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Wartime legal news

We have prepared a short digest of news that can be useful for entrepreneurs. Under martial law, the state leadership promptly makes decisions aimed at supporting citizens and businesses. Therefore, we will periodically inform you of changes. Below we have gathered the main news as of today.

Instead of the traditional legal pictures to cheer up, we sketch you a little military memes.

Certificate of force majeure

CCI of Ukraine by letter dated 28.02.2022 №2024 / 02.0-7.1. reported force majeure.

According to the letter dated February 24, 2022, force majeure is in force throughout Ukraine until the official end of martial law. To confirm the circumstances of force majeure, it is sufficient to present the specified letter of the CCI of Ukraine.

Entrepreneurs who have been subjected to force majeure must notify their contractors in writing of these circumstances and attach a letter from the CCI of Ukraine.

Keep in mind that martial law is a force majeure for you if it prevents you from fulfilling a specific obligation. For example, the lack of funds due to the fact that the company stopped working is not force majeure.


Currency restrictions

On February 24, 2022, the National Bank, by its resolution №18, introduced certain restrictions in the work of the banking sector. Now the National Bank is gradually easing restrictions and amending this resolution. Here is a list of current restrictions:

  • Cash withdrawal from the account of one client - up to 100 thousand UAH per day. In addition to withdrawals for the payment of wages and social benefits, or withdrawals by enterprises that perform mobilization tasks.
  • Cash withdrawal from a foreign currency account - up to UAH 30,000 per day.
  • Currency trading is prohibited. There are exceptions, including: exchange of one foreign currency for another; purchase and subsequent transfer of currency for payments for critical imports. The list of critical import goods was approved by the Cabinet of Ministers Resolution №153 of February 24, 2022. This list is constantly updated.
  • It is allowed to pay with bank cards abroad and withdraw cash from them abroad.
  • Expenditure operations on the accounts of residents of Russia and Belarus and on the accounts of legal entities whose ultimate beneficial owners are residents of Russia or Belarus have been suspended. Exceptions: transfer of funds to a special account of the Armed Forces of Ukraine, payment of wages, payment of taxes and payment of utilities.
  • The hryvnia exchange rate against the US dollar was fixed at UAH 29.25 / USD.
  • Crediting funds to the accounts of individuals from cards issued by Russian or Belarusian banks is prohibited. It is also forbidden to accept such cards in Ukraine.
  • Any transactions using Russian or Belarusian rubles, as well as payments to legal entities and individuals located in Russia or Belarus are prohibited. Exceptions are for exporters, which are paid in rubles. Such rubles must be exchanged for another currency before crediting them to the exporter's account.
  • It is recommended that banks first of all collect retail business entities that accept payment by bank cards at all outlets.

Banks have the right to sell foreign currency to customers at the expense of their own currency position in order to fulfill their customers' obligations under credit agreements with banks.



For the period of martial law:

  • tax audits do not start, and the started audits are stopped;
  • operations on voluntary transfer or alienation of funds, goods, including excisable goods, provision of services for the benefit of the Armed Forces of Ukraine and territorial defense units without reimbursement of their value are not considered sales operations for tax purposes. Accordingly, such transactions are not subject to VAT or excise tax;
  • funds transferred to the benefit of the Armed Forces of Ukraine and other military formations, as well as the value of property / works / services according to the list determined by the Cabinet, system members will be able to include in the costs;
  • licenses for the production, storage and trade of fuel, alcohol and other excisable products continue;
  • the term of all terms determined by the tax legislation is stopped. This applies to the deadlines for appealing tax notices-decisions and the deadlines for reviewing previously filed complaints or other appeals;
  • fines for violation of the procedure for the use of RRO are not applied.

If the taxpayer is unable to pay taxes or file any tax returns, he is not liable. He must perform this duty within three months of the cessation of martial law.


Reporting and other documents 

  • during martial law and within three months after its completion, no liability will be applied for violation of the procedure and deadlines for submission of reports and any other documents required by any law;
  • Individuals, sole proprietors, legal entities may submit tax, accounting, financial, accounting, settlement, audit reports and any other documents within 90 calendar days after the cessation or cancellation of martial law for the entire period of non-submission.

Issuance of permits

By Resolution №165 of 28 February 2002, the Cabinet of Ministers suspended the deadlines for the provision of administrative services and the issuance of permitting documents by permitting authorities during martial law in Ukraine.

This resolution in no way prevents the authorities from providing administrative services and issuing permits during the period in force before the imposition of martial law. It provides an opportunity to extend the deadlines for those bodies that do not have the opportunity to review documents in a timely manner.

Reduced payment deadlines for certain food products

The Cabinet of Ministers by Resolution №160 of 26.02.2022 established that the term of settlements for certain delivered food products of Ukrainian production may not exceed ten calendar days from the date of issuing a bill by the supplier of such products to pay for the delivered products.

The list of such goods was approved by the Cabinet of Ministers Resolution №341 of 22.04.2020 "On measures to stabilize prices for goods of significant social significance, anti-epidemic goods."


Features of registration and military action

  • Notaries were obliged to refuse notarial acts to all Russians and legal entities where Russian residents are participants or beneficial owners with a share of 10% and more.
  • It is forbidden to make writs of execution under credit agreements that are not notarized.
  • Registration actions against legal entities can be performed only by state registrars and officials of the Ministry of Justice who are included in the list approved by the Ministry of Justice.
  • Documents for registration of legal entities and sole proprietors can be submitted by e-mail. It is unclear whether this will work for all registration actions, or only for those that do not require the submission of notarized documents.
  • It is allowed to submit documents for registration without their notarization, if the relevant documents are signed in the presence of the state registrar.
  • State registration of legal entities, sole proprietors and real estate takes place regardless of their location.
  • On March 7, the Ministry of Justice announced that it did not plan to restore the State Register of Real Property Rights. This means that buying and selling real estate is not possible now.

You can pay salaries and pay taxes on seized accounts

By order №212-r of March 11, 2022, the Cabinet of Ministers allowed enterprises whose accounts were seized in enforcement proceedings to make the following payments:

  • wages, but not more than 5 minimum wages per month per employee;
  • taxes, fees and SSC.

Features of food labeling

The Cabinet of Ministers adopted two resolutions №186 of 03.03.2022 and №234 of 09.03.2022 which simplified the procedure for labeling food products for the period of martial law:

  • if the importer cannot ensure the labeling of food products in the Ukrainian language, the supply of products without such labeling is allowed. In this case, the entire batch of such products must be accompanied by information in Ukrainian and this information must be provided to the consumer on demand at the point of sale.
  • in case of closure of facilities due to hostilities, entrepreneurs may use the remnants of packaging or containers for food and feed for their intended purpose at other facilities that produce similar food and feed;
  • due to forced changes in the recipe, which are associated with the absence or insufficiency of appropriate raw materials, for the period of martial law, it is allowed that the actual composition of the product differs from the label. In this case, the consumer should be informed in any possible way about the presence of substances in the food product that may cause allergic reactions or intolerance.

Announced help packages

The government has announced a number of measures aimed at supporting business in martial law. Including:

  • exemption of private individuals of groups I and II from the payment of SDRs during martial law and within one year after its completion;
  • exemption of enterprises and sole proprietors of the third group from the payment of SDRs for employees who were called up to the ranks of the Armed Forces and other armed groups (including territorial defense). The fee will be paid by the state;
  • abolition of all control and supervision measures, except for price regulation and control over pricing;
  • compensation from the budget of interest on loans to cover any costs associated with agricultural activities. State guarantees to farmers for 80% the amount of loans they have attracted;
  • providing assistance to enterprises that want to relocate production facilities to Western Ukraine. The government promises to create conditions for free relocation to the place of temporary relocation, as well as for the selection of appropriate areas for production, relocation and resettlement of personnel, for the selection of workers in the place of deployment after relocation.

There is currently no information on how to use such assistance, as some of these measures require the adoption of separate laws. So we are still waiting for details.


Material assistance "eSupport"

Individuals of all groups and employees for whom SDRs are paid can receive financial assistance in the amount of UAH 6,500 within the "eSupport" through the Action application.

Payment is available in the areas where the most active hostilities are taking place. These are: Chernihiv, Sumy, Kharkiv, Kherson, Mykolaiv, Zaporizhia, Donetsk, Luhansk, Zhytomyr, Odesa, Volyn, Kyiv and Kyiv.

Please also note that the payment can be obtained only if the individual or the employer submitted reports for the IV quarter of 2021 or in general for 2021.

You can learn how to apply and receive a support card here.

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