Ukraine's new OHS law 5007-IX: what changes for business?

The Law "On Labour Protection" was adopted in 1992, and for 34 years every business in Ukraine has worked under it. It contained three definitions. The new law has 45 of them, plus more than 30 references to procedures and lists that do not exist yet. Admit it, this looks a lot like IKEA furniture: the instructions are there, but half the screws are missing from the box.

Important: we are talking about the Law of Ukraine "On Safety and Health of Workers at Work" No. 5007-IX of 12 October 2026 (bill No. 10147). The Verkhovna Rada rejected the draft resolutions to cancel it, and since 21 October the law has been awaiting the President's signature. As of 3 November 2026, we see no newer changes to its status. We analysed the text signed by the Chairman of the Verkhovna Rada. Article numbers are given in brackets so you can easily check them against the primary source. If the status changes, we will update this article.

When will the new law take effect, and should you worry now?

Spoiler: not tomorrow. The law takes effect six months after martial law ends. On the same day, the old 1992 Law "On Labour Protection" will cease to apply. Together with it, the "Labour Protection" chapter of the Labour Code (KZpP) will disappear.

But there is a catch. The Government must adopt all secondary procedures within one year of the law's publication, not of its entry into force. These two dates are not linked to each other in any way. So both scenarios are possible:

• the procedures appear before the law itself, and businesses get time to prepare;
• the law is already in force, but some procedures have not been approved yet. Then the requirement to act "in accordance with the procedure" will refer to a document that does not exist.

So it is too early to worry, but it is exactly the right time to prepare. The main change is not about forms and logbooks but about the very approach to occupational safety.

What changes in substance: from procedures to risks

The current law, of course, also requires safe working conditions. But it rests primarily on fixed procedures: which briefing, how often, who holds which certificate, which equipment needs a permit.

The new law is Ukraine's version of the EU Framework Directive 89/391/EEC and several related directives. At its centre is a cycle familiar to anyone in the EU:

1. Identify the hazards at every workplace.
2. Assess how likely and how serious they are.
3. Decide what to do about them and draw up a plan with owners, deadlines and a budget.
4. Check whether the measures worked.
5. Review the assessment.

Briefings, training and medical examinations are not going anywhere. What changes is this: the employer now justifies on its own who needs them, which ones and how often, based on its own occupational risk assessment. More freedom, but the responsibility for every decision is yours too.

Employer duties: what you will have to do differently

The law lists 24 employer duties and states explicitly that this list is open-ended (Art. 25). Let's go through the ones that will change day-to-day work the most.

Risk assessment and the hierarchy of measures. Article 16 sets the order of actions, and it is a matter of principle:

1. Eliminate the hazard.
2. If that is impossible, replace it with something less hazardous.
3. Install engineering controls: guarding, ventilation, etc.
4. Introduce organisational measures.
5. Only as a last resort, issue personal protective equipment (PPE): helmets, gloves, respirators.

In other words, handing out a respirator instead of fixing the extraction system will no longer work. Risks for pregnant workers, minors and people with disabilities are assessed separately. If you still don't have a risk map, start right there. Occupational risk assessment will be the foundation on which the entire new law stands.

Incident records. You will also have to record cases where nobody was hurt. A real-life scenario: in one week, a forklift passed within centimetres of a storekeeper three times. That is three incidents, and in each one you have to establish the cause. The employer chooses the recording format after consulting the workers.

Medical examinations based on your own list. Who undergoes medical examinations and how often is determined by the employer based on the risk assessment results. But there are mandatory categories:

• workers under 21 (annually);
• those exposed to harmful factors;
• night workers;
• those who have complained about their health due to working conditions.

Medical examinations are paid for by the employer, held during working hours and with pay retained.

Training and briefings. Training with a knowledge test becomes mandatory for only three groups: those performing hazardous work, those responsible for safety, and managers who organise such work. All other workers receive briefings. The familiar "once every three or six months" gives way to a frequency set by the employer. For hazardous work, the Government will set minimum requirements.

High-risk work: three routes (Art. 11). The new list of such work will be approved by the Government.

• Permit. Issued on the basis of an accredited expert review, free of charge and with no expiry. The State Labour Service (Derzhpratsi) must respond within 10 working days. If there is no response, work may start after another 10 working days by tacit consent.
• Declaration. Registered within 5 working days, and registration cannot be refused.
• Life and health insurance for workers. This is a new option. In our view, it is an odd one: insurance pays out after an accident, while the expert review checks whether the company is ready to prevent it.

Attention: read the grounds for terminating a permit carefully. The first ground is a fatal or group accident with severe consequences related to the permitted work. The employer's fault is not named as a condition. The second is "documented" obstruction of inspectors, but the law does not specify who confirms this and how. If one permit covers several sites, an event at one site can stop work at all of them. That is why it is worth keeping expert review, training and supervision records in order separately for each site.

High-risk equipment. The operating permit will be replaced by a free electronic notification to Derzhpratsi and mandatory technical inspections by accredited organisations. How simple this notification will be, the future procedure will show.

An independent audit every five years is mandatory for those performing high-risk work. The findings must be provided to Derzhpratsi on request within 10 working days, and workers must be made aware of them. Other companies may carry out the audit themselves.

Shared sites. If tenants, contractors or a cleaning company work on the same premises, employers must coordinate and warn each other about risks. For business centres, warehouses and construction, this is probably the most practical provision in the law.

A budget with no minimum. Previously, at least 0.5% of the payroll had to be spent on occupational safety. Now there is no fixed percentage, and spending must be sufficient, with no fixed minimum. For an office of five people, a few thousand hryvnias a year may be enough, while for a workshop with presses even hundreds of thousands are too little. The argument "the budget has already been approved" no longer works. Your risk assessment will tell you how much to spend, and the inspector will check it.

Who will be responsible in the company: the designated safety officer

The occupational safety service gives way to the "designated safety officer" (in EU Directive 89/391/EEC terms, the designated worker). This is a function, not a job title. Depending on the size of the company, it is performed by an employee, a department, a sole proprietor (FOP) or an external company (see the table).

So companies with up to 50 employees and no high-risk work will be able to hand this role over entirely to an external provider. Currently, the threshold is lower: fewer than 20 people. The qualification requirements for designated safety officers and outsourcing companies will be set by the Government.

If you have over 50 employees or high-risk work, this does not mean "go find an engineer yourself." The designated safety officer or department must be on your payroll, but the law explicitly allows engaging an external company at the same time (Art. 15(2)). This is how we already work with companies from 20 employees: we provide you with a specialist, you hire them onto your staff, and our team stands behind them. The team runs the system day to day and covers the work during holidays or sick leave. After the reform, the model stays: instead of an OHS engineer, it will be a designated safety officer, and for large companies, several specialists around whom a department is built. Once the Government approves the requirements for designated safety officers, we will adjust the model to them.

The designated safety officer must be "professionally independent" of the employer, even though the employer may pay their salary. The law does not explain what this means. We build independence into the order defining their powers and into direct reporting to the company's head, not to the shop manager whose work the designated safety officer checks.

Important: an external company does not take your responsibility away. The new law establishes the principle of the employer's full responsibility (Art. 4(2)(2)). The provider's liability is defined by the contract and insurance. That is why the contract must clearly describe tasks, deadlines, access to information and the limits of liability. This is exactly how our OHS outsourcing is built: a dedicated engineer is assigned to you, and their tasks are set out in the contract.

The law also gives employers several new tools:

• monitoring safety with technical means, such as cameras, provided workers are warned in advance;
• suspending, without pay, a worker who refused a medical examination, briefing or training;
• refusing to hire a candidate who refused a pre-employment medical examination or was found unfit, and the law explicitly does not treat this as discrimination;
• dismissing a worker who has failed a knowledge test twice (but there is no direct ground for this in the Labour Code (KZpP), so the risk of reinstatement by a court is high);
• requiring a sobriety test;
• receiving free consultations from Derzhpratsi.

The law sets only minimal limits for cameras and sobriety tests: warn workers, do not violate their dignity, document the requirement. Who sees the results and how to challenge them is not stated. The employer receives a medical opinion on fitness and restrictions, not a diagnosis.

What changes for workers

Workers get the right to safe conditions, free PPE, information about risks, and training in accessible formats. They can refuse work that threatens their life and leave the workplace in case of serious danger without any consequences. Their duties are clear too: follow instructions, complete training and medical examinations, not disable protective devices, and report threats immediately.

But some guarantees from the old law have moved to other acts, and some seem to have been lost:

Article 22 of the Constitution prohibits narrowing existing rights when new laws are adopted. So these points may become grounds for constitutional complaints. Practitioners' advice is simple: don't rush to cut benefits from your collective agreement, and don't engage minors on days off. Being the first party to a court case is hardly a winning position.

Inspections and fines: what to expect from Derzhpratsi

Under the new law, an inspector may require changes within a reasonable period and, in case of immediate danger, stop work at once. Whether to fine or limit themselves to advice, the inspector decides "by their own conviction." The law gives no criteria, so identical violations at two companies may end differently.

The new law does not define the grounds, duration or procedure for inspections. At the same time, after martial law the new Law "On the Basic Principles of State Supervision (Control)" No. 4840-IX will also take effect. In other words, the new occupational safety rules will operate within a new supervision system that nobody has yet seen in action.

Now the good news. Derzhpratsi will advise businesses free of charge and, at the employer's request, carry out a "status analysis." This is an inspection without penalties: if you fix the violations within the set deadline, there will be no fine. One caveat: the analysis is carried out subject to the authority's resources, so it is not a guaranteed service.

Fine amounts are tied to the minimum wage on the day the violation is detected (Art. 35). For our calculation, we used the 2026 minimum wage of UAH 8,647:

• Overall range: roughly from UAH 8.6 thousand to UAH 346 thousand.
• 1 minimum wage (UAH 8,647): high-risk equipment without notification or technical inspection (per unit), failure to inform workers and failure to hold consultations (one-off), workplace certification not carried out (per workplace).
• Multiplier: many fines are calculated per workplace or per worker, so the total grows quickly.
• Mitigation: reduction coefficients are provided for small businesses, and if you pay within 10 banking days, half the amount is enough.

Check the full table of sanctions against the current version of the law once it is published.

Where the law has contradictions and gaps

Any framework law has blind spots. This one has noticeably more than we would like. Here is what we found:

• The term "labour protection" has not gone anywhere. It remains in the Criminal Code, the Tax Code and the Code of Administrative Offences (KUpAP). The law contains no provision that directly equates it with "safety and health of workers." This affects, among other things, the tax relief for workwear and PPE.
• The law's title. In Ukrainian law, "health protection" belongs to the medical field, and the law itself mentions two different bodies for two different kinds of "health protection."
• High-risk work in a small company. One provision requires an in-house designated safety officer even for 10 employees, while another allows everyone with up to 50 people a fully external provider. A solution that satisfies both provisions at once: your own designated safety officer with an external team alongside.
• Dismissal on health grounds. The new rules on transfer and compensation are not aligned with the KZpP.
• The right to leave a dangerous workplace is worded differently in different articles. How a commission will assess a decision a person made in a few seconds, practice will show.
• Permits and standards under the old law. Their future requires separate attention. Also gone are the deferral mechanism for when hazardous conditions cannot be eliminated immediately and the duty to review NPAOP (labour protection regulations) at least once every 10 years.

Some of this will be clarified by Government procedures, and some will most likely be settled by the courts. We track every new document, and clients on our ongoing support receive updated orders and instructions without having to ask.

FAQ

Do we need to rework our documents right now?

Rewriting everything for a law that has not yet taken effect makes no sense. But a risk assessment, incident records and a list of workers for medical examinations will be needed in any scenario.

Will it be possible to fully outsource occupational safety?

Yes, if you have no more than 50 employees and no high-risk work. If you have more employees or such work, the designated safety officer must be on your payroll, but an external team can run the system together with them: the law explicitly allows this (Art. 15(2)). In both cases, responsibility stays with the employer.

Will briefings disappear?

No. Only the fixed frequency for most workers will disappear: the employer will set it based on the risk assessment.

We already have an OHS engineer. What happens to them?

Nothing needs to be broken. The engineer can become the designated safety officer: we will update the order assigning duties and the job description for the new functions. If the Government sets additional qualification requirements, we will tell you what further training is needed. If there is one engineer and the system is large, an external team can be placed alongside them.

Will previously issued permits remain valid?

This is one of the open questions. Don't get rid of them: transitional rules have not been set yet.

Conclusion

The new law counts paperwork less and asks more about real risks. And that is something you can learn today. Make a list of workplaces and their hazards, start recording near misses, and review your contracts with contractors on shared sites. If you want to see your weak spots through an inspector's eyes before the first inspection, an OHS audit will help: a checklist of 220+ items, a report on risks and an action plan.

If you have read this far and realised that the "designated safety officer" in your company exists only on paper for now, we are ready to take this area off your hands for any number of employees: up to 50 with no high-risk work, fully under contract; in other cases, together with your in-house designated safety officer, whom we will help you find. With OHS outsourcing, a dedicated engineer will run the system for your company, and during OHS documentation development we will prepare orders, instructions, regulations and logbooks tailored to your business. Get in touch — we definitely have a rational solution for you.