The Pension Fund proposes to legalize representation in the submission of information on employment history: a draft amendment has been published.
The Pension Fund has prepared a draft resolution “On Amendments to the Procedure for Submitting Information on the Employment Activity of Employees, Individual Entrepreneurs, and Self-Employed Individuals in Electronic Form.”
The draft act proposes to revise paragraphs 3 and 4 of the aforementioned Procedure (dated March 12, 2021, No. 11-1, and registered with the Ministry of Justice of Ukraine on June 16, 2021, No. 802/36424).
The main objective is to expand the circle of persons who may submit information on employees’ employment activity.
It is proposed to add the employee’s representative to the list specified in paragraphs 3 and 4 of the Procedure. This is particularly relevant for individuals who have moved abroad and are unable to digitize all necessary employment documents themselves.
Currently, this can be done either by the insurer on behalf of the employee or by the employee (the insured person) themselves.
As before, information on an employee’s employment activity is submitted to the Pension Fund through one of the following methods via the Pension Fund portal: by the employee, the insurer, or the insurer’s representative (this remains unchanged).
The changes will apply to in-person submissions. This may be done by the employee or the employee’s representative upon presenting identification documents and documents confirming the authority to act on behalf of the employee, as well as certified copies of documents that will allow the territorial offices of the Pension Fund to verify the employee’s identity.
This concerns the personal visit of the employee’s representative to the Pension Fund to submit the necessary documents. Digitization via the Pension Fund portal will only be available to the employee themselves through personal authorization. The representative will not have this capability, which is understandable, as any transfer of access rights to personal data could create potential legal risks.
The employee or their representative submits originals of the employee’s employment record book and other documents confirming employment history to the territorial office of the Pension Fund, as specified in the Procedure for Confirming Employment History for Pension Assignment in the Absence of an Employment Record Book or Relevant Entries, approved by the Cabinet of Ministers of Ukraine Resolution No. 637 dated August 12, 1993.
It will also be clarified that the insurer or their representative (or the individual entrepreneur for themselves) must submit missing information on the insured person via the Pension Fund portal regarding membership or non-membership in professional unions and/or individuals subject to mandatory medical examinations.
The proposed amendments are a direct response to the challenges of war and mass migration. As of 2026, verifying employment history for those without access to a qualified electronic signature or a physical Pension Fund office has become critical.
The e-Estonia system and the Polish ZUS have long integrated the institution of trusted representatives into digital offices. In Germany, the right to consult and submit documents through a representative (Rentenberater) is a separately licensed activity.
In the United States, the Social Security Administration allows appointed representatives to manage cases, but the authorization process requires strict multi-factor identification.
Ukraine is moving toward liberalization while attempting to maintain a balance between convenience and the security of Ukrainian legislation.
Author: Taras Luchenko
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