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Danylo Hetmantsev, head of the Parliamentary Committee on Finance, Tax and Customs Policy, has officially proposed increasing Ukraine’s minimum wage to 12,000 UAH in the state budget for 2026. Hetmantsev’s proposals include not only raising the minimum wage, but also setting the subsistence minimum at 4,700 UAH and comprehensively improving social standards and targeted support for specific categories of the population. Arguments and motivation for the proposalHetmantsev highlights that the current minimum wage in Ukraine — 8,000 UAH — has not changed since April 2024, and no revision is planned until the end of 2025. The government’s draft 2026 budget proposes 8,647 UAH, which, in his view, does not meet real social and economic needs. He insists: “the minimum wage should be no less than 12,000 UAH”, while the subsistence minimum should be based on real household expenses rather than “abstract or outdated norms”. Social standards in budget focusBeyond raising the minimum, Hetmantsev proposes key changes:– Subsistence minimum: 4,700 UAH (for working-age persons — 4,794 UAH, for pensioners — 3,786 UAH, for children — special increased rates).– Increasing social protection spending (+162 billion UAH): raising pensions (+70 billion), more support for low-income families and people with disabilities (+50 billion), developing social services (+6 billion), supporting family-based care and people with disabilities.– Boosting funding for state support programs for IDPs (+11 billion), including for housing, job placement, medical aid, and evacuation support. Impact on economy and businessThe minimum wage hike would have several effects:– Growth in the wage fund, strongly affecting the public sector, social sphere and small business.– Tax revenue growth, as increased wages will boost PIT and social security receipts.– Employer risks, including possible wage “shadowing”, labor shortages — especially in less automated sectors.– Rising domestic demand: more money means higher consumption, which boosts the economy. Parliament and expert discussionSome MPs support a sharp rise, seeing it as necessary amid inflation and rising costs, while others highlight risks for the budget and employers and call for phased growth. Additional attention is paid to challenges for small business, labor market competition and compensation mechanisms. Comparison with other initiativesAlongside Hetmantsev’s proposal, the Social Policy Committee proposes a minimum wage of 11,636 UAH and a subsistence minimum above 10,000. The difference in approach and growth rates is a subject for compromise between the government and business groups. Forecasts and outlookEven if implemented gradually, 2026 could see a record increase in social standards amid wartime and postwar economic challenges. Success will depend on real budget capacity, the shadow economy, inflation, and international support for Ukraine. ConclusionThe proposal to set the minimum wage at 12,000 UAH in 2026 is not only a financial and social move, but a political signal regarding national priorities. The current pace of change creates new opportunities for Ukraine’s development and improved living standards, but also new challenges for business, the budget, and society. The success of this initiative will depend on a balance between social guarantees, budget realities, and economic pragmatism. Author: Ihor Yasko, Managing Partner of “WINNER” Law Firm, PhD in Law. https://youtu.be/k2-1dq7hxcY?si=_MJPXm_zPGgoRbV5

How the criterion of insufficient labor resources worksInspectors analyze the company’s staff schedule, 1DF report data, and transparency of accounting and reporting for employees. If an enterprise employs only a director, an accountant, and a few people, while the documents show large production or trade operations, this may arouse suspicions of fictitious or unreal business. The main signs are: the number of staff does not match the declared scope of activity; lack of confirmation of engaging contractors, outsourcers, or services for performing work; non-compliance with industry standards (for example, in construction or production, there should be more employees than in an intermediary or IT company). What happens in the SMKOR systemThe payer automatically receives “risky” status.Almost all TI/AC submitted by a risky payer are blocked until the status is lifted.The data table that justifies the nomenclature and turnover is often disregarded—precisely due to insufficient labor resources.The reason for blocking is specified in the receipt: “insufficient number of labor resources required to carry out operations.” When TIs/ACs are blockedBlocking by this criterion occurs if all these conditions are met: TIs or ACs are submitted for large amounts for items requiring significant human resources (production, construction, agribusiness); company staff is not sufficient to actually perform such operations; no confirmation of outsourcing, specialized work, or involvement of other companies as contractors; no documents proving real operations—completion certificates, contracts with contractors, production reports, etc. How to avoid blocking tax invoicesPromptly update employee information in reporting forms (1DF, ESC), in company registers;In the data table (for TI), always specify the list of services, contractors, actual engagement of external labor resources;For complex operations (production, construction, service), provide additional documents—completion certificates, contracts, payment documents;Explain the actual workflow in responses to tax authority requests. Appeals and unblockingIf TIs/ACs are blocked because of insufficient labor resources: Submit explanations and copies of documents confirming real operations to the tax authority via the electronic cabinet; Attach certificates of employee engagement, contracts with external contractors, commercial proposals; If the data table is disregarded—you can appeal to the tax commission or go to an administrative court; Practice shows that proper documentation and explanations often lead to positive decisions, but the process may take time. New trends in 2025Since September 27, 2025, blocking criteria have been optimized, but insufficient labor resources remains one of the key reasons for assigning risky status.Already now, there is a trend toward mass blocking of TIs/ACs in manufacturing, construction, and agricultural companies with a “weak” staff;Risky status can only be removed by adjusting personnel policies, confirming actual operations, and continually submitting additional explanations to the tax authority. ConclusionInsufficient labor resources is a formal criterion for blocking tax invoices and adjustment calculations under SMKOR since 2025, which applies regardless of the scope of business activity or industry. To avoid problems, companies should ensure that staff matches operational volumes, document external resource engagements, and submit detailed explanations to the tax authority in advance. Confirmation of actual execution of operations is the basis for automatic TI/AC registration in the current risk system. Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”. https://youtu.be/rEd6me-Ume4?si=PHMtstR6iV7-ZkfK

Conducting business activities without state registration or obtaining the appropriate license is one of the most common and dangerous violations in Ukraine’s entrepreneurial sphere. The legislation—including the Code on Administrative Offenses (CAO), the Tax Code, and certain special laws—provides for severe administrative, financial, and sometimes even criminal liability, up to confiscation of income, equipment, and raw materials. Administrative liability Conducting business without registration as an individual entrepreneur or legal entity:Fine — from 1,000 to 2,000 non-taxable minimum incomes of citizens (UAH 17,000–34,000 in 2025).In addition to a fine, confiscation of produced goods, raw materials, means of production, and funds received from illegal activity may be applied—either with or without confiscation, at the discretion of the court. Repeat violations or significant income (over UAH 1.34 million):Fine increases to 2,000–5,000 NTMIC (UAH 34,000–85,000).Confiscation of goods, funds, and equipment becomes mandatory. Lack of tax registration or accounting:Separate fine — UAH 340 for lack of tax registration (Art. 117 TCU).Failure to keep or properly maintain record of income and expenses — UAH 51–136 (Art. 164-1 CAO). Liability for activities without a license Business activity without obtaining the required license:Fine — also from 1,000 to 2,000 NTMIC (UAH 17,000–34,000), with possible confiscation of product and earned funds.For specific activities—alcohol, financial services, security, transport, etc.—additional sanctions apply according to sectoral laws. Repeat violation, significant income, or serious consequences:Fine up to 5,000 NTMIC (UAH 85,000) and unconditional confiscation of profits, equipment, and materials. Special cases: civil and criminal liability Under civil law (Art. 49 of the Civil Code), state authorities or other parties may seek to have contracts made without a license or proper registration declared invalid and to recover all received funds.Criminal liability remains only for certain special sectors (for example, unauthorized medical practice—up to 3 years imprisonment, Art. 138 Criminal Code). Liability for income and unpaid taxes If an inspection reveals taxes unpaid on income derived from illegal activity, an additional penalty of 10% of the tax liability is charged (Art. 123 TCU).Lack of tax reporting — UAH 340 per violation (Art. 120 TCU). Court practice and trends Court practice leaves violators virtually no chance: even minor business activity (internet sales, provision of professional or intermediary services) without registration is recognized as “entrepreneurial” with all consequences.A prominent trend is stricter control over online service providers, video bloggers, marketplaces, and more.Self-employed individuals and freelancers who avoid registration risk the same fines as classic sole proprietors or legal entities. Practical implications and advice All contracts made by a person without state registration or license are considered null and any income is subject to confiscation to the state budget.Bank operations and associated e-wallets, cards, online services are subject to automatic financial monitoring and tax oversight.There is a risk of bank account blocking and ultimate seizure of assets for the state budget. Conclusions Conducting any business activity without state registration or the necessary license is a direct basis for fines from UAH 17,000 to 85,000 (in repeat or aggravating circumstances), along with confiscation of all income, goods, and equipment. Legislation leaves almost no loopholes: “grey activity” in any form is extremely risky and can cause devastating financial, reputational, and/or criminal consequences for individuals or companies. The only way forward is to do business openly, ensure registration, and obtain all required licenses before starting. Svitlana Krutorogova — attorney, Legal Company WINNER. https://youtu.be/rEd6me-Ume4?si=8FZ6r_uofeedgzrj

In 2025, the State Tax Service of Ukraine (STSU) received full access to automatic international exchange of tax information regarding the accounts of Ukrainian residents abroad. Thanks to the introduction of the CRS (Common Reporting Standard), Ukrainian tax officers will be able to annually receive reports from foreign financial institutions on fund movements, account balances, and the income of Ukrainians in over 110 jurisdictions worldwide, which radically changes the approach to oversight of foreign assets, combating tax evasion, and automating financial supervision. CRS: global financial transparencyCRS is a model for annual data exchange between the tax authorities of participating countries, developed by the OECD and implemented in Ukrainian law since 2023. From now on, Ukrainian banks, insurance, investment and other financial institutions automatically report on the accounts and operations of residents (individuals and legal entities) to the STSU; in return, Ukraine has the right to receive equivalent information from abroad. The first exchanges covered data on accounts with a balance of more than $1 million, both for individuals and companies. The second exchange (September 2025) extended to accounts over $250,000. Accounts with a lower balance, for now—under martial law—are not subject to taxation or financial control, although the information is collected and may be analyzed in the future. What information is transmittedUnder CRS, the STSU receives the following data: full name, identification code, date of birth, address of the account holder; account number, name of the financial institution; balance at the end of the year or at the date of account closure; all receipts and write-offs for the year, dividends, interest, capital gains, or other income; information about whether the account is owned by a company or by a nominee (trust, partnership). How and why the received information is used Verification of tax residency: the STSU checks the citizenship status of the owner, compares with declarations and official residence. Detection of undeclared income and tax evasion: if the account owner has not declared funds that qualify as income under Ukrainian law, the tax authority may additionally charge taxes, fines, and penalties. Control over foreign investments, assets, and business: corporate accounts, passive income accounts, e-wallets, foreign exchanges, and payment systems are becoming transparent for Ukrainian tax authorities. Consequences for Ukrainians abroadIf an account exceeds $250,000 and is not declared or taxes have not been paid, the STSU has the authority to assess additional tax obligations and fines (especially from 2026 when mass use of received data in audits is expected). Accounts with a lower balance are subject to a “tax silence” regime for now, but the data may be used in the future if martial law status or legislation changes. Transactions via e-wallets, international payment systems, and virtual accounts (PayPal, Revolut, etc.) are subject to analysis. Unified register of accounts and national control systemUkraine is developing a Unified State Register of bank accounts and safes for individuals and legal entities, which will be automatically integrated with international CRS reports. Financial agents submit information annually by July 1 to the STSU, and in September a report is sent to CRS—then the Ministry of Finance verifies and analyzes the data. Legal and tax risksOpening a foreign account or investing outside Ukraine must now be carefully justified and transparent to the tax authorities. “Forgotten” accounts, undeclared investments, or inherited sums may be grounds for additional tax charges and financial liability—up to criminal prosecution in cases of significant tax evasion. Practical adviceAll Ukrainian residents with a foreign bank account over $250,000 must ensure it is properly recorded in the asset and income declaration. Businesses should consider CRS when structuring their corporate finances and flows. It is best to consult tax/international experts in advance on tax residency, reporting, and optimize tax burden transparently. ConclusionsThe STSU now has a real international tool to control all financial accounts of Ukrainians abroad; from autumn 2025 this control will be comprehensive and systematic. CRS exchange with over 110 countries is a step toward global tax transparency that enables the detection of undeclared income, prevention of tax evasion, and optimization of fiscal policy. All Ukrainians should act transparently, as financial “shadows” are becoming increasingly visible to the tax authorities. Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”. https://youtu.be/rEd6me-Ume4?si=8FZ6r_uofeedgzrj

How the criterion of insufficient labor resources worksInspectors analyze the company’s staff schedule, 1DF report data, and transparency of accounting and reporting for employees. If an enterprise employs only a director, an accountant, and a few people, while the documents show large production or trade operations, this may arouse suspicions of fictitious or unreal business. The main signs are: the number of staff does not match the declared scope of activity; lack of confirmation of engaging contractors, outsourcers, or services for performing work; non-compliance with industry standards (for example, in construction or production, there should be more employees than in an intermediary or IT company). What happens in the SMKOR systemThe payer automatically receives “risky” status.Almost all TI/AC submitted by a risky payer are blocked until the status is lifted.The data table that justifies the nomenclature and turnover is often disregarded—precisely due to insufficient labor resources.The reason for blocking is specified in the receipt: “insufficient number of labor resources required to carry out operations.” When TIs/ACs are blockedBlocking by this criterion occurs if all these conditions are met: TIs or ACs are submitted for large amounts for items requiring significant human resources (production, construction, agribusiness); company staff is not sufficient to actually perform such operations; no confirmation of outsourcing, specialized work, or involvement of other companies as contractors; no documents proving real operations—completion certificates, contracts with contractors, production reports, etc. How to avoid blocking tax invoicesPromptly update employee information in reporting forms (1DF, ESC), in company registers;In the data table (for TI), always specify the list of services, contractors, actual engagement of external labor resources;For complex operations (production, construction, service), provide additional documents—completion certificates, contracts, payment documents;Explain the actual workflow in responses to tax authority requests. Appeals and unblockingIf TIs/ACs are blocked because of insufficient labor resources: Submit explanations and copies of documents confirming real operations to the tax authority via the electronic cabinet; Attach certificates of employee engagement, contracts with external contractors, commercial proposals; If the data table is disregarded—you can appeal to the tax commission or go to an administrative court; Practice shows that proper documentation and explanations often lead to positive decisions, but the process may take time. New trends in 2025Since September 27, 2025, blocking criteria have been optimized, but insufficient labor resources remains one of the key reasons for assigning risky status.Already now, there is a trend toward mass blocking of TIs/ACs in manufacturing, construction, and agricultural companies with a “weak” staff;Risky status can only be removed by adjusting personnel policies, confirming actual operations, and continually submitting additional explanations to the tax authority. ConclusionInsufficient labor resources is a formal criterion for blocking tax invoices and adjustment calculations under SMKOR since 2025, which applies regardless of the scope of business activity or industry. To avoid problems, companies should ensure that staff matches operational volumes, document external resource engagements, and submit detailed explanations to the tax authority in advance. Confirmation of actual execution of operations is the basis for automatic TI/AC registration in the current risk system. Author — Maksym Bahniuk, Head of Tax and Customs Law Practice at the Law Firm “WINNER”. https://youtu.be/rEd6me-Ume4?si=8FZ6r_uofeedgzrj

Starting in October 2025, Ukraine will launch automatic registration with Territorial Recruitment and Social Support Centers (TRSCs) for all male citizens aged 25-60 who have not previously been registered for military duty without legal grounds. The updated rules aim to reform state human resource management during wartime, digitalize bureaucratic procedures, and ensure transparent accountability for both citizens and employers. Goal of the reform and general principlesThe key idea is to digitize military registration, eliminate the need for TRSC visits for those not previously on the register, and identify all cases of evasion. The principle of electronic interaction between information systems is introduced, with registries automatically “matching” to identify individuals subject to mobilization registration. Data sources and registration mechanismImportantly, automatic registration is based on data already available in state registers, including: Unified State Demographic Register, Migration Service data, passports, identification codes; Voter register, taxpayer register, bank databases, the “Oberih” register, and any valid information on residence or actual place of stay. The mechanism works as follows: A person aged 25 or older not registered for military duty is automatically entered into the list through electronic processing of registry data; No personal visit to TRSC is needed; Data is integrated and cross-checked via the state electronic system “Trembita” and other departmental platforms; Conscripts may register remotely via the “Reserv+” app. Who is exempt from automatic registrationAutomatic registration does not apply to: those serving sentences or subject to compulsory medical measures; individuals with documented exemption from registration or deemed unfit for military service due to health; cases where basic personal data is missing for correct identification. Deregistration is also automaticDeregistration after reaching the cutoff age (60 for most categories) is also automatic based on registry data. Heads of government agencies, local self-government bodies, enterprises, and institutions must record such cases in personal record lists within 7 days of the last day of the month in which the employee reached the cutoff age. Role of employersLegal entities, sole proprietors, and HR departments must thoroughly update personal military service lists. Failure to do so is subject to fines under the Code of Administrative Offenses, and oversight responses are stricter for missed entries or lack of internal audits. Benefits for citizens No need to visit TRSC for anyone already in the state registers; confirmation of data — online only (through the “Reserv+” app or electronic military service cabinet); avoidance of queues and bureaucratic barriers, less human error in data entry and correction. Youth (conscripts aged 17–25) can still register either remotely or in person; no initial medical examination is required at the preliminary registration stage. Risks, challenges and practical nuancesThere are concerns regarding personal data protection and the possibility of contesting erroneous registrations—a matter for judicial and administrative practice. Only regular registry updates and interagency cooperation guarantee data accuracy. Citizens can check their registration status via the e-cabinet and apply for corrections if errors occur. A step towards electronic mobilizationMass automatic registration is the foundation for creating a single electronic registry of reservists (Oberih platform), reducing mobilization times during wartime, and enabling effective state human resource management. ConclusionAutomatic TRSC registration for Ukrainian men aged 25-60 is a shift towards fully digital, automated citizen–state interaction. Military obligations become transparent, evasion almost impossible. The reform eases social tension, complicates life for draft evaders, removes barriers for law-abiding citizens, and makes military registration part of e-Ukraine. Svitlana Krutorogova — attorney, Legal Company WINNER. https://youtu.be/k2-1dq7hxcY?si=WVENGeCVR7P-amhi

The liability of a tax agent for underreporting personal income tax (PIT) in Ukraine is among the strictest areas of financial and administrative control. A tax agent—be it an employer, entrepreneur, or other legal entity who accrues and pays income to individuals—must correctly calculate, withhold, and pay PIT as well as timely submit all reports. Main regulations and duties for a tax agentAccording to the Tax Code of Ukraine (Articles 167, 168, 176), tax agents are liable not only for miscalculation, but also for untimely payment and incorrect declaration of PIT. The State Tax Service, during an audit, analyzes documents, calculations, and reporting over three years (1095 days). Types of liability for underreporting PITFinancial liability – fines:10% of the tax amount—for typical underreporting when paying income.25%—for deliberate underreporting (proven by audit, where the agent intentionally concealed the basis or miscalculated).50%—for repeat violations within 1095 days (3 years).75%—a third or further violation within this period. Late payment interest (penalty):Accrued on the entire unpaid amount from the day after the payment deadline. The rate is 120% of the annual NBU key rate for each day of delay, including the day of payment fulfillment. Administrative liability (CUoAP):A warning or fine of 34–51 UAH (2–3 NMDG) for a first violation.51–85 UAH (3–5 NMDG) for a repeat violation during the year. Features of applicationAll fines are imposed solely on the tax agent; the income recipient is not held liable for the shortfall—except in cases defined by Section IV of the Tax Code (e.g., when income is received without a tax agent).If the agent independently detects an error and recalculates PIT in the current year—fines are not applied (Art. 169.4 TC).Additionally, the State Tax Service may initiate criminal proceedings for large sums or systematic evasion. Mechanisms for avoiding sanctionsContinuous audits of PIT calculations, use of modern accounting software;Self-correction of errors and submission of revised tax returns;Timely response to tax queries, proper documentation, and accurate payroll reporting. Impact on business and employeesFor companies—this means a risk of significant financial and reputational losses, as PIT non-payment often leads to tax audits and complicates business operations.For employees—guarantees of receiving ‘net’ salaries; the state does not hold them accountable if the agent is at fault.From the state’s perspective—strict policies to minimize abuse, with active control automation and sanctions. ConclusionsA tax agent’s liability for underreporting PIT covers a set of fines, penalties, and administrative sanctions ranging from 10% to 75% of the tax amount, plus interest for each day of delay. Independent correction of errors is the most effective way to avoid penalties. Consistent tax practices, use of electronic services, and adherence to established procedures are the key to business legal security. Author — Maksym Bahniuk, Head of Tax and Customs Law Practice, Law Firm “WINNER”. https://youtu.be/rEd6me-Ume4?si=8FZ6r_uofeedgzrj

Online trade has long been an important part of Ukrainian business, and for legal operation of an online store or provision of remote services, it is mandatory to register a cash register (RRO) or a software RRO (PRRO). Submission of applications using forms 1-RRO and 1-PRRO in 2025 is regulated by updated procedures and contains several specific nuances for internet traders. Legal grounds and list of documentsMain regulations: Law of Ukraine No. 265/95-VR, updated Ministry of Finance orders No. 547 and No. 317. The registration procedure consists of three stages: Submission of notice using form 20-OPP (“taxable object” — physical or online point); Submission of an application using form 1-RRO (classic cash register) or 1-PRRO (software/virtual register); Awaiting confirmation from the State Tax Service and receiving a registration certificate. How to properly fill out form 20-OPP for online trade Column 3 “Type of Object”:Select “Internet trade object”, “Trade point”, “Online store”, “Order pickup point”—depending on actual activity. Column 4 “Name”:Enter the commercial name under which the object will be registered in all tax registries (e.g., “webshop.ua”, “online order pickup warehouse”). Filling out forms 1-RRO and 1-PRROKey principle:The name of the business unit and the object identifier must fully match those indicated in the 20-OPP form. Format and content of applications: Section 1 “Action”:Select “Registration” for a new device. Section 2 “Subject Data”:For sole proprietors—automatic filling of personal details, taxpayer ID; for legal entities—organization data and tax identifier. Section 3 “Business Unit Data”:Enter the full name of the taxable object as in 20-OPP;Object identifier (cash register code) if any;Registration address—for an online store, the address of the warehouse, pickup point, or main office is allowed;The type of activity must necessarily include a remote trade feature (e.g., “online trading”, “distance sale of goods via website”). KOATUU/KATOTTG code:Fill in according to the directory—only KATOTTG is allowed (often the address of the physical point or head office). Line “type of software RRO”:For software solutions—select items relevant to online trading, servicing via website or mobile app. Commercial name and info placement tipsAvoid generic names like “store”—specify the actual activity (“online store”, “online order pickup point”, “online store warehouse”);Online stores can register a business unit at the location of the warehouse, head office or even the pickup point (physical address);If the workplace is a mobile pickup point or delivery, this can also be indicated as a business unit;Data must match the 20-OPP, otherwise registration will be denied. Modern PRRO advantages for online businessA software RRO is an ideal solution for remote trading because: It is not tied to a specific address but must be registered at a legal address or relevant object; All fiscal information is stored in a cloud service and electronic receipts are issued without a physical device; Mobile points or temporary trade sites are allowed. Common mistakes when filling out forms Discrepancies between the business unit name in 20-OPP and 1-RRO / 1-PRRO; The wrong type of object selected—such as “store” instead of “online store”; Lack of exact information about the object, warehouse, pickup point—violation of fiscal record rules; Incorrect address is listed for mobile trade or delivery points. Filing applications via the Electronic Cabinet Forms are available in the “RRO/PRRO Registration” section of the State Tax Service Electronic Cabinet; Automatic filling of core data, manual entry for object-specific data; The possibility to save and sign applications with an electronic signature; You can track the processing status directly in the cabinet. ConclusionsFilling out 1-RRO and 1-PRRO forms for online trade requires thorough preparation: careful selection of object type, accurate business unit naming, specifying the actual address, and verifying all fields with the 20-OPP data. These details are key for successful registration and lawful remote operation in 2025. Accurate application completion is a guarantee of avoiding fines and operation blocks. Author — Yulia Popadyn, attorney of the tax and customs law practice at WINNER Law Firm. https://youtu.be/rEd6me-Ume4?si=8FZ6r_uofeedgzrj

From October 1, 2025, Ukraine has significantly strengthened its tools for combating mobbing (workplace bullying) — the State Labour Service (SLS) officially receives the authority to conduct unscheduled inspections of employers specifically in relation to such cases. The new provisions are in effect during martial law, provide a detailed and transparent procedure for handling employee complaints, and establish a new practice of state control in work collectives.What is mobbing and why is this issue importantMobbing is systematic moral or psychological abuse, bullying, isolation, humiliation or other actions that create a tense and toxic atmosphere in the workplace and can lead to psycho-emotional exhaustion or even dismissal for the employee. The concept was first enshrined in law in 2022, but real mechanisms of protection were weak — government inspections remained blocked and operated only for certain violations. Key legislative changes from October 1, 2025 SLS’s right to unscheduled inspectionsFrom now on, SLS (and its territorial bodies) can initiate an unscheduled inspection of an enterprise upon application by an employee or trade union regarding mobbing. Such inspections are permitted under martial law and cover all forms of ownership, fields of activity, and also individual entrepreneurs employing staff. The only basis is an employee/trade union complaintSuch control can only start based on a written application of a specific employee or an official complaint from a trade union. The authority cannot act on its own or on anonymous reports. Mobbing can also be included in a general inspection if an employee reports it during a visit of SLS inspectors for other reasons. Separate from other inspectionsAn unscheduled mobbing inspection cannot be conducted in parallel with other checks (e.g., regarding informal employment or wages). This ensures a focused, professional approach and avoids superficial inspections. How inspections are conducted Inspectors analyze the complaint, interview employees and management, examine documents that may confirm or refute systematic bullying. The presence of orders, instructions, internal company policy on mobbing, and internal dispute resolution mechanisms are studied. Based on the results, an act is drawn up, which may serve as a basis for administrative or disciplinary liability of management or the guilty persons. Courts clearly distinguish between lawful employer requirements and mobbing: demands related to the fulfillment of work functions or production standards are not recognized as mobbing. Employee protection mechanismSLS has created a special online service for submitting mobbing complaints: employees can confidentially file a report, provide explanations, and attach evidence (audio, video, witness statements). The organization will be required to consider the complaint internally if pretrial procedures have not been conducted.If bullying is confirmed, SLS has the right to go to court, and inspectors can draw up reports that will be considered under administrative procedures. If there is harm to health, a promising line of criminal liability is also available.Administrative and disciplinary liabilityEstablishing the fact of mobbing is the basis for fines and other employer sanctions. Fines may reach several minimum wages; reinstatement of an employee subjected to bullying may be ordered, or even dismissal of the perpetrators with a “black mark” in the State Register of labor rights violators. Significance of the new rules for employees and businessFor employees: Provides direct and effective protection from psychological pressure, humiliation, or “systemic harassment.” Clear complaint submission algorithm and confidential review encourage not hiding collective problems. An employee can be reinstated or seek compensation for damages through court.For employers: Need to review personnel policies, implement clear complaint response rules, provide communications ethics training. Increased accountability for management and HR, higher demand for preventive communication training. Risk of reputation and financial loss if mobbing is ignored or treated formally. Outlook for the labor market and legal practice     The launch of full inspections on mobbing issues will help build a healthier labor market, reduce burnout risk, stress disorders and unforeseen dismissals. Judicial rulings will define boundaries of permissible behavior, set precedents, and foster a culture of zero tolerance for psychological abuse at work.     From October 1, 2025, Ukrainian employees and businesses have received a powerful new tool — guarantees of dignity protection in the workplace and a concrete response algorithm to mobbing. This is a step toward a mature European model of labor relations and corporate responsibility. Author — Yulia Popadyn, attorney of the tax and customs law practice at WINNER Law Firm. https://youtu.be/k2-1dq7hxcY?si=WVENGeCVR7P-amhi

In September 2025, the government submitted the draft state budget for 2026 to the Verkhovna Rada. In addition to purely financial indicators – revenue, expenditure, deficit, and macroeconomic projections – the document contains accompanying legislative initiatives. Among them, lawyers, notaries, and the real estate sector paid special attention to the proposal to temporarily suspend certain provisions of the Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine Concerning Protection of Bona Fide Acquirers’ Property Rights”. This law, adopted in 2023 in response to numerous conflicts around double property sales, restitution lawsuits, and widespread fraud in state registration, introduced mechanisms to ensure stability in civil turnover. Its main purpose is to protect bona fide acquirers from losing property in cases where previous transactions are invalidated, and the risk would otherwise be transferred to the acquirer by law. Essence of the Government InitiativeThe draft budget for 2026 proposes temporarily suspending a number of provisions of this law. According to the government, it is not a full repeal but a deferred application – for the duration of martial law and one year after its completion. The rules proposed for suspension include: Provisions preventing recovery of property from bona fide acquirers, even when the seller lacked the legal right to dispose; Norms restricting prosecutors’ and state agencies’ powers in cases of illegal alienation of state and communal property; Mechanisms for compensation at the expense of the state or local community, if the property cannot be returned to the previous owner. In practice, this prioritizes public interests and restoration of legal owners’ rights over the stability of private property turnover. Government MotivationThe formal reason for this step is the challenging economic situation and the need to protect state and communal assets from illegal alienation. According to government structures, during wartime there has been a surge in grabbing state and communal property through forged court decisions or illegal actions by registrars. In many cases, such assets ended up with third parties who considered themselves bona fide acquirers. The government believes that absolute protection of acquirers blocks the possibility for the state to recover illegally alienated land, buildings, and other assets. This negatively impacts both budget indicators and the balance of state property. Thus, the proposed solution is presented as temporary, aimed at minimizing losses during the war and the subsequent transitional period. Risks for the Private SectorFrom a legal perspective, the initiative risks returning the real estate market to the uncertainty that existed before the “bona fide acquirer” law. Key risks include: Lack of confidence in transaction security. Real estate buyers again face the risk of losing ownership rights if the seller’s transaction is considered invalid. Growth in litigation. Suspension of the law will encourage state bodies to more widely use restitution, inevitably increasing court cases. Declining investment appeal. Domestic and foreign investors are unlikely to invest in assets if legal guarantees are unstable in wartime. Persistence of corrupt practices. Lack of finality in bona fide acquirer protection opens doors for abuse during registration and court challenges. Professional Community PositionNotaries, lawyers, and developers have expressed concern. Professionals note that introducing temporary restrictions undermines a key civil principle – ownership stability. At the same time, some jurists acknowledge that amid mass encroachments on state assets, the government must balance private and public interests. There are also proposals for compromise, for example: Special checks on state and municipal property transactions during martial law; State insurance for purchase and sale transactions in case of subsequent restitution; A clear list of property categories subject to suspension, rather than applying this to the entire market. Constitutional AspectRights advocates point to possible constitutional violations, as Article 41 directly guarantees private property. Although the Constitutional Court has recognized the state’s ability to restrict rights in wartime, proportionality and temporary nature must be precisely regulated. Having such provisions in the budget law could be grounds for constitutional appeal. Outlook in the Verkhovna RadaSupport for the initiative is likely, given the traditional package voting logic of the budget process. However, discussions in relevant committees will be a platform for intensive debate, and the risk of amendments from pro-business or developer groups remains. ConclusionThe government’s attempt to temporarily suspend some guarantees for bona fide acquirers via the budget reflects the current state of Ukrainian legal policy: a shift from private ownership protection toward public interest in wartime. This initiative carries systemic risks for the economy, real estate market, and legal certainty. Parliament faces a tough choice: to guarantee acquirer protection at the expense of state recovery mechanisms, or emphasize public interest while undermining private sector confidence in the law. The way this transitional issue is resolved in 2026 will impact both individual cases and overall trust in the Ukrainian legal system. Svitlana Krutorogova — Attorney, “WINNER” Law Firm. https://youtu.be/k2-1dq7hxcY?si=WVENGeCVR7P-amhi