A checked stack of employment documents beside one document set aside

The HR documents a Ukrainian employer must actually hold — and the ones that are only habit

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Rules checked on 8 October 2026 (Labour Code and Law No. 2136-IX) and 22 September 2026 (Law on Remuneration of Labour and the statistics forms). The martial-law rules described here apply while martial law is in force.

Ask a Ukrainian HR manager what paperwork a company needs and you will get a long list: orders, cards, journals, schedules, instructions, staff tables, job descriptions, work books. Some of it is law. Some of it is habit carried over from older rules. A foreign owner setting up a subsidiary needs to know which is which — because the documents the law actually requires are the ones an inspector asks for first, and the rest is a choice.

This briefing sorts them. Where a document is required, it names the article. Where we could find no requirement, it says so.

1. Before the first working day: two hard preconditions

Article 24 of the Labour Code is blunt: an employee may not be admitted to work without

  1. an employment contract formalised by an order (наказ) of the employer; and
  2. a notification of the hiring to the tax authority — the body that administers the single social contribution — under the procedure set by the Cabinet of Ministers.

Both have to exist before the person starts. Not on day one, not at the end of the first week. Letting someone work before then breaches Article 24 — and the risk is that it is treated as undeclared work under Article 265, which fines the “actual admission of an employee to work without formalising the employment contract“: UAH 86,470 per person in 2026, three times that if repeated within two years, and a warning instead for employers on the single tax in groups 1 to 3. Whether a missing notification alone, with the contract and order in place, meets that wording is arguable; do not test it. The full fines table is in our employer costs rate card.

Is the contract itself in writing? In peacetime, “as a rule”, says Article 24, with writing mandatory only in listed cases — among them when the employee insists, remote and home-based work, contracts with non-fixed working hours, a контракт (the special form of employment contract under Article 21, available only where a law provides for it), employment by an individual, minors, domestic workers and work in high-risk areas.

Martial law loosens this further. Article 2 of Law No. 2136-IX provides that while martial law lasts, the parties agree the form of the employment contract between themselves. The same article lets the employer set a probation period for any category of employee, and conclude fixed-term contracts for the period of martial law or to replace a temporarily absent employee. Whether the general form rule also displaces the specific written-form requirements for remote work and non-fixed hours, the text does not say.

Our advice is simpler than either rule: always use a written contract. The order is what formalises the hiring, but a written contract is what proves the agreed pay, duties, working time and any probation or fixed term when anything is disputed — and under martial law, when the law no longer insists on writing, it is the only thing that does.

What the employee hands over. Under Article 24: a passport or other identity document; their work book if they have one, or their employment record from the state register of insured persons; and, where legislation requires them, a document on education or qualification, a health certificate and a military registration document.

One narrow exception, added by Law No. 4630-IX of 9 October 2025: enterprises recognised as critical for the defence-industrial sector may hire employees liable for military service whose military registration documents are missing or irregular, or who are not on the register, for the duration of a probation period of at most 45 calendar days — without that counting as a breach by the company’s officials (Law No. 2136-IX, Article 2(3)).

2. What you must tell the employee before they start

Article 29 lists nine things the employer must communicate before work begins, in a way agreed with the employee:

  1. the employer, the place of work, the job title with the list of job duties, and the start date;
  2. the workplace and the equipment provided;
  3. rights, duties and working conditions;
  4. dangerous and harmful factors not yet eliminated at the workplace, their possible effects on health, and the right to benefits for working in such conditions — under signature;
  5. the internal labour rules or the working regime, working and rest time, and the collective agreement if there is one;
  6. occupational safety, sanitation and fire-safety briefing;
  7. professional training, if any is provided;
  8. annual leave, and the conditions and amount of pay;
  9. the notice periods for ending the contract that both sides must respect.

For a remote-work contract, the employer covers items 1, 3, 5 and 7–9, and where needed also provides the equipment and means for the work, with recommendations on using them. The information can take the form of a remote briefing or training in safe working methods on the specific equipment, and the contract may add safety conditions by agreement.

This is why a well-run Ukrainian employer gives every new hire an onboarding acknowledgement: one document listing the nine items, signed by the employee. Item 4 must be signed in any case; signing the rest costs nothing and is the evidence you will want later.

It can be electronic. The last paragraph of Article 29 allows employees to be acquainted with the employer’s orders, notices and other documents on their rights and duties through electronic communication channels named in the employment contract, with an advanced or qualified electronic signature. The contract may also agree other ways of acquainting the employee — except for the item-4 information on hazards, which must follow the procedure in Article 29 itself. So: name the channel in the contract, and use a proper electronic signature rather than a click or an email reply.

Job descriptions sit here too. Item 1 requires the employee to be told the list of their duties. We found no provision requiring a standalone “job description” document, but it is the natural way to do it — and a contract that says only “manager” is not.

3. The rules of the house

Internal labour regulations (правила внутрішнього трудового розпорядку) are a statutory document. Article 142 says the working order of an enterprise is determined by them, approved by the labour collective on the submission of the employer and the elected trade-union body, on the basis of model rules. They may include conduct rules, including confidentiality obligations. Working hours, breaks, the five- or six-day week and the start and end of the day normally live here — which matters under martial law, when the employer may set several of these alone (see power cuts, air raids and working time).

The collective agreement is different in kind. Article 11 says one “is concluded” at enterprises, institutions and organisations, and with individuals who employ staff — but Article 12 makes clear it is an agreement between two sides. On the employees’ side stand the primary trade-union organisations, or, where there are none, representatives freely elected by the employees for collective bargaining. So it is not a document an employer can produce on its own. In practice many small foreign subsidiaries with no union have none; if the staff elect representatives and bargaining begins, it is a real process with real content — pay systems, working regime, guarantees, safety, equality (Article 13).

4. Time and pay records

The time record is required in substance. Article 30(2) of the Law on Remuneration of Labour obliges the employer to ensure reliable accounting of the work performed by each employee and accounting of payroll costs. There is no statutory document called a “timesheet”: Form П-5, approved by State Statistics Committee Order No. 489 of 5 December 2008, is recommended, not compulsory — the State Statistics Service confirmed this in clarification No. 9/4-10/9 of 12 January 2012. A payroll system, an attendance application or a controlled spreadsheet will do, provided the record is current, reliable and reconcilable to payroll.

A defensible monthly record, in practice, shows:

Item What to capture
Who and when Employer, department, month; each employee’s name and payroll number
Regime Five- or six-day week, shifts, flexible hours, remote work, part-time, summarised accounting
Plan The approved working calendar or shift schedule for the month
Each day Hours worked, or a coded absence: leave, sick leave, business trip, idle time, suspension, military-related absence
Premiums Overtime, night work and work on rest days, shown separately
Totals and sign-off Monthly totals, who prepared it, who approved it — and corrections that leave a trail rather than overwriting

Keep it current through the month and close it before payroll. A record reconstructed at year-end, or after an inspector arrives, is evidence against you rather than for you.

Pay statements. At every payment, the employer must tell the employee the total pay broken down by type of payment, the amount and basis of each deduction, and the net amount payable (Law on Remuneration, Article 30(1)). On dismissal, every amount accrued and paid must be set out in writing, item by item, on the day of payment (Labour Code, Article 116). And on request, the employer must issue a certificate of the employee’s work and pay (Article 49).

5. Leave

The leave schedule is mandatory. The order in which annual leave is taken is set by schedules approved by the employer in agreement with the elected trade-union body, and communicated to all employees (Article 79). The exact dates are then agreed with each employee within the schedule. A company with no union still needs the schedule. The article names only a trade-union counterpart for the agreement step, so the practical reading is that such a company approves the schedule itself — a reading, not something the article spells out.

6. Work books: mostly gone

Since 2021 a Ukrainian employee’s work history is kept electronically in the state register of insured persons (Article 48, as rewritten by Law No. 1217-IX). Paper work books survive only on request: a first-time employee may ask for one, and the employer must then issue it within five days; and the employer must make entries in a work book kept by the employee if the employee asks. The old routine of the employer holding every employee’s work book in a safe is gone.

7. Must, should, or habit

Document Status Source
Hiring order Required before work starts Labour Code, Art. 24
Notification of the hiring to the tax authority Required before work starts Labour Code, Art. 24
Written employment contract Peacetime: required in listed cases, “as a rule” otherwise. Martial law: form agreed by the parties. Use it always Labour Code, Art. 24; Law No. 2136-IX, Art. 2
Pre-start information, hazards under signature Required; may be acknowledged electronically through a channel named in the contract Labour Code, Art. 29
Internal labour regulations Required, on model rules Labour Code, Art. 142
Collective agreement Needs a workers’ side; cannot be made unilaterally Labour Code, Art. 11–13
Leave schedule Required Labour Code, Art. 79
Record of work performed and time used Required in substance Law on Remuneration, Art. 30(2)
Form П-5 timesheet Recommended, not compulsory State Statistics Committee Order No. 489; clarification No. 9/4-10/9
Itemised pay statement at each payment Required Law on Remuneration, Art. 30(1)
Itemised written statement on dismissal Required Labour Code, Art. 116
Paper work book Only at the employee’s request Labour Code, Art. 48
Job description Duties must be communicated; no requirement found for a standalone document, which is the usual vehicle Labour Code, Art. 29(1)
Staff schedule (штатний розпис) No requirement found in the Labour Code articles we checked; widely kept —

8. What martial law adds

Three more document families arrive with martial law, each covered in its own briefing:

9. A checklist for a new subsidiary

  1. Draft the internal labour regulations from the model rules and put them through the labour collective.
  2. Prepare an employment-contract template — naming the electronic channel for acknowledging documents, and covering probation and any martial-law fixed term — plus a hiring-order template and a nine-point onboarding acknowledgement.
  3. Set up the hiring notification to the tax authority so it is filed before each start date.
  4. Decide the time-record format, who keeps it, how corrections are made, and how it closes into payroll.
  5. Set up itemised pay statements for every payment and a dismissal settlement statement.
  6. Approve the leave schedule for the year and tell everyone.
  7. Set up military registration records, and pre-draft the remote-work and suspension orders you may need.
  8. Ask each new hire whether they want a paper work book — and record the answer.

How ClarusApex can help

For the people employed through APEX AV LLC, we hold all of this: contracts, orders, notifications, regulations, time records, pay statements and military registration. For companies setting up their own Ukrainian entity, we produce the starter set and check it against what an inspector asks for first. See Start up and stay compliant.

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