Difficulties in obtaining urban planning conditions and restrictions (UPC) were cited as the key problematic stage for launching projects by 35% of respondents, according to the Ukrainian Association of Developers (UAD) based on the results of the annual study “Administrative Barriers in Residential Construction.”
Urban planning conditions and restrictions (UPC) are a document outlining the basic parameters of future construction: permissible height, building density, setbacks from property lines, lot boundaries, requirements for landscaping, greening, and other planning restrictions. In effect, the UCRs determine exactly what can be designed on a specific land plot and within what parameters.
According to the study’s findings, among more than ten factors hindering the implementation of development projects, difficulties in obtaining UCRs ranked first (35% of respondents). Also among the top administrative barriers are difficulties in land and property relations (30%), instability of permits/cancellation by third parties (24%), and difficulties in obtaining technical specifications (22%).
“The General Urban Plan remains one of the most sensitive stages of construction. Formally, this should be a straightforward document—a digital extract from the master plan detailing the parameters of the future project. However, in practice, it is precisely at this stage that developers often encounter manual administrative procedures, leading to delays, unfounded conditions and rejections, and inconsistent interpretations of the same regulations. “It is critically important for the market to have a clear appeal mechanism,” noted Yevhen Favorov, chairman of the Ukrainian Association of Developers.
The problematic nature of the GUP procedure is confirmed not only by industry data but also by the findings of the National Agency for Corruption Prevention. In the draft Anti-Corruption Strategy for 2026–2030, the NACP noted that the existing procedure for obtaining initial data for design creates conditions for corrupt abuses and illegal construction, and that legislative approaches to issuing GUOs must be systematically reviewed.
Furthermore, in its report, the NACP also noted that while building permits are formally required to replicate the requirements of urban planning documentation at the local level regarding a specific land plot, in practice they are issued by local officials “on a case-by-case basis,” which creates opportunities for procedural delays, unjustified denials, or manipulation of the content of restrictions.
The UAD notes that the study’s findings also highlight a lack of trust in local-level decision-making. According to the survey, respondents’ level of trust in state authorities is relatively higher than in local authorities—5 out of 10 possible points for state authorities versus 3 points for local authorities. Overall, developers tend to view regulatory changes over the past four years positively: 16% believe the situation has definitely improved, 51%—somewhat improved, 11%—remained unchanged, 13% see it as having somewhat worsened, and only 9%—definitely worsened. At the same time, the reform of DAS to GIAG received one of the highest ratings among the indicators measured in the study—7.04 out of 10.
“GIAG has already proven its effectiveness as a reformed body of state architectural and construction control and supervision. It is important for the market that, where there is an unlawful refusal or blocking of the process at the local level, there exists a clear and independent mechanism for appeal and review. This is a matter of fair rules of the game,” added Favorov.
The Association emphasizes that local authorities must retain their role in shaping urban planning policy, approving documentation, and determining territorial development. At the same time, in cases where an authorized body unreasonably refuses to issue a building permit or fails to make a decision within the established timeframe, businesses need a tool to protect a lawful project.
“The industry demands the creation of an appeal mechanism for cases of unlawful refusals. There is no question here of taking away powers from communities. There must be a safeguard against inaction or abuse. If a project complies with legislation and urban planning documentation, it should not be blocked for months. For such cases, an independent and transparent appeal mechanism is needed,” Favorov emphasized.
Full digitization and automation of the permitting process are cited as a strategic solution for the sector. In its recommendations, the NACP also identified the automation of administrative decisions and the transformation of the analog permitting process into a digital one as one of the key tools for minimizing corruption risks. The Association emphasizes that since the development market is in greater need of reformed state oversight, the appeal mechanism through the State Agency for Urban Development (SAUD) could be a good interim solution until the full automation of the GOU. The UAD believes that reducing corruption risks in the housing allocation procedure, creating a clear appeal mechanism, and further digitizing procedures will facilitate the launch of new housing projects and, consequently, increase the supply of housing for those who need it—namely, military personnel, people with disabilities, and other categories eligible for purchase benefits.
CONSTRUCTION, corruption risks, DEVELOPERS, housing sector, MOU
