How Outdated Urban Planning Documentation Is Hindering the Development of Ukrainian Cities: Findings from LUN City 2026

As part of the LUN City 2026 event, a panel discussion titled “A Strategic Factor in Development: The Lack of Urban Planning Documentation and Project Approval” was held, moderated by architect Anna Iskierdo. Speakers included MP Olena Shulyak, Chairman of the Ukrainian Association of Developers Yevhen Favorov, UDP Commercial Director Yevhen Bokiy, Avalon CEO Roman Davymuka, and Perfect Group Project Manager Oleksiy Koval.

Anna Iskierdo opened the discussion by noting that 14% of housing in Ukraine is either destroyed or in need of renovation—that is, one in every seven buildings—and that 80% of the existing housing stock was built before 1991. Despite the enormous demand for new construction, cities continue to operate based on outdated regulations.

“Kyiv is operating under a master plan that was first drafted in 1997, then approved in 2000, and remains in effect to this day, but it is certainly no longer relevant,” noted Olena Shulyak.

Olena noted that even before the full-scale invasion, the Verkhovna Rada had passed a law requiring all communities to develop a new type of documentation—a comprehensive spatial development plan that combines land-use planning and urban planning components. Initially, the deadline was set for January 1, 2025, but due to the war, the Rada extended it to January 1, 2028.

“We can see that the city of Kyiv isn’t in a hurry. In general, big cities aren’t in a hurry. Small communities are in a hurry because they understand very clearly: no plan means no development, no money, and no investments. Apparently, Kyiv and other big cities don’t need investments; they need these rules that are currently in effect,” the lawmaker added.

According to her, her motivation has run out: 

“I think we need to start taking some punitive measures. If it were up to me, I wouldn’t pay any taxes to the city at all until it develops the necessary documentation. Because right now, everyone is suffering: both the residents of Kyiv and all the cities that lack a vision for the comprehensive development of their territories.”

Yevgeny Favorov presented the results of an industry survey of more than 30 development companies: they cited the instability of permits, the process of obtaining urban planning conditions and restrictions, and the urban planning preparation of land plots as the key barriers to construction.

According to him, developers' portfolios hold enormous potential—thousands of hectares of industrial land that are effectively unused.

“We currently have thousands of hectares of land in our portfolio, but we are still a long way from obtaining the necessary permits because it is virtually impossible to change their designated use. The master plans were approved 20 years ago—some form of industrial production was planned for these areas. Today, there is no production there at all. It’s just a plot of land with a rough fence that no one is interested in, but it already has engineering infrastructure—and investments in that infrastructure are usually the largest.”

According to him, the decision-making process—from the start of the process to the approval of the detailed site plan and amendments to the master plan—takes three years. As an example of the European approach, he cited a program in Germany:

“The German government has exempted municipalities from the requirement to amend their urban planning documents. While they have not eliminated the need to obtain approval from local authorities, they have simplified the process for changing land use as much as possible. Local authorities must take public interest into account—by holding public hearings—but they need a tool to make this process as straightforward as possible.”

Anna Iskerd noted that during the full-scale invasion, Lviv adopted approximately 10 detailed zoning plans—3 to 4 times more than in Kyiv, where only two were adopted during that period. 

“I can only point out the symptoms, which differ slightly from those in Kyiv. In Lviv, there is a major conflict regarding urban planning documentation. We have a document approved in 1923—a historical-architectural master plan—and to this day, no one can definitively say whether it is urban planning documentation or heritage preservation documentation. We are caught in a conflict between different types of documentation,” explained Roman Davymuka.

According to him, this creates a climate of uncertainty in which any city official thinks first and foremost not about development, but about how the prosecutor’s office will view his decisions.

“We have a situation where dozens of court cases are pending regarding approved detailed plans that differ from the master plan dating back to 2010. Every new document is a new story, requiring a fresh approach as we navigate through these documents.”

As a result, according to Davymuka, developers are moving into neighboring communities—and this is giving rise to new conflicts, particularly regarding the development of Lviv Airport, where the neighboring Sokilnytsia community is planning its own large-scale development project.

“The city is trying to halt this development by involving the Cabinet of Ministers and seeking relevant decisions regarding the airport as a strategic facility. But overall, the issue of neighboring communities is one that falls within the context of decentralization, elections, and related reform processes.”

Oleksiy Koval added that, in the Ukrainian context, the detailed territorial plan (DTP) effectively serves as a substitute for the master plan, whereas in European countries it is merely a supplementary document.

“In Western countries, a detailed plan is merely a supplementary document that clarifies certain details. But here, a detailed plan can completely change the designated use of a plot of land. Is that a bad thing? Given that we don’t have a master plan, it’s the only way to make any changes.”

According to him, even after obtaining a detailed plan with a revised land use designation, the developer faces new restrictions—such as height limits—established by other urban planning documents.

“We run into surprises at every turn. In Western countries, you go in to develop a detailed plan, knowing the site’s technical and economic indicators clearly—for you, calculating the economic model and feasibility is a matter of hours. Here, we go in as if to war: we’re playing the lottery and don’t even know what we’ll get in the end, because there will be obstacles at every stage.”

The discussion also touched on the practice of building apartments on land not zoned for residential use—a model that allows developers to circumvent requirements regarding social infrastructure, landscaping, and the number of parking spaces.

Yevgen Bokiy shared the story of his company: five years ago, UDP acquired the site of the Bolshevik factory, but has still been unable to develop it.

“We’re facing a dilemma today: the first option is to wait for the new master plan to be adopted, but right now we don’t even have the technical specifications ready to hold a tender for a developer. If we break that down into months and years, I won’t live to see the master plan. The second option is to resume steel production almost in the city center, with the corresponding environmental consequences. And the third is to build apartments on land not designated for that purpose. It’s like having your hands tied and being told: ‘Go to work.’”

He proposed a systematic solution for brownfield sites, similar to the status of industrial parks.

“If we, as a government, can establish certain criteria—for example, a minimum of 10 hectares of land, provided the area is self-sufficient in terms of kindergartens, schools, and other infrastructure—to allow for revitalization as an industrial park, this would be an alternative to waiting for new master plans. Two or three such decisions—and that’s equivalent to what Kyiv has received over the past three years. For example, Podil—the heart of Kyiv—is entirely industrial, but there is no industry there—only warehouses, auto repair shops, and freight terminals. If such areas are converted into residential and community development, provided that schools and kindergartens are built, a single decision covering 20–30 hectares could provide Kyiv with 300,000 square meters of development.”

Oleksiy Koval noted that, unlike in other regions, apartments in Kyiv have traditionally been slow to sell.

“Buyers in Kyiv aren’t interested in apartments, and it’s always been that way. It comes down to commercial rates, and people don’t understand how you can live in an apartment—it’s not part of the residential housing stock. We tried a compromise solution—'residential units'—but that didn’t work out either: buyers don’t understand what they are or how to resell them later.”

According to him, the situation is different in Odesa and the western regions, where apartments are traditionally viewed as investment properties—there, this type of property is well understood by buyers.

Olena Shulyak emphasized that housing construction must now become a national priority, particularly in the context of support from international partners—the European Investment Bank has already allocated 400 million euros for the construction of social housing in certain communities.

“Developers who truly follow the rules don’t want to break any of them and want to see their projects through. We all need to come together to ensure that the rules are clear, free of corruption, and designed to benefit both businesses and residents.”

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