Law 922-VIII — Ukraine's Public Procurement Act

Scope and thresholds

Article 2 divides buyers into four categories: state, regional and local authorities and law-enforcement bodies; the Pension Fund and the unemployment social insurance fund with their territorial bodies; other public-need legal entities that are budget managers or recipients, or in which the state or a community holds a majority of votes or more than 50 per cent of capital; and, in the fourth category, entities operating in the utility sectors defined in Article 2(2) where the state or another buyer holds more than half the capital or votes, or where they hold special or exclusive rights.

Article 3 attaches money to those categories. The Law applies to the first three categories where the value of goods or services reaches 200,000 UAH, or works 1.5 million UAH; and to the fourth category at 1 million UAH for goods and services and 5 million UAH for works. Below those figures but at or above 50,000 UAH, Article 1(28) and Article 14 provide the спрощена закупівля — simplified procurement. Below 50,000 UAH, Article 3(3) requires only that the buyer observes the Law's principles and publishes a report on any contract concluded outside the electronic system.

One threshold matters specifically to foreign suppliers. Article 10(3) requires the notice for a competitive procedure to be additionally published in English where the expected value exceeds the equivalent of 133,000 EUR for goods and services, or 5,150,000 EUR for works, converted at the National Bank rate on the date of publication. Above those figures you can expect an English-language notice; below them you should not.

What the Law actually governs

Article 5 sets the principles — fair competition, economy and efficiency, openness and transparency, non-discrimination, objective evaluation, prevention of corruption and conflicts of interest — and these are the provisions the Особливості expressly preserve. Article 10 sets what must be published and when, and makes access to it free. Article 16 sets qualification criteria; Article 17 sets exclusion grounds. Article 22 governs tender documentation and Article 23 technical specifications, including the requirement that any reference to a trade mark, patent or origin be accompanied by "or equivalent". Articles 25 and 27 govern bid and performance security, Article 30 the electronic reverse auction, Article 33 the intent-to-contract decision, and Article 41 the contract itself.

Article 18 creates the appeal system: the Antimonopoly Committee of Ukraine as the appeal body, acting through a Commission for the Review of Complaints, with complaints filed as electronic documents through the procurement system under a qualified electronic signature, and a fee set by the Cabinet.

Section X, the final and transitional provisions, is where several of the commercially important rules live — most notably point 6-1, the localisation requirement introduced by Law No. 1977-IX of 16 December 2021.

How the Law and the Особливості fit together

This is the relationship people get wrong. The Особливості (Resolution 1178) do not suspend the Law. They are a Cabinet regulation that establishes the procedure and conditions of procurement for the duration of martial law and 90 days afterwards, borrowing the Law's definitions and restating its procedural provisions where the wartime position differs.

The division in practice: the Law tells you who is a buyer, what the money thresholds and publication duties are, what documentation must contain, and how you appeal. The Особливості tell you which procedure applies at which value, how long you have to bid, which grounds require your bid to be rejected, and what a buyer may do without a competitive procedure. Where they conflict on procedure, the Особливості govern; where they are silent, the Law does.

The Особливості also expressly reach back into the Law in places. Point 3 states that buyers apply point 6-1 of Section X — localisation — except subpoint 4, and substitutes its own rule for works and services that involve the buyer acquiring a listed good. Point 28 says tender documentation is formed under Article 22 with the Особливості taken into account, but replaces the Article 17 exclusion grounds with those in point 47. Point 49 applies Article 33 with its own additions.

What a supplier should take from this

Use the Law as the map and the Особливості as the current road. If you are asking "am I dealing with a covered buyer", "will there be an English notice", "what may the documentation ask of me", "how do I complain" or "does localisation catch my product", the answer is in the Law. If you are asking "how many days do I have", "what will get me rejected" or "can the buyer skip the tender", the answer is in the Особливості.

Read the consolidated text, and check the redaction date. The Law has been amended repeatedly — the version consulted for this page carried amendments up to Law No. 4888-IX of 27 May 2026 — and the article numbering commentators cite is not always current.

Related terms

• Особливості (CMU Resolution 1178) — Ukraine's martial-law procurement overlay
• Спрощена закупівля (simplified procurement, Ukraine)
• Локалізація (local content requirement, Ukraine)
• АМКУ — the Antimonopoly Committee as Ukraine's procurement appeal body

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