H
How the war has changed the rules of stay for foreigners in Ukraine – article by Tetiana Zakharkiv for The Page
According to the official statistics of the State Migration Service (SMS) regarding the stay of foreigners in Ukraine, as of July 1, 2025, 47,600 persons are registered as foreigners and stateless persons with temporary residence, and 306,403 persons are registered as immigrants. Compared to 2021, the number of foreigners with temporary residence permits decreased approximately fourfold, while the number of foreigners with permanent residence permits remained almost unchanged. The decrease in temporary residence permits was mainly due to the decline in the number of students studying at Ukrainian universities.
Entry of foreigners into Ukraine, obtaining work permits, temporary and permanent residence permits, as well as extension/replacement of these documents have their own specifics during martial law. Let’s review the key points to be aware of.
Validity of expired temporary and permanent residence permits
The Cabinet of Ministers of Ukraine adopted Resolution No. 1202 of October 21, 2022, “Certain issues of implementing legislation in the field of migration under martial law,” which states: “Residence permits for temporary or permanent residence, except those issued to citizens of the Russian Federation, whose validity expired or which are subject to exchange in accordance with legislation after February 24, 2022, confirm legal grounds for temporary or permanent residence in Ukraine and the right to enter Ukraine during martial law and for 30 calendar days from the date of its termination or cancellation.”
The Cabinet of Ministers of Ukraine adopted Resolution No. 1202 of October 21, 2022, “Certain issues of implementing legislation in the field of migration under martial law,” which states: “Residence permits for temporary or permanent residence, except those issued to citizens of the Russian Federation, whose validity expired or which are subject to exchange in accordance with legislation after February 24, 2022, confirm legal grounds for temporary or permanent residence in Ukraine and the right to enter Ukraine during martial law and for 30 calendar days from the date of its termination or cancellation.”
This provision allows foreigners and stateless persons to use expired residence permits during martial law and for 30 days after its termination/cancellation. The SMS emphasizes on its official website that Resolution No. 1202 remains in force. This means that if such persons did not manage to apply for extension in time, they still do not lose their legal grounds to stay in or enter Ukraine.
However, the following should be considered. First, this rule does not apply to citizens of the Russian Federation. Second, a residence permit may be canceled (revoked) if the grounds on which it was issued cease to exist, as well as on other grounds set out in Cabinet Resolution No. 322 of April 25, 2018.
Although the law provides that “a foreigner or stateless person whose permit has been revoked or declared invalid must return the permit,” there remains a risk of using invalid documents. To prevent fraud or other illegal actions, the SMS website provides a “Check by invalid documents database” service. One must enter the series and number of the permit. If the permit is found invalid, one can additionally contact the SMS to clarify the reasons.
Change in salary requirements for foreigners
Until 2022, the Law of Ukraine “On Employment” required employers, when obtaining a work permit, to ensure that a foreign employee’s salary was at least 10 minimum wages (with some exceptions). However, on October 15, 2022, Law No. 2623-IX “On Amendments to Certain Laws of Ukraine Regarding the Use of Foreigners and Stateless Persons’ Labor in Ukraine and the Provision of Employment Mediation Services Abroad” came into force. The provisions on minimum salary levels for foreigners/stateless persons were removed. Thus, foreigners are now subject to the same salary rules as Ukrainian citizens.
Until 2022, the Law of Ukraine “On Employment” required employers, when obtaining a work permit, to ensure that a foreign employee’s salary was at least 10 minimum wages (with some exceptions). However, on October 15, 2022, Law No. 2623-IX “On Amendments to Certain Laws of Ukraine Regarding the Use of Foreigners and Stateless Persons’ Labor in Ukraine and the Provision of Employment Mediation Services Abroad” came into force. The provisions on minimum salary levels for foreigners/stateless persons were removed. Thus, foreigners are now subject to the same salary rules as Ukrainian citizens.
Nevertheless, the procedure for obtaining a work permit has not been canceled. On the contrary, it often takes longer because the Security Service of Ukraine (SBU) conducts checks.
Work permits are not required for permanent residence holders, refugees, or persons granted additional protection in Ukraine. In addition, journalists accredited to work in Ukraine, professional athletes, artists, emergency rescue workers for urgent tasks, clergy in certain cases, etc., do not need a permit.
Need for foreigners to obtain transit visas to reach Ukraine
Due to the absence of air travel, entry into Ukraine is only possible by land transport (cars, buses, trains) through border crossings with EU countries and Moldova. Accordingly, a foreigner on the way to Ukraine inevitably enters the Schengen zone or Moldova, which may require a transit visa. Before traveling, it is important to determine the transit country and check its visa rules.
Due to the absence of air travel, entry into Ukraine is only possible by land transport (cars, buses, trains) through border crossings with EU countries and Moldova. Accordingly, a foreigner on the way to Ukraine inevitably enters the Schengen zone or Moldova, which may require a transit visa. Before traveling, it is important to determine the transit country and check its visa rules.
It is also important to choose the correct type of transit visa. A Schengen type A visa is only for staying in an airport’s international transit zone and is not suitable. Instead, a Schengen type C short-term visa is required for entry and stay in Schengen countries for up to 90 days within a 180-day period.
One must also remember that having a transit visa does not cancel the need for a Ukrainian visa if required. The current entry regime by country can be checked on the MFA website. Among the countries whose citizens require visas to enter Ukraine are Algeria, Angola, Afghanistan, Bangladesh, Ghana, Guatemala, Guinea, Ethiopia, Yemen, Jordan, Cambodia, Pakistan, Nigeria, etc.
SBU checks of foreigners applying for residence permits
In the first half of this year, 262 persons were denied permanent residence permits, 528 were denied temporary residence permits, and 128 were denied immigration permits. These figures are roughly consistent with those before February 24, 2022, meaning the number of refusals has not increased.
In the first half of this year, 262 persons were denied permanent residence permits, 528 were denied temporary residence permits, and 128 were denied immigration permits. These figures are roughly consistent with those before February 24, 2022, meaning the number of refusals has not increased.
However, foreigners are checked more thoroughly. The migration service itself conducts inspections. The most common reason for refusal is the foreigner’s absence at the registered address stated in their documents. SMS staff may visit to confirm the foreigner actually lives there.
Other grounds for refusal or cancellation include information received from the National Police, SBU, or other state bodies that the foreigner’s actions threaten national security. For citizens of certain states recognized as security threats, preventive measures apply. In particular, issuance and renewal of work permits for such persons require approval from regional SBU offices, which may include direct interviews. A negative SBU decision results in refusal of a work permit, and thus a residence permit.
A separate large category subject to thorough SBU checks includes foreigners/stateless persons serving under contract in the Armed Forces of Ukraine, candidates for officer positions, or positions involving access to state secrets. On February 11, 2025, the Cabinet adopted Resolution No. 146 “On Approval of the Procedure for Conducting Psychophysiological Research Using a Polygraph During Special Checks of Foreigners and Stateless Persons.”
The Resolution states: “At the initiative of SBU officials or military commanders, with SBU approval, such research may be conducted during the validity of a military service contract as part of a special check of foreigners.”
Conclusion
Overall, the rules of stay for foreigners in Ukraine during martial law have not become more complicated—except for Russian citizens and some nationals of states deemed security threats.
Overall, the rules of stay for foreigners in Ukraine during martial law have not become more complicated—except for Russian citizens and some nationals of states deemed security threats.
Simplifications include the possibility of using expired residence permits during martial law, and the removal of the requirement for foreigners’ salaries to be at least 10 minimum wages when employers apply for work permits.
Complications include the need to obtain an additional Schengen or Moldovan transit visa to enter Ukraine by land due to lack of flights, and in some cases, SBU checks.
More at the link.