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    Work Permits in Ukraine (2025 Update): What Employers and Foreigners Need to Know

    Posted by 21 May 2025 in Legal alert

    Work Permits in Ukraine (2025 Update): What Employers and Foreigners Need to Know

    Posted by:

    Taras Horbatiuk

    Taras Horbatiuk, Managing Partner

    Work Permits in Ukraine (2025 Update): What Employers and Foreigners Need to Know

    Introduction

    Ukraine continues to reform its work and employment permit regime to facilitate legal foreign labor, especially under the new Law on Employment (Law No. 5067-VI) as amended by draft Law No. 5795 (adopted Sept. 21, 2022). As the country rebuilds its economy, international companies and HR agencies face a complex but improving framework for hiring foreign workers. This article summarizes the latest foreign worker regulations in Ukraine (as of 2025), explains how to get a work permit, outlines employer obligations, and highlights common challenges. We also include links to Intermarium’s related guidance on work and immigration permits, and encourage consulting an immigration law specialist if needed.

    The core law governing foreign employment in Ukraine is the Law “On Employment of the Population” (Law No. 5067-VI of July 5, 2012), as amended. This law (often called simply the “Employment Law”) has been updated repeatedly. The most significant recent amendments came into effect in late 2022 under the adopted Draft Law 5795 (registered as Law No. 2623-IX on Sept. 21, 2022). These changes aim to simplify procedures and equalize conditions for foreign workers:

    • Streamlined Application Process. Employers can now submit permit applications directly to the regional employment center or via electronic portals (no longer only through a government service center). Documents may be filed in person, by mail, or through an online “e-cabinet” system. Crucially, the administrative fee must be paid before applying (unlike the prior post-issuance payment) and the payment receipt attached to the application. If a permit is denied, the fee is refunded within 10 working days.

    • Equalized Wage Requirements. Before 2022, employers had to promise very high salaries (often 10 times the minimum wage) to hire foreigners. The reforms abolished that “10× rule”. Now foreign employees must be paid at least the same minimum wage as Ukrainians (roughly USD 200/month currently). This change removes a major barrier: as one analysis explains, requiring 10× wages led many employers to resort to informal or part-time arrangements. In practice, foreign workers are simply subject to the same minimum salary requirement as local workers.

    • Flexible Employment Options. Under the updated rules, a foreigner may hold multiple part-time jobs. An alien can work for different employers or in different positions simultaneously, as long as each employer obtains its own permit. Moreover, a foreigner holding a full-time permit may also take a part-time secondary job without a separate permit, provided the part-time contract does not extend beyond the main permit’s validity. In addition, the law explicitly allows concurrent employment: a foreigner can combine the job covered by the permit with a short-term position (e.g. covering an absent colleague) for up to 60 days per calendar year.

    • Foreign Students and Graduates. One of the most employer-friendly reforms is the inclusion of foreign students in the labor market. Non-Ukrainian students enrolled in Ukrainian universities may obtain work permits to work during their studies and for a period after graduation – without needing to exit and re-enter Ukraine on a work visa. In fact, the law provides that no administrative fee is charged for a permit issued to a foreign student (or to refugees and certain protected persons). This change simplifies internships and hiring of graduates: a graduate who finds a job by the end of studies can stay and work legally without the old hassle of a new visa or quota.

    • Permit Duration and Limits. The term of a work permit now depends strictly on the type of worker (see “Permit Validity” below). Importantly, the old maximum 3-year permits remain available only for seconded foreign employees and intra-corporate transferees. All other foreign nationals must accept permits of no more than 2 years (renewable). (The law also expressly allows employers to request a shorter term than the maximum.)

    • Increased Fees. Administrative fees for issuing and renewing permits were raised. For example, as of 2023 the issuance fee is 3 subsistence minimums (about ₴9084) for up to 6 months, 5 minimums (₴15,140) for 6–12 months, 8 minimums (₴24,240) for 1–2 years, and 10 minimums (~₴30,280) for 2–3 years. Extension fees are one subsistence less than the original fee. (All fees are set annually by budget law.) Note: the first two categories (refugees, students) remain exempt from any fee.

    • Reporting and Compliance. The amendments introduce new obligations and penalties. Employers must report the loss of a permit immediately to the authorities (employment center, border guards, migration service). The labor service will issue a duplicate permit within 7 working days upon application. The permit can also be changed or cancelled upon employer request. Importantly, authorities now refuse renewals if they detect that the employer failed to pay required taxes or social insurance for the foreign worker during the previous permit period. In other words, any back taxes or missed mandatory contributions (such as the unified social contribution) can nullify your ability to keep a foreigner employed. (The law explicitly makes non-payment of social contributions a ground for canceling the permit.) Therefore, maintaining full tax compliance is critical.

    • Security Clearances. Due to national security concerns, hiring nationals of certain countries (currently Russia, Belarus, and any other states deemed hostile to Ukraine) is tightly controlled. The issuance or extension of permits for citizens of Russia, Belarus or other “threat” countries requires approval from the regional Security Service of Ukraine (SBU). This means that even if the employer fulfills all other criteria, the SBU must sign off for the permit to become valid. (Practically, this imposes an extra review step and delay.)

    These changes (detailed in Law No. 2623-IX and related resolutions) significantly simplify the step-by-step process of employing foreigners. For a comprehensive guide to all procedures and eligibility, see our dedicated article.

    Who Does Not Need a Work Permit?

    It is important to note that not all foreign workers need a permit. Under current law, these categories are exempt and may work freely (subject to any other legal requirements):

    • Permanent Residents and Protected Persons: Foreign nationals or stateless persons who have permanent residency in Ukraine, or who have been granted refugee status, asylum, temporary protection, or immigration visas are treated like Ukrainian citizens. They may take any job without a work permit.

    • Certain Short-term or Specialized Roles: The law lists many specific exemptions. For example, foreigners working for foreign diplomatic missions, foreign armed forces, or international organizations follow separate rules. Representatives of foreign media accredited in Ukraine (e.g. foreign journalists) can work without the usual permit. Professional athletes, artists, and emergency rescue workers on urgent tasks are similarly exempt. Foreign seafarers and flight crews servicing vessels or aircraft in Ukraine are also free to work.

    • Foreign Branch and Subsidiary Staff: Employees of branches, representative offices or subsidiaries of a foreign company (organized under foreign law) are effectively exempt from obtaining a standard work permit. These workers register their assignment through the migration authorities instead. The recent law even explicitly added branch office staff to the non-permit list.

    • Visiting Specialists and Projects: Religious workers (clergy) invited by registered Ukrainian faith organizations can work under special permission. Foreigners engaged in approved international technical aid or educational projects, including invited teachers and researchers in Ukrainian universities, may work without an ordinary permit. In short, many one-off and quasi-diplomatic roles are carved out.

    In practice, if a foreigner falls into one of these exempt categories, the employer must still register the foreign national with the Migration Service, but no “permit to use labour” is issued. All others planning to work (including most expatriate hires, long-term transfers, and gig-economy workers) must obtain a proper work permit before employment begins.

    Eligibility and Employer Requirements

    To obtain a work permit in Ukraine, the foreign employee’s prospective Ukrainian employer must meet certain conditions and prepare supporting documents. Key requirements include:

    • Registered Employer: Only a duly registered Ukrainian legal entity or individual entrepreneur can sponsor a work permit. The hiring company must not have serious tax or legal violations, and its charter cannot restrict foreign hires. The employer will attest that the position is not limited to Ukrainian citizens (i.e., does not involve state secret or other citizenship-based restrictions).

    • Minimum Wage and Tax Compliance: As noted, the offered wage to the foreign national must be at least the national minimum. Equally important, the employer must be current on all employer-side taxes (notably the unified social contribution). If audits reveal unpaid contributions for the foreign worker, the permit may be denied or canceled.

    • Job Description and Contract: A genuine employment contract (or gig-employment contract) between the employer and the foreigner must be prepared. The contract should align with the foreigner’s qualifications and the job title specified in the permit application. Under the new rules, the employer confirms in the application that the job is not one of the few positions reserved for Ukrainians (such as judges, military roles, certain civil service jobs).

    • Quota or Notification: Ukraine no longer uses explicit national quotas for work permits, but some fields (e.g. private security guards) still require the employer to show that enough Ukrainian applicants were not available. In general, most foreign employees do not need any extra quotas, thanks to recent liberalizations.

    • Legal Basis: The employer must apply for the permit on the basis that the employee is one of the categories entitled to a permit (e.g. “foreign hired worker”, “seconded employee”, “intra-corp transferee”, etc.). Special paperwork is needed for secondments or intracompany transfers, such as the foreign parent company’s decision to send the employee to Ukraine.

    Required Documents

    The specific documents depend on the employee’s category, but a typical application package includes:

    • Application form. A completed and signed permit application (by government form) confirming the job title and confirming that the position is not restricted by citizenship or secrecy.
    • Passport copies. Certified copies of the foreign worker’s passport pages with personal data and entry stamp (with a notarized Ukrainian translation).
    • Photograph. One color passport photo (3.5×4.5 cm) of the worker.
    • Employment Contract. A draft labor contract or gig contract signed by both parties, describing the job and term.
    • Supporting Agreements: For secondments, a copy of the international assignment contract or foreign employer’s order; for intra-company transfers, a foreign company’s transfer order plus the local hiring contract.
    • Special-case documents: E.g., if the foreigner is a student or refugee, relevant proof (such as a student enrollment certificate or refugee determination papers) is required. An invitation and study certificate is needed for foreign students intending to work.
    • Payment Receipt. Proof of pre-payment of the permit fee (state duty) for the chosen validity period.

    The employer submits the above documents to the regional Employment Service (the central authority for employment/migration). Note that all documents must be signed or translated properly; minor errors can cause delays. (If anything changes after issuing the permit – e.g. change of job title – the employer must apply for an amendment.)

    Application Steps and Fees

    Step-by-step application (summary):

    Prepare Employer Records: Ensure the position is registered, draft the employment contract, and gather the foreigner’s passport and qualifications. Pay the State Fee: Deposit the appropriate fee into the state budget before filing the application. Fees depend on duration (3, 5, 8 or 10 subsistence minimums; see above). Submit Documents: File the application package (including the receipt) with the regional Employment Service. This can be done:

    • In person (or by authorized agent) at the employment center;
    • By registered mail (with inventory list);
    • Online via the official portal’s electronic cabinet system.

      Review Period: The authorities have up to 7 working days to process the application (often it’s faster). If more documents are needed, you will be notified. Issuance of Permit: If approved, the center issues the formal Labor Permit document. The employer must then register this fact with the State Migration Service (to record the foreigner’s legal stay based on work). Register and Visa: After the permit is issued, the foreigner can apply for a work visa or temporary residence based on employment, if not already in Ukraine legally. Once in Ukraine on that basis, they must register their address with the local migration office within 30 days.

    If the permit is denied, the service will notify the employer with reasons (e.g. lacking documents, quota issues, security clearance denied). The paid fee will be refunded within 10 working days. The employer can fix deficiencies and reapply if needed.

    See Intermarium’s step-by-step guide for more detail on the application process and document checklist. Our Immigration lawyers can help prepare a complete package and liaise with the authorities.

    Work Permit Validity and Renewal

    Under current rules, permits are issued for the specific term of the employment (or intracompany transfer) and categorized by worker type:

    • Seconded Foreign Employees (posted from a foreign company under an external contract): up to 3 years (aligned with the contract term).
    • Intracompany Transferees (intra-corporate assignees): up to 3 years.
    • Foreigners with Protected Status (asylum seekers, refugees, etc.): up to 1 year, renewable if protection status extends.
    • Foreign Students (during and immediately after study): up to 1 year per permit.
    • Other Foreign Workers (all remaining categories): up to 2 years for each permit. (Employers can request a shorter period if preferred.)

    Permits may be renewed indefinitely as long as the employment continues and all conditions are met. Employers should submit a renewal application at least 1 month before expiration (the same rules and documents apply, except a new contract if extended). Each renewal also requires paying the (reduced) fee and submitting updated documents (e.g. renewed contract, up-to-date proof of salary and taxes).

    Example: A normal foreign employee hired today might first get a 1- or 2-year permit. Before it expires, the employer applies to extend it for another term (paying 4, 7 or 9 subsistence minimums, depending on length). In practice, renewals are common for long-term employees.

    Employer Obligations and Compliance

    While holding a work permit, the employer must fulfill ongoing obligations:

    • Inform the State: The employer must report the permit to the State Migration Service (registration of the foreigner’s temporary stay and work). Any change of address, job title, or loss of the permit requires notifying authorities immediately.
    • Employment Contract: A copy of the signed employment contract (for the permit-holder) must be submitted to the employment center. If the foreigner’s job or salary changes substantially, the permit may need to be updated or reissued.
    • Tax and Insurance: The employer must withhold and pay all relevant taxes (income tax, social contributions) for the foreign employee. Failure to do so for more than 2 months from the contract date is now explicitly grounds for revoking the permit. This means a foreigner should never work if the employer stops reporting them on payroll.
    • Document Safekeeping: The work permit original is kept by the employer. In case of loss or damage, the employer must notify the Employment Service, Border Guard and Migration Service, then apply for a duplicate. A duplicate must be issued within 7 working days. (Previously there was no duplicate rule, causing delays; the law now fixes this.)
    • Permit Return: If the foreign employee leaves the job or Ukraine, the permit must be returned to authorities, and the migration record updated. The employer should also remove the worker from any residence registration.

    Employers must be cautious about illegal employment. Hiring a foreigner without a permit (when required) can result in steep fines. (For reference, fines were raised recently: up to UAH 6,800 for illegal work and up to UAH 8,500 for failing to get a permit in time.) If violations are detected, the permit (and accompanying residency status) can be canceled retroactively.

    Common Challenges and Tips

    Several practical issues often arise in foreign employment:

    • Application Delays: Missing documents or incorrect translations are the main reason for rejections. Always double-check that all forms are properly filled and notarized. Allow extra time for SBU clearance if hiring from Russia/Belarus or other high-risk countries.

    • Tax Non-Compliance: As noted, a permit can be revoked if the company stops paying the employee’s social contributions. Always keep payroll records up to date and regularly verify that contributions are being recorded correctly in the Social Insurance register.

    • Renewal Timing: Apply for extensions well before expiration (at least 20–30 days early). The law does not allow work to continue beyond expiry without a new permit. If a permit lapses, the foreigner must stop work and could face overstaying issues.

    • Part-Time Misunderstanding: Take advantage of the part-time rule, but use it correctly. A foreigner can work a second (short) job only if the hours and contract end by the time the main permit ends. And if a foreigner has no full-time permit, they cannot take even a part-time job.

    • Paperwork Errors: Keep clear records of the paid fee receipt, application receipts, and any communications. If a document changes (e.g. passport renewal), update it in the permit application promptly.

    Despite the complexities, Ukraine’s updated foreign worker regulations aim to make legal hiring more predictable and fair. Employers should build these requirements into their HR procedures (often via consulting an employment permit lawyer in Ukraine). Intermarium Law Firm regularly assists companies with permit applications and full migration support.

    Conclusion

    In 2025, obtaining a work or employment permit in Ukraine remains a multi-step legal process, but recent reforms have eased many burdens. Key points for international companies and HR teams:

    • Only employ foreigners once you have the proper permit (unless the individual clearly falls into an exemption category).
    • Prepare the complete application (contract, passport copies, photos, etc.) and pay the fee in advance.
    • Anticipate compliance checks: equal wage policies, tax payments, and in some cases security vetting.
    • Use the new part-time and student provisions to your advantage if applicable.

    For detailed assistance on how to get a work permit in Ukraine, including the latest procedural guidance, see Intermarium’s insights and contact an immigration lawyer. Our firm’s experts can review your case, ensure all legal steps are followed, and help you avoid pitfalls. By aligning with Ukraine’s laws (Law 5067-VI and its amendments), employers can confidently hire the talent they need and foreign nationals can work legally and securely in Ukraine.

    Posted by:

    Taras Horbatiuk

    Taras Horbatiuk, Managing Partner

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