In 2026 Ukraine updated the rules for reviewing citizenship decisions: since 16 January, Law No. 4502-IX has been in force, setting out a new version of Article 21 of the Law “On Citizenship of Ukraine”, and since 13 February a new Procedure for citizenship matters applies (Presidential Decree No. 110/2026).
According to the analysis of the lawyers of Pravovyi Tsentr Law Firm, for people who received a Ukrainian passport in the 1990s–2000s this raises one practical question: on what legal basis, and on the strength of which documents, was their citizenship granted.
Two different situations
Citizens “of 1991” (Article 3 of the Law). These are people recognised as citizens because they lived in Ukraine on 24 August 1991 or 13 November 1991. Such a decision can be cancelled only if it was based on false information, forged documents, deception or the person concealing a material fact. The mere fact that different archival records have surfaced today is usually not enough.
Acquisition of citizenship (Articles 7, 8, 10, etc.) — above all by territorial origin through parents, grandparents or great-grandparents. Here the grounds for review are broader: in addition to the above, they include documents that had expired or did not prove the grounds for acquisition, and an unfulfilled obligation to renounce foreign citizenship.
Examples: situations worth checking
Legal wording is not always easy to follow, so below are typical situations described by the lawyers of Pravovyi Tsentr Law Firm. They show where questions may arise, but do not in themselves mean that citizenship will be cancelled: each case is assessed only after the documents are obtained.
A grandmother from a territory that is now in Poland (Article 8). A man obtained citizenship by territorial origin. The certificate submitted to the migration service stated that his grandmother was born in a village that formed part of the Ukrainian SSR in 1944–1951 and now belongs to Poland. Later it emerges that the original parish record shows a different surname or date of birth, or that it concerns another village with the same name. For acquisition under Article 8 this may already be a ground for review: the law expressly refers to documents that do not prove the grounds for acquisition (Article 21(2)), and intent on the person’s part is not required. The defence rests on whether the family link and territorial origin are confirmed by other documents.
The chain of kinship does not add up (Article 8). Citizenship was granted through a grandfather. The applicant’s mother’s birth certificate lists the grandmother under a different surname, with no marriage record; or dates of birth differ by several years between documents. A break in the chain “applicant — parents — grandparent” is one of the most common problems. Sometimes it can be closed with requests to civil registry offices and state archives (marriage or name-change records), sometimes not.
Conscript service in 1991 (Article 3). A young man was conscripted from Kharkiv in 1990. On 24 August 1991 he was serving in a military unit in another Soviet republic and, as was usual then, was registered at the unit rather than at his home address. Later he was issued a Ukrainian passport as a permanent resident of Ukraine. In theory this raises the question whether he can be regarded as having “permanently resided” in Ukraine on that date. But to cancel a decision under Article 3 the law requires false information, forged documents, deception or concealment of a fact by the person themselves (Article 21(1)). If he submitted genuine documents (a military ID with entries) and the authority made the decision, the service itself is usually not a ground. It is different if a certificate of residence at his parents’ address was submitted that did not reflect the facts.
Residence established by a court on witness testimony (Article 3). There was no residence registration in Ukraine on 24 August 1991, so in the 1990s permanent residence was established by a court on the basis of witness testimony. Archival records now show the person was registered and working in another republic at the time. Everything depends on whether the person gave false information to the court and the migration service. If so, this is a risk both for citizenship and in terms of liability, so such cases require very careful analysis before any step is taken.
An obligation to renounce another citizenship was not fulfilled (Article 8). A foreign national obtained Ukrainian citizenship by territorial origin and signed an obligation to submit, within two years, a document confirming the termination of their citizenship. The document was never submitted and the second passport was kept. This is a direct ground for cancelling the acquisition decision (Article 21(2)). At the same time it should be established whether there were reasons beyond the person’s control why the document was not issued, and whether the situation falls under the cases where multiple citizenship is recognised (Article 5-1); multiple citizenship with an aggressor state is not allowed.
When there are most likely no grounds for review. The person was registered and living in Ukraine on 24 August 1991, received a passport on the basis of genuine documents and held no other citizenship. In such a situation the citizenship decision usually cannot be cancelled. But only the documents show this: the file often turns out to look different from what the person remembers, so the check should start with obtaining the case materials.
What changes after a decision is cancelled
For many people, a citizenship review is not a threat but a way to bring their legal status into line with reality: the person holds another citizenship, lives abroad, or never had lawful grounds to be considered a Ukrainian citizen. That is why it is important to understand in advance what will change.
Status.
• Cancellation ends the legal effects of the citizenship decision from the date of the cancellation decision (Article 21(3)). It does not apply retroactively.
• If the person kept the citizenship of another state (for example, did not renounce it despite an obligation to do so), they become a foreign national of that state.
• If there is no other citizenship, the person may apply to the State Migration Service under a separate procedure for recognition as a stateless person, where there are grounds for it. A previous citizenship is not restored automatically; that depends on the law of the state concerned.
Military registration.
• Under the Law of Ukraine “On Military Duty and Military Service”, military duty applies to Ukrainian citizens. Foreign nationals and stateless persons do not have it and may serve only voluntarily under contract.
• Once the cancellation decision takes effect, the person is removed from the military register as no longer a Ukrainian citizen.
Travel abroad and stay in Ukraine.
• Exit restrictions that apply to male Ukrainian citizens do not apply to foreign nationals: a foreigner crosses the border on their own national passport on general terms.
• A stateless person travels on a travel document issued after recognition as a stateless person.
• To remain in Ukraine, a foreigner needs a basis for stay — a temporary or permanent residence permit.
What to bear in mind.
• Until the decision is made, the person remains a Ukrainian citizen with all obligations, including military registration. A request or application does not change status by itself, and cancellation does not release anyone from liability for violations committed before its date.
• The State Migration Service decides after verification; the outcome and timing depend on the documents and cannot be guaranteed. The decision may be appealed.
• A person whose decision on acquisition of citizenship was cancelled under Article 21 cannot later acquire Ukrainian citizenship by territorial origin.
• A foreigner loses rights reserved for citizens: voting rights, the right to own agricultural land, and some social benefits.
• Where the grounds involve false information or forged documents, the risk of criminal liability is assessed separately (taking limitation periods into account). That is why the lawyer decides on strategy only after analysing the documents.
A detailed legal analysis is available on the website of Pravovyi Tsentr Law Firm.
Where to start: lawyer’s requests
The first step is not an application for review but obtaining the existing documents. A lawyer requests facts and copies of documents; the authority normally replies within 5 working days (up to 20 for large volumes). Each request costs UAH 4,000.
Copies of the citizenship case file (State Migration Service)
First issuance of a Ukrainian passport (State Migration Service)
Residence registration as of 1991
Obligation / declaration on foreign citizenship (State Migration Service)
Copy of an ancestor’s birth record
“Full citizenship basis check” package — UAH 10,000. Based on your questionnaire, the lawyer selects the necessary requests (up to five), prepares and sends them, plus one follow-up request if the documents are held by another institution. Legal analysis of the documents received is ordered separately.
Order the “Full Check” package — UAH 10,000
This material is for information only and is not legal advice.