Inspections in Ukraine Regarding the Employment of Persons with Disabilities Who Is Being Targeted?

Масові перевірки в Україні працевлаштування осіб з інвалідністю Хто під прицілом?

Mass Inspections in Ukraine Regarding the Employment of Persons with Disabilities. Who Is Being Targeted?

Ukraine has intensified control over compliance with employment quotas for persons with disabilities. Inspections are conducted by the Social Protection Fund for Persons with Disabilities in cooperation with the Pension Fund of Ukraine (which provides monitoring data) and the State Labor Service of Ukraine.

Who is being inspected?

  • Enterprises, institutions, and organizations (regardless of ownership), including organizations of public associations of persons with disabilities;
  • Individual entrepreneurs who hire employees.

The exception applies to employers with fewer than 8 employees.

Employment quotas for persons with disabilities:

  • One job position — if the employer has between 8 and 25 employees;
  • 4% of the average headcount — if the number of employees exceeds 25 (i.e. 26 or more).

What are the fines?

The fine depends on the number of employees and is calculated for each unfilled position designated for a person with a disability:

  • For employers with 8 to 15 employees: 50% of the average annual salary at the respective enterprise, institution, or organization (including organizations of people with disabilities and individual entrepreneurs).
  • For employers with more than 15 employees: 100% of the average annual salary at the respective workplace for each position that was supposed to be filled by a person with a disability but was not.

Fines are not applied to institutions fully funded by state or local budgets.

In addition to economic sanctions against the enterprise, administrative liability may apply to company officials for failure to comply with the employment quota (Article 188-1 of the Code of Administrative Offenses of Ukraine).

Most common mistakes:

  • Hiring people with disabilities only part-time or as secondary employment;
  • Failing to meet the legally required employment quota;
  • Not taking into account individual needs of persons with disabilities when creating workplaces;
  • Failure to certify workplaces as required.

What should employers do?

  • Verify proper registration of employees with disabilities;
  • Check whether the employment quota is met;
  • Conduct workplace certification if necessary;
  • Regularly check your electronic account on the Pension Fund portal and ensure correct payroll reporting;
  • Seek legal consultation before or during an inspection.

What’s coming next?

The Ukrainian government is introducing new rules on employing persons with disabilities and holding employers accountable for failing to meet quotas. Starting in 2026, the system will become more flexible and aimed at fostering a genuinely inclusive labor market.

Key changes:

  • Employers who fail to meet the employment quota will have a choice: either create jobs for persons with disabilities or pay a special contribution to the Social Protection Fund. These funds will be used to create new jobs, upgrade workplaces, adapt infrastructure, and provide specialized training materials.
  • A targeted contribution system will replace traditional fines. The contribution will amount to 40% of the average monthly salary for each unfilled position.
  • The obligation to pay contributions will also apply to budgetary institutions, municipal enterprises, and local self-government bodies.
  • The quota calculation will now be quarterly, not annually.
  • The exemption remains for small employers (fewer than 8 employees) and some public institutions, but the range of obligated entities will expand significantly.
  • Funds from these contributions will be used transparently and specifically for initiatives that genuinely help people with disabilities get employed.

What does this mean for business and society?

The new approach is meant to encourage employers to create inclusive jobs, not just pay penalties. Every contribution will directly support the development of an accessible labor market and improve the quality of life for persons with disabilities. The updated rules will also simplify administration and reduce the risk of calculation errors.

Overall, the reform aims to transform employer responsibility from formal to meaningful, and to make support for persons with disabilities more effective and transparent.

WINNER” LAW FIRM
One of Ukraine’s leading firms in tax, criminal, administrative, commercial law, and litigation.
📞 Contact: +38 067-755-55-13
📽 Below: a video lecture “Tax Inspections: How to Act”
Presented by Maksym Bahniuk, Head of the Tax and Customs Practice at WINNER Law Firm

 

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