Common Mistakes in Annual Leave Processing. Maternity Benefits. Executive Salary limits. Updates in electronic invoice system and other news
The legislative news review is presented as of May 21, 2026.
Common mistakes when processing annual leave
During the vacation season, the Ministry of Labor and Social Protection issued a reminder about common mistakes organizations make when processing annual leave:
1. No vacation schedule
A vacation schedule is mandatory for all employers (even for individual entrepreneurs and private unitary enterprises). The schedule is generally approved no later than January 5th. It must be agreed upon with the trade union (if any) if required by the collective agreement.
Those who have the right to choose dates first are: mothers of 2+ children under 14 years of age, parents of disabled children, minors, Chernobyl victims, etc.
2. The vacation was not formalized by order.
Issue an order granting leave. Familiarize the employee with the order and sign it.
3. The employee does not take annual vacations
The working year ≠ calendar year! Counting starts from the date of employment.
A minimum of 14 days of vacation are mandatory each year. It is possible to reschedule vacation only with the employee’s consent (except for minors and those working in harmful and/or hazardous conditions who must receive full vacation annually).
4. Late payment of vacation pay
Scheduled: Pay no later than two calendar days before vacation. Off-schedule: no later than two business days from the start of vacation (if the employee agrees).
5. Illegal recall from vacation
It is possible to recall from vacation only: at the employer’s initiative and with the employee’s consent. It is forbidden to recall: minors or workers in hazardous conditions.
For more details, please follow the link.
Maternity benefits for the main place of work and for part-time work
The Ministry of Labor and Social Protection clarified the details of maternity benefits:
- If you have multiple jobs, benefits are assigned only to your primary place of employment. Earnings from all jobs (both internal and external part-time) are taken into account when calculating the amount.
- What if the employee is on parental leave and works part-time? Even if the employee is on parental leave to care for a child under 3 years of age and works part-time (part-time—up to 0.5 of a full-time position), benefits will be due.
It is assigned at the main place of employment from the average daily earnings taking into account earnings from a part-time job, or from the average daily earnings from which the previous maternity benefit was assigned (the more advantageous option is selected).
Exception: If you do not have a primary place of employment at the time of pregnancy and childbirth, then the benefit is assigned to one of your part-time jobs (at your choice).
A certificate of incapacity for work (sick leave) is provided at the main place of employment.
For each external part-time job, a certificate of temporary disability is required, since benefits for part-time work are not assigned.
If the benefit is mistakenly paid both for the primary job and for a part-time job, then the amount received for the part-time job must be returned, since the Social Protection Fund will not credit these expenses to the policyholder.
For more details, please follow the link.
Restrictions on payment of wages to the head of the organization
On June 19, 2026, amendments to the Code of the Republic of Belarus on Administrative Offenses, introduced by Law No. 138-Z of April 15, 2026 “On Amendments to Codes on Administrative Liability Issues,” will come into force.
Now, administrative liability is provided for paying the head of an organization salary in an amount exceeding the ratio of the average salary of the head of the organization to the average salary in the organization as established by law:
- for an official – a fine from 15 to 30 basic units;
- for a legal entity – a fine of 100 to 200% of the excess amount.
According to subparagraph 1.2 of the Decree of the Council of Ministers of the Republic of Belarus No.597 dated July 08, 2013, the ratio of the average salary of heads of organizations to the average salary for the organization as a whole cannot exceed 8.
The restriction applies to organizations regardless of their form of ownership, with the exception of:
- budgetary organizations;
- organizations receiving subsidies, whose employees are equal in terms of pay to employees of budgetary organizations.
In relation to the heads of state organizations and organizations in whose authorized capital the state’s share of ownership is more than 50 percent, including banks, this ratio is agreed upon:
- up to 4 inclusive – with the body exercising owner supervision;
- over 4 and up to 6 inclusive – with the body exercising owner supervision and the regional executive committee (Minsk City Executive Committee);
- over 6 and up to and including 8 – with the body exercising owner supervision and the Prime Minister of the Republic of Belarus.
Changes in the form and instructions for electronic invoices
By Decree of the Ministry of Taxes and Duties (hereinafter referred to as MTD) dated March 31, 2026 No. 14 “On the Electronic Invoice” (hereinafter referred to as Decree No. 14), a new form of the electronic invoice and a new Instruction on the procedure for creating (including filling out), issuing (sending), receiving, signing and storing an electronic invoice (hereinafter referred to as Instruction No. 14) were approved.
Important: The familiar Decree No. 15 and Instruction No. 15 have ceased to be in force.
The lines for the “Loan” and “Individual” characteristics have been added to the electronic invoice form, the procedure for filling out these lines in sections 2 and 3 has been established, the provisions on the procedure for filling out the electronic invoice for the analyzed transactions have been clarified, and the provisions on filling out the goods section of the electronic invoice for food products and goods for children, subject to VAT at a rate of 10%, and traceable goods have been adjusted.
For more information, please follow the direct link to Pravo.by.
The SPOT (Delivery Confirmation System) system. No disruptions to deliveries
From June 1, 2026, a system for confirming the expected delivery of goods (SPOT) will begin to operate in Russia for the import of goods by road from EAEU member states, including Belarus.
Two days before importing goods into the country by road, you must:
- Generate an electronic document on the upcoming delivery of goods (DOPP) in the information system of the Federal Tax Service of the Russian Federation based on the seller’s information;
- Pay a security deposit to the budget in the amount of indirect taxes (VAT and/or excise taxes);
- Obtain a QR code for delivery of goods to Russia and give it to the seller (carrier).
Without a QR code (on paper or electronic), a vehicle carrying goods is not allowed to enter Russia. However, the previously received QR code does not change and remains valid for transportation.
Belarusian sellers are advised to provide Russian importers with the information necessary for the formation of DOPP in advance. This includes information about the carrier and vehicle, if the customer/contractor of the shipment is a Belarusian seller:
- name of the carrier;
- taxpayer identification number (UNP;INN);
- vehicle registration plate.
When changing vehicles, you must update your information in the DOPP in advance. The previously received QR code remains unchanged and remains valid for transportation.
The SPOT does not apply to the following group of goods: oil and goods produced from oil; electricity; goods transported by pipelines; goods for personal use, with the exception of goods imported for sale to individuals through electronic trading platforms, and others.
For more information, visit the Ministry of Taxes and Duties website.
The procedure for collecting unpaid remuneration under the civil contract
A Decree of the Council of Ministers explains how unpaid remuneration under civil contracts will be collected. The relevant Decree of the Council of Ministers of the Republic of Belarus, No. 239 of May 12, 2026, “On Supervision over Compliance with Labor and Occupational Health and Safety Legislation.”
The document was prepared in order to implement Decree No. 45 of February 12, 2026, which introduced an extrajudicial procedure for collecting remuneration from citizens for work performed under civil contracts.
The resolution provides for:
- Establishing a procedure for issuing demands to correct violations regarding non-payment of remuneration and decisions on their collection. A common procedure will be applied to both the collection of remuneration and the collection of wages. Decisions on the collection of arrears on these payments will be sent by the Department of State Labor Inspectorate to enforcement agencies. Simultaneously, unified forms of documents issued by the department are being established;
- supplementing the Regulation on the Department of State Labor Inspectorate with powers to establish facts of non-payment of remuneration to citizens and ensure their collection;
- other adjustments taking into account changes in legislation.
More details about the document can be found at the link.
On the application of the convention on the avoidance of double taxation with Italy
In accordance with paragraph 2 of the Decree of the Council of Ministers of the Republic of Belarus No. 164 dated March 7, 2024 “On Taxation Issues” on the suspension of the implementation by the Republic of Belarus from June 1, 2024 to December 31, 2026 of Articles 10, 11 and 13 of the Convention between the Government of the Republic of Belarus and the Government of the Italian Republic for the avoidance of double taxation with respect to taxes on income and capital and the prevention of fiscal evasion, signed in Minsk on August 11, 2005 (hereinafter referred to as the Convention), the Italian side informed about the decision to suspend the same articles of the Convention, the effect of which was suspended by the Republic of Belarus.
In connection with the above, when applying the Convention, one should take into account the mirror non-application by the Italian side of Articles 10 “Dividends”, 11 “Interest” and 13 “Capital Gains” of the Convention.
For more information, visit the Ministry of Taxes and Duties website.
To receive professional advice regarding the application of current legislation for accounting purposes or to receive advice on tax matters, please send your inquiries through the feedback form on the website or write to email: info@assurance.by.
