International Technical Assistance in Ukraine
State registration of an international technical assistance (ITA) project in Ukraine provides a basis for claiming benefits established by legislation and the applicable international treaty. Project participants also need to check the requirements for accreditation, procurement, foreign exchange transactions, reporting, and project closure. The main rules are set out in the Procedure for Attracting, Using and Monitoring International Technical Assistance, approved by Cabinet of Ministers Resolution No. 153 of 15 February 2002 (the Procedure).
This article is intended for foreign development partners (donors) and implementers of ITA projects, Ukrainian recipients, subcontractors, and legal and finance teams planning or supporting such projects in Ukraine.
1. What International Technical Assistance Means
2. Participants in ITA Projects
3. Registration of ITA Projects
4. Accreditation of ITA Implementers
5. Tax and Customs Benefits
6. Bank Accounts and Foreign Exchange Transactions
7. Subcontractors in ITA Projects
8. Monitoring and Reporting
9. Closing ITA Projects
Frequently asked questions
How DLF Can Help
1. What International Technical Assistance Means
ITA consists of financial and other resources and services provided by development partners under Ukraine’s international treaties free of charge and without a repayment obligation with the aim of supporting Ukraine’s socio-economic development. Assistance may take the form of property, works, services, intellectual property rights, financial resources, scholarships, and other resources not prohibited by law.
The Procedure excludes projects financed by NATO under the Agreement on the Status of the NATO Representation to Ukraine. Since 19 April 2024, it has also excluded ITA provided by international financial organisations under Ukraine’s treaties with those organisations as grants for budget support (Resolution No. 422 of 12 April 2024). Since 12 September 2026, the exclusions have also covered international military assistance provided free of charge and on a non-repayable basis by partner states to security and defence forces according to their identified needs during martial law, as well as humanitarian assistance from foreign donors under Ukraine’s treaties and its humanitarian assistance and charity legislation. These exclusions were introduced by Resolution No. 1102 of 9 September 2026.
2. Participants in ITA Projects
The main project roles are:
| Role | Who holds this role | Primary function |
|---|---|---|
| Development partner | A foreign state, government or its authorised bodies or organisations, foreign municipal authority, or international organisation | Provides ITA under Ukraine’s international treaties |
| Implementer | A resident or non-resident that has entered into a written agreement with the development partner or its authorised person | Ensures project implementation, including for remuneration |
| Recipient | A Ukrainian resident, natural or legal person | Directly receives ITA under the project or programme |
| Beneficiary | A state body or local-government executive body listed in the Procedure, taking account of its competence or jurisdiction | Has an interest in the project results and performs the prescribed functions |
Grant programmes often use “beneficiary” to mean the party receiving funding. The term has a different meaning in the ITA framework.
Special rules on designating and involving a beneficiary apply to the USAID projects expressly named in the Procedure and to projects supporting the development of civil-society institutions.
A subcontractor is a resident or non-resident that has a written agreement with the implementer or recipient, implements all or part of the project, and conducts procurement using ITA funds.
Since 20 May 2026, the role of a procurement participant has also been defined. This is a resident or non-resident that has a written contract with a subcontractor and arranges the purchase and import into Ukraine of goods for the recipient using ITA funds. This role and the corresponding procurement plan changes were introduced by Resolution No. 614 of 13 May 2026.
3. Registration of ITA Projects
The Secretariat of the Cabinet of Ministers of Ukraine registers ITA projects and programmes free of charge. It decides within 10 working days of receiving the required documents from all applicants. Within five working days of the registration decision, the registration card is issued to the applicant and a copy is sent to the beneficiary. If the package is incomplete, the Secretariat notifies the applicant in writing within 10 working days.
The recipient or recipients and the development partner or its authorised person submit the documents to the Secretariat in electronic and paper form. The official ITA registration page provides materials on the procedure. If recipients are established or selected through a competition during project implementation, special registration rules apply.
Documents Required for Registration
- Requests from the recipient and the development partner or its authorised person, specifying the required details, including the project number assigned by the development partner, information on the development partner, implementer, recipient and beneficiary, and the recipient’s consent to the contracted activities where the corresponding exception applies.
- A copy of the contract between the development partner and implementer, or the relevant part, certified by either of them, stating the objectives and tasks, types and amounts of ITA, estimated cost, implementation period, and stages.
- The beneficiary’s letter confirming its support for the project and interest in its results and consent to the contracted activities and participation of a recipient whose activities fall within the beneficiary’s responsibilities, in the cases prescribed by the Procedure. For the special projects described above, no beneficiary letter is submitted; the recipient’s request states how the project meets the prescribed priorities.
- A document recording agreement on objectives, tasks, and activities between the development partner or implementer and the recipient (beneficiary), such as a memorandum or terms of reference. It must contain all required information, including expected results, performance criteria, resources, and the parties’ commitments. If the recipient consents to the contracted activities in its registration request, neither this document nor the copy of the grant agreement is submitted.
- A procurement plan in the form of Annex 5, certified by the development partner or implementer, where tax benefits are to be used. If the beneficiary is also the recipient, the plan must also be agreed with the beneficiary. The exception to submitting a plan for certain projects preparing Chornobyl nuclear power plant units for decommissioning, decommissioning those units, and converting the Shelter is explained in section 5 “Tax and Customs Benefits”. The procurement plan may be submitted in a language acceptable to the development partner, provided that it is accompanied by a Ukrainian translation.
- A copy of the grant agreement concluded by the recipient with the development partner or implementer, certified by the recipient, in place of the document recording agreement on objectives, tasks, and activities, unless the recipient gives the required consent in its registration request.
- A results report where registration documents are filed more than six months after the project started.
- An approval letter from the National Agency of Ukraine on Civil Service where the project provides for training, retraining, or professional development of Ukrainian civil servants.
All registration documents must be submitted in their original language, accompanied by a Ukrainian translation.
Grounds for Refusing Registration
The Secretariat may refuse state registration, in particular where:
- the documents do not meet the prescribed requirements;
- the project does not comply with the strategic or annual programme agreed with the development partner;
- the project implementation period has already expired when the documents are filed;
- the documents contain inaccurate information.
After the deficiencies have been remedied, the documents may be resubmitted.
Updating Project Registration
A project is re-registered where there is a change in the development partner, implementer, recipient or beneficiary, their names, the project name, objectives or content, its estimated value or implementation period, or where a procurement plan is submitted in the cases specified by the Procedure.
The documents required for re-registration depend on the type of change.
4. Accreditation of ITA Implementers
A non-resident legal entity implementing a project within the scope of Procedure No. 153 must be accredited by the Secretariat of the Cabinet of Ministers of Ukraine. State registration of the project provides a basis for this separate procedure. The official Secretariat page provides accreditation materials.
The following documents are required for accreditation:
- The development partner’s letter stating the implementer’s name and location, address and telephone number in Ukraine, official representative’s details, and lists of Ukrainian and foreign staff in Ukraine.
- A power of attorney legalised as required by law and naming the project.
Applicable treaties determine whether legalisation, an apostille, or exemption from these formalities applies. All documents must be submitted in their original language, accompanied by a Ukrainian translation.
Accreditation is free of charge. The decision is made within 10 working days of receipt of the documents. The certificate is issued for the term of the contract or project. The Secretariat sends a copy to the State Tax Service within five working days of the decision. Receipt of the copy provides a basis for tax registration of an implementer that is not already registered.
The certificate confirms the status of a non-resident implementer and provides a basis for applying, under the prescribed procedure, for special seals and stamps, special bank accounts, special service cards, and vehicle number plates for the implementer and its foreign staff.
Natural persons acting as implementers are not accredited under this procedure. A non-resident implementer must notify the Secretariat in writing within five days of changes to the information in its accreditation documents and provide the relevant documents. Extending the project duration requires reaccreditation.
5. Tax and Customs Benefits
Eligibility for tax and customs benefits is determined by legislation and the applicable international treaty. State registration of the project and the registration card provide the basis for claiming them.
| Benefit | Transactions | Main condition | Legal basis |
|---|---|---|---|
| VAT | Supplies of goods and services in Ukraine; imports of goods as ITA or financed with ITA funds | Treaty to which Ukraine has consented to be bound in the manner prescribed by law; registration, procurement plan where required, and reporting | Tax Code |
| Import duty | Goods imported as ITA under the applicable treaty | Consent to be bound by the treaty given by the Verkhovna Rada; customs clearance documents | Customs Code |
| Excise tax | Import of excisable goods as ITA, except alcoholic beverages and tobacco products | Consent to be bound by the treaty given by the Verkhovna Rada | Tax Code |
Procurement using ITA funds requires checking the applicable international treaty, project registration, and procurement plan where required. Purchases financed from other sources are subject to the general tax rules unless a separate exemption applies. Annex 5 permits co-financed procurement to be included in the plan for projects whose development partner is the EU. Eligibility for a tax exemption depends on the treaty and financing terms.
Customs clearance. The exemption requires the documents prescribed by law, including the registration card and procurement plan where required. No procurement plan is submitted for projects preparing Chornobyl nuclear power plant units for decommissioning, decommissioning those units, and converting the Shelter into an environmentally safe system under the international agreements and financing sources listed in the Procedure.
Monthly reporting. Implementers and subcontractors using tax benefits submit the confirmation required under Annex 8, in written and electronic form, to the tax office where they are registered by the 20th of each month. For a non-resident implementer that is not registered for tax purposes, the Procedure specifies the tax office at its Ukrainian accreditation address. Contracts concerning preparation for and decommissioning of Chornobyl nuclear power plant units and conversion of the Shelter are excepted: the recipient using the benefits submits the confirmation required under Annex 9 to its tax office, also by the 20th of each month in written and electronic form.
6. Bank Accounts and Foreign Exchange Transactions
An accredited non-resident implementer may open the bank accounts provided for by the Procedure to carry out the project in Ukraine. The required documents depend on the account type, customer identification requirements, and the bank’s procedures under National Bank of Ukraine regulations. These requirements should be confirmed in advance with the selected bank.
Foreign exchange rules under martial law. Under NBU Board Resolution No. 18 of 24 February 2022, funds credited to a client’s account under ITA projects or programmes for use in accordance with their terms are excluded from the calculation of available foreign currency funds used to apply the restriction on residents’ foreign currency purchases. NBU Resolution No. 136 removed the condition of prior state registration of the project or programme from this provision. Other applicable foreign exchange requirements must be checked separately.
Cross-border transfers. A separate exception applies to payments under ITA and cross-border cooperation projects or programmes. NBU Resolution No. 136 of 19 November 2024, effective from 20 November 2024, removed the requirement that such projects and programmes be financed by the European Union. For each transfer, the payment’s connection with the project, the supporting documents, and the foreign exchange rules in force on the payment date must be checked.
7. Subcontractors in ITA Projects
Separate accreditation is not required for subcontractors. The subcontractor’s role must be consistent with the definition above and its written agreement with the implementer or recipient. If the same non-resident legal entity also acts as an implementer, the accreditation requirements for implementers apply.
Benefits for a subcontractor’s procurement depend on the international treaty, tax and customs legislation, project terms, and procurement plan where required. The monthly confirmation requirements for a subcontractor using tax benefits are explained in section 5 “Tax and Customs Benefits”.
Where the plan changes because a subcontractor or procurement participant has been designated, the development partner (implementer) or recipient submits the updated plan to the Secretariat, showing the amendment date, with a copy of the subcontract or the subcontractor’s contract with the procurement participant. The Procedure sets out a separate process for other changes to the plan. The procurement plan under Annex 5 states the maximum subcontract amount; it cannot be below UAH 250,000, with any foreign-currency equivalent calculated at the NBU rate on the date the subcontract is concluded.
8. Monitoring and Reporting
Reporting deadlines and forms depend on each participant’s role. The special deadline for the implementer’s semi-annual monitoring results for 2026 does not change the reporting deadlines for recipients or beneficiaries.
| Monitoring / form | Who submits | To whom | Deadline |
|---|---|---|---|
| Semi-annual / Annex 3 | Recipient | Beneficiary; for the special projects described above, the Secretariat | by 10 July of the reporting year |
| Semi-annual / Annex 11 | Implementer | Secretariat of the Cabinet of Ministers | by 30 July; for 2026, by 1 November 2026 |
| Annual / Annex 3 | Recipient | Beneficiary; in the specified special cases, the Secretariat | by 10 January of the following year |
| Annual / Annex 11 | Implementer | Secretariat of the Cabinet of Ministers | by 30 January of the following year |
| Results of current and/or final monitoring / Annex 7 | Beneficiary | Secretariat of the Cabinet of Ministers | by the 30th of the month following each reporting half-year |
Final monitoring takes place as the project is completed. If recipients are established or selected through a competition during project implementation, the beneficiary submits their documents to the Secretariat. Where the project provides for supervisory boards or expert groups, the recipient also submits the required copies of meeting minutes. The beneficiary and recipient publish annual monitoring results and materials developed under the project on their websites.
Failure to submit the required current and final monitoring documents to the bodies designated to receive them is deemed unsatisfactory project implementation. Within 10 days, the Secretariat informs the development partner in writing and raises the question of suspending project implementation until the documents are received. During suspension, the relevant benefits, privileges, and immunities cannot be exercised; within 15 days, the Secretariat informs the customs and tax services and publishes the suspension information.
The benefits cannot be used from 00:00 on the day following publication of the suspension information on the Unified Web Portal of Executive Authorities. The right to use them is restored once these documents have been received. Within three working days, the Secretariat informs the customs and tax services and publishes the date on which the right is restored.
9. Closing ITA Projects
Tax, banking, asset, and employment steps are governed by legislation, the project agreements, and the way the project is implemented. The Procedure sets out the grounds and process for cancelling state registration.
A practical checklist for closing a project may include the following steps:
- Final monitoring. Prepare the reporting documents using the appropriate form: Annex 3 for the recipient, Annex 11 for the implementer, and Annex 7 for the beneficiary. Check where they must be submitted and any additional contractual deadlines.
- Tax matters. Check that tax obligations have been met and that purchases made using tax benefits are supported by the required documents and reports.
- Bank accounts and accreditation. Check the project terms and the bank’s and NBU’s requirements. Within 10 days of notification of cancellation of accreditation, the non-resident implementer or its authorised person must return the certificate to the Secretariat and provide confirmation of closure of the account at the authorised bank.
- Project assets. Check the accounting records and subsequent use of the assets for compliance with the international treaty, project agreements, and legislation. The recipient must recognise received tangible assets on the balance sheet within 10 calendar days and publish information on the received property within 10 calendar days of recognition. Information on a grant agreement must be published within 10 calendar days of its entry into force.
- Employment matters. Identify the lawful ground and procedure for terminating employment where project completion results in redundancies or other staffing changes.
- Registration and accreditation. Where re-registration, suspension of implementation, or cancellation of registration or accreditation is required, check the grounds and follow the applicable procedure.
Staffing changes are handled under the Labour Code of Ukraine. Before making staff redundant, the employer must generally give each affected employee at least two months’ notice and offer alternative work where required by law. During martial law, the special rules established by the Law of Ukraine on Organisation of Labour Relations under Martial Law also apply.
State registration may be cancelled, in particular, where:
- development partners, implementers, or recipients refuse to implement the project;
- the recipient cannot remedy violations involving misuse of ITA and/or the implementer cannot remedy violations relating to improper project implementation within the period set by the beneficiary;
- for projects subject to the special rules on beneficiaries, such violations cannot be remedied within the period set by the Secretariat of the Cabinet of Ministers of Ukraine.
Frequently asked questions
Who Registers ITA Projects in Ukraine
The Secretariat of the Cabinet of Ministers of Ukraine registers projects and programmes within the scope of the Procedure.
Does Each ITA Project Require Separate Registration
Both projects and programmes within the scope of the Procedure require registration. A programme brings together projects to achieve a common purpose. Whether a project or a programme is registered depends on the relevant project or programme documents. Accreditation of a non-resident implementer is handled separately.
Does the VAT Exemption Cover Every Project Transaction
The exemption applies to transactions that meet the requirements of the Tax Code, the applicable international treaty, and the project documents. Eligibility is checked separately for each purchase.
Is Accreditation Mandatory for Foreign Implementers
A non-resident legal entity implementing a project within the scope of Procedure No. 153 must be accredited by the Secretariat. Natural persons acting as implementers are not accredited under this procedure. Separate accreditation is not required for subcontractors.
What Happens if Monitoring Documents Are Not Submitted
Failure to submit mandatory monitoring documents to the bodies designated to receive them is deemed unsatisfactory project implementation. The Secretariat informs the development partner and raises the question of suspending project implementation. The benefits cannot be used from 00:00 on the day after publication of the suspension information. The right to use them is restored after receipt of the documents, in accordance with the procedure described above.
Do Grants for Budget Support Require ITA Registration
The exclusion applies to ITA provided by international financial organisations as grants for budget support under Ukraine’s treaties with those organisations.
How DLF Can Help
DLF attorneys-at-law assists foreign organisations, companies, and investors throughout the implementation of projects in Ukraine. Its services include advice on selecting a corporate structure, document preparation, ITA project registration, implementer accreditation, tax and customs structuring, foreign exchange compliance, review of agreements with recipients and subcontractors, employment matters, and project closure. Related work is handled through DLF’s corporate law / M&A and tax law practices.
Igor Dronov, Counsel — DLF attorneys-at-law
Contact: +380 44 384 24 54, info@dlf.ua.
This material is intended for general information only. How these rules apply depends on the circumstances of each case and requires a separate legal assessment.