Legal updates (17.07.2025)

Below, you will learn about:

• Labour relations under martial law: new requirements;
• Updated procedure for verifying UBO and ownership structure data in the USR;
• Card transfer limits have been revised;
• New deferral options in Reserve+;
• Relaxation of currency restrictions;
• Fine payment now available in Reserve+;
• The Ministry of Agrarian Policy has updated “critical” enterprise criteria;
• The rules for booking employees have been changed.

Labour relations under martial law: new requirements

Amendments regarding the organization of labor relations during martial law concerning the obligation to inform about updated contact details of employers and employees came into force on 14 June 2025.

Key aspects:

• the obligation has been established for both employees and employers to inform each other of any updates to their contact details (such as address of residence or location, e-mail address (if available), and phone numbers, etc.) no later than 10 days after such amendments occur;
• a 60-day period (i.e. until 14 August 2025) has been set for employers to update their contact details in the Unified State Register (USR); and employees who have been absent for more than 90 days or who are working in temporarily occupied territories are required to send their up-to-date contact information to their employers.

^{Source:  Law of Ukraine No. 4412-IX of 1 May 2025 “On Amendments to the Law of Ukraine 'On the Organisation of Labour Relations under Martial Law' regarding the exchange of information and suspension of labor contracts”.}

Updated procedure for verifying UBO and ownership structure data in the USR

Amendments aimed at improving the procedures for verifying USR data on ultimate beneficial owners (UBOs) and the ownership structure of legal entities came into force on 13 June 2025.

Key aspects:

• a procedure for resending a registrar’s request after one month is introduced, in case the legal entity is not located at its registered address or the postal item’s storage period has expired;
• a 10 working day period is set for responding to an additional request from the state registrar; if no response is received, the verification process automatically resumes;
• a procedure is defined for the registrar to send a formal notification letter to the Ministry of Justice, including all materials such as explanations and documents provided by the legal entity;
• a 30 working day deadline is set for responding to the registrar’s additional request; if there is no response, the registrar must inform the Ministry of Justice within 3 working days;
• it is specified that verification procedures will not begin or will be terminated if the legal entity independently updates its UBO or ownership structure information in the USR; 
• the Ministry of Justice is authorised to issue instructions to the registrar to remove UBO or ownership structure information, or any note about potentially unreliable data, from the USR;
• a list of exceptions is provided when the Ministry’s instruction should not be executed, including if the information was independently updated; if the UBO is subject to asset blocking sanctions; if the USR contains a court decision prohibiting registration actions.

^{Source:  Order of the Ministry of Justice of Ukraine No. 1173/5 of 30 April 2025 “On Approval of Amendments to the Procedure for Verifying Information Provided by a Legal Entity in Explanations and Documents to Confirm UBO or Ownership Structure Data”.} 

Card transfer limits have been revised

New restrictions on card transfers came into force on 1 June 2025.

Key aspects:

• the monthly outbound transfer limit for “medium” and “low-risk” clients has been reduced from UAH 150,000 to UAH 100,000;
• the limit for “high-risk” clients remains unchanged at UAH 50,000 per month;
• clients should now provide the bank with documents confirming the source and amount of income for transfers exceeding these limits.

^{Source:  Memorandum “On Ensuring Transparency in the Functioning of the Banking Services Market”.} 

New deferral options in Reserve+

The Reserve+ system has introduced the possibility of applying for deferment for two additional categories: persons temporarily unfit for military service based on the Military Medical Commission (MMC) decision and families where one spouse is in military service and the couple has a minor child.

In addition, Reserve+ displays the reasons for violations of military registration rules. 

^{Source:  Official press release of the Ministry of Defence of Ukraine dated 15 May 2025.}

Relaxation of currency restrictions

Amendments to the currency legislation came into force on 10 May 2025, with the aim of stimulating the liberalization of the foreign exchange market under martial law. 

Key aspects:

• resident legal entities are allowed to perform currency operations within the limits of the amount they received as foreign investments from abroad to their charter capital, starting from 12 May 2025;
• residents may now purchase foreign currency to fund a special bank account opened solely for the performance of obligations under a loan or credit agreement with a non-resident;
• requirements have been updated regarding permission for resident legal entities to transfer funds abroad to accounts of their branches or representative offices (without establishing a separate legal entity);
• a provision on the payment of consular fees by resident legal entities has been added.

^{Source:  Resolution of the Board of the National Bank of Ukraine No. 53 dated 9 May 2025 “On Amendments to the Resolution of the Board of the National Bank of Ukraine No. 18 of 24 February 2022”.}

Fine payment now available in Reserve+

Amendments have been made to the Code of Ukraine on Administrative Offences regarding the voluntary payment of fines. 

Key aspects: 

• the possibility for the user to submit an application in Reserve+ for acknowledging a violation has been defined;
• receipt of a resolution on the violation in Reserve+ is ensured;
• payment of a 50% fine using the details in Reserve+ with automatic confirmation of the resolution’s execution has been implemented.

^{Sources:  Law of Ukraine “On Amendments to the Code of Ukraine on Administrative Offences to Improve the Mechanism of Bringing Individuals to Administrative Liability for Violations of Military Registration and Defence Legislation”; Official press release of the Ministry of Defence of Ukraine dated 15 April 2025.} 

The Ministry of Agrarian Policy has updated “critical” enterprise criteria

On 12 February 2025, the Ministry of Agrarian Policy of Ukraine updated the criteria for defining enterprises of critical importance to the national economy in the agricultural sector during a special period. 

It is determined that the main type of economic activity of such enterprises (in the area of production, processing, and sale of agricultural products) shall be established as of 1 February 2025, according to KVED-2010 classification. 

Subsequent changes from the Ministry of Agrarian Policy occurred on 3 April 2025, clarifying some KVEDs that are taken into account when determining critically important enterprises:

• wording for KVED 01.25 was updated — it now covers the cultivation of berries, nuts, and other fruit trees and shrubs;
• wording for KVED 11.01 (distillation, rectification, and blending of alcoholic beverages) was changed — the word “alcoholic” was replaced with “spirits”;
• a new criterion was introduced: a company may be considered critical if it owns at least 90% of the charter capital of two or more entities already classified as critical. This should be confirmed by a copy of the relevant order from the Ministry.

^{Sources:  Order of the Ministry of Agrarian Policy and Food of Ukraine No. 916 of 12 February 2025 “On Amendments to the Criteria for Determining Enterprises, Institutions, and Organizations of Significant Importance to the National Economy in the Field of Agriculture in a Special Period”, Order of the Ministry of Agrarian Policy and Food of Ukraine No. 1588 of 3 April 2025 “On Amendments to Paragraph 1 of the Criteria for Determining Enterprises, Institutions, and Organizations of Significant Importance to the National Economy in the Field of Agriculture in a Special Period”.}

The rules for booking employees have been changed

Updated rules for the booking employees subject to military service have been in effect since 2 April 2025.

Key aspects:

• it is established that when calculating the total number of employees subject to military service subject to booking, employees already booked by other enterprises, institutions, or organizations are not taken into account;
• the technical capability for automatic exclusion of such employees from the total count has been implemented on the Diia Portal.

^{Source:  Resolution of the Cabinet of Ministers of Ukraine No. 360 dated 28 March 2025 “On Amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 76 dated 27 January 2023”.}