Reconstruction Digest:
Ukraine 2025

CONTENTS


I. REAL ESTATE

Amendments to the Civil Code of Ukraine
to protect bona fide acquirers is now in force

As of 9 April 2025, amendments to the provisions of the Civil Code of Ukraine aimed at strengthening protection for bona fide acquirers has come into effect.

These amendments were adopted to limit abuses of procedural remedies that previously enabled the de facto indefinite challenge of the transfer of state or municipal property into private ownership (i.e., land plots and buildings) through so-called negatory actions (claims for the removal of obstacles to property use).

A detailed analysis of these changes –
in our previous digest


II. PRIVATISATION

New privatisation rules for leased assets

On 16 April 2025, Law-12230 was adopted, introducing amendments to the procedure for privatisation of state and municipal property that has been leased.

Prior to these amendments, the Law of Ukraine On Privatisation of State and Municipal Property allowed tenants who had carried out inseparable improvements amounting to at least 25% of the market value of the asset to acquire the leased property through direct purchase, bypassing the auction process. This often led to abuses and, in some cases, undervaluation of state and municipal assets.


III.  LAND

New initiative: the state will transfer land under destroyed property
to its owners free of charge

On 13 May 2025, the Verkhovna Rada adopted Draft Law No. 13174 in the first reading, which provides for the transfer of land plots, without bidding, to individuals whose real estate was destroyed as a result of hostilities.

The draft law proposes to expand the list of state- and municipally owned land plots that are exempt from sale through competitive procedures by including those plots where real estate (buildings, structures) destroyed due to hostilities was previously located. The ownership rights to such property must have been officially terminated in the State Register of Property Rights to Real Estate (SRPR) due to its destruction. These land plots may be transferred into private ownership free of charge or granted for use to the former property owners of the destroyed property.

Additionally, the general prohibition on free-of-charge land transfers to ownership in effect during martial law will not apply to such land plots.

The draft law also introduces a condition such that, during martial law and for five years after its termination or cancellation, the designated use of such land plots may be determined:

  • without complying with the requirement of consistency between the land plot's designated purpose and the functional zoning of the territory;
  • without approved urban planning documentation – provided that the new designated use corresponds to the function of the real estate object that existed on the land plot prior to its destruction.

IV.  PUBLIC-PRIVATE PARTNERSHIP (PPP)


Public-private partnership reform:
Verkhovna Rada Committee recommends adoption of Draft Law No. 7508

In July 2022, the Verkhovna Rada registered Draft Law No. 7508, which aims to significantly reform the legislation framework governing public-private partnerships (PPPs). The reform aims to enhance the mechanism for attracting private investment into the public sector – an especially urgent need in the context of Ukraine’s reconstruction.

On 2 May 2025, the Verkhovna Rada Committee on Economic Development resolved to recommend the draft law for adoption in the second reading.

Key amendments
expected upon adoption include:

  • the introduction of simplified procedures for smaller public-private partnership (PPP) projects (valued at up to USD five million), as well as for reconstruction-related initiatives, allowing their implementation without the requirement of a full-scale feasibility study;
  • the expansion of PPP applicability to a broader range of assets, including transport infrastructure, residential housing and social infrastructure;
  • the ability to involve donor organisations and utilise grant funding to support PPP initiatives;
  • the deployment of electronic platforms to facilitate transparent and competitive tender procedures.

PPP under the U.S.-Ukraine Reconstruction Investment Fund

On 30 April 2025, Ukraine and the United States signed the Agreement on the Establishment of the US-Ukraine Reconstruction Investment Fund, the so-called "mineral resources agreement" (the Agreement). The Agreement was ratified on 8 May 2025.

In addition to its primary objective of establishing and operating the US-Ukraine Reconstruction Investment Fund, the Agreement also covers the implementation of PPP projects related to the construction and operation of infrastructure assets classified as “strategic” or “significant.”

For more details, please refer to our legal alert available via the link.

For more details,
please refer to our legal alert


V.  OTHER NEWS

Launch of the State Register of
Special Permits for Subsoil Use

As of 1 April 2025, Ukraine has officially launched an electronic State Register of Special Permits for Subsoil Use (Register).

Special permits are now issued exclusively in electronic form, as extracts from the Register. These extracts are generated via the online portal of the Unified Geoinformation System, the subsoil user's cabinet, or the platform EcoSystem.

Each extract includes essential information, such as:

  • the date of issue, term of validity and legal grounds for granting the permit;
  • records of any extensions and amendments;
  • the type and purpose of subsoil use;
  • details about the relevant subsoil area, etc.


All data in the electronic extract is valid as of the date and time of its issuance.

Access to the Register is temporarily restricted during martial law, with exceptions made for law enforcement agencies, state authorities and local self-government bodies.

Government expands business support
under the Own Business program in frontline regions

Under the Own Business program, entrepreneurs can receive microgrants ranging from UAH 50,000 to 250,000 to
start or develop their businesses. However, building on the successful experience of increasing microgrants in the Kharkiv region, the Cabinet of Ministers has raised the maximum grant amount to UAH 500,000 for entrepreneurs from the Donetsk, Dnipropetrovsk, Zaporizhzhia, Mykolaiv, Kherson, Chernihiv and Sumy regions.

This support is aimed at creating new jobs and can be used to purchase or lease equipment, procure raw materials and
supplies or cover rental costs.

Ukraine and South Korea expand their economic partnership

On 2 May 2025, the Ministry of Economy of Ukraine and the Ukrainian-Korean Business Council Association (UKBC) signed a Memorandum of Cooperation. The document outlines the coordination of efforts to strengthen bilateral economic collaboration between Ukraine and the Republic of Korea through the UKBC.

The parties will focus on attracting investment into key sectors of Ukraine including industry, agriculture, energy and infrastructure. Additional priorities include supporting companies in their efforts to enter the other partner's market, developing joint projects in innovation, digitalisation and green energy, as well as facilitating logistics and trade.

Soon, a list of priority projects is expected to be developed for implementation under the memorandum.

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