Author
Asylum seekers upon receiving an MSID may register their place of residence in Ukraine.[1] There are usually no problems with registering or declaring a place of residence or staying in one’s own housing or in a TAC. At the same time, it is difficult to register or declare a place of residence or stay in rented housing owned by another person in case an asylum seeker has an intent to do so, as such registration requires the consent of the owner.[2] Asylum seekers often register their place of residence or stay at the centres for homeless persons as in the case of residing in the private apartment, landlords often are reluctant to register a tenant.[3]
Asylum seekers are obliged to notify the SMS of their travels outside the administrative-territorial unit of Ukraine in which they reside.[4] In practice, asylum seekers have not faced particular problems regarding providing or failing to provide such notification.
The issue of travelling around Ukraine has mostly been raised after the full-scale invasion. In the R2P-HIAS survey conducted in 2022, 27% of respondents noted that they cannot travel freely inside Ukraine. Some indicated that they could not leave their domicile because of the checkpoints nearby, or because they fear being fined or deported.[5]
Also, asylum seekers are obliged to notify the administration of the TAC in advance of their absence at the centre for more than three days. In addition, asylum seekers are not allowed to be absent from the centre for more than fifteen days without notifying the centre administration.[6] If a person leaves their TAC without permission and is absent for more than three days without notifying the administration of the TAC, their right to use the living space and receive food supplies is suspended. The administration must immediately report the person’s disappearance to the local police. The suspended rights can be reinstated if the individual returns and if the authorised stay period has not expired, provided there are available spaces and they have not repeatedly violated the rules. They must renew their documentation before regaining access to the TAC if their documentation has expired.[7]
[1] Para. 5 Procedure for Declaring and Registering a Place of Residence.
[2] Information from the The Tenth of April, 14 May 2024.
[3] Information from the ROKADA, 01 May 2024.
[4] Article 13 Law on Refugees.
[5] R2P & HIAS, Asylum Seekers and Refugees in Ukraine Addressing Protection Risks During Wartime, 05 April 2023, available here.
[6] Part III(37) Regulations on Temporary Accommodation Centres for Refugees.
[7] Part III (45-49) Regulations on Temporary Accommodation Centres for Refugees.