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Employment of Persons with Disabilities: What Will Change from January 1, 2026

From 01.01.2026, large-scale changes in the sphere of employment of persons with disabilities will come into force. They are introduced by the Law of Ukraine dated 15.01.2025 No. 4219-IX, which significantly changes the rules for fulfilling the quota, the procedure for accounting for such employees, and the mechanism of employer liability. The new requirements become stricter, but at the same time replace the old system of fines with a more transparent mechanism — a targeted contribution.

Employment Quota: Key Innovations from 2026
The main change is the transition from annual control to quarterly control. Employers will no longer be able to “catch up” on indicators at the end of the year: each quarter is evaluated separately.
From 2026, the quotas will be:
• from 8 to 25 employees — one workplace for a person with a disability;
• over 25 employees — 4% of the average staff number per quarter;
• healthcare institutions, rehabilitation, and educational organizations — 2%.
The indicator is determined based on the average number of employees according to the rules of Instruction No. 286. Employees engaged in work from the Lists of heavy, harmful, or dangerous working conditions are not included in the calculation.

Who Counts Towards the Quota: New Salary Requirements
Currently, the fact of a person with a disability being on staff at their main place of work is sufficient — regardless of the amount of time worked or the salary amount.
From January 1, 2026, this approach changes: an employee with a disability will be counted towards the quota only on the condition that their accrued salary exceeds the minimum wage for a fully worked month.
That is, employees with part-time work, low salaries, or zero accruals will not be included in the quota.
Example: if the salary is UAH 10,000 for 0.5 FTE, the salary will be UAH 5,000, which is less than the minimum. Such an employee is not counted. The employer needs to either increase the salary or otherwise ensure the minimum wage is exceeded.
This effectively makes the practice of “hiring for show” impossible.

Targeted Contribution Instead of Fines
Administrative-economic sanctions, which were collected for many years for non-fulfillment of the quota, are abolished. Instead, a targeted contribution to support the employment of persons with disabilities is introduced, which is paid only in case of non-fulfillment of the quota.
Contribution formula: 40% of the average monthly salary × number of months in the quarter × (shortage of employees with disabilities).
During the period of martial law, a reduced coefficient applies — 50% of the base contribution.
Late payment of the contribution entails a fine: 7% — for late transfer; 10% for each period in case of additional accrual after an inspection (but not more than 50%). Approval of a separate procedure for calculation and administration of the contribution is expected.

Return of Reporting
Despite the previous cancellation of the F4-FSSI report, employers will have to report again.
From 2026, a report on the accrual and payment of the targeted contribution is introduced, which will be submitted to the Pension Fund together with the deadlines for reporting on the Unified Social Contribution (ESV).
For failure to submit or lateness, a fine is provided — UAH 170.
The report form must be approved by a separate regulatory act.

Practical Recommendations for Employers
To avoid unnecessary expenses in 2026, it is advisable to:
• check the average number of employees per quarter;
• analyze the salaries of employees with disabilities and adjust them if necessary;
• review HR policy to avoid a shortage of the required number of workplaces;
• monitor the appearance of the approved procedure for paying the contribution and the reporting form.

Conclusion
From 2026, the rules for the employment of persons with disabilities become more structured and demanding. Quarterly control, the salary criterion, and the mandatory targeted contribution stimulate employers not to formally “close” the quota, but to ensure real employment and decent working conditions. Proper preparation for the new requirements will allow avoiding financial losses and liability.

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