Brief report on the results of monitoring legislative changes and preparation for elections: activities of authorities and electoral process subjects,based on the analysis of open sources.
March 1 – May 31, 2025

1. Geopolitical and Domestic Political Context

Geopolitical Narratives

United States:
U.S. officials continue to emphasize the importance of upholding democratic procedures in Ukraine, even under martial law. In public remarks, they underline that elections must not come at the expense of citizens’ safety or public trust in institutions.
While the U.S. administration has not pressured Kyiv to hold elections urgently, it advocates for transparency in decision-making processes.
In a statement to Radio Liberty on March 12, 2025, U.S. Ambassador to Ukraine Bridget Brink noted:

“We respect Ukraine’s decision on the timing of elections. At the same time, it is essential that the Ukrainian people have confidence in an electoral system that functions even under the conditions of war.”

In May, the U.S. State Department reiterated—this time for the second time in spring—that elections in Ukraine should be based on internal consensus rather than international pressure. During a press briefing on May 16, Spokesperson Matthew Miller stated:

“We are not dictating an election date to Kyiv. But we continue to support Ukraine in preparing for a future where democratic processes can once again function actively.”

European Union:
Representatives of the European Parliament and the European Commission stress that any wartime election must adhere to key democratic principles: inclusiveness, safety, and participation of internally displaced persons (IDPs) and military personnel.
MEPs are calling for a cautious approach and strengthened preparation of electoral infrastructure.

In April 2025, EU Commissioner for Neighborhood and Enlargement Oliver Várhelyi stated that Ukraine must decide independently on election timing, but stressed the need for inclusion:

“Participation of IDPs, military personnel, and citizens abroad must be resolved before the campaign starts. Europe is ready to provide both technical assistance and observation” (source: European Pravda).

On May 22, the European Parliament adopted a resolution explicitly underscoring the importance of maintaining democratic continuity in Ukraine, including election preparations:

“Elections may only be appropriate following de-escalation of hostilities; however, the legal and logistical framework must be laid now” (source: European Parliament website).

Also in May, the European External Action Service (EEAS) launched consultations with Ukrainian institutions to explore technical support for electoral reform, particularly regarding remote voting for IDPs.

Core messages from international partners include:

• Ensuring safety of voters and candidates;
• Preserving institutional trust;
• Securing broad citizen participation, including IDPs and military personnel;
• Preventing Russian propaganda interference during the electoral process.

Domestic Political Developments

• Domestic political discourse remains divided. Some political factions, particularly parliamentary opposition, demand that parliamentary election dates be set, arguing that delays undermine state legitimacy.
• The Presidential Office and the parliamentary majority have not expressed clear intentions to hold elections before hostilities end, citing constitutional and security constraints.

There is no political consensus on election timing in Ukraine. Opposition parties, notably European Solidarity and elements of Batkivshchyna, are advocating for adherence to the electoral calendar, highlighting the need to renew political legitimacy through elections.
MP Iryna Herashchenko (European Solidarity) told Espreso:

“Even in times of war, we must not forget democracy. Elections are not a luxury; they are an obligation to the people.”

The majority (Servant of the People) and the Presidential Office reference the limitations imposed by martial law. Presidential advisor Mykhailo Podolyak told Ukrainska Pravda:

“No country holds elections during an active phase of war. This is a matter of safety, trust, and technical feasibility. We are not ready to expose people to such risks.”

In May, the debate continued on whether elections are a symbol of legitimacy or a threat to stability.

There is also growing concern over government actions against former President Petro Poroshenko and his party European Solidarity, which may amount to political persecution.

• The opposition is increasing public pressure: European Solidarity initiated a hearing in the Verkhovna Rada’s Legal Policy Committee on potential amendments to electoral law during martial law.
• On May 23, Batkivshchyna, led by Yulia Tymoshenko, held a roundtable with experts on voters’ rights during states of emergency.

Meanwhile, the government maintains a cautious position. In a major interview with The Guardian on May 27, Presidential Chief of Staff Andriy Yermak stated:

“We are ready for any scenario, but the safety of Ukrainians is the key factor. The time will come, and we will return to the electoral process. But not when rockets are raining down on our cities.”

On May 21, 2025, former Deputy Head of the Presidential Administration under Viktor Yanukovych, Andriy Portnov, was assassinated in Madrid. According to civic activists and independent media, Portnov maintained ties with top Ukrainian officials since 2019. Experts speculate that he may have overseen efforts to prepare post-war electoral legislation.

2. Activities of Electoral Institutions and Authorities

Central Authorities and Institutions

Central Election Commission (CEC):
During the reporting period, the CEC did not initiate any formal public discussions regarding election procedures under martial law. However, according to sources within the institution, internal working groups are conducting scenario-based modeling for a potential election process during or shortly after hostilities.

• The CEC continues to cooperate with international partners, primarily the International Foundation for Electoral Systems (IFES), OSCE/ODIHR, and the EU Delegation to Ukraine.
• The Commission is reviewing potential amendments to the Electoral Code to allow remote voting for internally displaced persons and military personnel.
• On May 7, 2025, CEC Chair Oleh Didenko held a closed-door meeting with representatives of civil society organizations and international donors to present a roadmap for preparing electoral infrastructure in 10 regions.
• A pilot project to test digital identification of voters among IDPs using the Diia app is reportedly being developed jointly with the Ministry of Digital Transformation.

Verkhovna Rada of Ukraine (Parliament):

• The Parliamentary Committee on Legal Policy held one closed and one public meeting in April-May regarding amendments to the electoral legal framework.
• Draft amendments to the Electoral Code to allow voting by military personnel at frontline-adjacent polling stations were submitted on May 12 by a group of MPs led by Serhiy Ionushas (Servant of the People). The draft was not supported during the committee's preliminary review.
• Several opposition MPs, particularly from European Solidarity, proposed a bill to establish a national registry of IDP voters. The draft was not included on the May legislative agenda.
• The Speaker of the Verkhovna Rada, Ruslan Stefanchuk, continues to reiterate that elections are not prohibited under martial law but require consensus and security guarantees.

 

Ministry of Digital Transformation:

• The Ministry continues to test the infrastructure for remote services for citizens abroad and IDPs. No official decisions on implementing e-voting have been announced.
• The Diia platform has initiated beta testing of a new "Military Voter" digital service, enabling soldiers to verify voting eligibility. The service is available in test mode in the Mykolaiv and Dnipropetrovsk regions.

Security Service of Ukraine (SSU) and Ministry of Internal Affairs (MIA):

• Both institutions are involved in a cross-agency working group focused on cybersecurity during potential elections.
• The MIA has publicly stated that law enforcement is not yet ready to ensure the safety of all polling stations in high-risk areas, particularly in the border and frontline zones.
• The SSU has initiated an assessment of risks of Russian influence operations during a possible electoral campaign.

Local Authorities

• Several regional military administrations (RMAs) in the west and center of Ukraine have begun inventorying the condition of polling stations.
• In Lviv, Ternopil, and Vinnytsia, local electoral commissions have received informal instructions to update voter registries, despite no formal announcement of elections.
• In Zaporizhzhia and Dnipro, regional administrators have expressed concerns about the lack of guidelines for organizing elections under martial law.
• Mayors of several cities—particularly Ivano-Frankivsk, Khmelnytskyi, and Uzhhorod—have publicly supported the idea of local elections "when the time is right" but emphasized the need for clear legal and financial frameworks.

3. Civil Society and Media Activity

Civil Society Organizations (CSOs):

• The All-Ukrainian NGO “Committee of Voters of Ukraine” (CVU) continued to monitor the public discourse on elections and inform citizens about the legal and procedural conditions under martial law. In May, CVU published an analytical brief on constitutional restrictions regarding the organization of national elections during the war.
• OPORA, another leading election watchdog, focused on monitoring changes to legislation and assessing the transparency of parliamentary discussions on electoral reform. They also launched an advocacy campaign promoting the need for inclusive procedures for IDPs and military voters.
• The Civil Network “Chesno” conducted an online survey with over 1,500 respondents regarding the readiness of citizens to participate in elections during martial law. Results showed that 63% of respondents support postponing national elections until after active hostilities cease.
• Several regional CSOs in the Vinnytsia, Lviv, and Poltava regions held public discussions on local self-governance and post-war electoral recovery as part of the USAID HOVERLA project.
• Human rights organizations, including ZMINA and the Ukrainian Helsinki Human Rights Union, highlighted the potential risks of electoral exclusion of vulnerable groups, including war veterans, persons with disabilities, and residents of de-occupied territories.

 

Media and Information Field:

• National television channels within the United News telethon framework provided limited coverage of electoral debates. Most references to elections appeared in interviews with MPs or officials rather than dedicated programming.
• Independent media outlets such as Ukrainska Pravda, Hromadske, and NV.ua published several op-eds discussing the legitimacy and feasibility of holding elections under martial law.
• Misinformation and disinformation campaigns regarding electoral processes intensified on Telegram channels and pro-Russian platforms, particularly those targeting military voters. According to Detector Media, these campaigns aim to undermine public trust in electoral institutions and suggest that elections are controlled by Western donors.
• There is growing demand for civic education on constitutional rights during wartime. In response, several media initiatives have partnered with lawyers and experts to produce explainer videos and Q&A sessions for social media.

4. Legal and Technical Readiness Issues

Constitutional Constraints:

• According to Articles 83 and 103 of the Constitution of Ukraine, regular elections for the Verkhovna Rada and the President cannot be held during martial law. Any attempt to organize elections in violation of these norms would be unconstitutional.
• Legal scholars and members of the Constitutional Court expressed concerns over legislative initiatives aimed at enabling elections during martial law, emphasizing the need for strict adherence to the rule of law and the risks of setting dangerous precedents.

Legislative Gaps:

• Despite the active public discourse, the Verkhovna Rada has not adopted any laws that would regulate potential elections under wartime conditions. Draft laws concerning voting by internally displaced persons (IDPs), military personnel, and citizens abroad remain under consideration.
• The lack of comprehensive regulation complicates technical preparations and creates legal uncertainty for election commissions.

State Voter Register and Territorial Commissions:

• The Central Election Commission (CEC) continues to maintain the State Voter Register; however, its updates are limited due to migration, lack of access to temporarily occupied territories, and security restrictions.
• Many district and precinct election commissions are inactive or non-functional due to displacement of staff and the destruction of premises.

Cybersecurity and Infrastructure:

• The National Security and Defense Council (NSDC) and the State Special Communications Service emphasized that electoral infrastructure would be a likely target of Russian cyberattacks, should the electoral process be launched.
• There is also insufficient access to safe premises for polling stations and technical equipment in frontline and de-occupied areas.

5. Conclusions and Recommendations

• No legal grounds exist for holding national elections (parliamentary or presidential) under martial law. Any such initiatives would contradict the Constitution of Ukraine.
• Preparations for post-war elections should begin now through inclusive discussions, legislative development, and technical modernization of the electoral system, especially regarding the participation of IDPs, military personnel, and citizens abroad.
• Civil society and expert communities must continue to provide legal analysis, public education, and international communication to counter disinformation and ensure transparency.
• The international community should maintain support for democratic development in Ukraine and help prepare for the post-war electoral cycle by offering technical assistance, observation missions, and strategic consultation.