Insurance programme for losses caused by russian aggression

On 18 March 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 352, which introduces significant changes to the Procedure for the provision of partial compensation for the value of property of business entities destroyed or damaged as a result of the armed aggression of the russian federation (“Resolution”). The Resolution transforms the compensation mechanism into a full-fledged state collective insurance programme under conditions of prolonged martial law.

Introduction of Mandatory Prior Participation

From now on, compensation will be offered only to those businesses that participate in the compensation programme and exclusively for the losses caused to their property during such participation. Participation is voluntary and subject to a fee. The participation fee amounts to 0.5% of the estimated loss, the amount of which is determined by the participant themselves within a limit of 30 million hryvnias. The programme also provides for compensation of insurance premiums under insurance contracts covering war risks.

The programme will be administered by PJSC “Export-Credit Agency” (“Agency”).

Terms of Participation

The programme covers damage caused to assets used in economic activity:

• Geographical scope: high-risk territories (10 specified regions), but for reimbursement of insurance premiums it applies throughout the non-occupied Ukrianian terrritories;
• Assets: production equipment, real estate and utility networks (a new category). Construction-in-progress projects are no longer covered by the programme;
• Eligible entities: business entities, excluding certain categories, such as non-residents, sanctioned persons, companies with tax debts, etc.

Procedure and Compensation Limits

The Resolution has tripled the previous payment limits: up to 30 million hryvnias for property and up to 3 million hryvnias per year for insurance premiums. Compensation cannot exceed these limits, even if the actual direct losses are greater.

The Agency’s decision-making is linked to the Ukrainian Register of Damaged Property (“Register”). Thus, in the event of destruction or damage to property, the first step is to record the relevant losses in the Register, followed by submitting a claim for compensation to the Agency. Payments are made only within the limits of budgetary allocations. In the event of a budget shortfall or receipt of compensation from third parties (commercial insurance), no compensation is paid, and participation fees are not refunded.

The recipient of compensation automatically assigns to the state the right to claim against the russian federation in the amount of the payment. The transfer of rights takes effect upon the crediting of funds to the recipient’s account.

Additional notes

For further information on the topic please contact partner Oleksii Maslov, or by telephone +380 44 591-3355 or via e-mail.