On April 23, 2026, the Cabinet of Ministers of Ukraine initiated amendments to the Law of Ukraine “On the Civil Service” to regulate certain aspects of civil service and improve the disciplinary proceedings process (Bill No. 15190).

What exactly is being proposed to change?

A new approach to civil servants’ explanations. The current version of Article 75 of the Law requires the appointing authority to obtain a written explanation from a civil servant before imposing a disciplinary sanction. In contrast, the bill proposes granting the civil servant the right to submit an explanation within a specified time frame. In such a case, it becomes critically important for the employer to document the very fact of notifying the civil servant that they have been granted this “right.” The Supreme Court, in its ruling of June 7, 2023, in Case No.140/16991/20, concluded that failure to properly notify a civil servant of disciplinary proceedings and depriving them of the opportunity to submit an explanation constitutes an independent and sufficient ground for annulling the results of such proceedings. This is particularly important in light of the proposed expansion of electronic communications.

Electronic evidence as the new standard. The draft law specifies that information or documents shall be sent to a civil servant at their place of residence or stay, to their email address, or via electronic communication services for transmitting text messages using the contact information available in their personnel file. Upon entering or serving in the civil service, a civil servant is required to provide their email address and contact information. In its ruling of November 16, 2023, in Case No. 300/3110/20, the Supreme Court noted that providing accurate information regarding the actual place of residence, email address, and other means of telecommunications is an obligationof a civil servant under the Law of Ukraine “On the Civil Service”; therefore, if inaccurate information is provided, the civil servant bears responsibility for the legal consequences, including those related to the receipt of correspondence and the timeframes for such receipt. For their part, government agencies will have to review their document management systems, and lawyers will need to master new competencies in the field of digital evidence, as screenshots, log files, and read receipts in a civil servant’s account may become key evidence in court.

Escalation of disciplinary liability. The draft not only classifies types of penalties according to their severity but also introduces a mechanism for their “escalation”: if a civil servant commits a similar violation again while a previous sanction is still in effect, a more severe disciplinary sanction may be imposed. For example, if a civil servant initially receives a reprimand for failing to enter information into the registry on time, a similar violation a few months later may already constitute grounds for a formal reprimand, while a repeat offense could lead to a warning regarding partial professional unsuitability. Formally, these are different disciplinary decisions, but in reality, they represent a gradual accumulation of the risk of dismissal. This is undoubtedly a logical tool for combating systemic dereliction of duty. At the same time, the possibility of pressure cannot be ruled out. However, it is the procedure itself that is key to the legality of the disciplinary action. In particular, as the Supreme Court clarified in its ruling of July 9, 2025, in Case No. 380/9508/22, dismissal for systematic absenteeism requires repeated occurrences over the course of a year, and a valid decision on a previous disciplinary sanction for the same violation is the required indicator of systematic behavior. This confirms the logic of the draft law regarding recurrence, but at the same time requires clear evidence for each stage of the disciplinary history.

A simplified reprimand—a potential problem. The most controversial new provision of Bill No. 15190 is the ability to issue a reprimand without establishing a disciplinary committee or conducting a full investigation. Formally, this makes it easier to respond to minor violations. For example, a manager can issue a reprimand for being late to an internal meeting or for failing to approve a document on time without conducting a full disciplinary proceeding. However, such a “mild” sanction should not be taken lightly, as it could serve as a “first step” toward more severe punishment in the future. In practice, this means that civil servants will be forced to challenge even such decisions in order to break the chain leading to potential dismissal.

New rules on suspension. The draft specifies the rules of conduct for civil servants during their suspension. In particular, it defines their obligations during this period: to comply with internal regulations; not to influence colleagues; not to take any actions that could lead to the destruction or forgery of items and documents; not to obstruct the investigation; and to cooperate with disciplinary proceedings. In practice, this might look like this: during an official investigation, an employee is temporarily suspended from their duties and prohibited from contacting colleagues who may be witnesses in the case. Violation of these restrictions may in itself constitute grounds for disciplinary action. At the same time, the duration of the suspension is no longer formally fixed but will be determined by the time required to gather information and may not exceed the duration of the disciplinary proceedings themselves.

Professional Development and Composition of Commissions. A positive aspect of the bill is the introduction of an individual development program for civil servants, the results of which will be taken into account when evaluating their performance. The approach to professional training is also being updated. The composition of disciplinary commissions is specified separately: they must include a representative of the human resources department, a person with a legal education, and a representative of the labor union or a representative of the civil servants.

Conclusion. Although the changes proposed by Bill No. 15190 establish stricter rules for civil servants, they have the potential to positively impact the quality of public administration and public trust in government authorities. However, their effectiveness will depend on many factors: proper notification, a genuine right to provide explanations, well-reasoned decisions, proportional penalties, and judicial oversight. New rules alone are not enough; what matters is how they will be applied by the heads of government agencies.