Law of the Republic of Belarus No. 138-Z dated April 16, 2026, substantially increases administrative liability for employers for violations in the field of labor relations.

The amendments will enter into force on June 19, 2026.

What violations are affected by the adopted changes?

1. Liability for «hidden» employment relationships and their substitution with civil law contracts

Actual admission of an employee to work without a written employment contract now entails significant financial penalties:

• for an official: up to 50 base units (in case of repeated violation – up to 100 base units*);

• for a legal entity: up to 100 base units (in case of repeated violation – up to 300 base units).

* 1 base value amounts to BYN 45 (approximately €12.50).

Please note: substituting employment relationships with civil law contracts when there are actual signs of employment may cost the company extremely dearly. Reclassification of contracts entails not only fines, but also additional assessment of taxes and insurance contributions for the entire period of the “hidden” employment relationship.

2. Wages under strict control

Limits on executive salaries:

If the director’s salary exceeds the ratio coefficient relative to the average salary in the organization, the fine for the legal entity will amount from 100% to 200% of the excess amount.

For reference: The ratio coefficient between the salary of the head of an organization and the average salary across the organization as a whole may not exceed 8 (Clause 2.1 of Resolution of the Council of Ministers of the Republic of Belarus dated July 8, 2013 No. 597 «On improving remuneration conditions for heads of organizations depending on financial and economic performance»).

Payment deadlines:

Failure to pay or delay of any payments to an employee (salary, vacation pay, final settlement) entails a fine of up to 50 base units, and in case of repeated violation – up to 100 base units.

3. Working and rest time under close scrutiny

Direct liability has been established for failure to comply with procedures for granting leave, violations in work schedules, and exceeding overtime limits.

Sanction: a fine for an official from 2 to 20 base units.

4. Other violations: the «catch-all» provision

A general provision remains in force for all labor law violations that caused harm to an employee but are not covered by specific articles (Clauses 1–10 of Article 10.12 of the Administrative Code).

It is important to understand what constitutes harm to an employee:

in the context of Article 10.12 of the Administrative Code, this includes not only direct financial losses (such as unpaid wages or compensation). It is a broader category that includes infringement of rights established by law; creation of obstacles to the exercise of labor rights or lawful interests that result in adverse consequences for the employee’s social or legal status.

Therefore, almost any violation may fall under this category: from errors in maintaining employment record books to violations of disciplinary procedures. The fine may amount to up to 20 base units.

Our recommendations:

1. Conduct an audit of civil law contracts to assess the risks of their reclassification.

2. Verify executive salary ratios against the current financial indicators of the organization.

3. Review vacation schedules and working time records for compliance with applicable labor legislation.

Still have questions? We are ready to assist you and help to minimize the risks to your business.