A stamped permit document and a border gate opening for a worker entering Ukraine

Work permits and residence for foreign staff in Ukraine: what actually applies in 2026

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Rules checked on 22 September 2026. Amounts follow the minimum wage of UAH 8,647 and the subsistence minimum for able-bodied persons of UAH 3,328, both set for 2026 by the State Budget Law, Articles 7 and 8.

If you are sending a manager, an engineer or a founder to work in Ukraine, two separate documents decide whether they may be there and whether they may work: a work permit, issued to the employer by the regional employment centre where the business is located, and a temporary residence permit, issued to the person by the State Migration Service. Neither substitutes for the other, and they are applied for in a fixed order.

The permit regime was rewritten in September 2022 and amended again in 2023 and 2024. Guidance written before that rewrite — and a good deal written since — describes a regime that no longer exists. Three points where it has gone stale are set out in section 3.

1. Who needs a permit — and who does not

The rule is in Article 42 of Law No. 5067-VI: an employer may engage a foreigner only on the basis of a permit, and each employer needs its own permit if the person works for more than one. A second post with the same employer needs no separate permit, provided the contract for it does not outlast the main permit.

Part 6 of the same article lists who may be employed without any permit. The ones that matter to foreign-owned businesses:

  • foreigners with permanent residence in Ukraine;
  • people with refugee status, an immigration permit, subsidiary protection or temporary protection;
  • employees of a branch or representative office of a company formed under the law of a foreign state — added by Law No. 3257-IX of 14 July 2023;
  • foreign media staff accredited in Ukraine; professional athletes and performing artists; clergy invited by registered religious organisations; staff on registered international technical assistance projects; teaching and research staff invited by Ukrainian universities.

The third bullet is the one to notice. If your Ukrainian presence is a representative office rather than a subsidiary, its foreign staff need no work permit at all. That is a real difference in cost and lead time between the two structures, and it sits alongside the other differences we set out in your first employees in Ukraine.

One category is handled elsewhere: highly qualified specialists whose skills are needed by the national economy come in under the Law on Immigration rather than the permit regime (Article 42, part 7).

2. The categories, and how long a permit lasts

Category Maximum term
Ordinary foreign employees and gig workers 2 years
Seconded foreign workers (under a contract between a Ukrainian and a foreign business) 3 years, limited by the contract
Intra-corporate transferees 3 years, limited by the transfer decision and the contract
Students at Ukrainian universities working during their studies 1 year, within the study period
Asylum seekers and applicants for stateless status 1 year, tied to the certificate

Permits are extended rather than reissued, and the employer may ask for a shorter term than the maximum but not a shorter term than the one stated in its own application (Article 42-3).

Note that gig contracts are inside this system. A Diia City resident engaging a foreign gig specialist needs a permit exactly as an employer does.

3. Three things most guides still get wrong

There is no longer a minimum salary for a work permit. Guides written before autumn 2022 — and many written since — state that a foreign employee must be paid at least ten minimum wages, or five for certain categories. Law No. 2623-IX of 21 September 2022 rewrote Articles 42-1 to 42-10, and the salary thresholds went with it. We searched the consolidated text: the phrase does not appear anywhere in the law. Pay what the role is worth.

The standard term is two years, not one. The old regime issued most permits for a year. Article 42-3 now gives ordinary foreign employees up to two years, and seconded staff and intra-corporate transferees up to three.

The fee is calculated on the subsistence minimum, and it scales with the term. Older sources quote a flat figure in minimum wages. Article 42-4 sets it in subsistence minimums for able-bodied persons, fixed at 1 January of the year the application is filed:

Permit term Multiple Fee in 2026
Up to 6 months 3 × subsistence minimum UAH 9,984
6 months to 1 year 5 × UAH 16,640
1 to 2 years 8 × UAH 26,624
2 to 3 years 10 × UAH 33,280

The Kirovohrad Regional State Administration publishes the same figure for a one-year permit in 2026 — UAH 16,640 — which matches the arithmetic above.

4. The procedure, and the deadlines that catch employers out

The employer files the application. The documents are listed in Article 42-2 and include a statement that the post is not one reserved for Ukrainian citizens and needs no security clearance, the passport pages with a certified Ukrainian translation, a photograph, and the draft employment contract or gig contract.

Decision times (Article 42-6), counted from registration of the application:

  • up to 7 working days for a new permit;
  • up to 3 working days for an extension or a change.

For citizens of the Russian Federation and Belarus — and of other states recognised as threatening Ukraine's sovereignty — the permit requires clearance from the regional office of the Security Service, and the clock runs until that clearance is given or refused (Article 42, part 1; Article 42-6).

The suspension loop. If the application is incomplete, the employment centre does not refuse it: by the next working day it decides to suspend consideration, publishes that decision and notifies you electronically (Article 42-8). You then have 7 working days to fix the objections for a new permit, or 3 for an extension or amendment, and the clock restarts when you file.

There is a trap in what follows, added by Law No. 4017-IX of 10 October 2024. If you do not accept every objection, you must file a reasoned letter explaining why you are rejecting the rest — and if the employment centre considers that letter unfounded, that by itself is a ground to refuse the permit (Article 42-9, part 1, item 1). Arguing with the objections is allowed, but it is not free: an argument the office rejects costs you the application.

Then two deadlines that are easy to miss (Article 42-7, part 4):

  1. The employment contract must be signed within 90 calendar days of the date the permit was issued.
  2. A certified copy must be filed within 10 days of signing.

Miss the first and the permit loses its basis. During the permit's life the employer must also apply to amend it when the company is renamed or reorganised, when the person gets a new passport or changes their name, or when the job title changes or they move to another post with the same employer (Article 42-5) — and to have it withdrawn when the contract ends (Article 42-10).

5. Residence: the D visa trap

A work permit does not let anyone into Ukraine, and it does not let them stay. The sequence is:

  1. A long-term (D) visa. Article 5-2 of Law No. 3773-VI requires a long-term visa in order to obtain a temporary residence permit, with narrow exceptions for asylum seekers and certain children.
  2. Entry, then the temporary residence permit from the State Migration Service. The grounds under Article 5, part 4 are the person's application, a valid medical insurance policy, the work permit — and the employer's or Diia City resident's undertaking to notify the migration service and the labour ministry if the contract ends early. Where the person is exempt from the work permit, the employment or gig contract is filed in its place.

This is where visa-free travel misleads people. A German, Polish or British citizen may enter Ukraine without a visa for a short stay. That does not help here: the residence permit still requires the D visa, which is obtained from a Ukrainian consulate before travelling. Arriving visa-free and then applying for a residence permit does not work for employment. The only in-country switch Article 4, part 4 allows is from study — a student already holding a temporary residence permit may obtain a work permit and stay on it (Article 4, parts 4 and 13).

Plan the consulate step first. It is the part of the timetable you control least.

6. Two questions every foreign employer asks

Are foreign employees subject to mobilisation? No. Article 1, part 6 of Law No. 2232-XII states that military duty does not extend to foreigners and stateless persons in Ukraine. They are not placed on military registration and cannot be mobilised, so the reservation procedure we describe for military reservation of key staff simply does not arise for them. Foreigners lawfully in Ukraine may serve voluntarily under contract, which is a decision of theirs, not of yours.

What does it cost to employ them? Exactly the same as a Ukrainian employee: 18% income tax and 5% military levy withheld, 22% social contribution on top. There is no separate rate for foreign staff. The figures and the worked examples are in our employer costs rate card.

7. The fines

Under Article 53, part 5 of the employment law, per person:

Breach Multiple Amount in 2026
Employing a foreigner without a permit 20 × minimum wage UAH 172,940
Employing on terms other than those in the permit, or by a different employer 10 × minimum wage UAH 86,470

The multiple is applied to the minimum wage in force when the breach is found, not when it was committed. Both are per person, so a small team employed on the wrong basis is a serious number. The second line is the quiet one: a permit issued for one job title does not cover a different job title, and a permit held by your subsidiary does not cover work done for your representative office.

8. A checklist

  1. Decide the structure first — a representative office employs foreign staff without permits; a subsidiary needs one per person.
  2. Check whether the person is already exempt: permanent residence, temporary protection, refugee status.
  3. For Russian or Belarusian citizens, plan for the Security Service clearance and an open-ended timetable.
  4. Apply for the permit; allow 7 working days plus the time to assemble certified translations — and budget for one suspension cycle if a document is queried.
  5. Apply for the D visa at a Ukrainian consulate before the person travels.
  6. Sign the contract within 90 days of the permit; file the copy within 10 days of signing.
  7. On arrival, apply for the temporary residence permit with medical insurance in place.
  8. Diarise the amendment duties: name changes, new passports, job-title changes — and withdrawal when the contract ends.

How ClarusApex can help

We run the whole sequence: whether a permit is needed at all, the application and its certified translations, the consulate step, the residence permit, and the amendment and withdrawal duties that follow. Where the role does not justify a permit and a relocation, we employ the person in Ukraine through APEX AV LLC instead. See Start up and stay compliant.

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