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The Registry of Damages Caused by Russia’s Aggression Against Ukraine held a meeting with representatives of business associations: new categories of claims for legal entities are now available

An expanded meeting with representatives of leading business associations and government agencies was held at the Kyiv office of the Register of Damages Caused by the Russian Federation’s Aggression Against Ukraine. Participants included Ukrainian MP Olena Shulyak, Kharkiv Mayor and Head of the Association of Frontline Cities and Communities Ihor Terekhov, as well as representatives of the All-Ukrainian Agrarian Council, the Chamber of Commerce and Industry, the Taxpayers Association of Ukraine, and other organizations—both in person and online. The central topic was the upcoming opening of application categories for legal entities and the state, as well as an explanation of the practical mechanisms for submission.

Olena Shulyak, Chair of the Verkhovna Rada Committee on the Organization of State Power, Local Self-Government, Regional Development, and Urban Planning, highlighted the three-tier structure of the international compensation mechanism: the Register of Damages — the Compensation Commission — the Compensation Fund. According to her, as of the date of the meeting, the Register had already received 130,000 claims exclusively from individuals, which indicates the enormous scale of work ahead. Ms. Shulyak emphasized the importance of ensuring that all categories of claimants—citizens, businesses, local self-government bodies, and state-owned enterprises—are fully prepared by the time payments begin.

Markiyan Klyuchkovsky, Executive Director of the Register of Damages Caused by the Aggression of the Russian Federation against Ukraine, gave a detailed presentation on the Register’s work—from the UN General Assembly resolution of November 14, 2022, which established the legal framework for the mechanism, to the current status and next steps. He explained that the Registry has currently opened 16 categories of claims for individuals, and opening categories for businesses and the state is the next priority—specifically, category A3.5 for sole proprietors has already been opened, while categories B and C for the state and legal entities are in the beta testing phase.

The Executive Director specifically highlighted the innovative “digital powers of attorney” tool, which will allow a company’s manager to delegate the submission of an application to a lawyer or another person via the “Diya” app in just a few minutes. Regarding the prospects for the mechanism as a whole, Mr. Klyuchkovsky noted: “According to World Bank estimates, the economic costs of the war amount to $667 billion—and this figure must be supported by a corresponding number of claims that reflect the actual scale of the destruction.”

He also reported that in December of last year, 35 countries and the European Union signed the Convention establishing the International Compensation Commission, and after 25 ratifications are collected, the Commission will be able to begin its work as early as 2027–2028.

Ihor Terekhov, mayor of Kharkiv and head of the Association of Frontline Cities and Communities of Ukraine, described the extent of the destruction in Kharkiv, which has been subjected to targeted shelling for four years: more than 13,000 damaged buildings, of which nearly 9,500 are residential, and another 200 buildings are beyond repair and must be demolished. He cited a concrete result of the existing compensation mechanism for citizens: “We have submitted over 35,000 claims for compensation for damaged housing; over 21,000 have already been approved, and people have been awarded nearly 1.9 billion hryvnias.”

He called for a similar systematic launch of a mechanism for businesses. Mr. Terekhov emphasized that the destruction of a business is not only a loss of property but also of jobs, budget revenues, and the stability of society in frontline territories.

“For Kharkiv, the Register of Damages is a matter of justice and the future. It is important to us that every destroyed home, every damaged structure, and every destroyed enterprise be properly documented and serve as the basis for actual compensation. Kharkiv is ready to be among the first cities in Ukraine to submit business claims to the Register of Damages and informed the Secretary General of the Congress of Local and Regional Authorities of the Council of Europe of this at the end of last year. The mechanism must be clear and as effective as possible so that people see a future and remain where they live.”

Dmytro Kokhan, Deputy Chairman of the All-Ukrainian Agrarian Council and a member of the Supervisory Board of the Ukrainian Business Council, presented the agrarian sector’s experience in systematically documenting losses since April 2022—from the initial recommendations to businesses to the government’s approval of calculation methods and documentation rules. In collaboration with Project Expedite Justice, the Council funded an independent assessment of losses for 150 agricultural enterprises, which were prepared to submit claims immediately after the relevant categories were opened.

He highlighted a specific challenge for businesses compared to individuals: assessing a company’s losses is a complex, multi-component calculation that is difficult to perform objectively without the involvement of certified appraisers. Separately, he raised the issue of the platform’s technical limitations—in particular, the 3 MB file size limit for uploads is critically small for large assessment reports of 300 MB or more.

Mykhailo Nepran, First Vice President of the Ukrainian Chamber of Commerce and Industry, explained that the Chamber has effectively become one of the main entities responsible for documenting lost assets in Ukraine: regional chambers visit the sites, independent experts conduct assessments, and the national chamber certifies the findings regarding the value of lost assets and lost profits across the country. He emphasized the urgent need for further standardization of approaches, as different experts still use different methodologies, which gives Russian lawyers grounds to challenge and invalidate Ukrainian conclusions on formal grounds in international courts.

Among the CCI’s proposals are the creation of a centralized database of expert conclusions involving the State Emergency Service, the Security Service of Ukraine, the National Police, and the Prosecutor General’s Office; a standardized document for recording damages; and the expansion of the methodology for calculating lost profits in collaboration with the State Property Fund. Mr. Nepran also highlighted the need to expand digital documentation tools—particularly in cases where experts cannot physically access the site and drone photography is the only option.

Grigol Katamadze, president of the Ukrainian Taxpayers Association, supported the initiative to establish a Register of Damages as an important step toward restoring justice. He raised a fundamental question regarding the sources of future compensation: whether it would be collected directly from Russia or covered by international aid from partners—and expressed a realistic caution that businesses might have to wait a very long time for these payments.

At the same time, the UTA President proposed an alternative approach: filing claims in foreign courts to seize frozen Russian assets for the benefit of affected businesses—as a tool that could yield results more quickly.

Roman Ryabov, head of the appraisal firm Delta Consulting and a member of the All-Ukrainian Association of Appraisal Specialists, speaking on behalf of practicing appraisers, welcomed the upcoming introduction of new categories for businesses, noting that the companies for which his firm had conducted damage assessments had long awaited this moment. He raised an important question regarding the possibility of submitting an assessment of lost profits, conducted in accordance with international standards, under category C3.1—and received confirmation that such a possibility is provided for.

Victoria Kovalchak, a representative of Project Expedite Justice, raised a question regarding foreign investors and legal entities that have suffered losses in Ukraine. She asked about the timeline for implementing the option to submit applications in English and alternative methods of identity verification for foreigners. In response, Mr. Klyuchkovsky confirmed that a technical solution is currently being developed and specifics are expected toward the end of this year, while no deadline has yet been set for the submission of applications to the Registry.

Yulia Chumak, Head of Advocacy at the Ukrainian Business Council, noted that cooperation with the UBC—the largest association of business organizations—in disseminating information regarding the launch of new application categories related to losses in the private sector would be highly beneficial and effective. She proposed leveraging the UBC’s potential as a platform for large-scale outreach to entrepreneurs and their employees regarding the Registry’s capabilities. People—partners, employees, and customers—are a vital component of any business. Thus, as part of an informational partnership, the UBC will be able to share information about the Registry’s operations, which is aimed at both entrepreneurs and citizens.

The meeting participants reached a consensus that populating the Register of Damages with actual claims from businesses, communities, and the government sends a political signal to international partners regarding the scale of the damage inflicted. A transition from closed beta testing to public testing of categories for legal entities is expected in the near future, with a full launch within a month. Business associations confirmed their readiness to help inform and disseminate materials from the Register among their members.