Key Takeaways
- • The State Property Fund of Ukraine (SPFU) explained that automatic formation of electronic real estate appraisal certificates is restricted in temporarily occupied territories and combat zones, per SPFU order dated July 6, 2026, No. 1422.
- • The SPFU described the suspension of automatic certificate formation and registration of appraisal reports in the Unified Database for affected objects as a forced technical measure.
- • Notarial transactions in these territories now proceed by providing the notary with the appraisal report together with its review, an alternative the Fund says preserves data and prevents a halt in civil real estate turnover.
- • Properties with sufficient information content may still receive electronic appraisal certificates and registered reports via the Valuation Module, according to the Fund.
Summary
The State Property Fund of Ukraine has explained why automatic formation of electronic certificates of real estate appraisal value has been restricted for property in temporarily occupied territories and combat zones. The Fund was responding to an appeal from the Notarial Chamber of Ukraine (NCU), which asked for regulation of problematic appraisal issues for taxation purposes arising in notarial actions involving real estate in occupied areas and in territories under a state of emergency or martial law.
According to the NCU, the restriction stems from SPFU order No. 1422 dated July 6, 2026, "On Amendments to the Procedure for Maintaining the Unified Database of Appraisal Reports." In responding to criticism of the restriction, the Fund stated that the Tax Code of Ukraine has higher legal force and priority over subordinate regulatory acts. The SPFU also noted that Article 172 of the Tax Code and the Procedure for Maintaining the Unified Database entered into force before the full-scale invasion, so the database software does not account for the adverse effect of temporary occupation on the information used to value property there.
The Fund said that the 2021 version of the Procedure already included specific provisions for electronic valuation of objects in temporarily occupied territories and areas under martial law or a state of emergency, referencing paragraph 14 of section I. It characterized the temporary suspension of automatic certificate formation and database registration, provided for in paragraph 2 of Order No. 1422, as a forced technical measure. Under the established alternative, the notary receives the appraisal report together with its review for the relevant transactions, which the Fund says allows data to be preserved and civil turnover of real estate to continue.
The SPFU further clarified that for properties in administrative-territorial units included in the List of territories, electronic certificates and appraisal report registration remain possible where the Valuation Module has adequate information to determine the value of the real estate object, indivisible unfinished construction object, or future real estate object.
According to the NCU, the restriction stems from SPFU order No. 1422 dated July 6, 2026, "On Amendments to the Procedure for Maintaining the Unified Database of Appraisal Reports." In responding to criticism of the restriction, the Fund stated that the Tax Code of Ukraine has higher legal force and priority over subordinate regulatory acts. The SPFU also noted that Article 172 of the Tax Code and the Procedure for Maintaining the Unified Database entered into force before the full-scale invasion, so the database software does not account for the adverse effect of temporary occupation on the information used to value property there.
The Fund said that the 2021 version of the Procedure already included specific provisions for electronic valuation of objects in temporarily occupied territories and areas under martial law or a state of emergency, referencing paragraph 14 of section I. It characterized the temporary suspension of automatic certificate formation and database registration, provided for in paragraph 2 of Order No. 1422, as a forced technical measure. Under the established alternative, the notary receives the appraisal report together with its review for the relevant transactions, which the Fund says allows data to be preserved and civil turnover of real estate to continue.
The SPFU further clarified that for properties in administrative-territorial units included in the List of territories, electronic certificates and appraisal report registration remain possible where the Valuation Module has adequate information to determine the value of the real estate object, indivisible unfinished construction object, or future real estate object.
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