Government Clarifies the Rules for Exchanging Temporary Residence Permits During Martial Law

The Cabinet of Ministers of Ukraine, on 5 February 2026, introduced amendments to Decree №1202 of 21 October 2022 entitled “Certain Issues of the Implementation of Migration Legislation During Martial Law.”

The amendments concern the procedure for exchanging temporary residence permits for foreigners and stateless persons.

Who Is Required to Exchange the Permit?

The Government has established a clear deadline for applying to exchange a temporary residence permit.

Foreigners and stateless persons (except citizens of the Russian Federation) whose deadline for applying to exchange their temporary residence permit arose after 24 February 2022 are required

1. to apply for the exchange within 90 days from the date this new resolution enters into force.

The Decree enters into force on 7 May 2026; therefore, the deadline for submitting applications is 5 August 2026.

Thus, the State has defined a specific time frame for regulating the residence status of persons who, due to martial law, were unable to exchange their documents in a timely manner.

What If the Exchange Deadline Has Not Yet Occurred?

Foreigners and stateless persons (including citizens of the Russian Federation) who hold temporary residence permits and whose exchange deadline has not yet arisen may apply for the exchange no later than the last day of validity of their temporary residence permit, provided that the legal grounds established by law exist.

What Is the Role of the State Migration Service?

The State Migration Service of Ukraine must, within three months from the date the Decree enters into force, carry out information and awareness-raising activities.

This includes informing foreigners and stateless persons about:

• the procedure for exchanging permits;

• the applicable deadlines;

• the required procedural steps.

What Does This Mean in Practice?

The introduced amendments aim to streamline migration procedures during martial law and establish clear rules for individuals residing in Ukraine on the basis of a temporary residence permit.

At the same time, persons affected by these provisions are advised to carefully monitor the deadlines and not to delay applying to the territorial offices of the State Migration Service.