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Fair and Transparent Pay for Civil Servants: What Was Intended and What Will Change with Law No. 4282

Last week, an event occurred that did not receive widespread media attention but is highly significant for the entire public sector: the President of Ukraine signed amendments to Law No. 4282, introducing unified approaches to the remuneration of civil servants.

Civil servants and civil society had been awaiting this decision since the Revolution of Dignity, when demands for justice and fair, equal pay policies emerged. The draft law was submitted to Parliament in November 2022 and finally adopted on March 11, 2025. Since then, the Law “On Amendments to Certain Laws of Ukraine Concerning the Introduction of Unified Approaches to Civil Servants’ Pay Based on Job Classification” had been awaiting signature and entry into force.

This law will not only improve the civil service remuneration system but also allow Ukraine to receive the next tranche under the Ukraine Facility program.

What will change for civil servants? And why is this law important for institutional development?

We spoke with Andrii Zabolotnyi, an expert from the Centre of Policy and Legal Reform (a member organization of the RPR Coalition) working on the governance, policy development, accountability, and civil service agenda.

What changes for civil servants?

Law No. 4282 introduces the following legislative changes:

Structure and transparency — key benefits of the law

One of the law’s strengths is that it seeks to bring order to the structure of civil service pay and bring it closer to private-sector standards. As Andrii Zabolotnyi explains: “From the outset, the goal was to ensure that the base salary — not unpredictable bonuses — formed the main part of remuneration. This is important for those already in the civil service, to reduce dependence on the manager’s ‘mood,’ and for potential recruits, who deserve to see expected salary levels in job announcements rather than vague promises of ‘bonuses.’ The variable part of salaries — bonuses, seniority pay, compensations — should be limited and predictable.”

Another advantage is the retention of the requirement to approve a unified Procedure for the Formation of the Wage Fund. This is a crucial document to understand how, by what rules, and in what amounts budget funds are allocated to various public bodies. Zabolotnyi notes: “This requirement has existed since 2019 but has not been implemented. As a result, there are major disparities in how the Ministry of Finance allocates funding based on agencies’ budget requests — and risks of non-transparent decision-making.”

A further positive change is the slight but important increase in the minimum salary for district-level civil servants — from 2 to at least 2.5 times the subsistence minimum.

Exceptions and areas for improvement

Work on the law began back in 2020 following the Cabinet’s approval of a concept to reform the pay system. However, at the final stage, after several revisions, civil society had limited access to the current version of the text before the vote, weakening the inclusivity of the process.

According to the CPLR expert, several issues remain: “The law is called ‘on unified approaches,’ but in practice, that’s not quite the case. There are exceptions for specific agencies — including customs, tax, and audit services under the Ministry of Finance, as well as court staff and justice institutions — whose pay is governed by separate laws. Some agencies are entirely excluded, like NABU, the Bureau of Economic Security, and other executive bodies governed by special laws. As a result, employees in these agencies doing the same work — legal support, international cooperation, administration — will still receive different salaries.”

There are also concerns about how public bodies are grouped by “level.” The 2024 European Commission Monitoring Report noted that Ukraine’s classification system had not been fully aligned with recommendations. For instance, the classification into first, second, and third levels does not reflect the content and complexity of job responsibilities — which directly impacts salary levels. It’s also unclear why some bodies, such as the Judicial Protection Service or Maritime Administration, are placed in the same tier as ministries.

“Another serious issue,” Zabolotnyi adds, “is the lack of a control mechanism for job classification. The central executive body for civil service will only verify classifications for a limited number of agencies, while the secretariats of Parliament, the Government, the President, the Constitutional Court, the Central Election Commission, the High Council of Justice, the HQCJ, and others remain outside its scope. There is no alternative oversight mechanism, such as public accountability, either.”

The law also retains a controversial provision allowing the Cabinet of Ministers to set additional wage coefficients for different agencies during martial law or states of emergency, and for six months after they end. “This creates a risk of manual control over salaries — decisions can be made without clear and transparent criteria,” the expert explains.

European Integration Dimension

Ukraine has obligations to its European partners — including under the Ukraine Facility Plan. Adopting this law in Q1 2025 was set as one of the program’s performance indicators.

The Roadmap for Public Administration Reform includes actions to improve the pay system. Its main goal is to make the system more consistent and transparent. A major benefit of this law is that it finally ends the practice of unregulated “incentive” payments — bonuses of 100% or more of salary, unilaterally awarded by managers from savings (including unfilled positions).

“We all remember the cases when some ministries offered sky-high salaries while others offered very little, or when certain top roles had disproportionately high pay. This has long been a sensitive issue both for society and inside the system. That’s why passing this law is a logical and necessary step. Yes, exceptions still remain — but we hope the law will be improved further in the future,” the expert concludes.

The RPR Coalition also congratulates the public administration sector on this milestone and hopes the reform of the pay system will continue.

The material was published within the framework of the project “Democratic Integration, Resilience, and Engagement” (Ukraine-DARE), implemented by Democracy Reporting International (DRI) in cooperation with the Reanimation Package of Reforms Coalition and the Center of Policy and Legal Reforms with the financial support of the Federal Foreign Office of Germany. The project aims to facilitate the approximation of Ukrainian legislation to the EU norms, build a dialogue on the challenges to democracy in Ukraine during the war, and promote civic engagement of young people. The opinions and views expressed in this material do not necessarily reflect the position of the Federal Foreign Office of Germany.

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