Medical Certificate, Medical Conclusion, and Sick Leave: What Employers Should Do

In Ukraine, an employer needs a sick leave certificate to grant an employee benefits: an electronic or paper certificate issued in a case provided for by law. A medical certificate confirming a doctor’s visit can help establish the reason for an absence, but by itself it does not provide grounds for calculating sick leave benefits. A medical conclusion on temporary incapacity for work is an electronic document issued by a doctor and used as the basis for generating a sick leave certificate.

When a store employee reports an illness, record the period of absence. The accountant or another person authorized by the employer must look up the sick leave certificate in the employer’s account on the Pension Fund of Ukraine (PFU) portal, check the employee’s details, the reason and dates of incapacity for work, the document status, and eligibility for payment. If there is no certificate, the employee should contact the medical facility, while the employer checks whether the employment relationship and personal details are correctly recorded in the social insurance records.

How to distinguish a certificate, a medical conclusion, and a sick leave certificate

Under Article 23 of the Law of Ukraine “On Compulsory State Social Insurance” dated 23.09.1999 No. 1105-XIV, the basis for granting benefits is a sick leave certificate generated from a medical conclusion or a document confirming adoption or the establishment of guardianship over a child. If an electronic sick leave certificate cannot be generated, a paper certificate is used in the cases established by law.

The employee brought only a certificate: what to do

Ask the employee to explain when they were absent and what the document confirms: a doctor’s visit, an examination, or an established period of incapacity for work. Compare this information with the shift schedule. A certificate for an appointment at a particular time does not automatically confirm that the employee was unable to work for the entire shift.

Organize the response as follows:

1. The person responsible for personnel records the dates and hours of absence, the document details, and the employee’s explanation.
2. If the employee says the doctor established incapacity for work, ask them to check with the medical facility whether a medical conclusion was generated and whether the information was sent for an electronic sick leave certificate.
3. The accountant searches for the certificate in the employer’s account at the same time.

The absence of a sick leave certificate by itself is not sufficient grounds to automatically deem the absence unjustified or impose disciplinary action. Assess the explanation and supporting documents separately from the question of insurance benefits. A valid reason for absence also does not automatically create a right to have that time paid as sick leave.

Do not promise the employee that a “certificate will be exchanged for a sick leave certificate.” Under Clause 3, Section III of the Procedure for Generating Medical Conclusions on Temporary Incapacity for Work, approved by Order of the Ministry of Health of Ukraine dated 01.06.2021 No. 1066, the start of a medical conclusion generally cannot precede the date it is generated. Exceptions apply to:

• the first medical conclusion concerning incapacity for work that arose abroad;
• a conclusion in the “Вагітність та пологи” (“Pregnancy and childbirth”) category that was not generated at 30 weeks of pregnancy;
• identification of a previously unidentified person with incapacity for work;
• the circumstances specified in Clauses 7 and 9, Section IV of the Procedure: issuance after incapacity for work is established within the permitted time limits, and correction of a medical conclusion.

Clause 7, Section IV allows a doctor to generate a conclusion no later than the day after incapacity for work is established if medical care was provided outside the place where medical practice is conducted. If the medical information system—the software used by the medical facility—is unavailable, exchange of data with the central database is technically impossible due to a malfunction, or the electronic healthcare system lacks the relevant technical capability, the doctor generates the conclusion no later than five days from the date incapacity for work is established.

The period in the conclusion must correspond to the period determined by the doctor when incapacity for work was established. The doctor determines whether an exception applies and which dates to state. A certificate does not allow a date in the past to be set arbitrarily.

Hypothetical example. A salesperson missed two shifts and provided a certificate for one consultation. The manager establishes the circumstances of both absences, while the employee checks with the doctor whether incapacity for work was established and for what period. The employer grants sick leave benefits after receiving the required documentary basis and establishing eligibility for the benefit.

How to find an electronic sick leave certificate and what to check before payment

A medical conclusion is generated by an attending doctor working for a medical facility or an individual entrepreneur. The facility or entrepreneur must be licensed to practice medicine and carry out assessments of temporary incapacity for work. Under Clause 2, Section I and Appendices 1 and 2 of the Procedure approved by Order No. 1066, the doctor must be authorized by their position and specialty to generate a conclusion in the relevant category. The doctor uses medical records and assesses incapacity for work. The human resources officer and accountant do not create medical records or determine the medical period of illness.

An electronic sick leave certificate appears in the policyholder’s account on the day it is created and initially has informational significance. It receives the status “Готовий до сплати” (“Ready for payment”) seven days after closure, or, for pregnancy and childbirth, seven days after opening. The accountant must check the actual status in the account and follow the PFU procedure for granting and paying sick leave benefits.

Before granting benefits, the accountant or another person authorized by the employer must take the following steps:

1. Find the sick leave certificate. Compare it with the employee’s notice of the period of absence. Do not use the medical conclusion number as the sick leave certificate number.
2. Check the person’s identity and employment relationship. Make sure the document concerns your employee and the insured event—an event that may give rise to a right to benefits—occurred during the period of employment. Under Article 12 of Law No. 1105-XIV, this period also includes probation and the day of dismissal.
3. Establish the reason for incapacity for work. The employee’s own illness, care for a child, and pregnancy and childbirth are subject to different payment rules. A notation linking the case to occupational activity requires separate consideration. Do not automatically apply the general illness rules to such a case.
4. Compare dates and extensions. Determine whether this is a new case or an extension of a previous one. For one continuous case, do not start counting the first five days again with each subsequent certificate.
5. Compare the reason for incapacity for work with the type of leave. Temporary incapacity benefits are not paid for a period of unpaid leave, creative leave, or additional study leave. In the case of the employee’s own general illness or a non-occupational injury, annual leave does not exclude benefits. For care for a child or another family member, take into account the restrictions in Part 6 of Article 15 of Law No. 1105-XIV.
6. Consider pregnancy and childbirth benefits separately. Under Article 18 of Law No. 1105-XIV, annual, unpaid, additional study, or creative leave does not exclude payment from the date the right to pregnancy and childbirth leave arises. Determine grounds for refusal or termination of payment according to the relevant type of benefit.

The sick leave certificate did not appear: who should correct the error

The employee should contact the doctor or the medical facility’s administration to check their details in the Patient Register of the electronic healthcare system: surname, first name, date of birth, identity document, and taxpayer registration number (TRN). If the employee has lawfully refused a TRN, they should check that the corresponding notation is correct.

The accountant compares personal details and employment information with reports and social insurance records. If the issue lies in the employer’s information, the accountant arranges for it to be corrected through the relevant reporting or by contacting the PFU. The employee can check their own details in the Register of Insured Persons, the state register of information about people covered by social insurance. After the details are corrected, the accountant searches for the certificate in the account again.

If the medical conclusion contains an error, ask the employee to contact the doctor promptly. Under Clause 9, Section IV of the Procedure approved by Order No. 1066, changes may be made no later than the seventh day from the date the conclusion was generated. Once this period has elapsed, the Medical Advisory Commission (MAC), or the head of the medical facility if there is no commission, considers whether a paper sick leave certificate may be issued.

To track the correction, the person responsible for documents records when the problem was found, who contacted the medical facility or the PFU, what needs to be corrected, and when to check the account again. Do not calculate benefits using a fabricated certificate number or ask for a document to be backdated arbitrarily.

When a paper sick leave certificate may be accepted

Before accepting a paper certificate, the accountant must establish the grounds for its issuance. Clause 8 of Order No. 1066 allows the paper form in the following cases:

• extension and closure of certificates issued before 1 October 2021;
• expiry of the time limit for correcting a medical conclusion, by decision of the MAC or, if there is no commission, the head of the medical facility;
• issuance to an insured person within two months from the child’s birth, based on the birth certificate and a court decision on adoption;
• technical problems with data transfer between registers that make it impossible to generate an electronic sick leave certificate for more than seven days from the date the medical conclusion was created, until the problems are resolved;
• suspension, under martial law, of users’ access to the central database of the electronic healthcare system;
• late contact to extend incapacity for work due to force majeure circumstances during martial law or a state of emergency, if the person remains incapacitated for work on the date of contacting the facility, according to an assessment of their condition and the attending doctor’s conclusion.

In the last case, the MAC, or the head of the medical facility if there is no commission, decides whether to extend the period starting from the day after the end of the previous confirmed period. If the paper certificate extends an electronic certificate, it must state the number of the electronic certificate being extended.

For paper certificates issued in these cases, Clause 6 of Order No. 1066 provides for the application of the rules on issuance, completion, and registration during martial law and for three months after it ends or is lifted. Before submitting the document for consideration, the accountant checks the grounds for the paper form and the document details.

Sick leave on a white sheet of paper: what conditions apply

Under Clause 8-1 of Order No. 1066, during martial law and for three months after it ends or is lifted, a medical facility may issue a sick leave certificate printed on white paper using the approved form. Three conditions must all be met: forms are unavailable, they cannot be obtained, and the head of the medical facility has made a decision.

The field for the series must contain the facility’s code in the Unified State Register of Enterprises and Organizations of Ukraine, and the number field must contain the sequential entry number in the sick leave certificate registration journal. This document is equivalent to a certificate on an official form. A free-form certificate, even one signed by a doctor, is not such a certificate.

The accountant checks the employee’s details and the period of incapacity for work and establishes whether the document is an initial certificate or an extension of a previous one. If there are doubts, give the employee specific questions for the medical facility, for example, about the grounds for issuing it on white paper, its details, or the number of the certificate being extended. Do not add information in place of the doctor.

After accepting the document, the responsible employees complete the reverse side of the paper sick leave certificate in the section for the employer.

Which document is required for a secondary job

A secondary job is work performed under a separate employment contract during time free from the primary job. Article 22 of Law No. 1105-XIV provides for benefits at the primary place of work and for a secondary job under the established procedure.

For a paper sick leave certificate, Part 5 of Article 23 of Law No. 1105-XIV sets out a separate documentary requirement: a copy certified by the manager’s signature and seal, if any, at the primary place of work. Ask the employee to provide such a copy. An ordinary photograph of the document without proper certification does not meet this requirement.

This rule also applies to a person who works under an employment contract and at the same time conducts business or other activity. If a person conducts business and other activity at the same time but does not work under an employment contract, the copy must be certified by the medical facility that issued the certificate. For an electronic sick leave certificate, the employer works with the information in its account.

These documentary requirements have applied since 1 April 2026 under the Law of Ukraine dated 05.11.2025 No. 4683-IX. Clause 1, Section I of this Law amended Part 1 and added Part 5 to Article 23, which establishes the procedure for certifying paper copies. The Law was published in the newspaper “Holos Ukrainy” on 31.01.2026 and, under Clause 1, Section II, entered into force two months after the day following publication—on 01.04.2026.

How to grant benefits and receive funding

Under Articles 22 and 24 of Law No. 1105-XIV, the decision to grant benefits is made by the employer as policyholder or by a person authorized by the employer. Documents for temporary incapacity benefits must be considered no later than ten working days from receipt, and documents for pregnancy and childbirth benefits no later than three working days.

For an electronic sick leave certificate, count the review period from the day it receives the status “Готовий до сплати” (“Ready for payment”): no later than ten working days for temporary incapacity benefits and three working days for pregnancy and childbirth benefits. This starting point is set out in the PFU procedure. The responsible employee must record the date the status was assigned and the final day for review so that the employer can make a timely decision.

1. The employer or an authorized person records the decision. It must identify the employee, certificate, period, and days to be paid. If not all days are paid, it must state the reason.
2. The accountant calculates the benefit. The accountant takes into account the insurance record—the period credited for social insurance—eligibility for preferential treatment, and statutory limits. In particular, the restrictions in Article 12 of Law No. 1105-XIV apply when the insurance record is less than six months during the preceding twelve months. Articles 15–17 of this Law set the conditions, duration, and amount of temporary incapacity benefits.
3. The employer prepares an account for funding from the PFU. If the PFU funds all or part of the benefit, the employer must use a separate current account for insurance funds in accordance with Article 26 of Law No. 1105-XIV. If it does not already have such an account, the employer opens one with a bank.
4. The employer submits a calculation application for amounts funded by the PFU. This document lists the calculated benefit amounts for which insurance funds are requested. The employer prepares it in the policyholder’s account on the PFU portal and sends it to the Fund no later than five working days from the date of the decision to grant payment. If the employer pays for all sick leave days from its own funds, it does not submit a calculation application to the PFU to fund those days.
5. The accountant monitors receipt of funds. Under Article 26 of Law No. 1105-XIV, the PFU funds the policyholder within three working days after receiving the calculation application. The funds are credited to a separate account and used exclusively for insurance payments.
6. The accountant monitors payment to the employee. Under Article 24 of Law No. 1105-XIV, an employee under an employment contract must receive benefits on the next regular payday after the day they were granted.

The accountant must separately track the dates when benefits are granted, the calculation application is submitted, funding is received, and payment is actually made. If funds do not arrive within the prescribed period, the accountant checks the reason with the PFU and tells the manager the reason for the delay and the status of the inquiry.

Who pays for the first days

For the employee’s own general illness or an injury unrelated to an occupational accident, the employer pays for the first five days, and the PFU funds benefits from the sixth day. This rule is set out in Article 15 of Law No. 1105-XIV. The PFU funds pregnancy and childbirth benefits, as well as benefits for care for a sick child or another sick family member, from the first day eligible for payment.

Hypothetical example. For one continuous case of general illness lasting nine calendar days, if all days are eligible for payment, the employer funds five days and the PFU funds four: 9 − 5 = 4. The accountant calculates the amount of the benefit separately.

For care for a sick child under 14, benefits are provided from the first day for the period during which the child needs care according to the doctor’s conclusion. For outpatient treatment, meaning treatment without hospital admission, benefits are paid for no more than 14 calendar days. If the employee needs to stay with the child in hospital, benefits are provided for the entire period. For care for another sick family member, benefits are provided from the first day, but for no more than three calendar days. In exceptional cases, taking into account the severity of the illness and household circumstances, benefits are provided for no more than seven calendar days.

Part 6 of Article 15 excludes benefits for the relevant periods of care during annual, additional study, or creative leave. Article 16 also excludes temporary incapacity benefits for periods of unpaid leave. Therefore, the accountant first determines the reason for incapacity for work and the circumstances of the absence, then applies the funding rules.

When benefits may be denied and how to notify the employee

The grounds for refusing temporary incapacity benefits are set out in Article 16 of Law No. 1105-XIV. Before making a decision, the authorized person compares the documented circumstances with a specific ground and determines the period for which benefits are not payable:

• injury or illness while the employee was committing a criminal offense;
• intentional harm to health to avoid work or other duties, or feigning illness;
• being under arrest or undergoing a forensic medical examination;
• compulsory treatment under a court decision;
• illness or injury resulting from alcohol, drug, or toxic intoxication, or actions related to it;
• a period of unpaid, creative, or additional study leave;
• a period of incapacity for work stated in a sick leave certificate that has been found unjustified.

An employee loses the right to temporary incapacity benefits from the day of the violation if, while receiving those benefits, they:

• violate the regimen established by the doctor;
• fail to follow necessary instructions and recommendations from rehabilitation specialists in accordance with the individual rehabilitation plan agreed with the employee;
• without a valid reason, fail to appear at the appointed time for a medical examination, including before the MAC, or for an assessment of the person’s everyday functioning—an assessment of how their health affects daily life.

The body that grants the benefit determines, by its decision, the period for which the employee loses the right to benefits. The employer must rely on established circumstances and appropriate information. A shift manager’s assumption is not sufficient grounds for such a decision.

These grounds apply to temporary incapacity benefits. For pregnancy and childbirth benefits, apply the separate conditions in Article 18 of Law No. 1105-XIV, including those concerning overlap with other leave.

If the employer or an authorized person decides to refuse benefits, a notice stating the reason and appeal procedure must be issued or sent to the employee no later than five days after the decision. State the specific period, circumstance, and legal grounds in the notice. If an electronic sick leave certificate is missing because an error has not been corrected, first establish the reason. A delay in its appearance does not by itself prove employee misconduct.

Separately monitor the deadline for applying for benefits: under Part 5 of Article 24 of Law No. 1105-XIV, the application must be received no later than six calendar months from the date capacity for work is restored, or, for pregnancy and childbirth benefits, from the end of the relevant leave. Do not delay investigating a document issue until this period is nearly over.

How to transfer documents and limit access to medical information

For internal processing, designate a person responsible for receiving documents and communicating with the employee. If a paper certificate must be given to the employee to correct it at a medical facility, the responsible person records the certificate details, the date it was handed over, and the specific reason. Agree with the employee when they will report the result of their inquiry and resubmit the document.

To organize shifts, the store manager needs to know only the period of absence and the date of the employee’s next update. The accountant and authorized person need the information required to grant and calculate benefits. For routine sick leave processing, do not request a diagnosis, examination results, or the full medical file. Do not forward certificates in general employee chats. Give access only to people handling the relevant case.

Official sources

• Law of Ukraine “On Compulsory State Social Insurance” dated 23.09.1999 No. 1105-XIV — Articles 12, 15–18, 22–24, and 26: eligibility for benefits, payment conditions, documents, deadlines, and funding.
• Order of the Ministry of Health of Ukraine “Certain Issues Concerning the Generation of Medical Conclusions on Temporary Incapacity for Work” dated 01.06.2021 No. 1066 — Clauses 6, 8, and 8-1 of the Order; Sections I–V and Appendices 1 and 2 of the approved Procedure: generation and correction of conclusions, paper certificates, and requirements for doctors.
• Law of Ukraine “On Amendments to the Law of Ukraine ‘On Compulsory State Social Insurance’ to Improve the Procedure for Issuing, Extending, and Monitoring the Reasonableness of Issuing Sick Leave Certificates and Documents That Serve as a Basis for Their Generation” dated 05.11.2025 No. 4683-IX — Clause 1, Section I and Clause 1, Section II: documentary grounds, certification of paper copies, and entry into force.
• PFU procedure for paying sick leave benefits — electronic sick leave certificate status, document review, and submission of a calculation application.
• PFU guidance, “In Which Cases Can a Paper Sick Leave Certificate Be Issued?” — issuance of paper documents and completion of the reverse side by the employer.

Start by recording the employee’s absence dates and looking for the sick leave certificate in the employer’s account on the PFU portal. If the certificate is present, the responsible person checks its details and status and records the review deadline. If it is missing, the employee checks their details with the medical facility, while the accountant checks employment and social insurance records, then searches for the document again.