Small privatisation on ProZorro in 2026: fees, deadlines and the new rules for tenants

To bid at a small privatisation auction in 2026 you register on any accredited ProZorro.Sale platform, pay a registration fee of 864.70 UAH and a guarantee deposit of 20 % of the lot’s starting price. The winner signs the protocol within 7 days, pays for the asset within 20 days and signs the sale contract within 25 days.

From 6 June 2026 new rules apply in small privatisation: Law No. 4360-IX abolished the direct buy-out by a tenant and replaced it with an auction in which a tenant holding non-severable improvements has a pre-emption right to buy at the highest price bid at the sale. So the old arrangement of agreeing with the landlord and buying the premises no longer works.

Small privatisation covers assets worth up to 250 million UAH: individual buildings and premises, whole property complexes of small enterprises, unfinished construction, vehicles, shareholdings in state companies. Everything above that is sold under the large privatisation procedure with an adviser. Below: what bidding costs, how the auction works, and where guarantee deposits are most often lost.

What is sold through small privatisation

Article 5 of the Law of Ukraine “On the Privatisation of State and Municipal Property” No. 2269-VIII sets out the list. Small privatisation covers whole property complexes of state and municipal enterprises and their subdivisions, individual properties, unfinished construction, mothballed facilities and shareholdings of under 50 % of the charter capital. The 250 million UAH ceiling is measured by asset value in the financial statements.

The seller is the State Property Fund and its regional offices, or a local authority where municipal property is concerned. Bidding takes place solely in the ProZorro.Sale electronic system under the Procedure approved by Cabinet of Ministers Resolution No. 432 of 10 May 2018. There are no paper auctions or closed tenders in small privatisation.

Article 8 of Law No. 2269-VIII lists those who cannot buy: legal entities registered in the aggressor state or controlled by its residents, sanctioned persons, companies from offshore jurisdictions, and anyone who has not disclosed their ultimate beneficial owner. Checking a prospective buyer’s ownership structure is the first thing a small privatisation lawyer does, before the application is even filed.

What bidding costs

A bidder pays twice before the auction and once after winning. The registration fee is returned to nobody; the guarantee deposit is returned to everyone except the winner, for whom it counts towards the price.

Take premises with a starting price of 1,200,000 UAH: the registration fee is 864.70 UAH and the guarantee deposit 240,000 UAH, which must be in the account before the application deadline. If the winning bid is 1,500,000 UAH, the platform’s fee is 60,000 UAH and 1,320,000 UAH remains to be paid within 20 days.

How the auction runs and what happens with a single bidder

The sale notice is published in the electronic system, and the application period starts from then. A bidder registers on an accredited platform, signs the application with a qualified electronic signature, uploads the documents and pays both amounts. The money must reach the operator’s account before the application deadline, because a payment still in transit does not admit you to the auction.

Procedure No. 432 provides several formats: an auction with conditions, an auction without conditions, an auction with a reduced starting price, and an auction by stepwise reduction of the starting price followed by price offers. The first round of bidding is always at the starting price set from the book value or a valuation; if it fails, the price is reduced and a repeat auction announced.

Where only one application is filed, no auction is held: that bidder is declared the winner and the sale contract is made with them. That is why unremarkable lots in smaller communities regularly go at the starting price. Intermediaries who promise to “guarantee a win” are selling nothing: the outcome turns on whether a second bidder appears, not on arrangements.

What changed for tenants on 6 June 2026

Previously a tenant of state or municipal premises who, with the landlord’s written consent, had made non-severable improvements worth at least 25 % of the market value could privatise the property by direct buy-out without bidding. Law No. 4360-IX abolished that procedure.

The property now goes to auction in every case, but a tenant who meets the statutory conditions (a live lease, the landlord’s consent to the improvements, a confirmed 25 % threshold, no rent arrears) obtains a pre-emption right to buy at the highest price bid. If the tenant does not exercise it, the property passes to the auction winner and the tenant is compensated for the non-severable improvements.

For tenants that means the paperwork now matters more than any understanding: you need the works certificates, the payment documents, a valuer’s opinion on the improvements’ share of the value, and the landlord’s written consent obtained before the works began. Assembling that file is what legal review of the property (due diligence) is for — it also reveals the encumbrances, litigation and arrears that pass to the new owner.

A bidder’s step-by-step guide

1. Find the lot and study the documentation. Notices are published on prozorro.sale and on the State Property Fund’s website. The asset sheet gives the starting price, the guarantee deposit, the conditions of sale and the application deadline.
2. Check the property before paying anything. The register of real property rights, the register of court decisions, the movable property encumbrances register, the planning conditions. A site visit is arranged by the seller on request.
3. Register on a platform and obtain a qualified signature. A company adds its charter, a register extract and the beneficial ownership documents; an individual, a passport and tax number.
4. Pay the 864.70 UAH registration fee and the 20 % guarantee deposit. The payment confirmations are uploaded with the application before the deadline.
5. Bid. The rounds follow the platform’s timetable, with the increment and the number of rounds set in the notice. The system produces the protocol at the end.
6. Sign the protocol within 7 days, pay within 20 days, sign the contract within 25 days. Title is registered after payment in full; the administrative fee for registration within five working days is 330 UAH.

Typical mistakes

• Paying the guarantee deposit on the last day. The money must be credited to the operator’s account before the application deadline. An interbank payment sent on a Friday evening arrives on Monday, and the application is rejected with no refund of the registration fee.
• Not checking the property’s encumbrances and debts. A mortgage, an attachment, utility arrears or a title dispute stay with the asset. The auction cannot be undone on that basis, because the risk sits with the buyer.
• Winning and failing to find the money within 20 days. Late payment means losing the guarantee deposit — 20 % of the starting price — and the deal being terminated, with a repeat auction to follow.
• Counting on the old tenant buy-out procedure. After 6 June 2026 direct buy-out applications are not accepted, and the time spent preparing such a file has to be spent again on the auction route.
• Ignoring the conditions of sale. An auction with conditions imposes obligations: keeping the line of business, paying the enterprise’s debts, preserving jobs. Failing them grounds termination of the contract and the return of the asset to the state.

When you do not need a lawyer

If you are buying inexpensive premises with no encumbrances, no tenants and no conditions of sale, the procedure is clear enough without support: registering on a platform takes a day, the documents are standard, and the system walks you through the stages. The property can be checked yourself in the State Register of Real Property Rights and the Unified State Register of Court Decisions, both available online.

Support starts paying for itself where the lot runs into millions, where the property has tenants or unfinished construction, where it is sold with conditions, or where you are claiming a pre-emption right as a tenant with non-severable improvements. Then you need the legal status checked, the improvements’ share calculated, and a readiness to challenge the commission’s decision. Indicative figures are in the legal service prices section: a written legal opinion from 5,000 UAH, handling a commercial dispute from 30,000 UAH. Drafting the contracts and registering title is handled by our property lawyer.

Questions and answers

What does bidding on ProZorro cost in 2026

The registration fee is 0.1 of the minimum wage, that is 864.70 UAH, and is not refunded. The guarantee deposit is 20 % of the lot’s starting price and is returned to everyone except the winner, for whom it counts towards the price.

Is the guarantee deposit returned if I do not win

Yes, the platform operator returns it within a few working days of the auction. It is not returned to the winner, nor to a bidder who refused to sign the protocol or the contract.

What happens if only one bidder applies for a lot

No auction is held; the sole bidder is declared the winner and a sale contract is made at the price offered, which cannot be below the starting price. This is the standard outcome for small assets in rural communities.

Can leased premises be privatised without an auction in 2026

No. Since 6 June 2026 Law No. 4360-IX has abolished the direct buy-out. A tenant with confirmed non-severable improvements bids at the auction and has a pre-emption right to buy at the highest price offered.

What is the maximum value of a small privatisation asset

250 million UAH by asset value. Anything above is sold under the large privatisation procedure with an adviser and a separate Cabinet decision.

How long is there to pay after winning

The protocol is signed within 7 days, the full price paid within 20 days and the sale contract signed within 25 days. Missing the payment deadline means losing the guarantee deposit.

Can a foreigner buy state property at auction

Yes, provided they do not fall within the restrictions in Article 8: not a resident of the aggressor state, not under sanctions, not registered in an offshore jurisdiction, and having disclosed their ultimate beneficial owner.

Are small privatisation auctions held during martial law

Yes, bidding on ProZorro.Sale continues, except for assets in areas of active hostilities and temporarily occupied territories, where privatisation is suspended.

How can auction results be challenged

The claim goes to the commercial court where the respondent is based, seeking to have the auction results and the contract declared invalid. The court fee on a company’s monetary claim is 1.5 % of its value, but no less than 3,328 UAH.

Who pays to register title to the asset bought

The buyer. In 2026 the administrative fee is 330 UAH for registration within five working days, 3,330 UAH for two working days and 16,640 UAH within two hours.

Sources

• Law of Ukraine “On the Privatisation of State and Municipal Property” No. 2269-VIII, Arts. 4, 5, 8, 18
• Procedure for electronic auctions to sell small privatisation assets, Cabinet Resolution No. 432 of 10.05.2018
• Law of Ukraine No. 4360-IX — the new rules on privatising leased property from 06.06.2026
• ProZorro.Sale: small privatisation — the fee calculator and the list of accredited platforms
• State Property Fund of Ukraine — sale notices and asset lists

Small privatisation on ProZorro with Svarog

We check the asset before the guarantee deposit is paid, prepare the bidder’s file, attend the signing of the protocol and the contract, and register the title. A separate strand is defending a tenant’s pre-emption right under the rules in force since 6 June 2026, including the calculation of the non-severable improvements’ share.

+38 095 554-54-24 · Kyiv, 7 Khoriva Street (Podil) · Mon–Fri 9.00–18.00