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Electronic labor book: what to do by June 2026

18.04.2026 14:06
Andrii Toverovskyi
Andrii Toverovskyi

Expert in tax and legal business matters

Electronic labor book in Ukraine: what an employer needs to do by June 10, 2026

The electronic labor book in Ukraine is already working: the main accounting of labor activity is kept not in a paper book, but in electronic form in the register of insured persons. The paper labor book has not completely disappeared, but its role has changed: it is no longer the basic personnel document for daily accounting, but is used primarily to make entries at the request of the employee and to confirm old periods of work that have not yet been transferred to the register. (Law of Ukraine)

For an entrepreneur, the practical conclusion is as follows: if employees still have undigitized paper labor books, it cannot be postponed anymore. The current transition period expires on 06.10.2026. As of the date of the reply, the law on its extension has not been adopted: draft law No. 14257 is only being processed in the committee. Therefore, employers should proceed from the deadline of June 10, 2026, organize the verification of personnel records, submission of data to the PFU, and the issuance of paper books to employees against signature after the completion of digitization. (Law of Ukraine)

What is an electronic labor book

The “electronic labor book” actually refers to information about the employee's labor activity, which is stored in the register of insured persons of the State Register of Compulsory State Social Insurance. It is this register that is the main source of data on labor activity, and not a separate paper form. (Law of Ukraine)

The PFU procedure provides that in electronic form, not only hiring and dismissal can be recorded, but also other periods and events: work, training, practice, service, care, unemployment, internship, relations under civil law contracts, part-time work, transfer, as well as the basis for termination of employment relations with reference to the rule of law and details of the document that executed the corresponding entry. (Law of Ukraine)

Are paper labor books canceled

No, there is no complete disappearance of the paper labor book. The law preserved it as a document that can be kept at the request of the employee. If an employee is hired for the first time and asks to issue a paper labor book, the employer is obliged to do this no later than five days after hiring. If the employee already has a book kept by him, the employer is obliged, at his request, to make entries in it regarding hiring, transfer, dismissal, incentives, and awards. (Law of Ukraine)

That is, this model currently applies: electronic accounting is the main one, and the paper labor book is an additional document that is maintained at the request of the employee or used to confirm old records during the transition period. (Law of Ukraine)

What the employer should do when hiring an employee

When concluding an employment contract, the employee submits a passport or other identity document, a labor book — if any — or information about labor activity from the register of insured persons. In cases expressly provided for by law, an education document, a health status document, a military registration document, and other documents are also submitted. (Law of Ukraine)

For the employer, this means:

if the candidate has a paper labor book, it can be used as a source of data on previous work; (Law of Ukraine)
if there is no paper book, the employee can provide data from the register of insured persons; (Law of Ukraine)
if this is the first place of work, the employee has the right to submit a requirement for issuing a paper labor book, and the employer must issue it no later than five days after hiring; (Law of Ukraine)
admission to work, as before, is possible only after formalizing the employment contract by order or instruction and notifying the tax authority about hiring the employee. (Law of Ukraine)

What has changed during the employee's work

Current personnel accounting is maintained by the employer not through storing a paper labor book at the enterprise, but through the proper execution of personnel documents and the submission of information to state registers in the prescribed manner. If the register of insured persons lacks information about hiring, moving between departments, transfer, dismissal, reinstatement at work, suspension or resumption of the employment contract, assignment of rank, category, undergoing internship or training, the policyholder submits such information through the web portal of PFU electronic services with a qualified electronic signature applied. (Law of Ukraine)

For an entrepreneur, this means that the focus should not be on labor book forms, but on the quality of personnel orders, the correctness of the wording for the grounds of hiring, transfer, and dismissal, the compliance of document details, and the timely submission of information to the PFU if there are gaps in the register. It is these data that will subsequently affect the confirmation of the employee's service record and the assignment of a pension. (Law of Ukraine)

What the employer should do by June 10, 2026

The transition period is set for five years from the date of entry into force of Law No. 1217-IX. In practice, this is the period from 10.06.2021 to 10.06.2026. During this time, the PFU includes missing information about labor activity in the register based on data submitted by the policyholder or the insured person. Until this process is completed, the data of the paper labor book are used to record information about labor activity for the period prior to the entry into force of the law. After completion of these works, available labor books are issued to employees personally against signature. (Law of Ukraine)

Thus, by 06.10.2026, the employer should perform the following minimum actions:

conduct an inventory of employees who have paper labor books or old periods of work not yet reflected in the register; (Law of Ukraine)
check whether information about hiring, transfer, dismissal, and other personnel events has been entered into the register; (Law of Ukraine)
organize the scanning of labor books and supporting documents or the creation of electronic records in the policyholder's cabinet; (Law of Ukraine)
after completion of digitization, issue paper books to employees against signature; (Law of Ukraine)
do not wait for a possible extension of the deadline, as of the date of the response it has not been adopted by law. (Electronic Cabinet)

How information is submitted to the Pension Fund

The PFU procedure explicitly allows the submission of information both by the employee himself and by the policyholder. Submission is possible in person or through the PFU electronic services web portal in electronic form with the mandatory application of an electronic signature based on a qualified certificate. For periods prior to the entry into force of Law No. 1217-IX, information can be submitted either as scanned copies of documents or in digitized form by creating an electronic record with attached scans. As a general rule, information is submitted once, and repeatedly — in case of correcting inaccuracies. (Law of Ukraine)

Scanned copies must be made from the originals, in color, contain all pages of the labor book with entries, in chronological order, as well as document fields. Recommended resolution — 300 dpi, file format — jpg or pdf, the size of each file — no more than 1 MB. For business, this means that poor-quality scans, incomplete pages, or cropped fields can cause problems with confirming the service record. (Law of Ukraine)

What to do if an employee resigns

On the day of dismissal, the employer is obliged to issue to the employee a copy of the order or instruction on dismissal, a written notice on accrued and paid amounts, and make a final settlement within the time limits specified by Article 116 of the Labor Code. If the employee asks, the employer must also make a proper record of dismissal in the paper labor book kept by the employee. (Law of Ukraine)

Separately, a special rule of the transition period applies: if the employment contract was concluded before the entry into force of Law No. 1217-IX, and the employee is dismissed before the completion of the procedure for entering missing information into the register, the employer is obliged to issue him a properly executed paper labor book on the day of dismissal. (Law of Ukraine)

For a sole proprietor employer, there is another exception: if such an employer is drafted into military service during mobilization or in another way provided by law, he can fulfill the obligations under Article 47 of the Labor Code within a month after dismissal from service without applying sanctions and fines. (Law of Ukraine)

What happens if the book is not digitized by 10.06.2026

The official explanation of the PFU comes down to the fact that the insurance record does not disappear automatically just because the paper book was not digitized by 10.06.2026. But this significantly complicates the future assignment of a pension, primarily regarding periods of work before 01.01.2004, which did not get into the electronic register. In this case, the person will have to separately confirm the service record with the original book or other documents. (Pension Fund of Ukraine)

The PFU also explains that if the book was not submitted by the employer, the employee can submit scanned documents independently through the PFU web portal even after the end of the transition period, but this no longer cancels the fact that the current official deadline for mass transition is 10.06.2026. For an entrepreneur, this means a simple rule: it is safer to close the issue now, while the employee is working, personnel documents are available, and sources of confirmation of the service record are not lost. (Pension Fund of Ukraine)

Risks, liability and money

The law does not explicitly establish a special separate fine precisely for an “undigitized labor book”. But this does not mean the absence of risks. If an employer violates other requirements of labor legislation, general financial sanctions under Article 265 of the Labor Code may be applied to him, in particular for violation of other requirements of labor legislation — in the amount of the minimum wage for each violation. (Law of Ukraine)

The most sensitive consequences for business arise upon dismissal. For a delay in issuing a copy of the dismissal order due to the employer's fault, the employee is paid average earnings for the entire time of forced absence. For non-payment of due amounts within the time limits specified in Article 116 of the Labor Code, the employer risks paying average earnings for the entire delay time until the day of actual settlement, but not for more than six months. (Law of Ukraine)

Therefore, the main risk for an entrepreneur here is not so much a “fine for an electronic book”, but a combination of problems: incomplete personnel accounting, disputes over service records, conflicts during dismissal, employee claims, and additional costs for correcting old mistakes. (Law of Ukraine)

A short example from practice

In April 2026, the Pension Fund officially explained using an example of a situation with an undigitized labor book that an employee does not lose the insurance record automatically, but without entering old records into the register, pension processing may require personal submission of originals and additional confirmation of the service record. For an employer, this is a practical signal: the earlier old records are digitized, the fewer risks of disputes with the employee in the future. (Pension Fund of Ukraine)

What an entrepreneur should do right now

check which employees have paper labor books and whether all records are already in the register; (Law of Ukraine)
prepare high-quality scans of all pages with entries and supporting documents on the service record; (Law of Ukraine)
appoint a person responsible for submitting information through the PFU web portal with a qualified electronic signature; (Law of Ukraine)
check the wording of orders on hiring, transfer, and dismissal so that the grounds match the data transferred to the register; (Law of Ukraine)
upon every dismissal, issue a copy of the order, a written notice of settlement, and, if necessary, make an entry in the paper book; (Law of Ukraine)
do not count on an automatic extension of the digitization period until the corresponding law is adopted. (Electronic Cabinet)

Official sources

Labor Code of Ukraine, No. 322-VIII: Art. 24 (documents upon hiring), Art. 47 (employer's obligations upon dismissal), Art. 48 (electronic accounting of labor activity), Art. 116–117 (settlement and liability upon dismissal), Art. 265 (financial sanctions). (Law of Ukraine)
Law of Ukraine of 05.02.2021 No. 1217-IX “On amendments to certain legislative acts of Ukraine regarding the accounting of an employee's labor activity in electronic form”: a 5-year transition period, the procedure for using paper books until the data transfer is complete, issuance of books to employees against signature, a special rule for dismissal before the completion of the procedure. (Law of Ukraine)
Resolution of the Board of the Pension Fund of Ukraine dated 12.03.2021 No. 11-1, registered with the Ministry of Justice under No. 802/36424: who submits data, how xml-files and scans are submitted, requirements for scan copies, procedure for correcting records, cases of submitting missing personnel data through the PFU web portal. (Law of Ukraine)
Official explanation of the PFU regarding the consequences of non-digitization of the labor book by 10.06.2026: practical consequences for the service record and pension, the position of the PFU regarding the deadline. (Pension Fund of Ukraine)
Draft law card No. 14257 on the website of the Verkhovna Rada of Ukraine: as of the date of the reply — “being processed in the committee”, meaning that the extension of the digitization period has not yet become law. (Electronic Cabinet)

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