Exchange of Temporary Residence Permit in Ukraine in 2026: New Rules of Resolution No. 141
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If you are a foreigner living in Ukraine on the basis of a temporary residence permit, there is news you should not ignore. A document that only recently gave you the right to legally reside in the country may soon lose its validity. Along with this, real risks arise, from fines to deportation, forced return, and an entry ban.
Many people have become used to postponing the exchange of their residence permit, taking into account martial law in Ukraine and the previous relief measures. However, the new resolution of the Cabinet of Ministers of Ukraine changes the rules. The state now sets a clear deadline for exchanging temporary residence permits, and there is almost no time left to delay.
Changes in the law: who is affected by the mandatory permit exchange
The basis for the new rules is Resolution No. 141 of the Cabinet of Ministers of Ukraine dated February 5, 2026, which amended Resolution No. 1202 dated October 21, 2022, “Certain Issues of Implementing Legislative Acts in the Field of Migration Under Martial Law”. This document previously introduced certain relief measures for foreigners, except citizens of the Russian Federation, due to objective difficulties during the war. In particular, it allowed them not to rush with the exchange of residence permits.
Now the state’s approach has changed. Some of these relief measures have been cancelled. The text of the resolution has been amended to remove provisions that effectively allowed foreigners to postpone the exchange of temporary residence permits in Ukraine. In other words, the previous principle was that if the residence permit expired during martial law, it continued to be considered valid. Now this rule has been cancelled for most categories of foreigners.
We have already analyzed the legal details of the new rules in our article: Residence Permit in Ukraine 2026: New Rules and Exchange Deadlines. Today, we will focus on how much time you have to exchange the document and what the final deadlines are.
Deadline for Submitting Documents to the Migration Service
If the deadline for applying for an exchange, meaning the expiration date of your residence permit, occurred after February 24, 2022, you have exactly 90 days from the date the resolution enters into force to submit all necessary documents for the permit exchange. This does not apply to citizens of the Russian Federation, for whom separate, much stricter restrictions and other legalization procedures apply. Since the resolution enters into force on May 7, 2026, this “window” will remain open until August 4. However, taking into account the time needed to collect documents and possible queues, we recommend starting preparation now.
Please note! If the permit was issued, for example, in 2025 for 2 years, it remains valid until the end of its term and is not tied to the 90-day deadline under Resolution No. 141.
Therefore, the changes do not apply to all foreigners without exception. They primarily concern those who already had an obligation to extend their permit but postponed it due to the previous rules. For them, this is now a decisive period. Foreigners and companies employing foreign specialists are advised to audit their current residence permits and the legal grounds for staying in Ukraine. This will make it possible to collect the necessary data for status extension without haste and protect both the business and the foreigner from sanctions for violating migration rules.
|
Parameter |
How it was before |
How it is now under Resolution No. 141 |
|
Exchange deadline |
It was possible to wait until the end of the war |
Strictly 90 days from May 7, 2026 |
|
Document validity |
Automatic extension |
Invalid after missing the deadline |
|
Consequences of delay |
None (under certain conditions) |
Fine + risk of deportation |
Successful case: Temporary Residence Permit Exchange: Successful Handling of a Complex Case
Consequences and Fines for an Expired Residence Permit
What happens if you do not exchange your permit on time? Delay creates significant legal risks. For a foreigner, these include:
- Fines: under Article 203 of the Code of Ukraine on Administrative Offenses, the fine may reach UAH 5,100.
- Illegal stay: after the 90-day period expires, your stay in Ukraine becomes illegal.
- Entry ban: in the event of forced return, you may receive an entry ban to Ukraine for 3 years or more.
- Problems with bank accounts: banks may impose restrictions on outgoing transactions if you fail to provide up to date data for verification, or KYC.
Documents for Exchanging a Temporary Residence Permit in Ukraine
The procedure for exchanging a temporary residence permit under Resolution No. 322 is not simply a “card replacement”. In practice, it is a repeated check of the legality of the foreigner’s stay in Ukraine, so preparation should be approached with maximum care.
To apply to a territorial office of the State Migration Service, you need to prepare the following document package:
- passport document of the foreigner, together with a notarized Ukrainian translation;
- old temporary residence permit subject to exchange;
- documents confirming the grounds for staying in Ukraine, such as a work permit, certificate from an educational institution, marriage documents, family reunification documents, and so on;
- valid medical insurance policy, if required by the grounds for stay;
- receipt confirming payment of the administrative fee;
- application in the prescribed form, which is completed at the time of document submission.
Legal Requirements for Preparing Documents for the SMS
It is important to understand that the list of documents for a residence permit is not exhaustive in every specific situation. Depending on the grounds for stay, the migration service authorities may request additional documents or clarifications. In addition, during submission, the applicant’s identity is verified, data is checked in the relevant registers, and biometric information is collected.
Special attention should be paid to the quality and validity of the documents. Any discrepancies in data, an expired passport, or lack of confirmation of the grounds for stay may become grounds for refusal to exchange the permit. In such a case, the person risks losing the legal basis for residing in Ukraine.
That is why the residence permit exchange procedure requires not only the formal submission of documents, but also a clear understanding of the legal requirements, since even a minor mistake may have serious legal consequences.
You might also like: Changing the Basis of a Temporary Residence Permit in Ukraine When Changing Jobs or Family Status
Exchange of a Temporary Residence Permit: Legal Assistance for Foreigners
As a law firm, we have been providing a wide range of services for foreigners for more than 10 years, including assistance with the exchange of temporary residence permits and legalization of stay in Ukraine. Our work always begins with a detailed analysis of your situation: we assess the grounds for stay, check deadlines, and identify risks that often remain unnoticed without legal experience.
When working with our clients, we:
- conduct an audit of all available documents and identify potential issues before submission;
- provide a clear action plan tailored specifically to your situation, without generic advice;
- prepare and review the full document package in accordance with legal requirements;
- assist with translations, applications, and supporting documents;
- advise on the grounds for stay and, if necessary, help properly formalize or update them;
- support communication with the State Migration Service authorities;
- respond to requests or comments from state authorities in order to avoid refusal;
- provide support in complex or non standard situations, including missed deadlines or risks of losing status.
Our immigration lawyer acts proactively: explaining what steps should be taken now to avoid problems with future permit extension or changes to the grounds for stay. In addition, since employment is the most common ground for obtaining a residence permit, we also ensure synchronization of the validity periods of the foreigner’s work permit and residence document.
Do not wait for the critical deadlines and the August rush. Contact us today to make sure that your right to stay in Ukraine is secure.
More information about our residence permit exchange service is available here.
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