New 2027 KVED Classifications for Licensed Businesses: How the Shift to NACE 2.1-UA Affects Licenses

Starting January 1, 2027, Ukraine will transition from NACE 2010 to the new classification of economic activities, NACE 2.1 UA. For some businesses, this will be a technical change. However, for companies operating in licensed, permit-based, or regulated sectors, the transition may have significantly more serious implications.

If your business operates in healthcare, pharmaceuticals, energy, waste management, construction, transportation, security services, financial services, electronic communications, or another regulated sector, the new codes should be reviewed not merely for statistical purposes, but also in terms of licenses, permits, contracts, bank compliance, and the actual business model.

The issue is not that a NACE code itself automatically grants or removes a license. The issue is that after the transition, the old code may no longer describe your business activities with sufficient accuracy. If the code in the Unified State Register, the licensing file, contracts, and actual business activities do not correspond, this may raise questions from a regulator, bank, counterparty, or tender customer.

What Changes with the Transition to the NACE 2.1 UA System?

The State Statistics Service of Ukraine has approved NACE 2.1 UA as the new national classification of economic activities. It will be introduced on January 1, 2027, and will replace NACE 2010.

The new classification is harmonized with the European NACE Rev. 2.1 system. Some codes will transition directly on a one-to-one basis. However, many types of activities will be divided, combined, or further detailed.

This increased level of detail is the main risk for regulated businesses. An old code may have been general, while the new classification separates activities into specific areas such as manufacturing, intermediation, storage, recovery, processing, specialized services, brokerage models, and similar activities.

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Why Does This Matter for Licensed Businesses?

A NACE code is not a license in itself and does not replace licensing conditions. This is important to understand so as not to overstate the risk.

However, in practice, NACE codes are used in the Unified State Register, licensing documents, bank questionnaires, contracts, tender documentation, tax analysis, and internal compliance procedures. Therefore, an incorrect or outdated code may not automatically result in the cancellation of a license, but it may raise questions such as:

• whether the registered business activity corresponds to the company's actual operations;
• whether the existing license covers the new or related activity;
• whether the company is carrying out an activity that requires a separate permit;
• whether the activity is correctly described in contracts and banking documents;
• whether there is a risk during a regulatory inspection or participation in a tender.

For a regulated business, this is no longer an “administrative formality” but a matter of the legal security of its operations.

Highest Risk Areas: Industry-Specific Code Detailing

Medicine, Laboratories, Rehabilitation, and Psychology

One of the most important examples is the old NACE 86.90, “Other activities in the field of healthcare.” Under NACE 2.1 UA, it is divided into several separate areas, including:

• 86.91 diagnostic imaging services and medical laboratory activities;
• 86.92 transportation of patients by emergency medical teams;
• 86.93 activities of psychologists and psychotherapists, except for activities of physicians;
• 86.94 activities of nurses and midwives;
• 86.95 activities of physiotherapists;
• 86.96 traditional and alternative medicine;
• 86.97 intermediation in medical, dental, and other services;
• 86.99 other activities in the field of healthcare.

For a clinic, laboratory, rehabilitation center, medical platform, or network of medical offices, this means that the old general code may no longer be sufficient. It is necessary to review not only the Unified State Register, but also the Ministry of Health license, places of business activity, medical specialties, contracts with physicians or sole proprietors, the patient acquisition model, and the actual list of services.

Pharmaceuticals, Pharmacies, and Medical Devices

In the pharmaceutical business, risk often arises not in a traditional pharmacy, but in more complex business models, including online sales, marketplaces, agency arrangements, intermediation, and the sale of medical devices or veterinary medicinal products.

For example, retail trade in pharmaceutical products remains a separate area of activity, but intermediation in specialized retail trade follows a separate classification approach. If the business does not simply sell products but organizes sales, attracts customers, or operates as a platform or intermediary, it is necessary to check whether the legal classification of this business model changes.

Energy, Renewable Energy, Charging Stations, and Energy Storage

The old NACE 35.11, “Electricity generation”, is further detailed in the new classification into electricity generation from non-renewable sources, generation from renewable sources, and electricity storage.

The new classification separately addresses electricity trading, brokers and agents, charging stations, gas storage, and intermediary models in the energy sector.

For companies holding NEURC licenses, renewable energy projects, charging infrastructure operators, electricity traders, or gas businesses, this may be critical. It is necessary to verify whether the new code corresponds specifically to the activity the company actually carries out and is authorized to perform.

Waste, Hazardous Waste, Recycling, and Waste to Energy

The waste sector carries one of the highest levels of risk. Under NACE 2.1 UA, the old codes relating to waste treatment and disposal are divided into more specific areas:

• materials recovery;
• energy production from waste;
• other recovery activities;
• incineration without energy recovery;
• landfilling or permanent storage;
• other disposal activities.

For companies handling hazardous waste, holding permits or licenses, subject to environmental impact assessment requirements, having contracts with industrial clients, or participating in tenders, this is not a mere formality. An incorrectly selected code may fail to reflect the actual process, including collection, transportation, treatment, recovery, disposal, incineration, or energy recovery from waste.

Construction, Development, and Specialized Works

In the construction sector, the risk is associated with distinguishing between development, construction organization, specialized works, engineering networks, fire protection works, and insulation works.

For example, the old code 41.10, “Development of building projects,” is mapped in the correspondence table to 68.12, “Development of building projects.” For a developer, general contractor, or company working on CC2 or CC3 class facilities, this may not be sufficient without an analysis of its actual role in the project.

It is necessary to check not only the code, but also the permits issued by the State Inspectorate of Architecture and Urban Development of Ukraine, construction contracts, the company's role in the construction process, types of works, and tender requirements.

Transport, Taxi Services, Logistics, and Freight Forwarding

In the transport sector, the new classification more precisely distinguishes between regular and non-regular passenger transportation, taxi services, transportation by passenger car with a driver, logistics services, intermediation in transportation, and ancillary activities.

This is important for carriers, taxi services, aggregators, freight forwarders, logistics operators, and companies involved in international transportation or the transportation of dangerous goods.

The risk is that a company may consider itself a “carrier,” while under the new classification its business model may in fact partly constitute intermediation, logistics services, or ancillary activities. This may be relevant for licenses issued by the State Service of Ukraine for Transport Safety, contracts, and insurance.

Security Services and Security Systems

For security companies, it is important to distinguish between physical security services, investigations, maintenance of security systems, remote monitoring services, installation, and technical maintenance.

Under NACE 2.1 UA, the old codes for private security activities and investigations are combined into a new area, while the maintenance of security systems follows a separate classification approach. If a company simultaneously provides security services, installs equipment, maintains systems, and responds to signals, it is necessary to verify whether these activities are correctly reflected in the Unified State Register and the licensing model.

Financial Services, Factoring, Payments, and Funds

The financial sector is particularly sensitive to the wording used to describe business activities. Old codes relating to other financial services may be divided into factoring, other types of lending, financing channels, fund management, or ancillary financial activities.

For financial companies, factoring companies, payment services, financial groups, or companies supervised by the NBU or the National Securities and Stock Market Commission, it is necessary to verify whether the new code corresponds to the license, description of the financial service, relevant registers, and financial monitoring requirements.

Change in the Classification: When Might an Additional License or Permit Be Required?

The transition to NACE 2.1 UA does not in itself mean that a company automatically needs a new license. However, it may reveal that the business is actually carrying out a different or additional type of activity. For example:

• a medical center provides not only physician consultations but also laboratory diagnostics, physiotherapy, or patient transportation;
• a pharmacy business uses an intermediary or online sales model;
• an energy company not only generates electricity but also stores it or operates as a broker;
• a waste management company not only collects waste but also carries out recovery, incineration, disposal, or energy production;
• a logistics company is actually carrying out licensed transportation activities;
• a security company combines security services, technical systems, and response services;
• a financial company provides factoring or payment services that require a separate legal assessment.

In such cases, the question is not “which code should be used,” but whether the company has the right to carry out the relevant type of activity.

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Risks of Failing to Review NACE Codes Before 2027

For regulated businesses, the risks may include:

• inconsistency between the data in the Unified State Register and the actual business activities;
• questions from the regulator during an inspection or when updating the licensing file;
• refusal or delays when applying for a license or permit;
• issues with the bank during a KYC or AML review;
• comments or concerns from a counterparty or investor during due diligence;
• failure to meet tender requirements;
• disputes over whether the company was authorized to perform certain works or provide certain services;
• the need to urgently amend the data in the Unified State Register, contracts, internal documents, and licensing materials.

The worst-case scenario is when the issue is identified not during planned preparations, but during an inspection, tender, bank inquiry, transaction with an investor, or submission of an application for a license.

How Can Businesses Prepare for the Introduction of NACE 2.1 UA: What Should Be Checked Before 2027?

We recommend that regulated businesses conduct a legal audit of the transition to NACE 2.1 UA. At a minimum, the following should be reviewed:

• the current NACE codes in the Unified State Register;
• the company's actual business activities;
• current licenses, permits, declarations, and registrations;
• the correspondence table between NACE 2010 and NACE 2.1 UA;
• whether the transition is one-to-one or whether a code is divided into several areas;
• whether a separate code is introduced for intermediation, storage, recovery, processing, or specialized services;
• contracts with clients, contractors, physicians, carriers, operators, or agents;
• bank questionnaires and compliance documents;
• tender requirements if the company works with government or large corporate customers.

Legal Support for Companies and Sole Proprietors Transitioning to New NACE Codes

The lawyers at “Pravova Dopomoga” can analyze the transition from NACE 2010 to NACE 2.1 UA specifically for licensed, permit-based, and regulated businesses. We can:

• check which of your current NACE codes will change in 2027;
• determine whether the transition is direct or presents potential risks;
• match the new codes with the company's actual business activities;
• assess the impact on licenses, permits, declarations, and registers;
• determine whether it is necessary to change or add codes in the Unified State Register;
• assess whether a new area of activity may require a separate license or permit;
• prepare recommendations for the director, accountant, lawyer, or compliance department;
• assist with making changes to the Unified State Register and preparing documents for the regulator.

It is better to review the transition to NACE 2.1 UA before 2027 rather than when the issue is already raised by a bank, regulator, tender committee, or counterparty. For a regulated business, the correct NACE code is not a formality but part of the legal security of its operations.

Want to check your business activity codes in advance? Contact the corporate lawyers at Pravova Dopomoga: submit an online request through the website or call the free hotline.