Employers in Ukraine are now subject to a new quarterly reporting requirement concerning the employment of persons with disabilities. Although the underlying legislative changes took effect on 1 January 2026, delays in approving the reporting procedure mean that companies are only now submitting their first reports, including retrospective reports for the first three quarters of the year.
What are the new requirements?
Under Law No. 4219-IX, employers must meet a statutory employment quota for persons with disabilities:
- 8–25 employees: at least one employee with a disability.
- More than 25 employees: 4% of the average number of employees.
- Certain specialised organisations: a 2% quota.
Companies with fewer than eight employees are exempt from the employment quota and any related contribution. However, they should still submit the quarterly report, even if it contains no figures and no contribution is payable.
Employees count towards the quota only if they meet the statutory eligibility criteria, including being employed as their primary place of work and receiving a salary above the statutory minimum wage. Certain categories of employees with disabilities may count as two employees.
Why is reporting only happening now?
Although the legislation entered into force on 1 January 2026, the reporting procedure was delayed. The Ministry of Finance approved the reporting form in August 2026, and it only entered into force on 25 September. The reporting process became operational in October.
Consequently, employers must now submit reports retrospectively for Q1, Q2 and Q3 2026.
The transitional deadline for all three reports is 9 November 2026. Any applicable contribution must be paid by 19 November 2026. The State Tax Service has confirmed that penalties and late-payment interest will not apply to Q1 and Q2, provided the reports and any contributions are submitted and paid by the transitional deadlines.
What should companies do now?
All employers should review their employee and payroll data for the first three quarters of 2026, determine whether they meet the applicable employment quota, and calculate any contribution due. They should then prepare and submit the required reports, including empty reports where no contribution is applicable.
Going forward, the reporting requirement will form part of the regular quarterly compliance process.
How Leinonen can help
Leinonen Ukraine can assist companies in Ukraine with assessing their obligations, reviewing employee and payroll data, calculating any applicable contribution, and preparing and submitting the required reports. We can also incorporate the new requirement into our clients’ regular accounting and payroll compliance processes.
