On 10 April 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 484, which amends the Procedure for the Operation of the Electronic Procurement System and the Authorisation of Electronic Platforms.
In particular, the Procedure establishes a distinction between simple and complex ARMA assets. A simple asset is transferred for management via auction, and the payment obligation arises upon the disclosure of bids. Complex assets are transferred via a special selection process, and the payment obligation arises after the publication of details regarding the participant and the submitted documents.
New financial conditions for participation in the procedures have also been established:
- the entry fee, equivalent to one minimum subsistence level, is non-refundable in the event of cancellation or if the auction is declared void;
- the winner pays 30% of the expected monthly income from managing the asset (but not exceeding UAH 5 million) prior to the conclusion of the contract;
- a portion of these payments is distributed between the platform operator and the electronic system administrator in fixed proportions;
- all payments and rules are standardised across all electronic platforms and cannot be altered by operators independently.
We will closely monitor further developments in this area and report on them in the future Legal News.
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