Historically, asylum applicants have enjoyed only very limited access to work in Ukraine. In order to legally employ an asylum applicant, employers had to offer a salary ten times higher than the Ukrainian minimum wage. In September 2022, the Parliament changed the law to suspend this rule.
Thus, the present algorithm for hiring an asylum applicant is the following:
Asylum applicants in Ukraine have the right to be employed in Ukraine with a work permit for foreigners and stateless persons, which is issued to the employer.[1] The permit is issued by the territorial body of the Employment Centres within seven business days and is free of charge.[2] The permit is issued for the period of validity of the MSID, but not more than one year. The permit may be extended if the MSID is renewed. In 2024, Employment Centres issued three such work permits,[3] while in 2025 this number increased to twelve.[4]
One of the obstacles for asylum applicants to be employed is the absence of a TIN, as a person needs to possess an ID for a TIN to be issued. An asylum applicant can obtain a verified by the SMS copy of their ID, which is kept in the SMS and receive a TIN based on this copy. In case of the absence of any ID or verified copy, the TIN cannot be issued.[5]
The issuance and extension of work permits for citizens of the Russian Federation, the Republic of Belarus, as well as other states recognised as posing a threat to Ukraine, is carried out in coordination with the regional bodies of the Security Service of Ukraine.[6] This requirement was added after the full-scale invasion of Russia. Employers often are not willing to hire Russians and Belarusians because of this provision.[7]
On 14 November 2025, the Cabinet of Ministers of Ukraine submitted to the Verkhovna Rada of Ukraine Draft Law No. 14211 of 14.11.2025 “On Amendments to Certain Laws of Ukraine Regarding the Employment of Foreigners and Stateless Persons.” The draft proposes amendments to several Ukrainian laws with the aim of introducing a single document granting the right to reside and work in Ukraine, as well as abolishing work permits for foreigners and stateless persons.[8]
The main concern on the aforementioned draft law is that if work permits for foreigners and stateless persons are abolished without including asylum seekers and without eliminating other obstacles, these categories may effectively lose the right to temporary employment prescribed under paragraph 1 of part 1 of Article 13 of the Law of Ukraine “On Refugees and Persons in Need of Additional or Temporary Protection.”
[1] Article 24 Law on Employment.
[2] Diia, Work Permission for Foreigners and Stateless Persons, available in Ukrainian here.
[3] SES’ responses to the R2P request for public information, April 2025.
[4] SES’ responses to the R2P request for public information, January 2026.
[5] Section III(1)(3) Regulation on the Registration of Individuals in the State Register of Individuals-Taxpayers.
[6] Article 24 Law on Employment.
[7] R2P observations.
