Ukrainian state policy is actively reforming all spheres related to the accounting of hired labor. Traditional mechanisms for notifying tax authorities about the hiring or dismissal of employees have long remained a major pain point for businesses, accountants, and sole proprietors. Ongoing discussions among professionals, attempts to unify reporting, efforts to reduce bureaucratic pressure, and address informal employment have laid the groundwork for reforming the deadlines for submitting information about HR changes. These steps are especially relevant in light of the global transition of the economy to digital interaction and enhanced control over compliance with labor and tax law.
Legislative background and motivation for changes
On July 16, 2025, the Verkhovna Rada adopted Law No. 4536-IX “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine,” which enters into force on January 1, 2026. It updates subparagraph 70.16.1 of Article 70 of the Tax Code—a key norm for labor relations accounting. Starting in 2026, there will be clear differentiation of employers and new deadlines for submissions:
for legal entities, government bodies, and tax agents — notifications within 20 calendar days after the end of the reporting month;
for sole proprietors and self-employed persons — within 40 calendar days after the end of the quarter.
The main goal of the reform is to synchronize the work of business and state registers, ensure effective control of labor records, relieve administrative pressure on especially small and microbusinesses, and improve data analytics for the tax service.
Logic of new deadlines: why a differentiated approach
The distinction between employers is a matter of scope and specifics.
Legal entities often have significant staff turnover and complex structures, so they report monthly—20-day deadlines allow rapid response to changes and ensure continuous control.
Sole proprietors and self-employed generally work with stable or small teams, with many features like seasonality or temporary staff—quarterly reporting minimizes routine and reduces the risk of technical errors.
How the new procedure will work in practice
Legal entities (LLC, JSC, government bodies, tax agents): all HR actions in a calendar month—hiring, dismissing, or transfers—must be reported to the tax service within 20 calendar days after the month ends.
Sole proprietors, self-employed: submit information on staff changes within 40 calendar days after the quarter ends.
Forms and reporting procedures remain unchanged: the reform concerns only deadlines and automation in tax systems.
HR departments must adjust local control schedules, factoring in new dates when planning hiring or dismissals.
Impact for business and accounting
Risks and limitations
Penalties for missed deadlines: under the Tax Code, delays or concealing information are grounds for fines and administrative responsibility (from 510 to 1700 UAH, depending on the violation).
Transition and form updates: businesses need to adapt processes, update instructions, and train staff.
Quarterly reporting for sole proprietors: dismissals or new hires at the end of a quarter result in late reporting to the tax service, which can create legal issues during audits or disputes.
Implementation phases
The new deadlines apply from January 1, 2026. Until then, all employers work under the old scheme—20 calendar days after the month for everyone. The transition is used to update internal rules, instructions, and automate data processing.
Conclusion: balancing interests and digitalization challenges
Introducing new deadlines for hiring/dismissal notifications is a key step toward digital interaction between government and business. For large labor markets, this means greater transparency and effective employment control. For small businesses, it reduces bureaucracy and accidental fines. Success depends on software modernization and business readiness for new requirements.
Author: Ihor Yasko, Managing Partner of “WINNER” Law Firm, PhD in Law.
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