IDP checks and issuance of certificates: lawyers comment on key changes that Ukrainians should know about

Oksana18.06.2025

0 76 9 minutes read

“Where are you now?” Ukrainians who officially have the status of internally displaced persons are hearing this question more and more often. Some – during a phone call from an unknown number. Others receive a notification about the need to appear for a “reconciliation” or even a commission visit. This is how the new wave of inspections of IDPs looks like, which unfolded after the update of the Cabinet resolution. This document also provides for changes to the Procedure for registration and issuance of a certificate of registration of an internally displaced person.

The editors of FAKT IA receive requests from readers: how to register an internally displaced person now? What nuances need to be known and taken into account? We turned to the lawyers of the “Repeshko and Partners” bar association for comments on the updated Procedure for the registration and issuance of a certificate of registration of an internally displaced person and answers to questions that concern Ukrainians.

As of June 5 2025 4,594,254 internally displaced persons were officially registered in Ukraine. Despite the long hostilities, this number of citizens is trying to arrange their lives, albeit not at home, but within the borders of their native country. In connection with constantly arising questions in the practical plane, the resolution of the Cabinet of Ministers of Ukraine dated April 4, 2025 No. 376, amendments were made to the Procedure for drawing up and issuing a certificate of registration of an internally displaced person, approved by the resolution of the Cabinet of Ministers of Ukraine dated October 1, 2014. No. 509. They touched on the issues that we will now consider.

Addresses (place of residence) of state authorities, local self-government bodies, legal entities under public law, their subdivisions, or any other premises where IDPs do not actually live/are not allowed as the actual place of residence/residence.

In the event that an IDP actually resides/stays/undergoes a course of treatment for at least 15 days, he/she has the right to receive a certificate based on the actual place of stay, and in the case of the end of the period of residence/stay/treatment, such a person must be registered at the new actual place of residence/stay within 60 calendar days. If a person does not register at the new place of actual residence/residence within the specified period, such a person shall be removed from the register in the month following the month in which the specified period ended.

The government decree established a unified approach to issuing IDP certificates for military personnel. Yes, military servicemen have the right to receive a certificate, taking into account the requirements of paragraph 4 of this Procedure (except for military servicemen in conscript service and military service upon the conscription of officers), who:

were/are undergoing military service and had a registered/declared place of residence in the territory where hostilities are taking place or in the territory temporarily occupied by the Russian Federation, included in the list of territories on which hostilities are (were) conducted or temporarily occupied by the Russian Federation, approved by the Ministry of Development, for which the date of the end of hostilities (ceasing the possibility of hostilities) or temporary occupation by the Russian Federation has not been determined, or who actually lived in the specified territories;
or in which as a result of hostilities, acts of terrorism, sabotage caused by the armed aggression of the Russian Federation against Ukraine, the residential premises were destroyed or damaged (to the extent that they were unfit for habitation).

It is no secret to anyone that sometimes IDPs, having wandered around the territory of their native country, decide to go abroad, where sometimes the conditions for refugees are better, and there are more prospects. Some of them, due to circumstances, do not have time to deregister as IDPs, and some deliberately count on the fact that there is never too much money.

From July 1, 2025, changes concerning IDPs who have gone abroad will also enter into force. It is after this date that mass inspections by state authorities will begin to ensure compliance with the current legislation by such persons.

Starting from July 1, 2025, the Ministry of Finance of Ukraine will check information on the stay of IDPs abroad every month. If it turns out that a person has been outside Ukraine for more than 90 calendar days in a row without valid reasons, the IDP certificate will be revoked. The following days are not included in the 90-day period of stay abroad:

business trip;
children’s recovery;
treatment, rehabilitation;
care for a sick child up to 18 years old;
death of a person’s family members and relatives;
internship;
stay in health care facilities;
stay in judicial and law enforcement agencies;
other officially confirmed circumstances.

It should be noted that in the event that, based on the results of the verification, the fact that the IDP has stayed abroad for more than 90 calendar days in a row is discovered by the authorized body that issued the certificate, an additional check is conducted.

After conducting an additional check, in case of confirmation of information about the departure of an internally displaced person to a permanent place of residence abroad, a decision is made to withdraw the certificate of entry into the register of IDPs.

In the case of the return of an internally displaced person from abroad, in respect of whom a decision was made to revoke the certificate of registration of an internally displaced person, the certificate is issued upon the person’s application in accordance with this Procedure.

We would like to remind you that state bodies periodically control the residence of all IDPs at the place of their registration.

Control of compliance with the requirements of the law during the provision of accommodation assistance to IDPs is carried out by the territorial bodies of the National Social Service, in particular by conducting an inspection of the actual place of residence/stay of the internally displaced person.

It is worth knowing that the actual inspection of IDPs is carried out no later than within 10 working days from the moment when the head of the territorial body of the National Social Service established the basis for this and made a decision to conduct the inspection.

The person being checked must be notified of the check at least three calendar days before it is carried out by phone or using another available means of communication that ensures the recording of a message or call (for example, the Viber or Telegram messenger).

If the person reported his absence due to staying with relatives or on vacation, etc., the check is postponed for two weeks, and in the case of military service, the check is not carried out on the condition that the military unit (employer) confirms the payment of a single contribution to the mandatory state social insurance by exchanging data of the Pension Fund of Ukraine from the register of insured persons of the State Register of mandatory state social insurance for the purpose of assigning state social assistance or provided certificates of service in the military unit (using postal/electronic means of communication) and the Ministry of Social Policy.

During the inspection of the actual place of residence/stay of such persons and in their absence at the actual place of residence/stay, the officials who conducted the inspection draw up the appropriate act in the form and on the day of the inspection inform the person for whom the inspection was carried out about the need to come to the social protection body at the place of residence on the register within 14 working days to undergo identification in order to submit an application in an arbitrary form regarding the absence of changes in the address of the actual place of residence accommodation/stay. Informing is carried out by telephone or by means of another available means of communication, which ensures fixation of the message or call.

If there are justified reasons for the IDP’s absence from the place of residence/residence within 30 calendar days after the check, the IDP submits an application to the social protection authority for the renewal of benefits with supporting documents (business trip, rehabilitation of children, accompanying children during participation in international competitions or participation in relevant competitions, internship, training, treatment, rehabilitation, illness of a person or a family member, death of family members and relatives, care of a sick child up to age 18 years old, visits to health care institutions, judicial and law enforcement agencies, due to which a person could be absent from the place of residence/stay against his own will), which is documented.

If the IDP has not arrived at the social protection body within 30 calendar days after the inspection, the social protection body makes a decision on the temporary suspension of assistance from the following month.

In the absence of a telephone and/or other available means of communication with the person subject to inspection, the officials responsible for the inspection, in the presence of their manager, draw up an act of informing the internally displaced person by means of telephone and/or other available means of communication according to the form.

The date and time of calls, messages, and their number (at least two) are indicated in the act of providing information by means of telephone and/or other available communication. The specified act is attached to the materials compiled based on the results of the verification of the actual place of residence/stay of the internally displaced person.

It should be emphasized that the payment of assistance is renewed subject to compliance with the criteria defined by the Procedure and based on the identification of the IDP from the month from which such payment was temporarily suspended, in the event that the IDP applies for renewal of the payment within 30 or 90 calendar days (if there are valid reasons).

Since the verification of the place of residence of an IDP primarily concerns monetary payments, the consequences of such verification are not only the deprivation of the status of an IDP, but also the payments due in this connection and already paid payments to which the IDP was not entitled.

In case of illegal or repeated payment to the recipient of assistance for a certain period, the amount of such paid assistance is returned by the recipient voluntarily or at the request of the social protection body.

The body of social protection of the population from the moment of detection of the fact of the excess of transferred (paid) assistance determines the amount of illegally or repeatedly received funds and within 30 working days informs the IDP about this by sending a message using postal/electronic means of communication, means of mobile communication that ensure recording of the message or call.

In case of non-return of excess paid funds voluntarily within the established time, the body of social protection of the population decides on the issue of their collection in court. At the same time, in the event that the social protection body receives information about the death of the recipient or that he is declared missing, or that he is declared dead, such a social protection body shall stop the payment and send a request to the bank for the return of the sums of funds, the excess credited to the current account of the recipient for the payment of benefits from the month following the month of the death of the recipient or the month of the entry into force of the court decision on the recognition of the recipient missing or declared dead. At the same time, if the bank informs that such funds were used by a third party after the person’s death, the social protection body of the population, in the presence of such information, sends such a person a demand for the return of funds, and in the absence of such information, notifies the law enforcement authorities of the established fact of the excess of the aid funds paid.

In this regard, we do not advise you to “play” with state funds, because it is well known from legal practice that the state will not ignore even small sums that were paid out without reason. In turn, a court decision obtained in favor of the state for the collection of illegally received payments can result not only in the blocking of bank accounts, but also in the seizure of property. Taking into account the above, we recommend that in the event of a change in life circumstances and, accordingly, changes in status, to notify the state authorities in a timely manner, especially since “Diya” will help to do this as quickly and conveniently as possible.

In order to simplify citizens’ access to administrative services, IDPs will be able to report changes in life circumstances through the Diya portal, namely: