HR records a foreign employer must keep in Ukraine

Foreign employers in Ukraine tend to assume that HR paperwork is a formality handled by whoever does payroll. It is not. The labour inspectorate checks documents, not intentions, and the fine is assessed on what exists on paper. Here is the file a Ukrainian employer is expected to keep, whatever the shape of the entity.

The core file, per employee

• The employment contract, signed before the person starts work, with any subsequent amendments as side agreements.
• The hiring order, and the notification of hiring submitted to the tax authority before the employee starts.
• Orders for transfers, leave, business trips, disciplinary action and termination.
• The job description, where duties are referenced in the contract rather than spelled out in it.
• Signed acknowledgements of internal rules, health and safety briefings, and the personal data processing notice.

Two points foreign employers get wrong most often: the notification of hiring goes in before the first working day, not after; and a signature on the contract alone does not replace the separate acknowledgements.

Company-wide documents

• The staffing table, with every position that exists and its salary range, updated whenever it changes.
• Internal labour regulations.
• The leave schedule, agreed at the start of the year.
• Timesheets, kept monthly. They are the evidence for everything paid.
• Health and safety documentation, including briefing logs.
• Military registration records for employees, with notifications to the recruitment centre when data changes. This obligation surprises foreign-owned companies more than any other.

Where the fines actually come from

In practice the inspectorate looks first at whether people are working without a contract or without the notification, whether salary is paid at least twice a month with no more than sixteen calendar days between payments, whether the payroll figures match the timesheets, and whether overtime and night work are recorded and paid as such. Reclassification of contracts with sole proprietors (FOPs) as employment belongs in the same list: if the relationship looks like employment in substance, the paperwork saying otherwise does not help.

Personal data

An employee file is personal data. That means a defined list of people with access, a processing notice the employee has signed, and rules on storage and destruction. If HR or payroll is outsourced, the transfer has to be covered by the contract with the provider. Group auditors ask about this routinely, so it is cheaper to set it up at the start than to reconstruct it later.

A practical order of work

For a company already operating, the sequence that works is: check what exists, fix what is missing, then decide who keeps it going. Checking first matters, because handing over a broken file simply moves the problem. That check is an HR records audit: a list of gaps and an assessment of the exposure, which usually takes a few days.

After that the file is either kept in-house or handed over as HR administration, normally together with payroll, since the timesheet feeds both. What that split looks like in detail is in HR outsourcing: what you actually hand over.