Staffing structure: how to draw it up, approve it and amend it

As of 28 August 2025, the provision of the Commercial Code requiring enterprises to maintain a staff establishment plan ceased to be in force. This has sparked a debate: the State Labour Service considers the document to be merely advisable, whilst the Ministry of Economy still regards it as mandatory. At the same time, the requirements for public sector organisations and educational institutions remain unchanged. In this article, we examine who is actually required to draw up a staffing table, the format in which it should be prepared, how to approve it by order, and what to take into account when reducing the number of posts.
What is in this article
Injobe
Job search platform
14 min to read
5 October 2026
Updated 1 October 2026
Staffing structure: how to draw it up, approve it and amend it

In brief

  • There will be no specific provision requiring a company to have a staffing table from 28 August 2025: with the Commercial Code (No. 436-IV), Part 3 of Article 64 ceased to have effect.
  • In August 2025, the State Labour Service and the Ministry of Economy provided conflicting responses regarding themandatory nature of the document. For state-funded institutions, the obligation remains: the staffing table is approved by the head of the higher-level institution at the same time as the budget estimate (paragraphs 32 and 37 of Order No. 228).
  • The approved form is the ‘Staffing Table for ___’ as set out in Ministry of Finance Order No. 57; for self-financing enterprises, the form is at their discretion. For state and municipal nurseries, new standard norms will come into force on 1 September 2025 (Order No. 844 of the Ministry of Education and Science), whilst the repealed Order No. 1055 is no longer applicable.

What is a staffing table?

A staffing table is a document that establishes the structure, staffing levels and basic salaries of employees for an enterprise, institution or organisation (definition from the letter from the Ministry of Social Policy dated 22 March 2012 No. 42/06/186-12).

‘Staffing table’ or ‘schedule’. The official name is staffing table: this is precisely how the document is referred to in Form No. 57 of the Ministry of Finance’s Order, Procedure No. 228, List No. 578/5 and letter No. 42/06/186-12. The term ‘staff schedule’ is not used in these acts.

What has changed since 28 August 2025

Until 28 August 2025, the document was referred to in Part 3 of Article 64 of the Commercial Code (No. 436-IV):

‘An enterprise shall independently determine its organisational structure, establish the number of employees and the staffing table’.

The Code was repealed by Law No. 4196-IX of 9 January 2025. The new law did not carry over the provision on the staffing table, whilst the Labour Code (Labour Code) and the Law ‘On Remuneration’ do not contain such a requirement.

State authorities responded to this legal loophole in different ways (with a 12-day difference):

  • The State Labour Service (letter dated 7 August 2025 No. 2983/2.3/2.1-25a): there is no explicit requirement for a staffing table in labour legislation; however, ‘we consider it appropriate for an employer to have a staffing table’.

  • Ministry of Economy (letter dated 19 August 2025 No. 4701-05/55169-09): “the approval of a staffing table at an enterprise is mandatory” — with reference to the Rules on the Organisation of Record-Keeping (Ministry of Justice Order No. 1000/5) and other acts in which the document is mentioned.

The texts of both letters have not been published on the Verkhovna Rada’s portal — they are known from publications in specialist journals. Please note: the letter is of an explanatory nature and is not a regulatory act.

Who is required to have a staffing table

The employerIs it mandatoryGrounds
Public sector organisationYesclauses 32 and 37 of Order No. 228
State or local authority pre-school education institutionNumber of posts — in accordance with standard staffing normspara.1 of the Standard Staffing Norms, Order No. 844 of the Ministry of Education and Science
General secondary education institutionNumber of posts — in accordance with standard staffing norms (excluding boarding schools, sanatorium schools, social rehabilitation schools, evening schools and special schools)para. 1 of the Standard Staffing Norms, Order of the Ministry of Education and Science No. 1205
Enterprise, institution, organisationNo direct provision since 28 August 2025Part 3 of Article 64 of the Commercial Code has ceased to have effect
Sole traders with employeesNo specific provisionLetter from the Ministry of Social Policy dated 21 May 2019 No.34/0/23-19/133

State-funded institutions

The procedure, approved by Resolution of the Cabinet of Ministers of Ukraine No. 228 of 28 February 2002, requires that staffing tables be approved by the head of the institution of the highest level (para. 32; exceptions — para. 33 and para. 35) at the same time as the budget estimate (para. 37(2)).

Sole traders and private companies

Labour legislation does not oblige sole traders to have a staffing table — this is also confirmed by the position of the Ministry of Social Policy (letter No. 34/0/23-19/133 dated 21 May 2019). Previously, the Ministry held the opposite view: letter No. 5907/0/10-16/06 described the document as mandatory for all business entities. The text of the 2019 letter is not available on the Verkhovna Rada’s website — it is known from secondary sources.

For enterprises, institutions and organisations, there will be no explicit provision from 28 August 2025, so the decision on whether to maintain a staffing table rests with the employer. However, the practical significance of the document remains: without it, it is more difficult to justify the abolition of a post in the event of an employee’s dismissal under paragraph 1 of Article 40 of the Labour Code.

Format and template for the staffing table

An approved format exists only for state-funded institutions. Order No. 57 of the Ministry of Finance dated 28 January 2002 approved the forms ‘Staffing Table for the year ___’ and ‘Standard Staffing Table for the year ___’.

Approval stamp:

I hereby approve the staffing level of ____ posts with a monthly wage bill based on basic salaries of ______ hryvnias

________ (post) ________ First name SURNAME (signature)

‘___’ ________ ____ M.P.

Form — six columns:

No.Name of organisational unit and postsPost classification codeNumber of postsSalary (UAH)Monthly wage bill based on salaries (UAH)
1_______________________
Total—x___x____

For self-financing enterprises, the form has not been officially approved: a note to the form states that it ‘is drawn up by state administration and local self-government bodies’.

How to draw up a staffing table: step-by-step guide

Procedure for self-financing employers (in budgetary institutions, remuneration is paid in accordance with Cabinet of Ministers decrees within the limits of budgetary allocations pursuant to Part 1 of Article 13 of Law No. 108/95-VR):

  1. Set out the structure: prepare a list of departments and the posts within each of them.
  2. Verify the job titles with the DK 003:2010 Classification of Occupations.
  3. Specify the number of staff posts for each post.
  4. To establish basic salaries (in accordance with Article 15 of Law No. 108/95-VR).
  5. Calculate the wage bill per month based on salaries and enter the amount in the approval field.
  6. Approve the document by order by the head of the organisation, specifying the date of entry into force.

Order on the approval of the establishment plan

The staffing table is approved by the head of the organisation by issuing a special local regulatory act (order) (letter from the Ministry of Social Policy No. 42/06/186-12).

Example of an order:

LIMITED LIABILITY COMPANY ‘___’

ORDER

‘___’ ____________ ____, ___ No. ___

On the approval of the staffing table

I HEREBY ORDER:

  1. To approve the staffing table of ‘___’ Ltd comprising ___ posts, with a monthly wage bill based on basic salaries totalling ___ hryvnias.

  2. To bring the staffing table into force from ‘___’ ____________ ____.

Director ___________ (Signature / First name, SURNAME)

The frequency of approval for self-financing enterprises is not specified in the regulations: the staffing table is amended in the event of changes to the structure, posts or salaries. The title of Ministry of Finance Form No. 57 ‘Staffing Table for the year ___’ is linked to the financial year for budgetary institutions.

Job titles, salaries and trade union approval

Job titles are checked against the National Classifier of Ukraine DK 003:2010 ‘Classifier of Professions’ (Order of the State Consumer Standards Service No. 327 of 28 July 2010).

An enterprise’s salary scales, allowances, supplementary payments and bonuses are established in the collective agreement in compliance with the provisions and guarantees set out in legislation (Part 1 of Article 15 of the Law ‘On Remuneration’ No. 108/95-VR of 24 March 1995).

In the absence of a collective agreement, these are agreed with the elected body of the primary trade union (or an authorised representative of the workforce). The staffing table itself, as a separate document, does not need to be approved — it is the content relating to remuneration that is subject to approval.

The ‘Basic Salary’ column is linked not to the minimum wage, but to the living wage. In accordance with Article 6 of Law No. 108/95-VR:

‘The minimum post salary (pay scale rate) shall be set at a level not lower than the subsistence minimum established for able-bodied persons as at 1 January of the calendar year’.

The minimum wage provides a different kind of guarantee: in accordance with Article 3-1 of Law No. 108/95of the Verkhovna Rada, the total monthly remuneration accrued for the work performed must not be lower than the minimum wage, rather than the salary specified in the staffing table itself.

How to amend the staffing table

The legislation does not establish a separate procedure for making amendments: changes are formalised in the same way as approvals — by an order of the head of the organisation.

The requirement for reducing posts is clear: a new staffing table must be drawn up and approved (or amendments made to the existing one), removing the posts that have been cut.

What changes to the establishment plan mean for an employee

A reduction in the workforce or in the number of posts constitutes grounds for termination of the employment contract under paragraph 1 of Article 40 of the Labour Code. An employee whose post is being made redundant must be given personal notice no later than two months in advance (Article 49-2 of the Labour Code), taking into account the right of priority to remain in employment (Article 42 of the Labour Code).

During the period of martial law, Part 2 of Article 5 of Law No. 2136-IX of 15 March 2022 ‘On the Organisation of Labour Relations under Martial Law’ provides that the provisions of Article 43 of the Labour Code (regarding trade union consent to dismissal) shall not apply, except in cases of dismissal of employees elected to trade union bodies.

Staffing table for schools and nurseries

The number of posts in educational establishments is determined by the standard staffing norms of the Ministry of Education and Science:

InstitutionDocumentStatus
General secondary education institutions (GSEI)Order of the Ministry of Education and Science No. 1205 of 6 December 2010in force, version dated 11 July 2025
Pre-school education institutions (PSE)Order of the Ministry of Education and Science dated 12 June 2025 No. 844in force from 1 September 2025
Pre-school educational establishmentsOrder of the Ministry of Education and Science dated 4 November 2010 No. 1055ceased to have effect on 1 September 2025

Templates and calculations for early years education institutions (ZDO) based on Order No. 1055 are now obsolete — they must be checked against the new Order No. 844.

Liability for the absence of a staffing table

The Code of Administrative Offences does not contain a separate provision specifically regarding a fine for the absence of a staffing table. Part 1 of Article 41 of the Code of Administrative Offences provides for liability for ‘other breaches of labour legislation’: the fine for officials of enterprises and sole traders ranges from 30 to 100 non-taxable minimum incomes.

Prosecution under this article is only possible if an inspector proves a breach of a specific provision of labour legislation. Breaches of Order No. 228 concerning staffing tables for budgetary institutions fall under budgetary legislation.

During martial law, restrictions apply to the conduct of inspections in accordance with CMU Resolution No. 303 of 13 March 2022.

Financial penalties imposed on employers under Article 265 of the Labour Code are not discussed here: as we were unable to verify the current version of this article against the primary source, we do not provide the amounts of the fines under it.

Salary in the staffing table: an example from Injobe

The employer fills in the ‘salary’ column with the amount they will actually pay for the post. When a post in the establishment plan needs to be filled, the vacancy is posted in the Injobe employer’s dashboard.

Electronic staff establishment plan

There is no specific provision regarding the electronic staff establishment plan. The general rule set out in Part 1 of Article 8 of Law No. 851-IV of 22 May 2003 ‘On Electronic Documents and Electronic Document Flow’ applies:

‘The legal validity of an electronic document cannot be disputed solely on the grounds that it is in electronic form’.

According to the Rules on the Organisation of Document Management (Order of the Ministry of Justice No. 1000/5), staffing tables are classified as organisational documents. It is important to note that the simultaneous circulation of the same document in both electronic and paper form is not permitted (Section III, Chapter 1, paragraph 2 of the Rules No. 1000/5).

A qualified or enhanced electronic signature or seal is used to sign an electronic staffing table.

How long should the staff establishment plan be retained?

In accordance with Article 37 of the List of Standard Documents (Order of the Ministry of Justice No. 578/5 of 12 April 2012), retention periods vary depending on the organisation’s status:

Where it is storedType of organisationRetention period
At the place of drafting and approvalinstitutions in whose activities documents of the National Archival Fund are createdpermanently
At the place of drafting and approvalat the institution where National Archival Fund documents are not created75 years
In other organisationsthe organisation holding a copy of another organisation’s records3 years

This material reflects the state of legislation at the time of preparation and is for information purposes only. To resolve specific personnel issues, we recommend seeking legal advice or submitting a written enquiry to the State Labour Service.

Looking for a job right now?
Browse jobs
logo
For candidates
For employers
Sign in
If you don't have an account, one will be created when you log in for the first time.
Sign in with popular services:
Or use email and verification code:
Just one step to your dream job!
Log in to the system and get full access to the functionality. Fill in your personal and company information after logging in.
helpNeed help?
logo
Sign in
If you don't have an account, one will be created when you log in for the first time.
Sign in with popular services:
Or use email and verification code:
Log in and let's continue!
This feature requires authorisation. It's fast!
helpNeed help?
Injobe logo