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Labour inspections in Ukraine under martial law: triggers, the visit and the fines

ByMarina

Rules checked on 22 September 2026. The special regime described here applies while martial law is in force; practice examples are dated.

Two authorities check whether employers in Ukraine keep to labour law. The State Labour Service and its regional offices inspect employers (Labour Code, Article 259). The tax service checks the registration of employees as part of its tax control, and a tax audit report that finds labour-law breaches is one of the documents on which the State Labour Service can impose a fine. In some cities a municipal labour inspectorate also contacts employers — the Dnipro example is in section 3.

1. Two procedures, and what martial law changes

Inspections on undeclared work are carried out as inspection visits under Cabinet Resolution No. 823. All other labour inspections follow Law No. 877-V on state supervision (Resolution No. 823, points 1 and 2). The two procedures differ — see section 4.

Under martial law, Article 16 of Law No. 2136-IX allows the State Labour Service only unscheduled inspections, on application by an employee or a trade union, and only on:

  • compliance with Law No. 2136-IX itself — for example suspended employment contracts and the martial-law rules on working time and leave;
  • undeclared work;
  • mobbing (workplace bullying) — an inspection on mobbing cannot be combined with any other subject;
  • whether terminations of employment were lawful.

An unscheduled inspection needs one of these grounds: a complaint by a person whose rights were harmed, approved by the central office of the State Labour Service; an accident, fire, death of an injured person or occupational disease connected with the employer; a court decision; an appeal by local-government officials where a law allows it; a request from the Kyiv City or a regional military administration; or failure to comply with an inspector's order issued after 1 May 2022. The law expressly also covers the staff of representative offices of foreign companies.

Article 16 says these inspections follow the procedure of Law No. 877-V, while Resolution No. 823 keeps its own procedure for undeclared work. The texts do not say which one governs an undeclared-work visit under martial law — so prepare for the stricter one, the inspection visit, which comes without notice.

Two more points on the legal basis: the general wartime halt of state inspections, Cabinet Resolution No. 303, contains no rule on labour inspections. And Resolution No. 823 was challenged in court in 2021 (case No. 640/17424/19); the official database lists it as in force.

2. What triggers an inspection

Trigger Who acts Legal basis Under martial law
Complaint by an employee, a former employee or a trade union State Labour Service Law No. 2136-IX, Art. 16; Resolution No. 823, point 5 The main route
Pension Fund data: employees without a hiring notice; part-time staff up 20% or more in a month; people on civil-law contracts with the same employer for more than a year; 30% or more of people on civil-law contracts; job cuts of 10% or more in a month at employers with 20 or more staff State Labour Service Resolution No. 823, point 5(6) Not among the Article 16 grounds; used in 2026 for information letters (section 3)
Tax service data: headcount out of line with output compared with the average for the type of activity; labour breaches found in its own work; business without registration State Labour Service Resolution No. 823, point 5(6) As above
Information on undeclared work or on salaries paid without taxes Tax service — actual inspection (фактична перевірка) of employment contracts, time records and pay Tax Code, 80.2.7 and 80.6 Carried out — see section 3
Liquidation or reorganisation (except conversion), closing a representative office or branch, bankruptcy, deregistration Tax service — unscheduled documentary audit of all taxes, including payroll taxes Tax Code, 78.1.7 Applies
An earlier order not complied with State Labour Service Law No. 2136-IX, Art. 16; Resolution No. 823, point 5(11) Applies
Accident, fire, death of an injured person, occupational disease State Labour Service Law No. 2136-IX, Art. 16 Applies
Checks of military registration at employers Military recruitment centres, with the regional State Labour Service offices and the tax service taking part within their powers Cabinet Resolution No. 892 of 16 July 2025 Applies

The scenarios foreign employers ask about:

  • Company closure. Liquidation, reorganisation or closing a representative office triggers an unscheduled documentary tax audit (Tax Code 78.1.7). It is a tax audit, not a labour inspection — but labour breaches found in it can lead to a fine from the State Labour Service.
  • Moving the registered address. We found no rule that makes a move a trigger. The practical risk is the opposite: if an inspector finds nobody at the address in the state register, they record that the visit could not take place (Resolution No. 823, point 14), and that record is a basis for a fine. Keep the register current and someone reachable there.
  • Changing the type of activity. Not a trigger in itself. It matters indirectly, because the tax service compares a company's headcount with the average for its type of activity.
  • Part-time employees paid below the minimum wage. Part-time work paid pro rata is lawful. But a jump in part-time staff is one of the Pension Fund flags; registering someone part-time who in fact works full time counts as undeclared work (Labour Code, Article 265); and for an employee's main job the social contribution is still due on at least the minimum wage (Law No. 2464-VI, Article 8(5)).

3. Practice in the regions, 2025–2026

The State Labour Service has not published national inspection statistics for 2025–2026 that we could find, and practice differs between regions:

  • Tax service, nationwide. In the first half of 2026 the tax service carried out more than 15,000 actual inspections of all kinds and found more than 1,600 undeclared workers, using a risk-based approach (Interfax-Ukraine, 10 July 2026, quoting the tax service). By August 2025, professional media reported almost UAH 21 million in fines imposed that year for undeclared work (prokadry.com.ua).
  • Dnipro — data-driven letters. In May 2026 the city council's labour inspectorate sent information letters to employers whose part-time headcount had risen by 20% or more in January 2026, based on Pension Fund data. The inspectorate stressed that this is not in itself a breach, but asked employers to check their records (Debet-Kredit, 27 May 2026).
  • Kyiv — joint preventive checks. In September 2026 the city police and the State Labour Service announced joint measures against labour exploitation (PB News, 17 September 2026).
  • Ivano-Frankivsk — awareness and tax checks. The State Labour Service runs the information campaign «Виходь на світло!» (“Step into the light”) (dsp.gov.ua); the regional tax office reported more than a hundred undeclared workers found in the first half of 2026 (MEGA).
  • Kharkiv — support in a frontline region. The regional office presents its work as support for business and for keeping jobs (dsp.gov.ua).
  • Cherkasy. The regional office's site shows seminars, consultations and guidance on mobbing (ck.dsp.gov.ua); we found no published inspection figures for the region.
  • Military registration. Since July 2025 the regional State Labour Service offices and the tax service may take part in checks of employers' military registration (Resolution No. 892). Professional media describe these as joint checks (Debet-Kredit).

Are companies with military reservation or Diia City status a special focus? We found no official statement or report that makes either a special target of labour inspections. Both are checked through other channels:

  • Critical status for military reservation is monitored by the Ministry of Economy using tax-service data, and a company that no longer meets the criteria loses the status and with it all reservations (Kadroland). The salary figures that matter for reservation are the same payroll figures the tax service sees.
  • Diia City residents report on their compliance every year, with an independent opinion, to the Ministry of Digital Transformation (Diia). Law No. 877-V protects residents from unscheduled inspections without the central office's written approval — but that protection is written into Law No. 877-V, and undeclared-work visits under Resolution No. 823 are not governed by it. Do not rely on it for those.

4. The visit: two procedures

Inspection visit on undeclared work (Resolution No. 823) Other labour inspections (Law No. 877-V)
Notice None — the inspector may come at any hour —
What the inspector shows at the start Service ID; a copy of the inspection order is handed over before you sign the act The inspection certificate issued on an order, the service ID, a copy of the certificate — and, for a complaint, a copy of the central office's approval
When you may refuse access Only if there is no service ID, or if the standard act form is not published on the State Labour Service website If those documents are not shown
Scope The questions in the published standard act form Only the questions named in the certificate
Maximum length 10 working days 10 working days; 2 for a small business; no extension
Your objections In the act, and in writing within three working days after signing; the inspector answers within three working days In the act
The order to fix breaches The next working day after the act, or after the objections are answered Within five working days after the inspection
Appeal against the order Within ten days to the head of the regional office, then to the head of the State Labour Service; the appeal suspends the order; decided within 30 days —

During an inspection visit the inspector may interview managers and staff alone, ask for any records that labour law requires, take copies, and record the visit on audio, photo or video. Their written requests for documents and access are binding. They may not reveal who complained or even that the visit follows a complaint, take away original documents or computers, or check a question that is before a court. You may record the visit too, ask for advice on compliance, and require trade secrets to be kept confidential.

Obstruction is expensive. Refusing access, not providing information on the inspector's written request, being absent from the registered address or not having the records labour law requires leads to an act recording that the visit could not take place (Resolution No. 823, point 14). The fine for refusing or obstructing an inspection is three times the minimum wage — UAH 25,941 in 2026 — and sixteen times, UAH 138,352, when the inspection concerns undeclared work.

5. After the inspection: the act, the order and the fine

The act is signed on the last day in two copies; if you disagree, sign with objections. The order (припис) sets a deadline for fixing the breaches and carries no sanction itself; the fine is a separate decision.

Does meeting the deadline avoid the fine? Under martial law, Law No. 2136-IX says that if an order is carried out in full and on time, the fines under Article 265 of the Labour Code do not apply. The Labour Code itself is narrower: meeting the deadline avoids liability for late or short pay, the minimum pay guarantees, the guarantees for employees in military service and “other” breaches, but not for undeclared work, repeat undeclared work, obstruction or breaches of the rules on contracts with non-fixed working hours. Resolution No. 823 adds that measures for undeclared work are taken together with the order, whether or not the breach has been fixed. Plan on a fine for undeclared work and obstruction even if you comply.

How a fine is imposed (Cabinet Resolution No. 509): by the head of the State Labour Service, a deputy, or the head of a regional office or their deputy, on the basis of an inspection act, an act recording that an inspection could not take place, a court decision on undeclared work or a tax audit report. The case is considered within 45 days of the documents arriving; you are told within five days of that date and receive the decision within three days of it being made. The fine is due within one month; paying 50% within ten banking days of receiving the decision settles it (Labour Code, Article 265). The decision can be challenged in court; an unpaid fine is collected by the state enforcement service.

6. The fines in 2026

Fines under Article 265 of the Labour Code are multiples of the minimum wage in force when the breach is found. At the 2026 minimum wage of UAH 8,647 (State Budget Law 2026):

Breach Multiple Amount in 2026
Undeclared work: no employment contract, part-time registration for full-time work, or pay without taxes and the social contribution 10 × per employee UAH 86,470
The same, repeated within two years 30 × per employee UAH 259,410
Salary or other payments more than a month late, or paid short 3 × UAH 25,941
Minimum pay guarantees not met 2 × per employee UAH 17,294
Guarantees for employees called up for military service or mobilisation duties not met 4 × per employee UAH 34,588
Refusing or obstructing an inspection 3 × UAH 25,941
Refusing or obstructing an inspection on undeclared work 16 × UAH 138,352
Too many contracts with non-fixed working hours, or false time records for them 3 × per employee UAH 25,941
Other breaches of labour law 1 × per breach UAH 8,647
Other breaches, repeated within a year 2 × per breach UAH 17,294

Employers paying the single tax in groups 1 to 3 receive a warning instead of a fine for a first case of undeclared work and for breaches of the guarantees for employees in military service.

7. What to have in order

  1. Employment contracts and hiring notices — every employee on a registered contract, with the tax authority notified before the first working day; no one registered part-time who works full time. The rules are in our briefing on how payroll works in Ukraine.
  2. Pay — two paydays a month, no delays of more than a month, pay at or above the minimum wage for full-time work.
  3. Time records, above all for part-time staff and for anyone on a contract with non-fixed working hours.
  4. Civil-law contractors — review anyone engaged for more than a year, and your share of contractors against employees.
  5. Dismissals and suspended contracts — the legal ground and the documents for each termination, and the time limits for suspensions; see our briefing on employing people under martial law.
  6. Military registration records and the guarantees for employees called up.
  7. The registered address — current in the state register, with someone there who can receive an inspector.
  8. One person in charge of inspections: they check the service ID, keep copies, stay present, write objections into the act, and diarise the three-day objection window, the order's deadline and the ten-day appeal window.

If a fine is imposed, decide within ten banking days whether to pay 50% or to challenge it in court.

Sources

Law, all checked on 22 September 2026:

Practice (dated reports):

How ClarusApex can help

We run a confidential compliance check before an inspector does — contracts, time records, part-time and contractor arrangements, military registration — and help after an inspection: reading the act, writing objections within three working days, meeting the order's deadline, and deciding whether to pay 50% of a fine or challenge it. See Start up and stay compliant.

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