Revocation versus invalidation
Since 2025 the Procedure approved by Cabinet of Ministers Resolution No. 322 no longer speaks of "cancelling" a посвідка (temporary residence permit, TRP). It sets out two separate mechanisms instead. Paragraph 63 covers revocation, and paragraph 63-1 covers declaring a permit invalid. How the card is issued in the first place is explained in our guide to the TRP. This article is about how it ends.
Revocation means the permit was issued correctly, but there is no longer a basis for it, or something has happened that the law links to its termination. Invalidation means the permit should never have been issued at all, because false information or forged or invalid documents were submitted, or it was processed in breach of the law. Invalidation is the more serious of the two and often brings further consequences for the foreigner.
Document checklist
0/4 doneWhen the DMS revokes a permit
Paragraph 63 of Procedure No. 322 lists the cases in which the ДМС (State Migration Service, DMS) revokes a permit:
Three of these come up most often in our cases. One is dismissal followed by a request from the employer. Another is loss of the basis, such as a student being expelled. The third is a missed exchange after a new passport.
- a reasoned request from the host party, including when the foreigner is dismissed, or the termination of the legal entity that acted as host party;
- a prison sentence imposed in Ukraine;
- actions that threaten national security, public order, health or the rights of citizens;
- a decision on forced return, deportation or an entry ban;
- receiving a Ukrainian citizen's passport, a permanent residence permit or refugee status;
- the end of the basis for staying in Ukraine, or a ruling that the document behind the permit is invalid;
- early termination of a military service contract on certain grounds;
- an application from the foreigner;
- the withdrawal of a decision recognising the person as stateless;
- loss or theft of the permit;
- the permit was not returned after the holder's death;
- the foreigner did not apply for an exchange within one month, as paragraph 18 of the Procedure requires.
Dismissal does not mean instant loss
A work-based permit is not revoked automatically on the day you leave your job. The DMS has to make a separate decision, and there is a gap between dismissal and that decision. Paragraph 64 of the Procedure requires a revocation decision to be made within five working days, so act straight away. If a new employer obtains a work permit during that gap and both employers notify the DMS of the move, the residence permit can be kept. The steps are described in the article on changing employers.
Other grounds work in a similar way. When a divorce or the end of studies can be foreseen, prepare a new basis in advance. The available options are listed in the article on grounds for a TRP.
How to surrender the permit yourself when leaving
Leaving Ukraine for good, or reaching the end of your basis, is the moment to have the permit revoked at your own request. This is subparagraph 7 of paragraph 63 of Procedure No. 322. Taking this route removes the risk of questions at a later entry about a status you never formally closed.
The application is written in the foreigner's name and addressed to the territorial office of the DMS. It asks the office to accept and revoke the permit under subparagraph 7 of paragraph 63 of the Procedure and gives the permit number, the code of the issuing authority and the expiry date. You may add a sentence saying that you do not need a written reply. The original card is attached.
Print the application in two copies. One stays with the DMS, and the other is stamped to confirm receipt. Keep that second copy and show it at the border if asked, as proof that the permit was handed in properly.
How to appeal a revocation
Both a revocation and a decision declaring a permit invalid can be challenged. Paragraph 77 of Procedure No. 322 offers two routes, an administrative complaint to the DMS within 30 calendar days or a claim in court. A complaint should come with documents showing that there is no ground for revocation.
An appeal makes sense when the stated ground does not match reality. For example, the employer filed its request by mistake, or the exchange was in fact filed on time. Such disputes are decided by documents with dates, so keep every copy that carries a DMS stamp.
Lawyer's experience
When a client is leaving, I almost always advise closing the permit by their own application. It takes one visit to the DMS, and afterwards the person holds a stamped copy that answers any question a border guard might ask. Before handing in the card, photograph both sides. The permit number and the issuing authority code will be needed if you ever have to reconstruct your document history.
Another detail from practice concerns the address. Give your registered address in the application with the exact postcode, not the general one for the city, because postcodes can differ along a single street. And if the client is filing outside Kyiv, the application must be addressed to the DMS unit that serves their own city.
Should you prefer not to deal with the wording yourself, we handle cancelling a residence permit when you leave for you. What to do if the permit was lost rather than handed in is covered in the article on a lost residence permit.
Official sources
Frequently asked questions
Do I have to hand in my residence permit if I am leaving Ukraine for good?+
The law does not penalise you for keeping it, but revocation at your own request removes the risks on later entries. You close the status yourself and hold a document that proves it.
What is the difference between revocation and declaring a permit invalid?+
Revocation applies when the basis for the permit has gone or another reason from paragraph 63 has arisen. A permit is declared invalid when it was issued on false information, forged documents or in breach of the law. The consequences differ, and so does the logic of an appeal.
Is my residence permit revoked automatically when I lose my job?+
No. The DMS revokes it by a separate decision, for example on a reasoned request from the host party or because the basis has ended. Until that decision is made there is still time to arrange a move to a new employer.
What can I do if my permit was revoked by mistake?+
A revocation decision can be challenged by an administrative complaint to the DMS within 30 calendar days or by a claim in court. Attach to the complaint the documents showing that the ground for revocation does not exist.
This article is general guidance, not individual legal advice.