New Rules for Sick Leave Verification: Ukrainian Health Ministry Clarifies Changes Effective April

The Ministry of Health of Ukraine (MOH) has issued a detailed explanation regarding the new amendments to the Law of Ukraine 'On Mandatory State Social Insurance,' which pertain to sick leave certificates. According to reports from Ukrinform, these amendments came into effect on April 1, 2026, and are designed to improve the procedures for the issuance, extension, and verification of the legitimacy of sick leave certificates.

Under the new regulations, the law clearly delineates the roles of authorized employees of the Pension Fund of Ukraine (PFU) and authorized medical professionals. The verification of the legitimacy of the issuance or extension of sick leave certificates will now be conducted by designated officials from the PFU, while medical conclusions regarding temporary incapacity for work (MVTN) can only be verified with the participation of authorized doctors. The requirements for these doctors will be established by the Cabinet of Ministers of Ukraine.

The MOH has noted that no other conceptual changes regarding the verification of legitimacy have been introduced in the law, meaning that previous regulations remain in effect. The procedure for conducting such verifications continues to be governed by the Cabinet of Ministers' resolution dated March 3, 2023, No. 185.

Additionally, medical institutions have gained a new opportunity to appeal decisions regarding the illegitimacy of sick leave certificates in a pre-trial manner. Previously, such appeals could only be made through the courts. The existence of an appeal halts the deadlines for the payment of compensation for insurance benefits and the accrual of penalties. If a reasoned decision regarding the appeal is not sent to the appellant within a specified timeframe, which ranges from 30 to 45 days, the appeal will be considered fully satisfied.

The provision allowing for a counterclaim against the doctor who issued an unjustified medical conclusion remains in effect; however, this claim can now only be made for an amount not exceeding the sum of the paid compensation for the insurance benefit. At the same time, the amount of accrued penalties is not taken into account.

Changes also pertain to insurance payments for paper sick leaves, which are issued exclusively under conditions of martial law. The list of cases in which the issuance of paper sick leaves is permissible remains defined by the MOH order dated June 1, 2021, No. 1066.

Furthermore, the issue of certifying copies of paper sick leave certificates for individuals working part-time under a labor contract while simultaneously engaging in entrepreneurial or other activities has been regulated.

The MOH has also emphasized that currently, the vast majority of sick leaves in Ukraine are processed through digital solutions. Paper sick leave certificates are only used in specific exceptional cases where, for objective reasons, it is impossible to generate an electronic sick leave.

It is worth noting that the Law of Ukraine dated November 5, 2025, No. 4683-IX, which introduces amendments to the Law of Ukraine 'On Mandatory State Social Insurance' regarding the improvement of the procedures for the issuance, extension, and verification of the legitimacy of sick leave certificates and the documents that serve as the basis for their formation, came into effect on April 1, 2026.

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