How do you appeal the revocation of a temporary residence permit in Ukraine?

What revocation means

Since 2025 the Procedure approved by Cabinet of Ministers Resolution No. 322 distinguishes between revoking a посвідка (temporary residence permit, TRP) and declaring it invalid. Paragraph 63 lists the grounds for revocation. They include a request from the host party when you leave the job, the end of your ground for staying, a return decision or entry ban, and a missed exchange deadline. Under paragraph 64 a revocation decision is made within five working days. The full list of grounds and the consequences are described in the article on TRP revocation.

When an appeal makes sense

An appeal is worth it when the ДМС (State Migration Service, DMS) got the facts or the law wrong. Three situations come up most often. The ground has not actually gone, for example the employer filed the request by mistake or has already withdrawn it. A new employer has obtained a work permit, so the ground continues. Or the exchange was missed for good reasons that the DMS ignored.

If the ground really has gone, for example the marriage ended or the studies are finished, an appeal rarely helps. In that case it is better to look for a new ground at once. The options are listed in the article on grounds for a TRP.

A complaint with a request to suspend

The first tool is an administrative complaint under the Law "On Administrative Procedure" No. 2073-IX. It is filed through the DMS office that made the decision and addressed to the higher authority. Its main advantage is in Article 83(4) of the law. At your request, filing the complaint suspends the decision, unless the law provides otherwise.

So ask plainly in the complaint for the revocation to be suspended while it is reviewed. Paragraph 77 of Procedure No. 322 gives you 30 calendar days to file, counted from the day you were notified of the decision. Under paragraph 78 the complaint must be reviewed within 30 calendar days. How to draft the complaint is explained in the article on the administrative complaint.

Court

The second tool is a lawsuit in a district administrative court. The court checks whether there was a ground for revocation and whether the procedure was followed. It can cancel the DMS decision. How to file the lawsuit is explained in the article on challenging DMS decisions in court.

You can use the complaint and the court one after the other, and people often do. If the higher authority dismisses the complaint, the decision can then be taken to court.

Evidence for each ground

The evidence depends on the ground for revocation:

• if you left your job, you need the new work permit, the employment contract and documents showing you continue to work;
• if the exchange was missed, you need documents proving good reasons, such as illness or a delay with your passport;
• if the DMS says your ground has ended, you need documents showing it continues, such as a university certificate or a marriage certificate;
• if the decision is linked to a return decision or an entry ban, that decision must be challenged too.

When a permit is declared invalid

Paragraph 63-1 of the Procedure covers a separate case. A permit is declared invalid if it should never have been issued, for example because false information or documents were submitted. Such a decision is challenged in the same ways, with a complaint or a lawsuit. What you must prove is different, though. You need to show that the documents were genuine and the information true. The original documents filed with the DMS and proof of their authenticity matter most here.

Family members' permits

If family members received permits as relatives of a foreigner holding a TRP, revoking the main permit affects them as well. Their ground rested on the status of the main holder. When appealing a revocation, assess the family's position at once and, if needed, file complaints for each person. The article on the TRP for family members covers this.

Staying in Ukraine during the dispute

The dispute must not leave you without a lawful ground to stay. If the complaint asks for suspension, the revocation does not take effect during the review, unless the law provides otherwise. If you go straight to court, the lawsuit itself does not suspend the decision, and you may need interim relief or another ground. How to extend your stay is explained in the article on extending your stay.

Lawyer's experience

Most revocations follow a dismissal, when the employee has already found a new job but the new work permit is not ready yet. In these cases speed decides everything. A complaint with a request to suspend buys time to finish the new work permit and keep your status.

My second point concerns missed exchanges. Foreigners often do not know that a new passport means the residence permit must be exchanged. If the permit has already been revoked, we look for good reasons for the delay and document them.

If your residence permit has been revoked, book a migration law consultation and we will assess whether an appeal makes sense and prepare the complaint.

Frequently asked questions