Ukraine pension reform includes opportunities for private pension funds

As part of a broader pension reform initiative, the Ukraine’s Ministry of Social Policy, Family and Unity plans to introduce a voluntary accumulative pension component with “automatic subscription” instead of a mandatory accumulative system. This approach is designed to encourage long-term savings while avoiding the structural risks observed in other jurisdictions.

Proposal: voluntary accumulative with automatic enrolment instead of mandatory 

The Ministry determined that a mandatory accumulative pension system would not be appropriate for Ukraine. According to the Minister, mandatory accumulative schemes have not demonstrated effectiveness in neighbouring countries (e.g. Poland and Hungary), which have since abandoned or scaled back their mandatory funded pillars.

Instead, Ukraine proposed a voluntary accumulative system with “automatic subscription” (i.e. an opt-out mechanism). The key features of the proposed model include:

• Launch date: the system is expected to commence in 2027.
• Contribution structure: employees would make additional contributions to the accumulative fund on top of their existing Unified Social Contribution payments.
• Opt-out right: participation would be automatic, but individuals will retain the right to opt out, which  would result in a lower pension at retirement.

Implementation and fund management

The institutional framework for managing the accumulative fund remains under discussion with various implementation options now under consideration, including potential cooperation with existing non-state pension funds.

The Ministry’s position is that the government’s primary role should be to establish robust mechanisms for protecting accumulated funds, rather than to directly manage investments. The objective is to develop investment instruments that guarantee, at minimum, inflation-adjusted returns over a 20-year horizon. Such guarantees are intended to build public confidence and encourage voluntary participation without resorting to compulsion.

Outlook

The voluntary accumulative component forms part of a three-pillar pension reform that also includes restructuring the solidarity system and transition from special pensions to professional pensions. Draft legislation is currently being finalised while coordination and consultations with international partners proceeds.

The reform will be a significant step towards the popularisation of non-state pension funds, which are now almost unknown to the public. Market participants, including pension funds, asset managers, and financial institutions, should monitor developments closely, since the regulatory framework for fund protection and eligible investment instruments has yet to be established.

For more information on the pension reform or related legal matters in Ukraine, contact your CMS client partner or the CMS expert: Ihor Olekhov.