Fighting the shadow economy, or imitation? Will new booking criteria help make salaries official?

The Ukrainian government has reinstated the link between employee reservations and salary levels. Now, companies can get an additional opportunity to reserve employees if they pay salaries two to three times higher than the average in Ukraine.What should the salaries be for booking, and will the government be able to bring remuneration out of the shadows thanks to the new criteria? More details in the journalist's article LIGA.net Volodymyr Fomichov.What criterion has been introduced?To obtain status critical enterprise, which can to book employees, the company must meet three criteria from the list approved by the government. These are: 1.5 million euros in taxes and fees per year, residency in Diia.City, strategic importance for defense, being a permanent representation of a foreign legal entity or media, etc.If a company meets only two of the criteria, the necessary "weight" can be "made up" by a high salary (after previously obtaining the status of an enterprise important for the economy).Yes, according to the new resolution, this will be possible if, in a company with more than 50 employees, their average salary for the last month is twice the average monthly salary in the country for the previous tax year.For companies with 20-49 employees, the requirement is even stricter: the salary must be at least three times higher than the average in Ukraine.The salary criterion is aimed at economically active enterprises that provide a high level of remuneration. This creates conditions for increasing the volume of taxes and the single social contribution, in a comment LIGA.net the press service of the Ministry of Economy noted. According to MP Danylo Hetmantsev, out of 27.6 million working-age people in Ukraine, only 10.6 million pay the unified social tax.A similar salary criterion was already in effect until December 2024; it was reinstated at the request of industry unions, associations, and federations, the ministry's press service noted. The Federation of Employers confirmed the request.What is the logic behind the government's actions? "In the context of ongoing full-scale Russian aggression, the state is objectively seeking a balance between supporting the economy and mobilization tasks," explains Yulian Khorunzhyi, senior partner at the Ario law firm. "Either a person fights or works and supports the economy," says Dmytro Stryzhov, CEO of the Sherif security company holding.But will the government really manage to bring salaries out of the shadows with the help of the new reservation criterion?Read alsoKnee-deep in oil. What really threatens Ukraine after the destruction of the oil depot and port tanksIs there anything to pay with?As of November 2025, the average salary in Ukraine was 27,167 hryvnias per month. Based on this amount, to obtain a reservation for larger enterprises, it must be no less than 54,334 hryvnias, and for those with fewer than 50 employees, it must be 81,501 hryvnias."For businesses, this is both an incentive to come out of the shadows and a financial challenge," says Alina Kalyuzhinova, a lawyer in the business support practice at the Juscutum law firm.According to the State Labor Service of Ukraine, the highest level of shadow employment in 2025 was in the hotel and restaurant business, at 40%. The average salary in the industry in the third quarter of 2025 was UAH 19,138, according to the State Statistics Service.38% of employment in construction is informal. The average salary for the same period is UAH 23,414.32% of undeclared work in trade, with an average salary of UAH 31,275 per month."I don't think this decision will have the 'side effect' of bringing anything out of the shadows," says Oleksandr Sokolovskyi, founder of the Textil-Contact group of companies, "there are no such salaries in the real sector yet."The possible benefit of introducing the new reservation criterion is also called into question by the fact that another norm remains in the list in parallel. According to it, the average salary for the possibility of reservation may be significantly lower than the innovation.This amount should be equal to two and a half times the minimum wage, or UAH 21,617. This rule is still in effect, says Kalyuzhinova from Juscutum.However, according to Stryzhov from Sherif, it will still be possible to bring part of the salaries out of the shadows. In his opinion, the new rule forms a more honest and understandable system of responsibility between business, the state, and society.

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