According to Prozorro’s analysis, not everyone is complying with the requirements yet, so here is what authorised representatives need to do.
What documents are integral annexes to contracts?
Article 41 of the Law has been supplemented with provisions requiring that contracts be accompanied by documents containing information on the prices of material resources in the following cases:
- Current repair services;
- New construction, reconstruction, restoration, capital repair of facilities under construction;
- Current repairs that include the development of design documentation;
- Construction that includes the development of design documentation.
For contracts that involve design documentation, these documents must be attached after the contract price has been determined based on the approved project documentation (if its approval is required by law).
What details about material resources need to be prepared?
Documents on prices for material resources for each item must specify:
- Designation of the resource (with specifications);
- Unit of measurement;
- Quantity;
- Selling price;
- Transportation cost;
- Procurement and storage costs;
- Country of origin of the goods.
Other relevant information can be added as necessary.
Which contracts are subject to publication?
Pursuant to Article 1 of the Law, a procurement contract is a commercial contract between a procuring entity and a bidder concluded following a procurement procedure/simplified procurement procedure. Clause 13 of the Aspects (Resolution of the Cabinet of Ministers of Ukraine No. 1178 dated 12 October 2022) lists the exceptions that allow a contract to be concluded without open bidding/an electronic catalogue.
Therefore, publication in machine-readable format is mandatory if both of the following conditions are met:
- Scope: the works/services listed in the block above (current repairs; new construction; reconstruction; restoration; major repairs; current repairs with design documentation; construction with design documentation);
- The contract was concluded following open bidding or in accordance with the exception under Clause 13 of the Aspects.
Deadlines for making documents public
According to Article 10 of the Law, the contract and any annexes thereto (including documents on prices for material resources) must be made public in machine-readable format within three working banking days from the date of the contract.
Formats for making documents public
Machine-readable format (as per CMU Resolution No. 835) means a structured format that allows automatic identification, conversion and retrieval of data without human intervention.
Acceptable formats:
- Text data: TXT, RTF, MD, ODT, DOC(X), (X)HTML;
- Structured data: RDF, XML, JSON, CSV, XLS(X), ODS, YAML.
Additionally, since July 2025 (amendments to the Procedure under Order of the Ministry of Economy No. 1082): contracts for “Transparent Construction” must be published in two formats:
- PDF;
- Machine-readable text data format (TXT, RTF, MD, ODT, DOC(X), (X)HTML).
Summary and checklist for Prozorro
If you upload contracts for works/services related to routine repairs to Prozorro, which have been concluded following open bidding or in accordance with Clause 13 of the Aspects, prepare and publish:
- Contract + all annexes (including documents on prices for material resources);
- Formats: PDF (required) and a machine-readable text format (TXT, RTF, MD, ODT, DOC(X) or (X)HTML);
- Deadline: Up to 3 banking days from the date of the contract.
