“Under-the-table” wages are illegal

The most significant changes made to the legislation on state social insurance are those concerning the special procedure for paying mandatory insurance contributions to the budget of the state extra-budgetary Social Protection Fund upon detection of hidden wage payments.

As of August 18, 2025, amendments to the Law of the Republic of Belarus dated 15.07.2021 No. 118-Z "On Contributions to the Budget of the State Extra-budgetary Social Protection Fund of the Republic of Belarus" (hereinafter – Law No. 118-Z) came into force, establishing the legal framework regulating relations related to the payment of mandatory insurance contributions (hereinafter – contributions) from income paid to employees without reflecting such payments in the organization's accounting or tax records.

The concept of "hidden wages" is now enshrined as a term and has its own definition – it is a payment in monetary and (or) in-kind form for the performance of work (services, creation of intellectual property) by an employee (citizen) under labor and (or) civil law contracts without its reflection by the employer in tax and (or) accounting records.

In cases where information is received from authorized state bodies about hidden wage payments to individuals with whom neither labor nor civil law contracts have been concluded, contributions will be accrued in accordance with Article 5-1 of Law No. 118-Z.

For the accrual of contributions on hidden wages, the maximum limit has been abolished, and a minimum limit has been established.

In such cases, the object will be recognized as payments made in favor of the employee on all grounds, regardless of funding sources, which were not reflected in tax and (or) accounting records, but not less than 1/30 of five times the average salary of employees in the republic for the month preceding the month of establishing the fact of hidden wages (remuneration), for each calendar day of the period for which hidden wages (remuneration) were paid.

At the same time, the individual personal accounts of employees will record amounts calculated based on 1/30 of the minimum wage, established and indexed in accordance with legislation in the month preceding the month of establishing the fact of hidden wages (remuneration), for each calendar day of the period for which hidden wages (remuneration) were paid, and mandatory insurance contributions to the fund's budget, accrued on these payments.

It should be noted that inaccordance with Part 1-1 of Article 4 of Law No. 118-Z, the object for calculating mandatory insurance contributions, in case of establishing the fact of hidden wages (remuneration), will be all types of payments in monetary and (or) in-kind form, made in favor of the employee on all grounds, regardless of funding sources, which were not reflected in tax and (or) accounting records.

 At the same time, payments listed in the List of Payments on which contributions are not accrued, approved by Resolution of the Council of Ministers of the Republic of Belarus dated 25.01.1999 No. 115, will not be excluded from the object.

In addition, from August 18, for individuals working under labor (civil law) contracts, additional contributions for "hidden" payments will be calculated based on the number of calendar working days (without considering the employee's employment status (full-time/part-time)), and if such days cannot be determined, the calculation will be based on 30 (31) calendar days of the month for which the employee received hidden wages.

For example, hidden   wages  of 1000 rubles for February 2026 were revealed. The average salary for January 2026 is 2757.1 rubles, five times the average salary will be 13785.50 rubles, and 1/30 of it is 459.50 rubles. This means that contributions to the Social Protection Fund for each calendar day of February 2026 will have to be paid in the amount of  160.83  rubles (459.50 x 35%).