From Regulations to Real Solutions: How Hromadas Ensure the Housing Rights of Internally Displaced People

Publication date: August 15, 2025

The issue of realizing the housing rights of internally displaced people remains one of the key challenges for Ukrainian Hromadas. Despite the existence of a regulatory framework, many procedures are still complicated or unclear at the local level. To overcome these barriers, the team of the Legal Development Network is implementing an advocacy campaign with the financial support of the Czech Development Agency and in partnership with the humanitarian organization “People in Need.” Its goal is to help Hromadas find and implement practical housing solutions that meet the real needs of internally displaced people.

Following a meeting within the framework of the “Vidnova” project, which covers Mykolaivska and Ivano-Frankivska Oblasts, we documented the main ideas, proposals, and solutions suggested by the Legal Development Network’s advocacy expert, Liudmyla Yaremchuk.

The results of the Legal Development Network’s research in six Hromadas of Mykolaivska and Ivano-Frankivska Oblasts demonstrate a large number of internally displaced people in need of housing.

In three Hromadas of Mykolaivska Oblast, there is a significant number of internally displaced people, with about half belonging to vulnerable categories.

• Halytsynove Hromada has received 876 internally displaced people, including:

–   241 children under 18,

–   195 pensioners,

–   49 people with disabilities,

–   391 people of working age.

“If we take into account that most of the working-age people are parents raising children, then we are dealing with families in difficult life circumstances,” emphasizes Liudmyla Yaremchuk.

• Bereznehuvate Hromada — 1,081 displaced people, 53.5% of whom are not able to work. This means that more than half of the displaced are pensioners, children, and people with disabilities.

• Bashtanka Hromada has 1,904 displaced people, including:

–   544 children under 18,

–   274 pensioners,

–   83 people with disabilities,

–   1,003 people of working age.

This means that 47.3% of all displaced people are from vulnerable categories.

Despite the significant need, none of these three Hromadas has created temporary accommodation facilities.

“We see the absence of established temporary accommodation facilities, despite the fact that these Hromadas have hundreds of families with children, pensioners, and people with disabilities,” emphasizes Liudmyla Yaremchuk.

Ivano-Frankivska Oblast

In Ivano-Frankivska Oblast, the situation is somewhat better — some Hromadas have organized temporary accommodation facilities, but the number of places does not correspond to the scale of the needs.

•  Kolomyia Urban Hromada — the largest host center:

– more than 8,000 internally displaced people,

– 2,202 children,

– 1,278 pensioners,

– 1,845 people of working age.

More than 43.8% of the internally displaced are not able to work, without taking family context into account. The Hromada has created eight temporary accommodation facilities, where 262 people live, with 15 available beds.

• Kalush Urban Hromada has three functioning temporary accommodation facilities, housing 81 displaced people, with no available places. About 48% of the displaced in the Hromada are from vulnerable categories.

• Tlumach Hromada accommodates 88 displaced people in two temporary accommodation facilities, with 8 available beds. The proportion of vulnerable categories is 50%.

These data clearly demonstrate the urgent need for a systemic solution to the housing issue for internally displaced people, particularly at the level of local and regional programs.

Housing Rights of Internally Displaced People: Between Law and Reality

Since the beginning of the full-scale invasion, the state has introduced a number of housing programs: compensation for destroyed property, concessional loans, and state support for construction. However, the effectiveness of these mechanisms often depends on the ability of Hromadas to adapt them to their conditions and the needs of the people.

In reality, local self-government bodies are often left alone with this problem. They bear the responsibility for accommodating, registering, and providing housing for internally displaced people, as well as for finding resources and preparing documentation.

As the Legal Development Network’s advocacy expert, Liudmyla Yaremchuk, notes:

“It is important to understand that the right to housing is not limited to having a roof over one’s head. It is about safety, the possibility of recovery, and social integration. Therefore, housing policy should be part of the Hromada’s development strategy, not a short-term anti-crisis measure.”

Partnership as a Tool for Change

Within the framework of the “Vidnova” project, experts from the Legal Development Network held a series of online meetings and consultations with Hromadas, Oblast administrations, and representatives of internally displaced people. One of the main tasks was to identify existing barriers and to find effective mechanisms for overcoming discrepancies between plans and practice.

Participants of the events emphasized that solutions do not always require large budgets. Hromadas already have potential — premises, reserve plots of land, and proactive specialists. The question is how to use them.

A key factor was open communication and cross-sectoral cooperation — in many cases, when a Hromada did not know where to start, interaction with lawyers, human rights defenders, and veterans’ communities was exactly what helped. This made it possible to: prepare appeals to ministries, carry out an inventory of municipal property, submit applications for international technical assistance, and initiate the creation of housing programs within the Hromada’s development strategies.

One positive example is a Hromada in Mykolaivska Oblast, where a former municipal building, unused for years, was legally transferred to the housing stock. With the support of partners, a technical inspection was carried out, project and cost documentation was prepared, and a project was submitted for grant funding for reconstruction. At the same time, by decision of the executive committee, regulations were approved for granting this housing to internally displaced people for temporary use, with transparent criteria.

This case will become part of a handbook that the project team is preparing for publication — as an example of a housing solution that can be scaled to other Oblasts.

During the discussion, Hromada representatives also shared the difficulties they most often face: the bureaucratic component — complexity in transferring buildings to the housing stock (need for permits, technical passports, condition assessments); lack of full-time specialists to manage housing programs; and limited financial resources.

Challenges in Implementing the Housing Rights of Internally Displaced People at the Local Level

•  Low level of practical implementation: legislation provides mechanisms, but there is a lack of clear action algorithms at the local level.
  Decisions often remain “on paper” because Hromadas lack resources or due to the complexity of administrative procedures. 

• Insufficient communication: local self-government bodies do not always receive timely or clear information from central authorities. There are also difficulties with initiative — Hromadas are not confident in the legality of certain steps, for example, transferring educational facilities into housing.

• Lack of clear instructions on transferring facilities into the housing stock. Liudmyla Yaremchuk noted that Hromadas confuse the concepts of “temporary accommodation place” and “housing for temporary residence.”
  There is also a lack of clarifications on the technical requirements for housing provided to displaced people, such as safety standards or sanitary conditions.

Housing Stock for Internally Displaced People: How Hromadas Can Implement Resolution No. 422

Resolution No. 422 allows Hromadas to create a temporary housing stock for internally displaced people. Hromadas can construct new housing, purchase apartments or houses, or convert non-residential premises into housing.

“Housing is provided for one year. If the family has not improved its financial or housing situation, the contract may be extended,” emphasizes Liudmyla Yaremchuk.

Priority for obtaining such housing is given to: families with children, large families, people with disabilities, and the elderly. This right is also granted to internally displaced people whose average monthly income does not exceed the rental cost or does not exceed the subsistence minimum per person.

Financing is carried out at the expense of local budgets and local programs:

“It is precisely through the adoption of local programs and the allocation of funds within them that we can implement this resolution locally,” emphasizes Liudmyla Yaremchuk.

The stories of Hromadas that have managed to turn empty premises into housing prove that change is possible. For this, not only political will is needed, but also support, knowledge, and partnership. Advocacy is not only about protecting rights — it is about constructive cooperation with the authorities and using tools that help Hromadas act within the law while taking into account people’s needs.

The focus of the “Vidnova” project is on creating an environment in which a Hromada will not be left alone and people will not be left without answers. Because providing housing is not only social policy, it is also the restoration of human life after loss.

This material was prepared by the Legal Development Network in cooperation with the humanitarian organization “People in Need” and with the financial support of the Czech Development Agency.

The conclusions, interpretations of the collected information, and other statements expressed in this material are solely those of the authors and do not necessarily reflect the views of the project’s donors and partners.

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