(As of 27 January 2026)
Ukraine’s reconstruction pipeline is no longer just about “projects to be funded someday” — it is increasingly a structured value chain that starts with need identification and ends with public monitoring of delivery and payments. For international stakeholders (including Swiss investors, donors, contractors, and advisors), the challenge is not willingness to engage — it is navigation: where to start, which systems matter, and which rules govern each step.
This matters now because international coordination and private-sector participation are being actively positioned as a cornerstone of Ukraine’s recovery architecture. In Davos-related programming and communications, Ukraine’s recovery narrative has been linked to practical digital infrastructure — including UR³ (“Ukraine Recovery, Reconstruction and Rebuilding”) as a government-led recovery framework presented to international audiences.
This article explains, step by step, how reconstruction projects typically move from a defined need to funding, procurement, contract execution, and oversight — and which platforms and legal regimes a foreign participant must understand to operate safely and effectively.
The “end-to-end” chain at a glance
In Ukraine, reconstruction procurement becomes predictable when you view it as two connected tracks:
- Public investment management / project pipeline (what should be built, why, and with what priority)
- Public procurement (how works/services/goods are competitively bought, contracted, paid, and controlled)
The key point for foreigners: you may encounter both Ukrainian public procurement law and donor/IFI procurement rules in the same project, depending on the financing structure.
Stage-by-stage guide (with practical “where to go next”)
Stage A — Need identification and prioritisation
Who initiates: municipalities, regional administrations, and central bodies — depending on asset ownership and sector.
Typical outputs (documents):
- Problem statement / needs note
- Initial concept and scope boundaries
- Entry into a project pipeline (where applicable)
Where to go / what to check:
- DREAM ecosystem (DREAM) positions itself as the basis for managing public investments across planning and implementation, with public transparency tools and a public analytics layer.
Practical tip: if you are a donor/contractor scouting opportunities, start from the project pipeline view (what exists, where, who owns it, what stage it is in), then map which procurements are expected to follow.
Stage B — Project preparation
This is where many reconstruction failures are “designed in” early: poor scope, weak cost logic, missing permits assumptions, unrealistic timelines.
Typical outputs:
- Pre-feasibility or feasibility study (ТЕО – feasibility study)
- Early cost estimate and options analysis
- Decision to proceed and packaging strategy (one contract vs lots)
Where to go / what to check:
- DREAM includes guidance content and indicates structured processes around public investment stages; it also states the portal operates in a beta/test mode (which matters for reliance and change management).
Legal note (for foreigners):
Early-stage documentation is where you should align procurement packaging with your compliance model: if a project will be donor-funded, confirm upfront whether donor rules displace or supplement Ukrainian procedures (and how audit rights, reporting, and integrity clauses will be handled contractually).
Stage C — Technical specifications / ToR
What it is: requirements defining what is being bought (works/services/goods) and how bids will be evaluated.
Common reconstruction pitfalls:
- Overly narrow brand/model references (discriminatory specs)
- Specs that ignore life-cycle cost (LCC) vs “lowest price only” logic
- Missing interface with construction permitting and design documentation
Where to go / what to check:
- Prozorro is the national e-procurement ecosystem where tender documentation and procurement records become publicly accessible.
- BI Prozorro / analytics modules are used for deeper monitoring and analysis of procurement data.
Practical tip: before bidding, validate the ToR against the market standard and verify whether the buyer’s requirements have triggered a pattern of appeals in similar tenders (use procurement analytics).
Stage D — Financing: budget, donor/IFI, grants, credit, PPP
Financing dictates the “rules of the game”.
Typical funding routes
- State / local budgets (public funds)
- Donors / IFIs (often additional procurement requirements)
- EU Ukraine Facility and donor coordination mechanisms that shape priorities and controls
- Public-private partnership (PPP) and concessions for selected infrastructure and services
Where to go / what to check:
- Ukraine Donor Platform context helps explain donor coordination and “pipeline discipline”.
- PPP Agency provides support and a knowledge base around PPP project preparation and implementation, including reconstruction-oriented cooperation.
Legal note (donor rules vs Ukrainian law):
Even when Ukrainian entities are buyers, donor/IFI funds may require their own procurement methods, advertising, eligibility rules, and integrity clauses. Treat this as a two-layer compliance model: (1) Ukrainian mandatory rules for public entities, and (2) funder conditions that can be stricter.
Stage E — Choosing the procurement method
Core legal framework:
- Law of Ukraine “On Public Procurement” (No. 922-VIII)
- Special wartime procurement rules adopted by Government Resolution
No. 1178 (and subsequent amendments)
In practice, the method selection is driven by: value, urgency, subject (goods/works/services), security constraints, and whether special regimes apply.
Where to go / what to check:
- Prozorro publication and procedure logic (prozorro.gov.ua)
- If e-catalog purchasing is relevant: Prozorro Market (cpo.uss.gov.ua)
Practical tip: ask one question first: Is the buyer required to run a competitive procedure in Prozorro under Ukrainian law, or is this a donor-run procurement with Prozorro only for transparency/reporting? The answer determines your bid strategy and documentation burden.
Stage F — Running the tender in Prozorro
How the system works (critical for foreigners):
Prozorro is a central database + public portal, but bidding actions happen via authorised electronic marketplaces.
Tender flow (typical):
- Notice and tender documentation published
- Clarifications/Q&A
- Bid submission through an authorised platform
- Evaluation and decision
- Contract publication
Where to go / what to check:
- Prozorro “About” overview and portal access
- Guidance specifically for non-residents (how participation is structured through the system) (infobox.prozorro.org)
Legal note (foreign participation):
Treat documentation as both a legal and compliance file: corporate documents, beneficial ownership data, integrity statements, and conflict-of-interest controls must be ready in a form acceptable to Ukrainian buyers and (where applicable) funders’ KYC expectations.
Stage G — Appeals and remedies
Appeal body: the Antimonopoly Committee of Ukraine acts as the procurement appeals body.
Timing (practically important): official guidance materials describe a 7 working-day review period that may be extended (up to 12 working days in stated cases).
Where to go / what to check:
- Complaints are submitted electronically through the procurement system (via the participant’s account).
Practical tip: appeal strategy should be built before you bid. If the ToR is discriminatory, the highest ROI action is often an early challenge — not “hoping evaluation will be fair”.
Stage H — Contracting and execution
Reconstruction projects live or die in execution: change orders, inflation, design evolution, and site realities.
What to focus on:
- “Material terms” and permitted amendments
- Acceptance and payment milestones
- Documentation discipline (acts, certificates, deliverables)
Where to go / what to check:
- The contract and amendments are visible through the Prozorro data trail (and analyzable through BI tools).
Legal note (risk allocation for foreigners):
Contract execution risk is often higher than tender risk. Ensure your bid price and schedule reflect: * design maturity, * permitting dependencies, and * currency/price volatility clauses to the extent legally permissible in the given procurement regime.
Stage I — Monitoring, audit, compliance
Ukraine’s procurement model is built around “everyone can see everything”, but control still matters.
Key controllers and tools:
- State Audit Service as the main procurement oversight body in practice
- Government communications confirm procurement oversight focus aligned with Ukraine Facility-related controls and Prozorro-based prevention mechanisms.
- DOZORRO enables civic monitoring, feedback, and practical escalation signals.
Foreign compliance layer:
- Sanctions screening (Swiss/EU/US and Ukraine-related)
- AML/KYC and beneficial ownership
- Conflict-of-interest and debarment controls (especially under donor/IFI rules)
Stage J — Transparency of payments and public reporting
Procurement transparency is incomplete without payment visibility.
Where to go / what to check:
- Spending.gov.ua is the unified portal of public spending, under the Ministry of Finance, providing visibility into transactions and spending units.
- Ukraine’s E-data ecosystem integrates multiple public finance transparency portals (including Spending, Openbudget, and others referenced in official communications).
Practical tip: for due diligence on a counterparty or project, triangulate: tender → contract → amendments → payment trail.
Platforms inventory (what each is for, and how to use it)
Prozorro (public procurement system)
- What it is: national e-procurement system and public portal for tenders/contracts.
- Stage used: procurement planning → tender → contract publication → amendments
- Typical users: procuring entities, suppliers, auditors, public
- What you can verify: tender docs, bidders, decisions, contracts
- How-to: find the tender on the portal; to participate, register on an authorised marketplace and submit bid via that marketplace.
Authorised electronic marketplaces
- What they are: front-end services that connect users to Prozorro’s central database.
- Stage used: bid submission, clarifications, complaint filing (via account)
- How-to: choose one platform your team can operate (language, onboarding support), then maintain one “compliance-ready” supplier profile.
Prozorro Market (e-catalog)
- What it is: e-catalog purchasing channel for eligible categories and faster buying cycles.
- Stage used: procurement execution (where e-catalog is permitted/appropriate)
- How-to: onboard as a supplier via the listed authorised channels; use catalog logic instead of full tender workflow.
BI Prozorro / analytics modules
- What it is: business intelligence modules for monitoring, benchmarking, and risk detection.
- Stage used: market analysis, red-flag checks, oversight
- How-to: use analytics to compare expected prices, typical qualification requirements, appeal frequency, and buyer behaviour.
DOZORRO (civic monitoring)
- What it is: public oversight and feedback platform for tenders, linked to procurement monitoring practice. (dozorro.org)
- Stage used: monitoring, escalation signals, reputational checks
- How-to: check discussions/feedback on similar tenders and buyers; use it as an early-warning layer.
DREAM ecosystem (public investment management / project pipeline)
- What it is: an ecosystem intended to structure public investment processes and transparency for recovery projects, with public analytics and mapping components; the portal states it operates in beta/test mode (legal basis law
No. 12245). - Stage used: need identification → prioritisation → project portfolio visibility → reporting.
- How-to: start with pipeline visibility, then map which procurements should emerge and who owns the project data.
Unified State Electronic System in Construction
- What it is: national construction-sector e-system with registers, map, analytics, services. (e-construction.gov.ua)
- Stage used: design/permitting dependencies, construction lifecycle visibility
- How-to: validate whether required construction approvals/registrations exist (or are realistically obtainable) before pricing and scheduling.
Spending.gov.ua (public spending transparency)
- What it is: unified web portal of public spending under the Ministry of Finance; includes search and reporting views. (spending.gov.ua)
- Stage used: post-award payment monitoring, audit trail building
- How-to: verify payment flows related to contracting entities and recipients by identifier and transaction filters.
PPP Agency + PPP / concession framework
- What it is: institutional support channel and knowledge base for PPP project preparation and implementation. (Public-Private Partnership Agency)
- Legal basis: PPP law and concession law are core anchors. (No. 4510-IX)
- How-to: use PPP Agency resources when a project is structured as PPP/concession rather than classic procurement.
UR³ (Ukraine Recovery, Reconstruction and Rebuilding)
- What it is: a government-led recovery framework presented internationally (including in Davos-related programming).
- How-to: treat UR³ as a strategic coordination layer; in practice, your operational navigation still runs through the investment pipeline (e.g., DREAM) and procurement systems (e.g., Prozorro).
Matrix: Stage → Platform → Output → Legal basis
| Stage | Main platform(s) | Output document / data | Primary legal basis (indicative) |
| Need identification | DREAM | project concept / portfolio visibility | Public investment governance (platform guidance) |
| Project preparation | DREAM + sector processes | feasibility/ToR inputs | project-level decisions + funding rules |
| Design & permits | EDESSB | permits/registrations, construction records | EDESSB framework / implementation notes |
| Procurement method choice | Prozorro | selected procedure + plan | Law 922-VIII + wartime Resolution 1178 |
| Tender execution | Prozorro + marketplaces | tender docs, bids, decisions | Law 922-VIII / 1178 |
| Appeals | Prozorro e-complaint + AMCU | complaint + decision | appeals rules per procurement framework; AMCU role |
| Contracting | Prozorro | contract + amendments | Law 922-VIII / 1178 (where applicable) |
| Oversight & monitoring | BI Prozorro + State Audit + DOZORRO | risk flags, monitoring actions | State Audit oversight practice |
| Payment transparency | Spending.gov.ua + E-data | transaction trail | public finance transparency portals |
| PPP alternative | PPP Agency | PPP pipeline support | PPP law + concession law |
Practical checklist
- Identify the asset owner and decision-maker (municipality, region, ministry).
- Locate the project in the public investment pipeline (start with DREAM visibility).
- Confirm whether the project is “works”, “services”, or “goods” for procurement structuring.
- Map permitting dependencies via EDESSB (especially for construction-heavy scopes).
- Clarify financing: budget vs donor/IFI vs PPP (rules diverge).
- Determine the applicable procurement regime: Law 922-VIII and, where relevant, Resolution 1178.
- Choose your operational entry: authorised marketplace for bidding (not just the Prozorro portal).
- Build a “bid-ready” compliance pack (corporate docs, ownership, integrity statements).
- Review the ToR for discriminatory requirements and document your challenges early.
- Benchmark the buyer and category using BI tools (price ranges, appeal frequency).
- If necessary, prepare an AMCU appeal pathway and timeline assumptions.
- Negotiate execution risk in advance: change control, acceptance logic, documentation discipline.
- Track contract publication and amendments in Prozorro data.
- Monitor payments through Spending.gov.ua and related E-data portals.
- Maintain an audit file aligned to both Ukrainian oversight and donor/IFI audit rights.
Red flags & common mistakes
- Treating DREAM as “optional PR” rather than pipeline reality (for project selection and transparency expectations).
- Pricing works before verifying permitting/design readiness (EDESSB signals).
- Assuming bids are submitted on prozorro.gov.ua (they are submitted via marketplaces).
- Ignoring special wartime procurement features under Resolution 1178 where applicable.
- Not challenging discriminatory ToR early (then losing at evaluation and running out of remedies).
- Underestimating appeal timing impact on mobilisation and cashflow planning.
- Weak change-order governance (scope creep without lawful amendment logic).
- No payment-tracking discipline (Spending.gov.ua exists specifically to make this visible).
- Failing to align donor compliance and Ukrainian legal compliance into one integrated process.
Who does what (stakeholder map)
- Procuring entity: defines need, drafts tender docs, runs procedure, manages contract.
- Project owner / investment planner: prioritises projects and forms the pipeline (often visible through DREAM).
- Supplier / contractor: bids via marketplace, delivers, documents acceptance, manages claims.
- AMCU: procurement appeals body; issues decisions affecting tender outcomes.
- State Audit Service: core public procurement oversight body in practice; monitoring and enforcement signals.
- Civil society / public: monitors via open data and DOZORRO feedback mechanisms.
- MinFin transparency layer: payment visibility via Spending/E-data.
- PPP Agency: supports preparation and implementation, knowledge base.
Ukraine’s reconstruction procurement is not “one website and one law.” It is a connected system: pipeline discipline (where projects are defined and prioritised), competitive procurement (where suppliers win), construction-sector digitisation (where delivery is tracked), and finance transparency (where payments can be verified). For Swiss and other international actors, success depends on building a workflow that is compliant with Law 922-VIII, adaptable to Resolution 1178, and robust under donor/IFI integrity and audit expectations.
If your organisation is evaluating entry into Ukraine’s reconstruction market — as a bidder, donor, advisor, or project partner — Lighthouse Legal Media can help you translate the legal framework into an operational plan: selecting the right route (classic procurement vs PPP), structuring compliant documentation, and building a monitoring/audit-ready delivery model.
