Oleh Didenko, Chair of the Central Election Commission of Ukraine

The issue of elections has rapidly surged to the top of Ukraine’s political agenda. Following President Volodymyr Zelensky’s statement that a Peace Agreement could be ratified through a nationwide referendum, and that presidential elections might be held simultaneously, the key question has resurfaced: is Ukraine capable of organizing elections within a short timeframe after the end of hostilities?

This was the central focus of Ukrinform’s conversation with Oleh Didenko, Chairman of the Central Election Commission (CEC) of Ukraine.

IT WOULD BE MORE APPROPRIATE TO ADOPT A SEPARATE LAW REGULATING THE SPECIFICS OF POST-WAR ELECTIONS

Q: Since our previous conversation last May, the number of challenges related to elections has only increased. Nevertheless, the President has instructed Parliament to update electoral legislation, including the possibility of holding elections during a contingency period. Would you explain the reasons why elections are impossible without legislative changes? Which laws need to be amended, or is entirely new legislation required?

A: You are absolutely right by noting that the problems have multiplied since May 2024 because the full-scale war continues to reshape realities. To address these changes, adaptation—especially at the legislative level—is essential. If elections are to fully meet democratic standards, electoral legislation must be revised.

Peacetime electoral laws did not factor the impact of war—on infrastructure, population displacement, security, and many other factors. Therefore, the law must be adapted. War-related challenges must first be addressed legislatively, and only then organizationally.

Q: Which specific laws are you referring to?

A: The precise laws are less important than the principle: certain issues can only be resolved by law. As the country’s sole legislative authority, the Verkhovna Rada is the only body empowered to address these matters through law. Under Article 92 of the Constitution of Ukraine, the organization of elections is exclusively a legislative matter. No other public authority, including the Central Election Commission, is empowered to decide this matter autonomously. It may be addressed solely through legislation enacted by the Verkhovna Rada and promulgated by the President.

The question of which specific laws are concerned is secondary. In my assessment, the preferable approach would be to adopt a dedicated law governing post-war elections, designed to set out tailored procedures and mechanisms that differ from those applicable under normal, peacetime conditions.

An additional issue concerns the definition of legal criteria governing the permissibility of holding elections in specific territories. This matter evidently requires regulation through a dedicated legislative instrument. A draft law to this effect was developed by the Central Election Commission in 2022 and proposed to the Verkhovna Rada. Subsequent parliamentary engagement involved international partners; nevertheless, as far as is known, the draft has not yet entered the formal legislative registration process.

Q: On 26 December, the first meeting of the working group tasked with drafting legislative proposals on the conduct of elections during a contingency period took place. I listened to your remarks, in which you outlined in considerable detail the challenges facing election administrators. What is the working group currently focusing on?

A: This question should be addressed to the head of the working group rather than to me. The group is chaired by Oleksandr Kornienko, First Deputy Speaker of the Verkhovna Rada of Ukraine. The group was established by order of the Speaker of Parliament, and its mandate is clearly reflected in its title. Accordingly, the overarching framework of its work concerns legislative regulation of post-war elections or, potentially, elections conducted during a contingency period.

Q: By the way, how should these elections be referred to? Special elections? Post-war elections?

A: This issue is indeed subject to debate. At present, elections at the presidential, parliamentary, and local levels are overdue. Previously, there were discussions regarding the nature of elections to be held following the lifting of martial law—whether they should be regular, early, or otherwise designated.

This debate is primarily theoretical. From a practitioner’s perspective, these are regular elections whose timing has been deferred as a consequence of martial law. Nevertheless, the final determination of their legal status can be made only through legislative action.

Q: Recently, the President stated that, should a Peace Agreement be signed, its ratification could take place through a nationwide referendum, and that presidential elections might be held concurrently with such a referendum. According to the President, this could occur within 60–90 days of the signing of the agreement, provided that the necessary legislative amendments have been adopted by that time. Would the Central Election Commission of Ukraine be institutionally capable of organizing an election campaign and administering elections within such a compressed timeframe? What would be the key challenges facing the Commission in this scenario?

A: The Head of State has indicated that presidential elections and a nationwide referendum could be held concurrently, provided that an appropriate legislative framework is in place. As I understand it, this is precisely the purpose for which the working group was established: to resolve this issue through legislation.

The outcome of this work should be a law defining the relevant mechanisms and procedures, including whether the referendum and elections are conducted simultaneously or separately, as well as the applicable timelines. The Central Election Commission of Ukraine would then implement the law as adopted.

The Central Election Commission of Ukraine is established and operates as a permanent state body in order to be able to launch the electoral process at any time. In peacetime, elections are held on a regular basis, with clearly defined timelines. However, there are also snap (early) elections, which may take place at any moment once the relevant decision is adopted and the legal grounds arise.

The Central Election Commission of Ukraine initiates the electoral process. Accordingly, it could be safely said that that the CEC will implement whichever law is adopted by Parliament, the Verkhovna Rada of Ukraine.

At the same time, the Commission is represented within the ad hoc working group, which includes five members of the CEC and three representatives of its Secretariat. This merits acknowledgment of the parliamentary leadership, as it indicates a shared intention to identify an optimal solution and a willingness to listen to the CEC’s position.

This, in turn, gives grounds for cautious optimism that the future legislation will take into account essential technical and organizational considerations, including realistic timelines required for the implementation of specific procedures, so as to avoid placing unfeasible or impracticable tasks on the election administration.

HOW DO YOU HOLD ELECTIONS UNDER MISSILE ATTACKS?

Q: To clarify what you describe as unrealistic tasks: during regular elections there is a clear understanding of how the process unfolds. Here, however, it is one force majeure after another. Let us assume you are instructed to conduct a nationwide referendum and a presidential election within 90 days. Is that realistic?

A: A counterquestion: when would those 90 days actually begin?

Q: During his remarks to journalists, the President stated that the 90-day period should begin once the relevant legislative amendments are developed.

A: And when will that happen? You see, there are a great many unknowns. To provide a concrete answer, one must first understand what kind of law this will be and what it will actually stipulate. Until such a framework exists, any answers remain largely theoretical. That is the first point.

The second concerns timing. When will such a law be adopted? If it is adopted now, but the peace settlement process continues afterward, followed by the conclusion of an agreement, and only then are electoral procedures launched, this would significantly extend the preparation timeline. Moreover, the Central Election Commission has been preparing for post-war elections since 2022, throughout the entire period of the full-scale invasion.

Q: Is it realistic to hold elections without lifting martial law? After all, the phrase “elections under martial law” sounds inherently contradictory.

A: In fact, if we take security as the key criterion, I do not see a contradiction here. If adequate security conditions exist, martial law can be lifted. Martial law was introduced precisely because such security conditions were absent.

The foremost requirement is to ensure an appropriate level of security. This is emphasized both by the President of Ukraine, and it is clearly understood by international partners as a necessary precondition. As I see it, there is a broad societal consensus on this issue. How can elections be conducted under missile fire?

If security conditions are ensured, this would in effect create the legal grounds for lifting martial law. In that case, the question of elections would largely come down to the timeframes required to conduct post-war elections. Those timeframes, in turn, depend on the specific procedures established by law.

As for timelines, throughout nearly four years of the full-scale invasion, whenever I have been asked about deadlines, I have deliberately avoided naming any fixed dates. I have consistently emphasized that the Central Election Commission is obliged to act strictly within the framework of the law. If the legislation remains unchanged, the electoral process for parliamentary elections must begin within one month after the lifting of martial law, and the CEC would be required to implement this.

That said, the longer the preparation period, the better the electoral process can be organized—this is self-evident. At the same time, timelines are always a matter of balance. On the one hand, a longer preparatory period increases the likelihood that elections will better meet international standards and best practices. On the other hand, this period should not be excessively long, so as not to undermine public trust or democratic legitimacy.

Q: Because there is broad interest in ensuring that the authorities acquire renewed mandates as soon as possible.

A: Exactly—so that this is not perceived as an attempt to abuse power or deliberately delay electoral processes. These are complex and sensitive issues that require carefully balanced solutions. Crucially, they are political decisions that must be taken by the Verkhovna Rada of Ukraine, not matters within the competence of the Central Election Commission. The Commission’s role is to implement those decisions once they have been formally adopted.

Q: I have been pressing you so closely on timelines and the Central Election Commission’s capacity to conduct elections in order to understand the extent of the damage to Ukraine’s electoral infrastructure caused by the war, and to hear your assessment of whether it can be restored within a short period of time.

A: The damage to the electoral infrastructure has been severe. As you mentioned, you have seen my presentation delivered during the meeting of the working group on drafting legislative proposals regarding elections in a special period; it contains fairly precise figures, which I will not repeat here. The presentation is available on the CEC’s website. What is important to highlight is that a significant number of polling stations are located in uncontrolled, temporarily occupied territories, and there is currently no reliable information about their condition.

There are also damaged and destroyed polling station facilities in territories that were de-occupied long ago.

Thus, when we discuss elections in the realities in which Ukraine currently exists, we must acknowledge that there remains a portion of occupied territory where elections cannot be held for objective reasons—despite the strong desire of the aggressor state to portray otherwise. Moreover, elections cannot be conducted not only in Ukraine’s currently occupied territories, but also in the territory of the Russian Federation, as this would constitute a powerful instrument of interference in Ukraine’s internal affairs.

We have already observed how Russia organizes so-called “elections” and manufactures their outcomes. Regrettably—putting it mildly—these processes fall far short of democratic standards.

With regard to government-controlled territories, there arises a clear need to adopt legislation defining the feasibility or infeasibility of holding elections. Such a law would establish where, even on territories under Ukrainian government control, elections cannot be conducted—for example, due to security risks or damaged infrastructure.

For instance, if a settlement has been completely or almost completely destroyed and its population has evacuated, the question arises whether there is any practical or democratic rationale for holding elections there. These are precisely the issues that must be resolved through law.

Accordingly, once a notional line of separation emerges and it becomes clear which territories are under Ukrainian control and where elections can realistically be held, it will be possible to make concrete calculations regarding the scale of electoral infrastructure that must be restored or replaced—that is, the number of polling stations that have been destroyed or damaged.

What complicates all such assessments is the fundamental uncertainty as to when this situation will materialize and under what conditions.

THE MOST VIABLE SOLUTION TO THE CHALLENGES OF OUT-OF-COUNTRY VOTING IS THE ESTABLISHMENT OF ADDITIONAL POLLING STATIONS

Q: Let us move from the issue of electoral infrastructure within Ukraine to the challenges of voting abroad. During your presentation to the working group, you noted that approximately 6.5 million Ukrainian citizens are currently residing outside Ukraine, yet only around 350,000 are registered with consular services. How can the voting rights of these citizens be effectively ensured?

A: Within the Central Election Commission, a dedicated working group is preparing proposals for legislative amendments specifically addressing out-of-country voting. This issue has been examined in considerable detail. Three potential approaches were assessed: online voting, postal voting, and the establishment of additional polling stations outside embassies and consulates.

The working group of the Central Election Commission immediately ruled out online voting in any form, considering it excessively risky for post-war elections and, more broadly, for Ukraine at its current stage of institutional and security development.

Postal voting attracted greater support during discussions; however, it was ultimately not endorsed at the level of the Central Election Commission.

Following collegial deliberation, the Commission concluded that the only viable and most effective solution to the problem of out-of-country voting is the establishment of additional polling stations outside diplomatic missions. Such a decision, however, can only be adopted through legislation. Should the relevant legislative framework be approved, its implementation would require substantial organizational efforts, primarily on the part of the Ministry of Foreign Affairs, to ensure practical execution.

A separate challenge concerns voter registration: Ukrainian citizens have traditionally shown low engagement with registration procedures, particularly consular registration, which constitutes a significant structural problem. In response, a number of policy options have been developed, most notably the concept of active voter registration.

This approach is directly linked to the proposal to establish additional polling stations abroad. In order to determine where such polling stations should be created, authorities must first have reliable data on voter demand. The core idea is to launch an active registration procedure well in advance of the election process, enabling any voter, through a personal application submitted either to a designated institution or online—specifically via the Diia digital platform—to declare their intention to vote at a specific location abroad.

Based on the data collected through this process, as well as information provided by Ukrainian embassies, authorities will be able to determine where there is a practical need to establish additional polling stations.

In addition, existing mechanisms—such as changing one’s electoral address or temporarily changing the place of voting—remain available and have functioned in previous electoral cycles.

However, all of these mechanisms require active participation by the citizen. If the state does not know that a citizen is abroad, or is unaware that the citizen intends to exercise their voting rights while abroad, it is institutionally impossible for the state to ensure that opportunity.

Q: In the context of establishing additional polling stations outside embassies, discussions have focused primarily on countries with the largest concentrations of Ukrainian citizens.

A: While the mechanism would be universal in design, its practical implementation would be most intensive in states hosting significant Ukrainian populations.

A key complicating factor is the domestic legislation of host countries. The laws of some states do not permit the establishment of polling stations on their territory outside diplomatic and consular premises. Examples include Canada and the Czech Republic.

According to available information, there may still be potential legal or diplomatic solutions in the case of Canada, whereas the situation in the Czech Republic is more challenging. This is particularly problematic given the large number of Ukrainian citizens residing there, as existing legal restrictions would make such a mechanism unworkable unless they are amended.

At present, the largest Ukrainian diaspora is in Germany, with Poland ranking second in terms of the number of Ukrainian citizens residing there.

A MECHANISM FOR CHANGING ELIGIBLE VOTER’S ELECTORAL ADDRESS IS ALREADY IN PLACE

Q: Can the instruments for changing the place of voting that you mentioned be applied to internally displaced persons?

A: Absolutely yes—they can be applied. A mechanism for changing the electoral address is already operational. The Central Election Commission has resumed the functioning of the State Register of Voters in terms of direct interaction with citizens. In practical terms, this means that the mechanism is already open, and an electoral address can be changed before the start of the electoral process.

Moreover, we aim to further simplify this mechanism, making changes to the electoral address valid for a longer period and ensuring that the majority of citizens are able to make use of it.

Q: Could you explain this in more detail? For example, if I am an internally displaced person and want to change my electoral address, what steps should I take now?

A: You need to submit an application to the voter register maintenance office, either in writing or in electronic form.

Q: And is this already operational?

A: According to a resolution of the Central Election Commission of Ukraine, this option becomes available from 1 January.

The only caveat is that the system will need to be tested during the initial days of operation, given the lengthy interruption in its use. At the same time, if this process becomes active, it will result in a more up-to-date State Register of Voters.

Why are we addressing these issues already now? Because experience from previous elections shows that a significant percentage of citizens tend to postpone such actions until the last moment. We recall the 2019 elections, when massive queues formed at voter register offices in the final days before voting. At that time, applications to change the place of voting in order to cast a ballot at one’s actual location could not yet be submitted electronically, and not everyone managed to complete the procedure in time.

As of now, the law stipulates that such an application must be submitted no later than five days before election day.

Today, the situation is fundamentally different from what it was in peacetime. Previously, those seeking to change their place of voting were primarily labor migrants and internally displaced persons who were in fact living away from their registered address. Due to the war, however, the scale of this phenomenon has increased significantly.

It is evident that the number of citizens has declined in the eastern regions and increased in the western parts of the country. At the same time, most forcibly displaced persons remain outside formal registration mechanisms, meaning they do not register their place of residence at their actual location.

If, in the final days before voting day, a large number of voters suddenly appear in a particular region, how can the electoral infrastructure be expected to withstand such pressure? Imagine a polling station facing a queue of, say, 10,000 voters. Clearly, most of them would be unable to cast their ballots. Such scenarios must therefore be prevented.

This requires a two-pronged approach. First, citizens should be encouraged to change their place of voting well in advance. One of the proposals included in the draft legislation—and one that is expected to gain support—is to extend the deadline for submitting applications to change the place of voting from five days before election day to fifteen days.

Second, the law must provide for a mechanism to establish additional polling stations immediately prior to election day. This would allow newly registered or relocated voters to exercise their voting rights. At present, the legislation does not allow for such measures. In peacetime, this would be inappropriate; however, these are exceptional procedures designed specifically for post-war elections as a response to large-scale internal displacement.

ANY CONCENTRATION OF MILITARY PERSONNEL AT A POLLING LOCATION CONSTITUTES AN ADDITIONAL SECURITY RISK FOR THEM

Q: What about the electoral rights of military personnel? How can voting be ensured for servicemen on the front line, including those in active combat positions? Are there already any policy solutions under consideration?

A: These issues have been the subject of extensive deliberation and preparatory work. A number of concrete legal provisions have been developed with the aim of safeguarding the voting rights of members of the armed forces.

It is difficult to envisage an election day for military personnel taking place while active hostilities are ongoing. If we are speaking about postwar elections, a portion of servicemen will by then have been demobilized or redeployed to permanent bases, while another portion will remain close to the demarcation line, as security threats will clearly not disappear overnight. Many of them will therefore continue to serve under special conditions, which necessitates careful consideration of how their electoral rights can be effectively ensured in such circumstances.

We have developed a number of new mechanisms, while also retaining existing ones under which servicemen vote at regular polling stations. At the same time, mechanisms that were already used in 2019 are being refined—specifically, the establishment of special polling stations, upon submission by the Ministry of Defense, at locations of actual military deployment. In addition, we plan to propose concrete mechanisms to enable voting at places of actual presence for those serving under special conditions.

However, all of this can be discussed only under conditions of peace. If active hostilities continue, any concentration of military personnel—for example, at a polling station—would pose an additional security risk to them. Therefore, elections require, at a minimum, a ceasefire. The President has consistently emphasized this sequence: first security guarantees, then elections. This logic is broadly understood, and security is universally recognized as the top priority.

Q: It is already clear that Russia will attempt to exploit the fact that a significant number of Ukrainian citizens remain in currently occupied territories, arguing that the impossibility of holding elections there constitutes a violation of their voting rights. The question, therefore, is how Ukraine should respond to this challenge.

A: Russia will always say whatever serves its interests, and Ukraine cannot build its policies or its day-to-day governance around the narratives of the aggressor state. Russia will say anything necessary to advance its objectives—discredit Ukraine’s authorities and ultimately destroy the Ukrainian state. We can clearly see this pattern in its actions.

Q: As for Ukrainian citizens who remain in currently occupied territories but wish to participate in elections, they would have to travel to government-controlled territory, change their voting address, and exercise their electoral rights there.

A: I do not see any alternative mechanism at this point. At the same time, this is fundamentally a matter of legislative regulation.

International practice does offer precedents. One example is Moldova, where residents of Transnistria voted at designated polling stations located in territories controlled by the Moldovan government. Similar accusations were voiced there as well—that certain rights were allegedly not being ensured—but such claims are inevitable. They are part of the broader toolkit of hybrid warfare.

Q: Let us return once again to the State Register of Voters. During your presentation to the working group, I was struck by the example of Bakhmut that you mentioned: both voters and polling stations are still registered there, even though the city itself effectively no longer exists. How is the issue of updating the State Register of Voters being addressed?

A: At the working group you referred to, some members of parliament proposed synchronizing various state registers as a way to resolve the problem of keeping the State Register of Voters up to date. However, this issue is complex and ambiguous, because other registers are not particularly accurate either—most notably the register of internally displaced persons.

Moreover, a difficult situation could arise if data from another register were used to amend the voter register without the voter’s knowledge. In such cases, the citizen would also need to be informed that their voting address had been changed. But how would that be done? We do not have reliable contact information. In other words, this is far from a simple technical task.

The key concern is to ensure that such actions do not make the situation worse. Some incremental improvements may be possible, but in any case, they can only be achieved through legislative amendments. This is because all operations involving the State Register of Voters are governed by procedures strictly defined in the Law of Ukraine “On the State Register of Voters.”

If legislation were to establish a provision allowing the use of a specific register of Ukrainian citizens located in government-controlled territory to update, at a minimum, data on voters whose registered voting addresses are in currently occupied territories, this could somewhat improve the situation. However, in the event of the de-occupation of the relevant territory, this issue would inevitably have to be revisited.

Overall, when it comes to updating the State Register of Voters, the central role belongs to citizens themselves—their active participation is crucial. It should be emphasized that this does not concern all voters, but specifically internally displaced persons and those voters who reside in Ukraine or abroad outside their place of official registration, primarily those who left occupied territories. The objective is to make these processes—updating records and changing voting addresses—as simple as possible.

If, instead, the state were to unilaterally modify registry data—transferring or altering records administratively—the result could be voter registers that are significantly less accurate than they are now. Therefore, civic engagement remains the most effective solution, even though it is not the easiest one.

IF THERE ARE GROUNDS FOR HOLDING ELECTIONS, THE NECESSARY FUNDING CAN BE ALLOCATED

Q: Another important issue is financing. There has been extensive discussion suggesting that elections are impossible not only for security reasons, but also because no funds have been allocated for this purpose in the 2026 state budget. In your view, how much funding would be required even to conduct a nationwide referendum?

A: I do not know, and no one can know, how much funding would be required, because there is no established procedure, no clearly defined territories, and no assessment of the extent to which electoral infrastructure has been damaged or remains intact. Without a legislative framework, there is simply nothing to calculate.

As for the budgetary argument, I do not understand this line of reasoning at all. If there are legal and factual grounds for holding elections, funding can be allocated accordingly.

In the past, when elections were scheduled and regular, planning took place in advance: we knew the elections would occur, conducted cost estimates ahead of time, and incorporated them directly into the draft state budget for the relevant year. Extraordinary elections are different—they are not budgeted for in advance. The same applies to post-war elections: no one knows when the war will end or when conditions for elections will emerge. Under such circumstances, does it make sense to allocate these funds in the budget every year?

Moreover, the situation and prices are constantly changing. Once again, without a legislative framework, there is no basis for financial calculations.

If the necessary preconditions are in place, I believe this will not pose a problem: amendments can be introduced to the Law on the State Budget of Ukraine to allocate funding for the electoral process or a referendum.

THE CEC HAD TWO EU INTEGRATION TASKS — BOTH HAVE BEEN COMPLETED

Q: Finally, I would like to ask about the results with which the Central Election Commission is concluding 2025. The Commission was tasked, among other things, with meeting certain EU integration requirements, on which Ukraine’s accession to the European Union depends. Have these tasks been fulfilled?

A: During the wartime period, when elections are not being held, the Central Election Commission has two major areas of activity: preparation for post-war elections and European integration.

The Roadmap for the Functioning of Democratic Institutions—whose implementation is an integral part of Ukraine’s European integration process—contains a number of measures for which the Central Election Commission has been designated as the responsible authority. In particular, this year the Commission served as the lead implementer for two key measures.

It was necessary to hold a public discussion on the implementation of OSCE/ODIHR recommendations in the electoral field. This discussion was conducted on 15 December 2025 (a report on the event is available here).

Prior to that, the Central Election Commission, for the first time, carried out a comprehensive assessment of the implementation status of OSCE/ODIHR election observation mission recommendations related to elections in Ukraine for the period 2014–2020. The Commission proposed approaches for addressing recommendations that remain unimplemented and adopted Resolution No. 48, which approved a package of legislative proposals intended to support a broad-based dialogue on the implementation of OSCE/ODIHR recommendations.

The resolution also outlined practical aspects of how these recommendations should be implemented by other relevant government institutions during the electoral process and introduced a regular mechanism for monitoring and analyzing progress in their implementation.

Another measure under the Roadmap for the Functioning of Democratic Institutions was the adoption, through an inclusive process, of the Central Election Commission’s communication strategy for post-war elections. This task has also been completed. Work on the strategy lasted more than a year. Importantly, the objective was not merely to draft and formally approve the document, but to ensure meaningful public participation in its development. To this end, a series of public consultations was held, which contributed to improving the final version of the strategy.

Beyond these two specific Roadmap commitments, a range of additional activities took place in the EU integration context, with active involvement from representatives of the Central Election Commission. At present, the Commission has no outstanding or overdue obligations related to European integration.

Tetiana Pasova

Photo: Kyrylo Chubotin / Ukrinform

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