By Maksym Sysoiev, Partner, Dentons
Ukraine’s Cabinet of Ministers have approved new mechanism that will provide state support for businesses that have suffered losses as a result of hostilities or that have obtained war-risk insurance. Resolution No. 1541 of 28 November 2025 establishes programs (for damage and for war-risk insurance) to be launched on 1 January 2026 and administered by the Export Credit Agency (ECA). Businesses can participate in one or both programs.
Below, we have prepared a brief overview of what will be provided under the programs.
What does the Resolution provide for?
The Resolution establishes procedures for:
- Partial compensation of the value of destroyed/damaged property
- Partial compensation of war-risk insurance premiums
Payments will be made from the state budget through the ECA.
What exactly is compensated?
Compensation for damaged/destroyed property
- Buildings, structures, engineering infrastructure, equipment, and unfinished construction projects (i.e. projects that started after 1 January 2021).
- The property must be located in high-risk regions: Dnipropetrovsk, Donetsk, Zaporizhzhia, Mykolaiv, Odesa, Poltava, Sumy, Kharkiv, Kherson, and Chernihiv regions. Those territories temporarily occupied by the Russian Federation as well as temporarily occupied or active combat zones are excluded from this program.
- The program only covers losses that were incurred after the Resolution entered into force (1 December 2025).
Compensation of insurance premiums
- Property can be located in any region of Ukraine except temporarily occupied territories and territories without a determined date of de-occupation.
- The insurance must cover war risks.
What war risks will be compensated?
- Missile, UAV, and artillery strikes or fragments
- Consequences of air/missile defense operations
- Fire, explosion, blast wave
Who is eligible for compensation?
Any business entity except:
- Nonresidents
- Companies undergoing bankruptcy/liquidation
- Tax debtors
- Persons subject to sanctions in Ukraine or the EU, or ultimate beneficiaries belonging to the aggressor state or terrorist organizations
- Those whose beneficial owner is a citizen of the aggressor state (except those legally residing in Ukraine)
- Recipients of state aid in violation of aid conditions
- Entities not registered in the State Agrarian Register (where registration is mandatory)
What is the cost for participating in the compensation programs?
- For compensation of damaged/destroyed property, a fee of 0.5 percent of the total amount of probable loss (as determined by the applicant)
- For compensation for war-risk insurance, the fee is UAH 5,000 (approximately € 102 according to the exchange rate of the National Bank of Ukraine as of 4 December 2025)
- The fee is non-refundable, regardless whether the event occurs or whether budget funds are available
How much compensation can a business expect to receive?
- Maximum compensation: UAH 10 million (approximately € 203 145 according to the exchange rate of the National Bank of Ukraine as of 4 December 2025) per business entity and its related parties
- Compensation cannot exceed actual direct losses
- The applicant determines the amount of probable loss
What is the procedure for participating in the compensation program for damaged/destroyed property?
Stage 1. Application to participate in the program
The applicant submits the following to the ECA:
- Copies of ownership documents
- An independent valuation report (prepared no earlier than 90 days before submission)
- An extract from the Unified State Register (issued no earlier than 10 days before submission)
- Confirmation of payment of the 0.5 percent fee
- Documents confirming the authority and identity of the signatory
The Agency reviews documents within 30 days.
Stage 2. Application for compensation (after the incident)
The applicant may apply once information and documents have been entered into the State Register of Property Damaged and Destroyed as a Result of Hostilities, Terrorist Acts, or Sabotage Caused by Russia’s Armed Aggression.
Deadline: no later than three months after the end/cancellation of martial law.
Documents to attach:
- Certificate of no tax debt
- Authority and identity documents of the signatory
- Additional documents required by the application
The ECA will review the compensation request within 30 days, based on the application, attached documents and certain documents submitted to the Register.
Stage 3. Assignment of claims
Submitting a compensation application = automatic accession to a contract assigning to the state the right to claim compensation from the Russian Federation in the amount paid.
The right transfers to the state at the moment funds are credited to the applicant’s account.
Stage 4. Payment of compensation
Funds are transferred to the applicant’s bank account.
Compensation is paid by the ECA only within available state budget funds. If the budget allocation is insufficient, compensation is not paid, and the applicant’s fee is not refunded.
How does the mechanism for war-risk insurance compensation work?
Compensation applies to property insurance contracts covering war risks provided that:
- The insurance contract includes war-risk coverage eligible for compensation.
- The insured amount does not exceed the actual value of the property.
- The insurance contract specifies a separate premium rate for war risks and covers only property eligible for compensation.
- The contract term and insurance period do not exceed one year.
How much compensation can a business receive for war-risk insurance?
Compensation of the premium is calculated using a formula set by the Resolution and cannot exceed UAH 1 million (approximately € 20 314 according to the exchange rate of the National Bank of Ukraine as of 4 December 2025) per business entity and its related parties for all insurance contracts that expire in the relevant year.
How can a business participate in the insurance premium compensation program?
Stage 1. Application for participation in the program
- When submitting documents required to conclude an insurance contract, the business must also submit to the insurer the application to participate in the premium compensation program (in a form approved by the ECA).
- Participation is voluntary, and there is a fee of UAH 5,000 (approximately € 102 according to the exchange rate of the National Bank of Ukraine as of 4 December 2025) paid to the ECA for each application.
Stage 2. Application for compensation
Upon expiry of the insurance contract, the participant submits to the ECA an application for premium compensation (for each contract) in a form approved by the ECA.
Stage 3. Payment of compensation
- The ECA reviews the request within 30 calendar days, based on the application, attached documents, and the ECA’s own calculations.
- The payment procedure is the same as for compensation for damaged/destroyed property.
This article was originally published on CEE Legal Matters on December 11, 2025.