New draft law on pensions: how to confirm seniority if archives are destroyed
3 November 2025 17:42
ANALYSIS FROM 
The government has decided to take care of those who, due to Russia’s armed aggression against Ukraine, have lost their paper employment record books and access to the archives of enterprises and institutions, which have mostly been destroyed or remained in the temporarily occupied territories. The Cabinet of Ministers has proposed several options for procedures to restore one’s insurance (employment) record and finally receive a decent pension. But to do this, a citizen will have to go through “seven circles of hell,” as
Thousands of IDPs, mostly from the currently occupied territories, who have worked for the state for decades, cannot receive a pension because they cannot confirm where and how long they worked before July 1, 2000, when there was no personalized record. This effectively deprives people of the right to a pension guaranteed by the Constitution of Ukraine.
The Verkhovna Rada decided to address this problem by introducing a draft law on amendments to the Law of Ukraine “On Compulsory State Pension Insurance” regarding confirmation of insurance record. In fact, this is a revised version of No. 13705 of 27.08.2025, aimed at expanding the mechanisms for confirming work experience, in particular through the use of data from state electronic systems and registers.
This will help restore justice for people who have worked in good faith but lost their documents and facilitate the digitalization of pension procedures. The goal is to simplify and improve the mechanisms for confirming insurance record and assigning (recalculating) pensions for citizens who have lost documents due to war, liquidation of enterprises or loss of archives, the bill says.
The Pension Fund will be obliged to search the archives
Main provisions:
- use of data from state electronic registers (on salary, employment, payment of contributions, etc.)
- the Pension Fund’s obligation to inform citizens about missing data and assist in collecting documents;
- inclusion of periods for which the employer has not paid contributions due to debts in the pension record, if the reports are submitted;
- the ability to confirm the length of service without an employment record book – through archives, a decision of the Cabinet of Ministers or a court.
The adoption of the law will ensure the digitalization of labor records, reduce bureaucratic pressure, and restore social justice in the pension sector.
Collecting evidence will be difficult
Lawyers warn that the path will not be easy. The draft law obliges the Pension Fund to help people collect evidence of seniority, and not just refuse them because they don’t have the documents. At the same time, the person will have to be proactive, especially if the Pension Fund is in no hurry to make a decision.
If there is no work record book and the archival documents have been destroyed or are missing, the length of service can be confirmed in other ways.
This is a difficult but, unfortunately, common situation. The draft law and current legislation provide for several ways, even in case of complete loss of evidence due to the occupation. First of all, you need to check all possible electronic data – in the databases of the Pension Fund and the tax authorities. Even if paper documents have remained in the occupied territory, digital information can be saved. Therefore, the first step is to submit an application to the Pension Fund so that they can make inquiries to all state registers. If there is no official data, you should go to court to establish the fact of work. The court can accept any circumstantial evidence: old photos from work, correspondence with the employer, references in certificates, diplomas, seniority records, as well as testimonies of colleagues or supervisors,” said
[Kommersant] lawyer Valentin Serkov.
“Even if the documents are completely lost, a person is not deprived of the right to a pension – the confirmation procedure will simply be longer and require additional evidence.
If there is no evidence, the draft law provides for the development of a new procedure for confirming seniority in exceptional cases (for example, by decision of the Cabinet of Ministers). This will create a special mechanism for those who have lost their documents due to war or occupation.
In any case, you should contact the Pension Fund in the government-controlled territory and explain the situation – there are now special internal instructions for IDPs and residents of the temporarily occupied territories.
Author – Alla Dunina
Read us on Telegram: important topics – without censorship
