Martial law in Ukraine extended to 29 January 2027: what employers should do

Martial law and general mobilisation in Ukraine have been extended until 05:30 on 29 January 2027. For employers this means: deferments and reservation of employees are extended automatically, with no new applications, 25 December and 1 January remain working days, and the wartime tax rules continue to apply.

This is the 21st extension, so most rules stay the same. A few things are easy to miss, though: new dates in employees’ e-VOD, updates to military registration lists, work schedules for December and January, and the reconciliation with the TCC (territorial recruitment centre). Below we set out what was adopted, who is affected and what HR and the accountant should do.

What has changed

Laws No. 5029-IX (extending martial law) and No. 5030-IX (extending general mobilisation) of 26 October 2026 were published in the official newspaper Holos Ukrainy on 27 October 2026 and took effect the same day. The new period runs from 05:30 on 31 October 2026 to 05:30 on 29 January 2027, i.e. 90 days. Presidential Decree No. 1060/2026 of 26 October 2026 was also signed. Overview of the consequences for business: news.dtkt.ua.

Six points matter for employers.

Deferments and reservation. Deferments, including those based on reservation, are extended automatically from 31 October 2026. No new applications are needed. However, the deferment date in the electronic military registration document (e-VOD) will change, so employers should obtain updated e-VODs from employees and amend the personal military registration lists.

Reservation procedure. Reservation is governed by Cabinet of Ministers Resolution No. 76 as amended. The latest amendments were made by Resolution No. 1328 of 23 October 2026, effective from 27 October 2026. See our article on employee reservation under Resolution No. 1328.

Employment relations. Law No. 2136 still allows an employment contract to be suspended for up to 90 days. Article 73 of the Labour Code on public holidays does not apply under martial law, so 25 December 2026 and 1 January 2027 are ordinary working days.

Mobilised employees. Since 19 July 2022, employers are not required to accrue average earnings to mobilised employees. They may pay them voluntarily.

VAT invoices. Under Law No. 2876, the deadlines for registering VAT invoices and adjustment calculations in the Unified Register of VAT Invoices are extended: by 5 calendar days for documents issued from the 1st to the 15th of the month, and by 3 days for those issued from the 16th to the end of the month. Penalties for late registration are 2, 5, 10, 15 and 25% instead of 10, 20, 30, 40 and 50%. These rules apply during martial law and for 6 months after it ends.

Inspections. The moratorium on inspections in place since 21 July 2025 does not cover unscheduled inspections or military registration checks carried out by the TCC.

Who is affected

• all employers: LLCs, private enterprises, NGOs and sole proprietors (FOP) with hired staff;
• HR officers and persons responsible for military registration who maintain the personal military registration lists;
• companies with reserved employees or employees with other deferments;
• employers with mobilised employees;
• accountants who register VAT invoices and prepare timesheets and shift schedules for December and January.

What to do and by when

1. Ask employees with deferments to send their updated e-VODs and amend the personal military registration lists.
2. Check the reservation dates for each reserved employee, taking into account the amendments made by Resolution No. 1328.
3. Prepare work schedules and timesheets for December and January with 25 December 2026 and 1 January 2027 as working days. Tell employees in advance.
4. Reconcile records with the TCC by 1 December.
5. Accounting: register VAT invoices and adjustment calculations within the extended wartime deadlines and make sure you do not miss them.
6. If you have mobilised employees, decide whether you will pay them average earnings voluntarily and document the decision.

Common mistakes and risks

• “The reservation has expired, we need to file new applications.” No. Deferments are extended automatically. But the e-VODs and military registration lists do need updating.
• Outdated data in military registration lists. The moratorium does not protect against TCC military registration checks, so any mismatch between the lists and the e-VODs will surface there.
• Holidays in the schedule. If 25 December and 1 January are marked as days off, the timesheet will not match the law, and the errors will carry over into payroll.
• “The moratorium exempts us from all inspections.” No. Unscheduled inspections are still possible.
• Rushing to the old deadlines. The extended deadlines and reduced penalties for VAT invoices apply not only until 29 January 2027 but also for 6 months after martial law ends.

FAQ

How we help

We handle HR records and payroll: we update military registration lists, prepare schedules and timesheets and calculate salaries under the wartime rules. Before an inspection we can carry out an HR audit and show what should be fixed. See HR record keeping, payroll outsourcing and HR audit. Contact us via the contacts page.

Prepared by the MK Audit team