The eVidnovlennia (eRestoration) compensation program was launched in May 2023 to provide support to Ukrainian citizens whose real estate was damaged or destroyed as a result of the armed aggression of the Russian Federation. Since then, eVidnovlennia has become an important tool for rebuilding the country, helping citizens return to normal life by providing the necessary funds to restore their homes.
The implementation of the program is a complex process involving citizens, local governments, state authorities, notaries, banks, and businesses. At the core of the program are the commissions responsible for reviewing matters related to the provision of compensation for residential properties damaged or destroyed due to hostilities, terrorist acts, or sabotage resulting from Russia’s armed aggression against Ukraine (hereinafter referred to as the commissions, or compensation commissions).
Unlike other components of the program, which are digitalized and less prone to corruption risks, the commissions are the main “human factor” of eVidnovlennia. Their responsibilities include:
- Reviewing applications,
- Verifying compensation recipients,
- Inspecting (surveying) properties,
- Deciding on suspension or resumption of application reviews and granting or denying compensation,
- Reviewing objections from applicants who disagree with inspection results, and
- Verifying the targeted use of compensation funds.
The proper functioning of the commissions is crucial to ensuring the transparency and effectiveness of the compensation mechanism.
This study focuses on the organizational and legal aspects and the results of the commissions’ work within the mechanism for providing compensation for real estate damaged or destroyed due to hostilities, terrorist acts, or sabotage resulting from Russia’s armed aggression against Ukraine.
The research analyzes the establishment, formation, and operations of 177 commissions for reviewing applications for compensation for damaged and/or destroyed housing in the period from April 29, 2023 (the date the Cabinet of Ministers of Ukraine Resolution No. 381, which provides for the creation of compensation commissions, came into effect) to April 29, 2024.
The information for this study was collected from open data, as well as responses to information requests and questionnaires received between May and June 2024 from 112 local governments and military administrations of settlements in 21 regions of the country. Also, between July and September 2024, 12 interviews were conducted with public representatives serving on commissions and local government officials involved in their establishment and operations.
Summary
The process of establishing commissions for compensation began in late April 2023. Within the first two months following the adoption of the regulatory framework, half of the commissions covered in this study were created — primarily in localities within regions most affected by the war, such as Dnipropetrovsk, Kyiv, Kharkiv, Chernihiv, and Mykolaiv regions. Since the legislation did not set clear deadlines for establishing these commissions, the process continued into 2024.
However, in a number of cities, commissions have still not been established, and such delays could become an obstacle to the prompt exercise of residents’ rights to compensation if their housing is damaged or destroyed as a result of the war. In addition, an analysis of local authority decisions revealed several procedural errors in the process of creating commissions. In particular, in some cases commissions were established by orders of the city mayor rather than by a decision of the executive body, as required by law. Such violations may become grounds for challenging both the respective orders and the commissions’ decisions themselves, thus undermining their legitimacy.
One of the key conditions for ensuring proper inspections or assessments of properties and for making well-grounded decisions on awarding compensation is the mandatory inclusion of specialists with construction expertise in the commissions’ membership. Nevertheless, some commissions still lack such specialists, which can negatively affect the quality of damage assessments, the objectivity of decisions taken, and the fairness of compensation distribution.
An important step toward greater transparency in the work of commissions was the requirement to include civil society representatives in commissions dealing with compensation for damaged housing. However, in practice, implementing this requirement has faced various challenges.
More than a third of local authorities did not take any measures to involve civil society representatives in their commissions. As a result, only one in four commissions actually meets the legal requirements on civil society representation. The study also found that some commissions included persons who do not meet the legal criteria for civil society representatives, such as local council members or employees of municipal institutions. At the same time, the fact that these representatives serve on a voluntary basis, combined with a constant flow of applications, often leads to declining motivation to actively participate and fulfill their duties.
This situation highlights the need to implement additional transparency mechanisms alongside civil society engagement — in particular, by partially opening data from the Register of Damaged and Destroyed Property.
Most commissions surveyed (77%) reported that all aspects of their work are adequately regulated by current legislation. However, the remainder identified the insufficient 30-day deadline for processing compensation applications, especially in cases involving extensive damage or destruction, as a key issue. The results of this study show that, on average, commissions process about 86% of applications for damaged properties each month and only 81% for destroyed housing. One of the most effective practices has been the creation of district-level commissions, especially in large cities frequently subjected to shelling. This has significantly improved processing times, reaching an efficiency rate of up to 95%.
Other challenges and issues faced by commissions in their work include:
- Delays in receiving responses from the Ministry of Internal Affairs regarding the absence of criminal records or indictments for applicants who submit paper applications instead of using the Diia app.
- Lack of access to properties for inspection, review, or compensation verification.
- A limited and outdated list of works and costs required for restoring damaged properties.
- An insufficient list of grounds for refusing compensation for destroyed property.
- Low public awareness of the obligation to notify authorities about the completion of construction or repair works so that compensation can be verified.
The level of appeals against the decisions, actions, or inaction of compensation commissions remains rather low, which may indicate overall applicant satisfaction with the work of the commissions and the perception that their decisions are fair and well-founded. For example, only 91 appeals were recorded out of more than 49,000 reviewed applications during the studied period. Court statistics confirm this trend: only eight cases of judicial appeals against commission decisions were recorded during the same period. However, the lack of detailed information on reasons for refusals in notifications to applicants makes it more difficult to challenge commissions’ decisions promptly.
Limited access to information about the commissions’ activities remains one of the key challenges in this area. Only 22% of local authorities ensure transparency and accessibility of information on the commissions’ membership, location, and working procedures as required by law. Information on the results of meetings and decisions is often published only partially, which hinders applicants’ access, limits public oversight, and undermines trust in the compensation process.
Based on the results of this study, we recommend:
- Establish new commissions and review decisions on existing ones. Local authorities should proactively establish commissions to consider compensation applications where they do not yet exist, to ensure that residents’ rights to housing restoration assistance are fully protected in case of wartime damage. In localities with significant damage and destruction of housing infrastructure, it is recommended to establish separate district-level commissions to improve processing efficiency. Where commissions are already operating, decisions on their establishment, their regulations, and membership should be reviewed to identify and eliminate any non-compliance with current legislation.
- Ensure compliance with legal requirements on civil society participation and construction expertise. If a commission does not meet the required civil society quota, local authorities should take steps to include representatives of international or civil society organizations. This should be done not only through direct invitations but also through other communication measures: publishing information on official websites, on social media, in local media, and posting it on information boards and in local authority premises. The same measures can be used to attract qualified construction specialists.
- Improve the process for reviewing applications and making decisions. Parliament and the government should consider extending the deadline for processing applications, expand the list of grounds for suspending or refusing applications, and update the checklist and costs for repair works. Also, applicants should automatically receive the full text of the commission’s decision via the Diia app. Local authorities should include provisions in their regulations allowing commission members to participate in meetings remotely using telecommunication tools.
- Improve the compensation verification process. The government should legally establish a percentage threshold for completed repair or construction works, after which the use of compensation funds will be deemed targeted. It is also important to introduce additional notifications for recipients reminding them to submit completion reports. Furthermore, there should be an option for applicants to cancel mistakenly submitted notifications via the Diia app.
- Ensure access to information on commission activities. Under the law, the government must publish data from the Register of Damaged and Destroyed Property (excluding personal data and other information specified by the Cabinet of Ministers) as open data on the official register website. Local authorities, in turn, must guarantee the publication of information on commissions’ locations, membership, working procedures, and meeting outcomes, including the number of cases reviewed, decisions adopted, and the amounts of compensation granted.
