Four Years On: How Ukraine's Labour Laws Have Adapted To War

Marking the fourth year of Russia's full‑scale invasion, in this article, our Ukrainian firm traces how the country's labour laws have shifted from emergency fixes to a more stable framework, balancing business continuity with the protection of employees in wartime.

The fullscale war has been raging in Ukraine for several years, during which labour legislation has evolved in parallel. What began as emergency labour measures in 2022 has developed into a more predictable framework, shaped by the practical realities of operating under martial law. This article explains how the regulatory landscape has shifted over time in Ukraine, highlighting the key developments employers need to know.

How labour legislation has changed since 2022

In 2022, the legislature introduced several temporary and simplified mechanisms to help employers and employees adapt to extraordinary wartime realities. These measures included:

• suspension of employment agreements without wage payment;

• simplified procedures for termination and employee transfers;

• greater flexibility regarding the form of employment agreements; and

• adjustments to working conditions.

In the following years, lawmakers shifted their focus towards systematisation, clarification of procedures, and balancing employers' operational needs with the preservation of fundamental labour guarantees. As a result, the evolution of wartime labour regulation in Ukraine has followed two key directions:

• development and refinement of the mechanisms introduced in 2022; and

• new legislative responses to challenges arising from prolonged martial law.

Suspension of employment agreements: from emergency tool to regulated procedure

One of the most controversial measures introduced in 2022 was the suspension of employment agreements. Initially, this mechanism allowed employers to "freeze" employment relationships without paying wages, shifting the obligation to compensate to the aggressor state.

Since then, legislators have formalised and limited this tool. Key refinements include:

• a maximum suspension period of 90 calendar days, extendable by mutual agreement;

• obligations for both parties to maintain communication and notify each other of changes in contact details;

• a requirement that suspension is permissible only where both employer and employee are unable to fulfil their obligations under the employment agreement.

As a result, suspension has transitioned from a broad anticrisis mechanism to an exceptional measure governed by clear legal parameters.

Termination of employment: New special grounds during wartime

Legislation governing termination of employment has also been revised since 2022. In addition to earlier simplifications (such as allowing dismissal during holiday or temporary disability), new special grounds for termination have been introduced to reflect wartime realities. Employment may now be terminated in circumstances such as:

• conscription or mobilisation of an individual employer during a special period, where continuation of employment is objectively impossible;

• the death, judicial declaration of absence, or declaration of death of an individual employer or an employee;

• the employer's inability to provide work due to destruction of production facilities, means of production, or employer property as a result of hostilities.

Employees may also resign at their discretion without the standard twoweek notice period if military action in the employer's location poses a direct threat to their life or health.

These amendments provide legal clarity for situations that have become common in practice but were previously unregulated.

Form of employment agreement: strengthening digitalisation

The 2022 reforms allowed parties to determine the form of employment agreements independently, including through verbal agreements. Regulation in this area continues to evolve with a strong focus on digitalisation.

The Verkhovna Rada of Ukraine (Ukraine's parliament) has already adopted, in its first reading, a draft law enabling employment agreements to be concluded electronically via the "Diia" application. Under this proposal:

• an electronic employment agreement would be concluded using a qualified electronic signature;

• parties may agree on electronic personnel document management procedures;

• electronic documents must comply with requirements governing electronic identification and edocument standards.

This mechanism simplifies the formalisation of labour relations during martial law and supports employee mobility, remote work, and business relocation, while ensuring a sufficient level of legal certainty.

State supervision: limited, but preserved oversight functions

During martial law, most scheduled and unscheduled inspections by the State Labour Service have been temporarily suspended. However, several exceptions remain in place. Control measures may still be carried out in cases relating to:

• workplace mobbing (psychological pressure);

• the proper formalisation of labour relations;

• the legality of termination of employment agreements;

• compliance with special labour legislation governing employment under martial law.

Despite restrictions, the state retains a basic supervisory role, ensuring essential protection of employees' rights.

Tax burden: increase in the Military Tax

As part of broader wartime fiscal measures, the rate of military tax has increased from 1.5% to 5%. This adjustment directly supports national defence funding and reflects the wider economic impact of wartime labour relations.

Employment of persons with disabilities: renewed social priority

The war has significantly increased the number of persons with disabilities, prompting a review of the regulatory framework. The legislator is gradually shifting from a punitive system to one focused on support and incentives. Key developments include:

• introduction of a contribution to support employment of persons with disabilities as an alternative to fines for noncompliance with quotas;

• a requirement for employers to provide reasonable accommodations, such as specialised equipment, modified duties, flexible work schedules, or reduced hours;

• development of state standards for workplace equipment tailored to different disabilities;

• a shift in focus from formal quota compliance to practical workplace adaptation.

These measures aim to improve the effective integration of persons with disabilities into the labour market, even during wartime, while ensuring employers retain operational flexibility.

Takeaway for employers

Throughout the war, Ukraine's labour legislation has shifted from crisis-driven simplifications to a more structured, balanced, and legally clear framework. Lawmakers have:

• formalised procedures for suspension and termination of employment;

• advanced digital tools for managing labour relations;

• maintained minimum state oversight; and

• strengthened mechanisms supporting vulnerable groups, particularly persons with disabilities.

Together, these changes help ensure legal certainty and stability of labour relations in extraordinary circumstances.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.