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Updated Rules for Unscheduled Inspections: What Changed and Where the Employer is at Risk
CMU Resolution No. 303 dated 13.03.2022 introduced a moratorium on most state supervision (control) measures during martial law.
However, CMU Resolution No. 121 dated 28.01.2026 did not “cancel inspections” but rewrote the exceptions: scheduled and unscheduled measures generally remain suspended, but the list of grounds for unscheduled inspections has become broader and more detailed.
That is, it is no longer a “total pause,” but a regime of selective control.
BASIC GROUNDS THAT WORKED BEFORE:
- court decision;
- application of the business entity for an inspection “at its own request”;
- verification of compliance with a prescription/order issued based on the results of a previous measure.
NEW/CLARIFIED EXCEPTIONS WHEN AN UNSCHEDULED INSPECTION IS POSSIBLE:
- instruction of the Prime Minister of Ukraine in connection with systemic violations and/or an event with a significant negative impact on human rights, the environment, or state security;
- presence of a threat to life or health, the environment, or state security;
- fulfillment of Ukraine’s international obligations;
- accident, fire, death, or severe accident/occupational disease related to the enterprise’s activity;
- verification of license conditions when the threat is documentarily confirmed by an authorized body;
- by decisions of bodies shaping state policy in the relevant sphere.
In parallel, the “corridor” of spheres where control measures are allowed has been expanded: from regulated prices and consumer rights protection (including utilities) and food/veterinary safety — to subsurface use, land control, and retail trade in medicines and medical devices.
For business, this means: risks can come not only from a “classic” inspection but also from adjacent regulators.
WHAT DOES THIS MEAN FOR HR AND OCCUPATIONAL HEALTH AND SAFETY?
In focus are three triggers for the employer: unfulfilled prescriptions, employee complaints citing danger, and accidents. In these situations, the “moratorium” does not save: control becomes targeted and legally tied to a specific event.
Advice: Conduct an Internal Audit Before They Come with a “Referral”
Check: formalization of labor relations, orders/timesheets, briefings, medical examinations, OHS training, logs, investigation/accounting of accidents, as well as the actual fulfillment of issued prescriptions.
And remember the “umbrella” of Law No. 877: during an unscheduled measure, controllers must verify only the issues that became its basis (and they must be specified in the referral).
The employer has the right not to admit an inspector without a service ID and a properly executed referral, as well as if a copy of the referral was not handed over before the start of the measure.
And if they try to check “everything at once” — remind them: an unscheduled measure = only specific questions.
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