Indexation is the smallest line on a Ukrainian payslip and one of the easiest to get wrong. In September and October 2026 it is worth at most UAH 139.78 a month per person. Miss it, and the fine is two minimum wages, UAH 17,294, for every employee affected.
Most employers do not skip indexation on purpose. They carry an old base month, or they raise a salary and never compare the rise with the indexation due that month. On 1 January 2026 the count restarted, which makes this a good month to check.
What changed on 1 January 2026
Article 41 of the State Budget Law for 2026 (Law No. 4695-IX of 3 December 2025) resets the calculation: the consumer price index used for indexation is counted cumulatively from 1 January 2026. In practice that means three things.
- January 2026 is the base month for everyone. It does not matter whether a salary was raised that month.
- The index starts adding up from February 2026. Anything accumulated before 2026 is gone.
- December 2025 does not carry over. An employee who received indexation in December 2025 has no automatic right to it in January 2026.
How the amount is set
Three rules decide what you pay, and the third one surprises people.
- The threshold. Indexation is due only once the index, counted cumulatively from the base month, passes 103%.
- The ceiling. Only the part of the salary within the living minimum for able-bodied persons is indexed. In 2026 that is UAH 3,328 a month. Everything above it is not indexed.
- The same money for everyone. Because of the ceiling, someone on UAH 15,000 and someone on UAH 40,000 receive exactly the same indexation.
Where it stands in September and October 2026
| Base month | Coefficient | Amount per month |
|---|---|---|
| January 2026 | 4.2% | UAH 139.78 |
| February 2026 | 3.1% | UAH 103.17 |
| March to July 2026 | Not yet due | None |
The amount is the living minimum multiplied by the coefficient: 3,328 × 4.2 ÷ 100 = UAH 139.78. The index from February to April 2026 reached 104.2% and passed the threshold. Nothing has changed since June: July added 100.3% and August 100.1%, so September and October 2026 carry the same coefficients.
The mistake that costs the most
A pay rise changes the base month, and that is where the arithmetic goes wrong.
- Rule 1A rise moves the base monthThe count starts again from the month after the rise.
- Rule 2Compare the rise with the indexation dueIn a month when indexation is already payable, put the two side by side.
- Rule 3A shortfall does not disappearA rise of UAH 100 against UAH 139.78 leaves UAH 39.78 as fixed indexation, paid every month until a later rise covers it.
- Rule 4Bonuses are not a riseRaising a bonus or an allowance while base pay stays flat does not move the base month.
One more trap: for someone who joined during the year, the base month is the last rise for that position, not their first working day.
What it costs to miss it
Indexation is not a courtesy. It is a minimum state guarantee under Article 95 of the Labour Code and Articles 12 and 33 of the Law on Remuneration of Labour. Breaching a minimum state guarantee carries a fine under Article 265 of the Labour Code of two minimum wages for each employee affected, which is UAH 17,294 in 2026, and the unpaid amounts still have to be paid on top.
The sums are small per person and large per inspection. Fifty employees who should have received indexation since February turn a line worth under UAH 140 a month into a six-figure exposure.
Five checks, about ten minutes
- What is the base month for each position? After the reset, most should be January 2026, unless pay was raised later in the year.
- Is anyone still carrying a base month from 2025? That is the clearest sign the January reset was missed.
- Does the payslip show indexation on its own line? In September and October 2026 it should be up to UAH 139.78, not folded into something else.
- Were rises compared with the indexation due that month? Look for any shortfall that should have stayed as fixed indexation.
- Are mid-year joiners using the position’s last rise as their base month?
Want to know where else you stand? Our payroll risk self-check asks fifteen questions, including this one. It runs in your browser and sends us nothing.
If you would rather hand the whole calculation over, read about payroll outsourcing.
Figures are those in force in September and October 2026: minimum wage UAH 8,647, living minimum for able-bodied persons UAH 3,328. Coefficients change as the consumer price index is published each month, so check the current month before you pay. This is general information, not legal advice.
This is the general position. Yours will have specifics.
Thirty minutes on a call and we can tell you which parts of the above actually apply to your company, what getting them wrong would cost, and what we would do about it. No slides, no obligation, and we will say so if you do not need us.
