The government has established new deadlines for the exchange of temporary residence permits for foreigners in Ukraine

Resolution of the Cabinet of Ministers of Ukraine No. 1202 provided that temporary or permanent residence permits (except those issued to citizens of the russian federation), the validity of which had expired or which were subject to exchange after 24 February 2022, continued to confirm legal grounds for residence in Ukraine for the period of martial law.

Such permits were subject to exchange within 30 calendar days after the termination or cancellation of martial law.

The Resolution establishes a specific deadline for applying for the exchange of such permits.

Foreigners and stateless persons (except citizens of the russian federation) whose deadline for applying for the exchange of a temporary residence permit occurred after 24 February 2022 are required to submit documents for its exchange within 90 days from the date this Resolution enters into force.

The Resolution enters into force on 7 May 2026. Accordingly, the period for applying for the exchange of a permit will last from 7 May to 4 August 2026 inclusive.

Foreign citizens and companies employing foreigners should check in advance the status of residence permits and the grounds for staying in Ukraine, as well as prepare the necessary documents for their exchange, in order to avoid risks of violating migration legislation.

Given the limited timeframe for submitting documents and the significant number of foreigners affected by the new rules, it is advisable to begin preparations for the permit exchange procedure in advance.

The GOLAW team can assist with:

• verifying the migration status of a foreign national and the grounds for staying in Ukraine;
• determining whether the exchange of a permit is required in a specific case;
• preparing a complete set of documents for obtaining or exchanging a residence permit in Ukraine;
• supporting employers in arranging the employment of foreign nationals.