a compliance gap.
The situation is more serious for HTP residents. One of a resident’s duties is to file the audit report, and a failure to do so can be brought to the attention of the Park’s Supervisory Board, which then decides upon residency status. The cost of losing the HTP arrangement would be much greater than the audit fee.
The commercial consequences are usually more severe than the legal ones. When audited statements are not available, it becomes more difficult to justify dividends, intra-group loans and bank onboarding, and buyers take the uncertainty into account when pricing the transaction. Although it is always possible to get an audit done late, it ends up costing more and providing less than if it had been carried out on time.
By no means is ownership a determining factor; a company is only required to have a statutory audit if it is a resident of HTP, if its revenue exceeds the threshold, or if it belongs to one of the categories listed in Article 22.
No. The company prepares one set of annual statements, so the audit covers the whole reporting year, including the months before admission.
The Ministry of Finance refers to the credit turnover on sub-account 90-1; professionals interpret this as representing gross sales revenue, that is to say the amount including VAT and other taxes levied on sales, while other income such as interest or exchange gains is not included.
Yes, for your 2026 statements. The obligation relating to a particular year is based on the revenue of the preceding year; if the revenue in 2026 remains below the threshold then the statements for 2027 will not be subject to an audit on grounds of size.
The statutory audit has to be performed by an auditor who is entitled to practise in Belarus, and many groups choose to appoint a local firm to prepare the report in the format required by the group auditor.
It represents a broader kind of engagement; in addition to verifying the reliability of the statements, the auditor also examines how the 1% contribution to the administration of the HTP was calculated and paid.
Not on your side. Without a Belarusian legal entity there are no local statements to audit, because the EOR provider is the employer and handles its own reporting. The question only arises once you register your own company in Belarus.
For foreign-owned IT companies in Belarus, the audit question rarely turns on ownership. It turns on HTP residency, which makes the audit annual and unconditional, and on revenue measured in rubles against a threshold that moves every year. After that come the event-driven triggers: consolidation, charter clauses, dividends, liquidation and the demands of investors and group auditors.
The practical approach is to decide early. Check status and revenue in the autumn, secure an auditor before the spring rush, and keep the books clean enough that the audit confirms rather than corrects. If you are not sure which rules apply to your entity, contact our team and we will map out the obligations and the calendar with you.
