Key changes

• Employment records regarding employees are entered electronically in the State Register of Mandatory State Social Insurance (“Register”), which is administered by the Pension Fund of Ukraine. The insurance period of employees, which determines their right to a pension and its amount, is calculated based on the data in the Register. If information on certain periods of employment is not included in the Register, this may adversely affect the employee’s right to a pension. 
• The Register contains a personal electronic card for each employee, which in recent years has been automatically updated when the employer pays pension insurance contributions (a part of the unified social tax). Employees can access their individual information contained in the Register by registering on the Pension Fund of Ukraine’s web portal.  
• For the period prior to 1 January 2004, this data is entered into the Register based on entries in the employee’s labor book.  
• Information about the employee’s work activity will be submitted by the employer, although the employee could also submit that information. We recommend that employers submit information on their employees’ work history reflected in their labor books to the Register to ensure that each employee’s electronic card is complete and to avoid possible disputes in the future.  
• Information on the employees’ work history should be submitted via the State Pension Fund of Ukraine’s web portal in the form of an .xml file. For the periods prior to 10 June 2021, the information should be submitted in one of the following ways: (i) in the form of a scanned copy of the labor book (or other documents provided for by law); or (ii) by creating an entry in the electronic cabinet on the Pension Fund’s web portal, attaching scans of the documents on whose basis the entry was created.
• Scanned copies of documents must meet the following requirements:
  • In color format and made from the originals.
  • Containing all pages with records in chronological order.
  • Readable, with visible series and number of the document.
  • Scanning resolution of 300 dpi.
  • In JPG format or PDF.
  • Not exceeding 1 MB in size.

Recommendations

According to the Law, data from employees’ labor books may be used to enter information into the Register only until 10 June 2026. As such, we recommend the following: (1) Inform the employees of the need to check the accuracy of their employment records in the Register; (2) Ensure that the employees’ labor books, containing all relevant entries, are scanned and uploaded to the Register by 10 June 2026; and (3) After scanning is completed, return the labor books to the employees against signed receipts.

We recommend reading the full text of the Law as the requirements are only briefly outlined above. Please seek advice if you have any questions or would like additional clarifications.

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Stanislav Muzhailo, Junior Associate, has contributed to this legal update.