Most employers in Ukraine are obligated to comply with the quota for employment of persons with disabilities. Failure to meet the quota can result in administrative and economic sanctions. However, as of January 1, 2026, the framework will change: the quota will remain in force, but sanctions will be replaced with mandatory contributions payable by employers. In addition, there will be mandatory reporting on compliance with the quota.

Changes related to the implementation of the employment quota

The changes are prescribed by the Law of Ukraine dated January 15, 2025 No. 4219-IX “On Amendments to Certain Legislative Acts of Ukraine to Ensure the Right of Persons with Disabilities to Work” (hereinafter – Law No. 4219), which provides for amendments to the Law of Ukraine dated 21 March 1991 No. 875-XII ‘On the Fundamentals of Social Protection of Persons with Disabilities in Ukraine’.

The Law No. 875 will set out new rules for compliance with the quota, payment of contributions for non-compliance, etc. Starting from 01.01.2026.

Until the end of 2025, employers are required to comply with the quota under the existing rules established by Law No. 875.

Quarterly calculation and reporting

Instead of an annual calculation, employers will be required to calculate the quota for employment of  persons with disabilities on a quarterly basis. Reporting on compliance with the quota will also be submitted quarterly as part of tax filings.

New job quota

• 1 job position — for employers with an average number of employees (ANE) ranging from 8 to 25 persons;
• 4% of the ANE — for employers with an ANE exceeding 25;
• 2% of the ANE — for healthcare institutions, rehabilitation facilities, social service providers, and organizations engaged in the rehabilitation or education of persons with disabilities.

Conditions for including an employee in the quota

Starting in 2026, three conditions must be met simultaneously for an employee with a disability to be included in the quota:

• The job must be the employee’s primary position
• The accrued salary must exceed the minimum wage
• The working hours must correspond to normal or adapted working hours

Administrative and economic sanctions are replaced by a targeted contribution

Instead of administrative and economic sanctions for failing to meet the quota, a “targeted contribution to support the employment of persons with disabilities” is being introduced. The employer will be responsible for calculating the amount of the contribution and paying it. Additionally, the employer will independently calculate the quota they are required to meet.

The contribution amount will be calculated by the payer based on the following factors:

• 40% of the average monthly salary (remuneration) for the relevant calendar quarter, calculated per employee
• the number of months in the quarter
• the difference between the established quota of jobs for the employment of persons with disabilities and the average number of employees with disabilities actually employed by the employer during the quarter (with a salary not less than the minimum wage).

Therefore, before calculating the contribution amount for the reporting quarter, the employer must determine:

• the job quota indicator for the quarter, rounded to the nearest whole number according to standard rounding rules
• the average number of employees with disabilities employed by the employer during the reporting quarter
• the average monthly salary for the reporting quarter

During the period of martial law and until the last month of the quarter in which martial law is lifted or terminated, the contribution amount will be 50% of the amount established by Law No. 875 (para. 3 of Section II of Law No. 4219)

Reporting on the payment of the targeted contribution

Employers who are payers of the contribution will have a new obligation — to submit reports on this contribution. The reporting form will be approved by the Pension Fund in coordination with the Ministry of Social Policy. The basic reporting period for the contribution will be a quarter. That is, reporting must be submitted quarterly. Employers will be required to submit reports on the calculation and payment of the contribution within the deadlines established by law for submitting reports on the Unified Social Contribution (USC), and to pay the contribution within 10 calendar days following the last day of the reporting deadline.

The obligation to submit reports on the contribution will only come into effect from January 1, 2026. In 2025, the quota must be met under the old rules.

Fines:

• For non-payment (or failure to transfer) or late payment (late transfer) of the contribution — 7% of the unpaid amount;
• For recalculation by the territorial body of the Pension Fund or by the payer of a late-calculated contribution — 10% of the recalculated amount for each reporting period, but not exceeding 50% of the recalculated contribution;

For failure to submit, late submission, or submission in an incorrect reporting form regarding the calculation of the contribution — 10 untaxed minimum incomes of citizens (170 UAH).

Penalty: 0.1% of the underpaid amount for each day of delay.

How can an outsourcing partner help?

Successful businesses must keep up with changes and comply with legal requirements, which can place an additional burden on HR teams. To avoid mistakes and get everything done on time and correctly, contact the HR administration specialists at Accace Ukraine. Our extensive experience and proactive approach will help your business prepare for any changes.