On 7 May 2026, Resolution of the Cabinet of Ministers of Ukraine No. 141, dated 5 February 2026, “On amendments to the Resolution of the Cabinet of Ministers of Ukraine, dated 21 October 2022, No. 1202” (the “Resolution”) entered into force.
What has changed
The Resolution requires foreign nationals and stateless persons (except for citizens of the russian federation) to submit documents for the exchange of temporary residence permits if the deadline for applying for the exchange of such permits fell after 24 February 2022.
Documents for such exchange must be submitted within 90 days from the date of entry into force of the Resolution, i.e. from 7 May to 4 August 2026 (inclusive).
Foreign nationals and stateless persons whose temporary residence permits are not yet due for exchange may apply for their exchange under the general procedure.
Previous approach
During martial law, temporary residence permits (except for those issued to citizens of the russian federation), the validity of which expired or which were subject to exchange after 24 February 2022:
- were considered valid throughout the entire period of martial law and for an additional 30 calendar days after its termination or cancellation;
- were to be exchanged within 30 days following the termination or cancellation of martial law.
Permanent residence permits: no changes
The rules on the validity of permanent residence permits during martial law remain unchanged.
For more information, please contact Maksym Tesliar, Partner, Head of Employment & Labour Law in Ukraine at maksym.tesliar@kinstellar.com or Iryna Shaposhnikova, Senior Associate, Employment & Labour Law at iryna.shaposhnikova@kinstellar.com.
