There will be consequences for receiving salary in cash. Learn about the fines and who will be responsible in 2025.

Unofficial Salaries: What Companies Face for "Envelope" Payments

According to legal regulations, employers who fail to formalize labor relations with their employees are subject to penalties linked to the minimum wage (MW). As a reminder, in 2025, the minimum wage is set at 8,000 UAH.

As explained by lawyer Konstantin Sklyar from "Winner Partners" Law Firm, in 2025, the following fines are established for not formalizing labor relations:

• actual admission of an employee to work without a labor contract: fine — 10 MW for each employee, which is equal to 80,000 UAH;
• repeated violation: if the violation occurs again within two years from the date of detection, the fine increases to 30 MW for each employee, which is equal to 240,000 UAH;
• for failure to comply with salary payment deadlines: fine — 3 MW for each employee, which is equal to 24,000 UAH;
• failure to comply with minimum state guarantees for wage payments: the fine is 2 MW for each employee, which is equal to 16,000 UAH.

Therefore, Valeria Gudi adds, today the penalty for actually allowing an employee to work without a labor contract (contract), and for paying salary (remuneration) without calculating and paying the unified social contribution for mandatory state social insurance and taxes (except in cases where the employee themselves is the payer of the unified contribution for mandatory state social insurance and taxes) is 80,000 UAH for each employee involved in the violation. "Legal entities and individual entrepreneurs who use hired labor and are taxpayers of the single tax of the first to third groups may receive a warning," says Valeria Gudi.

The actual basis for imposing a fine may include:

• a court decision on formalizing labor relations with an employee who performed work without a labor contract and establishing the period of such work;
• an act drawn up as a result of a state control event for compliance with labor legislation or employment, conducted due to non-compliance with a directive;
• an act drawn up as a result of a state control event for compliance with labor legislation, during which facts of using unregistered employees were revealed;
• an inspection act from the State Tax Service, or its territorial body, during which violations of labor legislation were identified.

Companies that unofficially collaborate with their employees will not only face fines — they will also need to pay taxes, the unified social contribution (USC), and the military levy. Additionally, the tax authorities may impose further fines for employers not reporting the actual income of their employees.

Are Employers Required to Hire People with Disabilities?

Ukrainian employers are required to adhere to legislative requirements for the employment of people with disabilities in 2025. Violating this regulation leads to fines, as outlined in Law No. 875 "On the Fundamentals of Social Protection of Persons with Disabilities in Ukraine."

Quotas for the employment of persons with disabilities:

• for enterprises with 8 to 25 employees: at least one job must be created for a person with a disability.
• for enterprises with more than 25 employees: a quota of 4% of the average number of full-time employees is established.

As noted by attorney Ekaterina Strukova from Stron Legal Services, if these regulations are not met, employers face administrative and economic sanctions. The amount of the fine depends on the number of employees in the enterprise: if there are up to 15 employees, the fine is half of the average annual salary at the enterprise for each unoccupied position intended for a person with a disability. For enterprises with more than 15 employees, the fine equals the average annual salary at the enterprise for each unoccupied position designated for a person with a disability.

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However, starting in 2025, sanctions against enterprises that do not employ people with disabilities will be lifted. Significant changes were made to the legislation in January 2025. On January 15, 2025, the Verkhovna Rada of Ukraine adopted the Law of Ukraine "On Amendments to Certain Legislative Acts of Ukraine Regarding Ensuring the Right of Persons with Disabilities to Work" (draft law No. 5344-d). This law introduces state standards for equipping (arranging) workplaces for various types of functional impairments and ensuring reasonable accommodation of workplaces in enterprises and organizations of all forms of ownership, as well as the introduction of a contribution to support the employment of persons with disabilities instead of administrative and economic sanctions for non-compliance with employment quotas. The contribution is set at a lower amount compared to the administrative and economic sanctions, but the obligation to pay it is established for all categories of employers — both private companies and state enterprises and institutions.

For companies employing persons with disabilities, there are benefits: they pay the USC at a preferential rate of 8.41% instead of the standard 22%

"The Verkhovna Rada adopted draft law No. 5344-d, which provides employers with an alternative: either to employ persons with disabilities or to pay a targeted contribution to support them in the Fund for Social Protection of Persons with Disabilities. This allows employers who cannot create appropriate jobs to support the employment of persons with disabilities through financial contributions," explained Ekaterina Strukova.

According to the draft law, the amount of the contribution is calculated by determining the result of multiplying the following indicators:

• 40% of the average monthly salary (remuneration) in the relevant calendar quarter, calculated per employee;
• the number of months in the quarter;
• the difference between the established standard of job positions for the employment of persons with disabilities and the average number of full-time employees — persons with disabilities for the quarter, employed by the employer.

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