This Resolution of the Pension Fund of Ukraine No. 16-1 dated April 28, 2026, introduces systemic changes to the procedures for administering pension contributions, specifically regarding the reimbursement of expenses for privileged pensions and the application of financial sanctions. The document transitions the interaction between the Pension Fund of Ukraine (PFU) and payers to a digital format, establishing the legal validity of electronic document management via the web portal of electronic services. Furthermore, the mechanisms for accruing interest and collecting fines have been updated to align them with modern administrative procedure requirements.
### Structure and Main Provisions
The Resolution amends four sections of the Instruction (No. 21-1 of 2003):
* **Chapter 6 (Privileged Pensions):** Electronic exchange of calculations of actual expenses has been introduced. If a payer does not open the electronic document within two days, the PFU is obligated to send it via registered mail. The procedure for handling bankrupt enterprises and those located in occupied territories has also been clarified.
* **Chapter 8 (Arrears):** The procedure for accounting for demands for the payment of arrears and the procedure for their delivery (in person against signature or via registered mail) have been updated.
* **Chapter 9 (Financial Sanctions):** This section has been completely updated. The grounds for imposing fines, the procedure for appealing them (including the administrative procedure in accordance with the Law “On Administrative Procedure”), and the status of the PFU decision as an enforcement document are clearly defined.
* **Chapter 10 (Interest/Penalty):** The procedure for the simultaneous adoption of decisions on the accrual of interest and the application of financial sanctions has been clarified.
### Key Provisions for Practical Use
1. **Electronic Document Management:** Calculations sent via the electronic cabinet on the PFU web portal are considered received from the moment the electronic receipt is recorded. This is critical for compliance with appeal and payment deadlines.
2. **Appealing Sanctions:** Appealing a decision on a fine suspends the deadline for its payment until a decision on the complaint is issued or a court ruling enters into legal force.
3. **Enforcement Document:** A decision on the application of financial sanctions is now explicitly defined as an enforcement document. If the amount is not paid within 10 working days and has not been appealed, it is referred to the State Executive Service.
4. **Statute of Limitations:** It is important to remember that statutes of limitations do not apply to the collection of financial sanctions.
5. **Specifics for Bankrupt Entities:** For enterprises for which liquidation proceedings have been initiated, calculations of actual expenses for privileged pensions are no longer sent.
