Ukraine's property market has been operating under extraordinary legal conditions since 2022. Now, a further wave of legislative reforms to Ukraine's real estate legislation is reshaping the rules for foreign nationals and foreign-owned entities holding or seeking to acquire property in the country. Those who do not act promptly risk title complications, blocked transactions, and potential loss of registered rights.
Recent amendments to Ukraine's real estate and land legislation impose new verification, disclosure, and registration obligations on foreign property owners – effective from mid-2025. Foreign nationals and entities with interests in Ukrainian real property must now satisfy enhanced due diligence requirements and re-confirm their holdings through the Derzhavnyi reiestr rechovykh prav na nerukhome maino (State Register of Real Property Rights, Ukraine's central land register). Failure to complete required steps within the prescribed compliance window may result in suspended property transfer rights or restricted conveyancing capacity.
This alert sets out what changed, which categories of foreign owners are directly affected, and the immediate steps required to protect your position in Ukraine.
What changed – the regulatory developments and their scope
Ukraine's legislature has enacted a series of measures amending the country's real estate and land legislation. The principal changes came into force in stages from the second half of 2024, with the most operationally significant provisions applying from 1 July 2025.
The core changes affect three areas. First, ownership verification: foreign owners must now submit updated identity and beneficial ownership documentation to the State Register of Real Property Rights. This applies to both residential and commercial assets. Second, property transfer restrictions: conveyancing transactions – including sales, donations, and exchanges – involving foreign parties require an enhanced pre-transaction check. The competent notary must confirm that the seller's or buyer's details in the land register match current documentation before executing a notarialnyi akt (notarial deed). Third, land rights: foreign legal entities holding long-term lease rights or surface rights over agricultural or industrial land must disclose ultimate beneficial ownership through the State Register within the compliance period.
Ukraine's land legislation has historically restricted foreign ownership of agricultural land. The current reforms tighten enforcement of those restrictions and introduce penalties for undisclosed indirect foreign control. Companies incorporated in jurisdictions listed on Ukraine's controlled-jurisdiction register face additional scrutiny before any property transfer can be notarised.
The practical consequence for conveyancing is immediate. Notaries are now required to refuse execution of a notarial deed if the land register entry does not reflect current, verified ownership data. This means that a foreign owner whose registration details are outdated. due to corporate restructuring, passport renewal. Alternatively. Change of registered address. may be unable to complete a planned sale or refinancing until the register is updated.
For foreign owners monitoring the situation in neighbouring jurisdictions, our alert on real estate regulation developments in Russia provides a comparative regional perspective.
Who is affected – threshold criteria and compliance deadline
The following categories of foreign owners are directly within scope of the new requirements.
- Foreign nationals holding title deeds to residential or commercial property in Ukraine, regardless of acquisition date.
- Foreign legal entities – including holding companies, investment vehicles, and special-purpose companies – with registered real property rights in the State Register.
- Foreign nationals or entities holding long-term lease rights, emphyteusis rights, or superficies rights over Ukrainian land parcels.
- Ukrainian companies with a foreign beneficial owner exceeding a defined ownership threshold, where those companies hold real property.
- Non-resident trustees or nominees acting as registered owners of Ukrainian real estate on behalf of foreign principals.
The compliance deadline for submitting updated documentation to the State Register of Real Property Rights is 31 December 2025. Owners who fail to meet this deadline may face a registration freeze – meaning no property transfer, mortgage, or encumbrance can be processed until compliance is confirmed. Importantly, this freeze applies automatically upon expiry of the compliance window; it does not require a separate regulatory order.
Foreign owners who have undergone corporate restructuring – including mergers, demergers, changes of jurisdiction, or beneficial ownership changes – since their original registration face a heightened risk. Their existing title deed entry may no longer reflect the current legal position. Any discrepancy between the land register record and current ownership documentation will block a notarial deed at the point of transaction.
The tax implications of restructuring or disposing of Ukrainian real property under the current legislative environment are complex. Our analysis of tax law in Ukraine addresses the fiscal dimensions of real estate transactions for non-residents.
To receive an expert assessment of your property holdings in Ukraine and your compliance exposure under the new rules, contact us at info@ferrazwhitmore.com.
Immediate actions for foreign property owners
Foreign owners and their advisers should take the following steps without delay.
1. Audit existing registrations. Obtain a current extract from the State Register of Real Property Rights for each Ukrainian asset. Verify that the registered owner details – name, identification number, jurisdiction of incorporation, and registered address – are accurate and match current documentation. Even minor discrepancies can block a notarial deed.
2. Update the land register where necessary. If any registration entry is outdated, initiate the correction procedure through a Ukrainian notary or directly through the State Register. Document the chain of title clearly, including any corporate restructuring events. A lawyer in Ukraine with specialist real estate experience can manage this process efficiently.
3. Review beneficial ownership disclosure obligations. If your Ukrainian property is held through a corporate structure, assess whether the beneficial ownership chain is fully disclosed and correctly reflected in the relevant registers. Structures involving intermediate holding companies in controlled jurisdictions require particular attention.
4. Conduct pre-transaction due diligence before any planned disposal or financing. If you intend to sell, mortgage, or otherwise encumber Ukrainian real property before year-end, commission a full due diligence review now. Identifying registration gaps before signing heads of terms avoids costly delays at the notarial deed stage.
5. Assess the impact of wartime restrictions on your transaction timeline. Ukraine's martial law regime continues to affect certain categories of property transaction. Some transfers in areas subject to special status require additional administrative clearance. A law firm in Ukraine with current local practice knowledge can advise on whether your specific asset is within a restricted zone or category.
For a tailored strategy on real estate compliance and property transfer procedures in Ukraine, reach out to our team at Ferraz & Whitmore's Ukraine real estate practice or email info@ferrazwhitmore.com.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in real estate regulation, property transfer, and conveyancing matters for foreign owners in Ukraine and across CIS markets. We work with international investors, institutional buyers, and in-house legal teams who require results-oriented counsel on due diligence, land register compliance, and notarial deed procedures across multiple legal systems. Our CIS practice includes practitioners with direct experience of Ukrainian real property law and the evolving regulatory environment for non-resident owners. As a law firm in Ukraine advising international clients, we bring both jurisdictional depth and cross-border perspective to every mandate. To discuss your real estate position in Ukraine, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.