Security Audit of Select Hromadas: Consolidated Findings

What is a security audit?

A security audit is a universal monitoring tool for assessing institutional capacity. It provides a transparent framework for decision-making on whether elections can or cannot be held in specific territories. The audit results are accessible to society, the state, and Ukraine’s Western partners alike. The assessment covers the following areas: basic preconditions, physical security, socio-economic factors, and the state of democratic processes.

The audit makes it possible to analyse:

• Preparedness to respond to security challenges: the security level in a hromada and the capacity of local authorities to respond effectively to potential threats.
• Dynamics of socio-economic processes: whether residents of the hromada have access to services that ensure the provision of basic social and economic conditions (healthcare, financial and postal services, etc.).
• Feasibility of implementing electoral procedures: an assessment of the conditions for holding free and fair elections and the availability of organisational capacity to ensure the electoral process.

Assessment framework

The assessment is conducted using 35 indicators grouped into four blocks and four stages.

Audit Passing Criteria

• Each stage is scored as 1 point (passed) or 0 points (not passed).
• Only hromadas that score 4 out of 4 points are considered to have passed the audit and to be ready to hold elections.
• A lower score indicates that the audit has not been passed; however, the assessment makes it possible to identify problematic areas requiring further improvement.

The full audit methodology is published on the website of the Civil Network OPORA.

Previously, in March–April 2025, OPORA conducted pilot security audits in four hromadas: Kryvyi Rih (Dnipropetrovsk Oblast), Snihurivka (Mykolaiv Oblast), Zaporizhzhia, and Poltava. An interactive dashboard was developed to enable comparison of the results.

The second wave of the study, the results of which are presented below, took place in October–November 2025. Data were collected for the period of July–September 2025.

Geography of the Audit

For a comprehensive analysis, 11 hromadas with different levels of war-related risks and challenges were selected, including de-occupied hromadas, border hromadas, hromadas located in active hostilities zones, and rear hromadas (located more than 100 kilometres from the frontline).

The de-occupied hromadas include the Izium urban hromada in Kharkiv Oblast and the Pervomaisk settlement hromada in Mykolaiv Oblast.

The Olevsk urban hromada in Zhytomyr Oblast is located near the border with Belarus, while the Snovsk urban hromada in Chernihiv Oblast lies on the border with Russia.

The largest group consists of hromadas located in active hostilities zones: Kramatorsk urban hromada (Donetsk Oblast), Kherson urban hromada, Novomykolaivka settlement hromada (Zaporizhzhia Oblast), Nikopol urban hromada (Dnipropetrovsk Oblast), and Velyka Pysarivka settlement hromada (Sumy Oblast).

The rear hromadas are represented by the Kremenchuk urban hromada (Poltava Oblast) and the Pivdenne urban hromada (Odesa Oblast).

Data Collection Methods

The data were collected by OPORA’s network of regional consultants using the following methods: field observation, desk research, requests for access to public information, interviews with public officials and local residents, and open-source data.

Audit Limitations

The study was conducted under the legal regime of martial law, which affected the values of the indicators. The conditions of martial law also influenced the volume of available information, the possibilities for data verification, and the depth of analysis. These factors should be taken into account when interpreting the results.

The audits had a screening character, aimed at the rapid identification of key issues and the piloting of the methodology. Due to changes in the security situation — particularly in hromadas located near the line of active hostilities — the data require continuous updating and additional verification.

One of the data sources used for the assessment consisted of requests for access to public information. Incomplete or delayed responses from some hromadas limited the comprehensiveness of the analysis. In such cases, open sources or information obtained through interviews with local residents were used, which affected the overall accuracy and level of detail of the assessment.

The Komyshuvakha settlement territorial hromada (Zaporizhzhia Oblast) refused to provide the information requested by OPORA, erroneously considering it non-public, while other hromadas provided similar data without restrictions. Due to the absence of part of the required information, the assessment of several indicators became impossible; therefore, the Komyshuvakha hromada was excluded from the study and replaced by the Novomykolaivka settlement hromada.

Priority Steps for Restoring Democratic Processes in Hromadas Based on the Results of Two Audit Waves

• A security audit should become a mandatory tool for assessing the readiness of physical and social infrastructure in de-occupied hromadas and hromadas located in active combat zones. These hromadas demonstrate the lowest assessment scores. At the same time, there is no direct correlation between security risks and physical distance (50 or 100 km) from the line of contact. Instead, the systematic use of such assessments can encourage capital investment in the restoration of critical infrastructure even before political renewal takes place.

• There is a need to develop a legislative framework to identify territories where the holding of safe and democratic elections is not possible. Any decisions affecting constitutional rights must be justified by verified data. At the same time, a formalistic approach should be abandoned (such as defining a notional 50- or 100-kilometre geographical zone where ensuring the security of the electoral process is allegedly impossible). The level of security is determined by a combination of factors, including the intensity of hostilities, the condition of infrastructure, the availability of shelters, and the capacity to respond to critical situations related to citizens’ lives and the provision of basic services. Implementing such an approach creates the preconditions for informed decision-making.
• The scale of the assessments conducted demonstrates the need to introduce pilot security audit programmes at the national level, which may be implemented through inter-agency co-operation. This would make it possible to test legislative mechanisms in advance, assess realistic timeframes and resource requirements, and ensure high-quality preparation and organisation of the first post-war elections.
• Although no hromada passed the security audit with a 100 per cent success rate, the identified issues can be addressed before the start of the electoral process, provided that sufficient investment and time for implementation are available. This applies to the restoration of electoral infrastructure, energy facilities, the continuation of demining activities, the construction of civil protection facilities, and the strengthening of human resource capacity in specific sectors.
• The identified risks confirm the need to approve security protocols for all participants in the electoral process, taking into account international standards and best practice. These protocols will also serve as an important prerequisite for the full operation of international election observation missions.
• Security audits demonstrate the urgent need for continued support for hromadas, including international assistance, to strengthen their capacity and resilience.

Key Findings

• The audit was conducted under the legal regime of martial law, under which elections and referendums are prohibited by law. If the legal regime of martial law were to be lifted, 3 out of the 11 hromadas would have passed the physical security assessment with positive results: Pivdenne (Odesa Oblast), Kremenchuk (Poltava Oblast), and Kramatorsk (Donetsk Oblast). However, the security situation in wartime is not stable, which must be taken into account when developing and adopting decisions.

• The key challenges in the area of physical security are shelling, the lack of shelters near the premises of precinct election commissions (PECs), and an underdeveloped emergency alert system. Of all the hromadas studied, only the Olevsk hromada did not experience shelling during July–September 2025. In no hromada are polling station premises 100 per cent covered by shelters within a 500-metre radius, and in 5 hromadas fewer than 50 per cent of polling stations have access to shelters in the event of a security threat. In rural areas, the situation with shelters is significantly worse than in urban areas: in some settlements, there are no shelters within a radius of 5–10 kilometres. Rural settlements are also less well covered by alert systems. Air raid alert systems cover less than 70 per cent of the population in the Olevsk, Velyka Pysarivka, Snovsk, and Novomykolaivka hromadas.
• Under the “Socio-Economic Development” block, rear-area hromadas Olevsk and Pivdenne, as well as the Pervomaisk hromada, which was under occupation from March to November 2022, passed the audit with positive results. The Novomykolaivka hromada, located near the combat zone, also passed this block of the audit, largely due to the relatively low intensity of shelling. The hromada maintains an adequate level of service provision in the areas of education and healthcare, and the population has access to digital services (mobile communications, internet, television and radio broadcasting). However, Russian attacks on Ukraine’s energy system in October–November 2025 led to blackouts (power outages lasting more than 12 consecutive hours) in a number of hromadas, which also affected the final assessment.
• According to the “Democratic Processes” indicators, the Kremenchuk and Pivdenne hromadas received positive assessments. The key obstacles for other hromadas were additional bans on peaceful assemblies imposed by local administrations (5 hromadas), significant destruction of electoral infrastructure (4 hromadas), and limited capacity to recruit members of PECs due to a substantial reduction in population (5 hromadas).
• Hromadas located in active combat zones and along the border with Russia (Nikopol, Snovsk, Kramatorsk, Velyka Pysarivka, Novomykolaivka, and Kherson) or those de-occupied in 2022 (Izium and Pervomaisk) generally demonstrate the weakest results across all audit blocks. The strongest overall results are demonstrated by rear-area hromadas: Olevsk, Pivdenne, and Kremenchuk.
• Even in territories where hostilities are ongoing or have taken place (territories included in the list approved by the Ministry for Communities and Territories Development), hromadas continue to function and provide the population with basic services (education, healthcare, administrative services), while local self-government bodies and military administrations retain governance capacity. This indicates the continued manageability of governance in these territories.
• The intensity of shelling depends on proximity to the frontline. Accordingly, the highest intensity of shelling has been recorded in the frontline Kherson (3,861 incidents), Nikopol (1,220), and Kramatorsk (155) hromadas. Regrettably, these hromadas have also suffered the highest number of civilian fatalities. In the Kherson hromada, 45 residents were killed between August and October 2025; in the Nikopol hromada, 11 residents were killed between July and September 2025; and in the Kramatorsk hromada, 7 residents were killed.
• In de-occupied and frontline hromadas, a significant reduction in the number of residents has been recorded, with outmigration amounting to 50–75 per cent of the pre-war population. In particular, approximately 23–25 per cent of residents remain in the Kherson hromada, fewer than 70 per cent in the Kramatorsk hromada, 31 per cent in the Velyka Pysarivka hromada, 44 per cent in the Pervomaisk hromada, and around half of the population in the Izium and Nikopol hromadas.
• In 8 hromadas, polling stations have been partially destroyed, with the greatest damage observed in active combat zones and de-occupied territories. In the Nikopol, Izium, Velyka Pysarivka, and Pervomaisk hromadas, more than 50 per cent of precinct election commission (PEC) premises have been destroyed or damaged. Some hromadas are unable to assess the condition of electoral infrastructure due to ongoing hostilities, while several others lack alternative premises to replace all or part of unusable polling stations.
• The operation of the State Register of Voters, particularly in terms of interaction with voters, has not been restored in all hromadas. In the Kherson hromada, all three voter register maintenance units are non-operational due to hostilities. Regular updating of voters’ personal data does not take place at all in the Kherson hromada, and occurs only partially in the Kramatorsk hromada, as the Kramatorsk City Court and the Department of Labour and Social Protection of the Population of the Kramatorsk City Council do not submit data for inclusion in the State Register of Voters. Voter register maintenance units in only 3 out of 11 hromadas — Snovsk, Olevsk, and Pivdenne — report no staffing or material resource constraints.
• In 7 out of 11 hromadas, the police arrive at the scene of an offence or incident within the response times recommended for peacetime (7–10 minutes in urban areas and 20–40 minutes in rural areas). These include the Snovsk, Olevsk, Pivdenne, Pervomaisk, Novomykolaivka, Kremenchuk, and Izium hromadas. At the same time, in hromadas that regularly experience intense shelling, response times may be longer or delayed (Kherson) or not recorded at all (Kramatorsk and Velyka Pysarivka hromadas).
• Staffing levels of police units operating in hromadas range approximately between 70 and 93 per cent. As a rule, police departments in hromadas that are more frequently targeted by attacks and face greater security challenges have lower staffing levels than those operating in safer conditions. For example, police staffing levels stand at 77.7 per cent in the Kramatorsk hromada, 78 per cent in the Kherson hromada, and 85 per cent in the Izium hromada.
• The largest areas contaminated by mines are found in the Pervomaisk (9 per cent) and Izium (7 per cent) hromadas. Isolated mined areas have also been recorded in the Novomykolaivka, Snovsk, Olevsk, Kramatorsk, and Pivdenne hromadas. No mined areas have been identified in the Kremenchuk hromada.
• Civilian casualties caused by landmines have been recorded in the Kherson and Izium hromadas. In these hromadas, as well as in the Nikopol and Velyka Pysarivka hromadas, the situation is further exacerbated by the use of FPV drones against civilians and regular shelling.
• In most hromadas, ambulance response times remain within peacetime norms (approximately 20 minutes). The exception is the Velyka Pysarivka hromada, where the response time reaches 49 minutes. Staffing levels of medical personnel generally remain within the range of 70–85 per cent, allowing for the provision of basic medical services.
• In 8 out of 11 hromadas, response times of the State Emergency Service (SES) meet peacetime standards (up to 25 minutes). These include the Snovsk, Olevsk, Pivdenne, Pervomaisk, Kremenchuk, Izium, Kherson, and Kramatorsk hromadas. However, in certain areas located in active combat zones, arrival times depend on the current security situation and may fluctuate significantly. This is the case, for example, in the Velyka Pysarivka hromada. Data for the Nikopol and Novomykolaivka hromadas are unavailable, which prevents an assessment of the operational responsiveness of SES units.
• None of the 11 hromadas has been left without access to justice: courts continue to operate and take all possible measures to ensure citizens’ right to judicial protection. Air raid alerts constitute a systemic obstacle to court operations: 10 of the 12 courts studied suspend hearings during alerts, while 2 continue proceedings subject to the consent of the parties. The administration of justice in the Nikopol and Kherson hromadas takes place under conditions of regular and intense shelling. In 3 hromadas (Kramatorsk, Izium, and Velyka Pysarivka), territorial jurisdiction has been transferred to courts in other oblasts, which has reduced access to justice for residents.

Block 1. Preconditions for Passing the Audit

All 11 hromadas in which the security audit was conducted are under the control of the Ukrainian authorities. However, during the monitoring period (July–September 2025), only one hromada — the Olevsk urban hromada in the north of Zhytomyr Oblast — did not experience shelling by Russian forces. All other hromadas were subjected to attacks involving various types of weapons, including ballistic missiles, artillery, and unmanned aerial vehicles. The most severe impact was recorded in Kherson, which came under approximately 4,000 attacks between August and October, and in Nikopol, where more than 1,000 attacks were recorded between July and September. These hromadas also suffered the highest number of civilian casualties. The situation is further aggravated by the deliberate use of drones by Russian forces to kill civilians.

Ukraine remains under a legal regime of martial law which, in accordance with legislation, makes it impossible to hold elections both nationwide and within individual hromadas. In light of this, none of the 11 hromadas meets the basic preconditions for passing the audit. At present, the organisation of elections in hromadas is not possible.

Indicator 1. Has the legal regime of martial law or another special regime prohibiting the holding of elections in the hromada been lifted?

Passed the audit: 0 / Failed the audit: 11

As of 1 December 2025, the legal regime of martial law has not been lifted; therefore, the holding of national and local elections is not possible.

Since 24 February 2022, Ukraine has been under a legal regime of martial law, introduced by a Presidential Decree and approved by Parliament. As it is currently unknown when the war will end, the duration of the martial law regime has been extended periodically: initially for 30 days, and since May 2022 for 90-day periods. At present, martial law has been extended until 3 February 2026. If no peace agreement is reached by that date, the regime of martial law will be further extended.

Indicator 2. Is the hromada under the control of the Ukrainian authorities?

Passed the audit: 11 / Failed the audit: 0

All 11 hromadas are under the control of the Ukrainian authorities. However, even if the regime of martial law were to be lifted, elections could be held only in the Pivdenne hromada (Odesa Oblast), which meets the requirements of the other indicators.

Indicator 3. Have there been any shelling incidents (missiles, strike drones, artillery, etc.) affecting the territory of the hromada over the past three months?

Passed the audit: 1 / Failed the audit: 10

Between July and September 2025, Russian forces shelled the territory of all hromadas covered by the study except for the Olevsk hromada. Attacks involved various types of weaponry, including ballistic missiles, artillery, and unmanned aerial vehicles.

The most severe impact was recorded in the Kherson and Nikopol urban hromadas, which are separated from enemy positions only by the Dnipro River. According to the Kherson City Military Administration, the territory of the hromada was subjected to 3,861 shelling incidents between August and October 2025. By contrast, the territory of the Nikopol hromada was shelled 1,220 times (data for July–September 2025).

Other hromadas experienced shelling far less frequently. For example, 155 shelling incidents were recorded in the Kramatorsk hromada; 72 in the Velyka Pysarivka hromada (September–November 2025); 42 in the Izium hromada; and 3 each in the Kremenchuk and Pivdenne hromadas.

Over the three-month period, the highest number of civilian casualties was recorded in the Kherson and Nikopol hromadas. In the former, 45 people were killed and a further 425 injured; in the latter, 11 people were killed and 88 injured. A significant proportion of deaths and injuries resulted from drone attacks: Russian forces deliberately conduct so-called “safaris” (“hunts”) using FPV drones with the aim of killing random civilians.

Table 1. Shelling of hromadas, July–November 2025

Block 2. Physical Security

Only three hromadas passed the audit under the “Security” block — Kremenchuk, Kramatorsk, and Pivdenne. Although these hromadas face a significant number of security-related challenges, they demonstrate a sufficient level of preparedness and capacity to respond to them.

The weakest performance was recorded in the Velyka Pysarivka and Kherson hromadas, where the security situation is assessed as critical.

• The most widespread challenge is the insufficient number and inadequate condition of protective shelters within a 500-metre radius of precinct election commission (PEC) premises. In 5 hromadas (Velyka Pysarivka, Izium, Olevsk, Pervomaisk, and Snovsk), fewer than 50 per cent of buildings housing PECs are equipped with shelters.

• Another common issue is the availability of centralised alert systems. Only 3 hromadas — Kramatorsk, Nikopol, and Kremenchuk — have alert systems that fully cover the hromada’s population, while in the Velyka Pysarivka, Novomykolaivka, Olevsk, and Snovsk hromadas, less than 70 per cent of residents are covered by alert systems.

• Only the territory of the Kremenchuk hromada can be considered fully safe; in all other hromadas covered by the study, there are risks of contamination by explosive remnants of war.

• Eight hromadas do not have fully safe road infrastructure. Movement along roads in these areas is associated with heightened risks.

• In the vast majority of hromadas studied, the National Police and the State Emergency Service (SES) are not only operational and adequately staffed, but also properly handle emergency calls and meet peacetime standards for response times.

• During the study period, no cases of threats or attacks against civic or political activists, public officials, or representatives of state and local self-government bodies were recorded in any of the hromadas.

• Incidents involving civilian injuries caused by explosions during the study period were recorded in only 2 out of the 11 hromadas — Kherson and Izium.

Indicator 4. Hazard status regarding contamination of the hromada’s territory with explosive remnants of war (ERW)

Passed the audit: 9 / Failed the audit: 2

Only the territory of the Kremenchuk hromada can be considered fully safe. In all other hromadas covered by the study, there are risks of contamination with explosive remnants of war (ERW).

The most critical situation is observed in the Kherson hromada, where approximately 56 per cent of de-occupied territories remain uninspected and are therefore considered potentially contaminated with ERW. The hromada regularly suffers from Russian shelling, and certain settlements are subject to mandatory evacuation.

By contrast, in the Izium hromada approximately 7 per cent (2,951 ha) of the territory is either contaminated or potentially contaminated with ERW; in the Pervomaisk hromada, 9 per cent (3,560 ha); and in the Kramatorsk hromada, only 0.53 per cent (218 ha).

In some hromadas, hazardous areas may include territories close to the border with the Russian Federation or Belarus, as well as zones of active hostilities. In particular, in the Snovsk hromada there are at least six such settlements, and in the Novomykolaivka hromada, two. In the Pivdenne hromada, coastal areas are considered potentially hazardous, while in the Olevsk hromada this applies to areas along the border with Belarus.

Surveys of the Velyka Pysarivka hromada were not conducted due to its location within a 20-kilometre border zone and the application of regulatory restrictions. A similar situation exists in the Nikopol hromada, where surveys were also not carried out; however, according to police information, residents in the hromada have discovered unexploded drones, unmanned aerial vehicles, unexploded ordnance, and fragments of enemy weaponry on its territory.

Indicator 5. Safe road infrastructure

Passed the audit: 9 / Failed the audit: 2

Eight hromadas do not have fully safe road infrastructure, and movement within their territories is associated with heightened risks. In three hromadas located within the 20-kilometre border zone, it is not possible to verify safe routes due to the prohibition on conducting non-technical surveys and humanitarian demining. In three hromadas, risks to movement are primarily linked not to mine contamination, but to the active use of FPV drones and regular shelling.

Safe access to all settlements:

• Kremenchuk hromada
• Novomykolaivka hromada
• Olevsk hromada

Safe access to most settlements / minor restrictions:

• Pervomaisk hromada
• Pivdenne hromada
• Snovsk hromada

Unsafe access or safe access only to selected settlements:

• Velyka Pysarivka hromada
• Izium hromada
• Kramatorsk hromada
• Nikopol hromada
• Kherson hromada

Table 2. Safe Access to Hromadas

Indicator 6. Functioning of the National Police

Passed the audit: 10 / Failed the audit: 1

Despite the ongoing war, in the majority of hromadas the police arrive at the scene of an offence or incident in a timely manner. In 7 out of 11 hromadas, response times remain within recommended peacetime standards (7–10 minutes in urban areas and 20–40 minutes in rural areas). These include the Snovsk, Olevsk, Pivdenne, Pervomaisk, Novomykolaivka, Kremenchuk, and Izium hromadas.

In hromadas that regularly experience intense shelling, response times may be longer (Kherson hromada) or not recorded at all (Kramatorsk and Velyka Pysarivka hromadas) due to the high level of security threats. Data for the Nikopol hromada are unavailable.

Where there is a real threat to the life and health of police officers caused by enemy hostilities, some hromadas allow for the deployment of police units to be delayed until the security situation improves.

Staffing levels of police units operating in hromadas range approximately between 70 and 93 per cent. At the same time, there is no direct correlation between the intensity of shelling and staffing levels. In some hromadas that are more severely affected by attacks, police units are staffed at higher levels than those operating in safer conditions. For example, the Kherson District Police Department is staffed at 78.2 per cent, while the Koriukivka Police Department, which serves the Snovsk urban hromada, is staffed at 70.6 per cent.

Emergency service telephone line 102 operates in all hromadas; however, in the Kherson hromada, calls are redirected to the Main Directorate of the National Police in Ternopil Oblast.

Indicator 7. Emergency Response

Passed the audit: 8 / Failed the audit: 3

In 8 out of 11 hromadas covered by the study, the response time of the State Emergency Service (SES) meets the standard (up to 25 minutes). These hromadas are: Snovsk, Olevsk, Pivdenne, Pervomaisk, Kremenchuk, Izium, Kherson, and Kramatorsk.

However, in certain areas located within active combat zones, arrival times depend on the current security situation and may fluctuate significantly. This is the case, for example, in the Velyka Pysarivka hromada.

The emergency hotline 101/112 operates across all hromadas covered by the study; however, in the Velyka Pysarivka hromada, handling calls via the 101 line is complicated due to communication problems.

Authorised bodies also report that staffing levels are sufficient to ensure a prompt response to emergencies.

Data for the Nikopol and Novomykolaivka hromadas are unavailable, which prevents an assessment of the operational responsiveness of local SES units.

Indicator 8. Availability and condition of the emergency alert system (“air raid alert”)

Passed the audit: 7 / Failed the audit: 4

Most hromadas face challenges with centralised alert systems. Only 3 hromadas — Kramatorsk, Nikopol, and Kremenchuk — have alert systems that fully cover the population of the hromada.

In 4 hromadas, the air raid alert system covers around 70 per cent of residents, while in 3 hromadas coverage is below 70 per cent. In particular, in the Kherson hromada, alerts cover only 30 per cent of populated areas.

The Pivdenne urban hromada lacks the financial resources to introduce a centralised alert system. In the Kramatorsk hromada, there is a need to modernise existing systems, including improving emergency communications.

In the Velyka Pysarivka hromada, the local automated centralised alert system (MACAS) is absent, as the equipment was destroyed as a result of enemy shelling in February 2024. In the Izium hromada, the establishment of a MACAS is planned for completion by December 2026, while in the Novomykolaivka hromada, a project for the construction of a MACAS was approved in 2025.

Rural settlements are less well covered by alert systems. To ensure that residents are informed, hromadas often use alternative methods, such as vehicles equipped with loudspeakers, the “Air Raid Alert” mobile application, SMS notifications, and similar tools.

In the Snovsk hromada (three sirens) and the Olevsk hromada, the alert system covers only the central settlement.

Indicator 9. Availability and adequacy of protective shelter systems

Passed the audit: 6 / Failed the audit: 5

One of the most acute challenges in the hromadas covered by the study is the availability and adequacy of protective shelter systems, both for the general safety of residents and for the potential protection of voters and members of election commissions during elections. At present, in none of the hromadas studied are precinct election commission (PEC) premises 100 per cent covered by shelters within a 500-metre radius.

The number of shelters near PEC premises is critically low in the following border hromadas — Velyka Pysarivka (27 per cent), Snovsk (29 per cent), and Olevsk (42 per cent) — as well as in de-occupied hromadas — Pervomaisk (41 per cent) and Izium (46 per cent).

The strongest performance in this regard is observed in the Pivdenne (91 per cent), Nikopol (89 per cent), and Kremenchuk (83 per cent) hromadas.

Overall, the situation with shelters in rural areas is significantly worse than in urban areas; in some cases, no shelters are available within a radius of 5–10 kilometres. In this context, hromadas with a large number of rural settlements (such as Velyka Pysarivka, Snovsk, and Olevsk) may face additional challenges related to the organisation of shelter systems even in peacetime.

The situation also varies across hromadas in terms of shelter capacity. In particular, some hromadas do not monitor this information. According to data obtained by OPORA, shelter capacity may range from 30 per cent of the population in the Kremenchuk hromada to 98 per cent in the Velyka Pysarivka hromada. Notably, even in frontline hromadas these figures remain relatively high: 88 per cent in the Kherson hromada and 79 per cent in the Kramatorsk hromada.

It should be noted that in the Kramatorsk hromada, since the beginning of the full-scale invasion, information on the precise locations of protective shelters has been removed from public access. Residents can obtain information on shelter locations from local authorities and locate them using installed signage.

Table 3. Availability of shelters near PEC premises within a 500-metre radius

Indicator 10. Level of societal threats

Passed the audit: 11 / Failed the audit: 0

During the study period, no cases of threats or attacks against civic or political activists, public officials, or representatives of state and local self-government bodies were recorded, either officially or in the public domain, in any of the hromadas studied.

Indicator 11. Incidents related to mine hazards over the past three months resulting in civilian deaths or injuries

Passed the audit: 10 / Failed the audit: 1

Incidents involving civilian casualties caused by mines during the study period were recorded in only 2 of the hromadas studied — Kherson and Izium.

The most dangerous situation is observed in the Kherson hromada, where five mine-related incidents occurred over the past three months. In particular, on 22 September 2025, Vadym Khomenko, Chief Engineer of Suspilne Kherson, was killed after triggering a “Petal” (PFM-1) mine that had been deliberately dropped earlier by Russian forces from a drone.

In the Izium hromada, one such incident was recorded during the same period.

No incidents involving civilian mine explosions were recorded in the remaining hromadas covered by the study.

Block 3. Socio-Economic Situation

The security audits conducted indicate a gradual normalisation of the socio-economic situation in hromadas. Of the 11 hromadas assessed, 4 passed the audit under this block — Pervomaisk, Olevsk, Pivdenne, and Novomykolaivka. Even in areas located within the combat zone (within 20 km of the line of contact), and despite the difficult security situation, hromadas continue to function and provide the population with basic services, including education, healthcare, and administrative services.

Ensuring electricity supply and the functioning of schools remain critical for the operation of hromadas. The energy supply situation deteriorated significantly in October–November 2025 as a result of Russian attacks. Only 4 hromadas avoided prolonged blackouts (power outages lasting more than 12 consecutive hours). The situation is particularly critical in the Kherson hromada (whose territory is classified as critical infrastructure) and in the Velyka Pysarivka hromada, where seven settlements are permanently without electricity. As regards schools, in 5 hromadas (including Kherson and Kramatorsk) education is provided exclusively in a remote format. One of the key barriers to resuming in-person education is the lack of shelters in schools.

In 7 out of 11 hromadas, stable access to mobile communications and the internet is maintained, and emergency medical services arrive within established response-time standards. At the same time, in the Velyka Pysarivka hromada of Sumy Oblast, the average ambulance response time exceeds the standard by 29 minutes.

In all hromadas, branches of both state-owned and private postal operators are operating; however, in some regions their activities are restricted due to the security situation. All 11 hromadas have access to Ukrainian radio and television broadcasting.

In the majority of hromadas (7 out of 11), state-owned and private banks are operating, allowing residents to access all basic banking services. Of the 11 hromadas analysed, only one — the Olevsk hromada — does not face staffing shortages. In 10 out of 11 hromadas, local offices of the State Treasury Service are operational and perform their functions in full. In Kherson, the local Treasury office operates remotely, and payment arrears have been reported.

Only one hromada — Velyka Pysarivka — lacks public transport and suburban connections entirely. In rear-area hromadas such as Pivdenne and Kremenchuk, transport services operate at pre-war levels or even better than before the start of the full-scale invasion. In some hromadas, particularly frontline ones (Nikopol, Kramatorsk, and Kherson), the operation of urban and intercity transport is affected by constant Russian shelling and the dangers associated with travel along key roads.

Indicator 12. Functioning of retail outlets and availability of goods

Passed the audit: 11 / Failed the audit: 0

In 10 out of 11 hromadas, grocery shops operate on a stable basis, with no shortages of food products or essential goods. At the same time, in the settlements of the Velyka Pysarivka settlement hromada in Sumy Oblast, there are difficulties in accessing shops and limitations in the range of available goods due to the high vulnerability of supply chains and a shortage of retail infrastructure.

Indicator 13. Mobile network coverage

Passed the audit: 11 / Failed the audit: 0

In 7 out of 11 hromadas, mobile communications operate reliably and are provided by several operators. In the Velyka Pysarivka hromada, services from two operators (Vodafone and Kyivstar) are available in only one village (Tarasivka), while in 8 of the hromada’s 23 settlements only one operator is present. There is no mobile coverage in 14 settlements of the Snovsk hromada.

In the Izium hromada, mobile communications operate in the city of Izium and several large villages. On the main streets of most villages, at least one network is available, but stable coverage is often lacking in peripheral areas.

In the Nikopol urban hromada, mobile services from three operators are available; however, the quality of coverage is poor.

Indicator 14. Internet access

Passed the audit: 11 / Failed the audit: 0

In 7 out of 11 hromadas, stable access to wired internet or its alternative in the form of 4G is available.

Fifteen settlements in the Velyka Pysarivka hromada have access to optical fibre internet or 4G, covering the hromada centre (Velyka Pysarivka) and several villages.

Parts of the Snovsk hromada have internet access, and the city council has access to Starlink broadband internet.

In the city of Izium, a PON (Passive Optical Network) high-speed internet operator is available and continues to function during blackouts; however, internet access is not available across the entire hromada.

In the Pervomaisk hromada, internet coverage extends to approximately 75 per cent of the territory (Kyivstar, Ukrnet, HomeNet). Starlink equipment is available but has not been activated due to a lack of funds to cover service costs.

Indicator 15. Functioning of emergency medical services

Passed the audit: 11 / Failed the audit: 0

In all hromadas, the emergency hotline 103/112 is operational. In 7 out of 11 hromadas, emergency medical teams meet the established response-time standard of 20 minutes for emergency calls.

In the Velyka Pysarivka hromada, the average arrival time of an emergency medical team is 49 minutes, exceeding the established standard by 29 minutes. In addition, dispatch to certain settlements is prohibited due to security risks.

In the Pervomaisk hromada, the average response time of emergency medical services ranges from 20 to 30 minutes, depending on the season, epidemiological burden, and road conditions.

In the Kherson hromada, the average response time is 8 minutes and 57 seconds. However, the deployment of emergency (ambulance) teams is carried out with due regard to the current security situation.

It was not possible to establish ambulance response times in the Snovsk and Izium hromadas.

Indicator 16. Electricity supply

Passed the audit: 5 / Failed the audit: 6

As a result of Russian strikes on Ukraine’s energy system in October–November 2025, scheduled hourly power outages have been introduced nationwide. At the same time, prolonged blackouts (power outages lasting more than 12 consecutive hours) were recorded in certain hromadas.

Only 4 out of 11 hromadas experienced no blackouts during the past three months — Pivdenne, Olevsk, Pervomaisk, and Novomykolaivka.

Blackouts were recorded in the Snovsk, Izium, and Nikopol hromadas. In October 2025, the Kramatorsk hromada experienced two power outages lasting more than 12 hours.

On the night of 7–8 November, the Russian Federation carried out a combined strike on the Kremenchuk hromada, causing significant damage to energy infrastructure. A large part of the hromada experienced a blackout as a result.

In two hromadas — Kherson and Velyka Pysarivka — the electricity supply situation is critical. In the Kherson hromada, electricity supply is unstable, and the territory of the hromada is classified as critical infrastructure requiring priority electricity supply in accordance with established minimum load requirements (the hromada is located within the 20-kilometre zone along areas of active hostilities).

In the Velyka Pysarivka hromada, seven settlements are permanently without electricity (Popivka, Dmytrivka, Bratenytsia, Shevchenkove, Ponomarenky, Oleksandrivka, and Lukashivka villages).

Indicator 17. Proper functioning of secondary education institutions

Passed the audit: 7 / Failed the audit: 4

In all hromadas, secondary education institutions operate with varying degrees of instability. There are ongoing challenges related to the provision of shelters in schools, as not all institutions have their own civil protection facilities.

In 5 hromadas, schools operate exclusively in a remote format. For example, in the Kherson hromada, the educational process is conducted online in 45 schools. In the Kramatorsk hromada, 18 schools operate online, while one relocated secondary education institution operates in an in-person format. In the Izium hromada, five lyceums operate remotely, and one institution (Levkivska Gymnasium) is suspended. In the Nikopol hromada, all education is delivered online. Of 26 schools, 21 are equipped with basic shelters, and of 28 kindergartens, 18 have basic shelters.

In the Velyka Pysarivka hromada, two general secondary education institutions with three branches have suffered significant damage and destruction and operate only online due to the hromada’s location in an active combat zone. Although 60 per cent of facilities have shelters, only one is considered fully suitable, while two are assessed as partially suitable.

In the remaining 6 hromadas, schools combine in-person education with distance learning. For example, in the Snovsk hromada, three schools operate online and eight in a blended format. At the same time, eight schools in the hromada are equipped with shelters in accordance with State Emergency Service (SES) recommendations.

In the Kremenchuk hromada, 18 schools operate in a blended format, 12 in an in-person format, and one (an evening school) in a distance-learning format. Twenty-eight institutions are equipped with shelter facilities, while the remaining schools use shared shelters.

In the Pervomaisk hromada, two schools operate in a blended format and three online. Two institutions have shelters on site or nearby. As a result of Russian aggression, two educational institutions have been destroyed and five damaged.

In the Pivdenne hromada, five institutions operate in a standard (in-person) format and one in a blended format. All schools are equipped with shelters in line with SES recommendations: four institutions have their own shelters and two use nearby shelters.

In the Olevsk hromada, ten schools deliver education in a blended format and twenty-two operate fully in person. All educational institutions have shelters.

In the Novomykolaivka hromada, four schools operate in a blended format, while one has shifted to distance learning.

Indicator 18. Functioning of Administrative Service Centres (ASC) and Civil Registry Offices (DRACS)

Passed the audit: 11 / Failed the audit: 0

In all hromadas, administrative services are provided in person. However, the operation of Administrative Service Centres (ASC) and Civil Registry Offices (DRACS) is disrupted by air raid alerts, during which institutions suspend their activities. Only in the Nikopol hromada are administrative services provided on a continuous basis.

In the Velyka Pysarivka hromada, the ASC is operational but does not provide a number of services, such as registration of real estate, business registration, and passport services.

Indicator 19. Functioning of postal operator branches

Passed the audit: 11 / Failed the audit: 0

Postal operators operate in all 11 hromadas. However, in 9 hromadas (all except Kramatorsk and Olevsk), postal operators — including Ukrposhta and Nova Poshta — operate on an unstable schedule due to air raid alerts. In the Olevsk hromada, according to local residents, post offices do not suspend operations during air raid alerts. In the Kramatorsk hromada, despite the high number of alerts, postal operators also continue to operate without interruption.

Indicator 20. Access to Ukrainian television and radio

Passed the audit: 11 / Failed the audit: 0

All 11 hromadas have access to Ukrainian television channels (at a minimum, Suspilne) and radio stations (at a minimum, Ukrainian Radio). However, in the Velyka Pysarivka hromada, access to radio and television broadcasting is not ensured in at least 90 per cent of the hromada’s settlements, which is a prerequisite for achieving the maximum assessment score.

Indicator 21. Functioning of state and/or private banks and operation of ATMs

Passed the audit: 10 / Failed the audit: 1

In the Velyka Pysarivka hromada, state-owned and private banks do not operate, there are no ATMs, and residents do not have full access to financial services.

In the majority of hromadas (7 out of 11), state-owned and private banks operate normally, and all basic banking services are available, including account top-ups, payment of bills, in-person consultations with bank staff, access to online banking, sufficient cash availability in ATMs, and the absence of queues.

The operation of state-owned and private bank branches is significantly restricted in three hromadas: Nikopol, Pervomaisk, and Kherson. In Nikopol, this is due to frequent air raid alerts; queues at bank branches are also reported, and during one shelling incident a woman was injured while standing in a queue at a bank. In addition, unstable mobile communications in the hromada affect access to mobile banking services.

In the Pervomaisk hromada, there are no permanent bank branches. A mobile branch of Oschadbank operates periodically near the administrative building of the settlement council or the post office. The nearest permanent bank branches are located in the city of Mykolaiv, approximately 25 km from the Pervomaisk hromada.

The operation of bank branches in the Kherson hromada was suspended during the Russian occupation between March and October 2022. Immediately after de-occupation in November, PrivatBank and Oschadbank resumed operations. At present, banking services in Kherson are significantly restricted due to security challenges and air raid alerts. Branches of Kristalbank and Bizbank are temporarily closed.

Indicator 22. Functioning of healthcare facilities

Passed the audit: 11 / Failed the audit: 0

Of the 11 hromadas analysed, only one — the Olevsk hromada — received the highest possible assessment for the functioning of healthcare facilities: compared to the pre-war period, the number of facilities has not changed and there is no staffing shortage. In the remaining 10 hromadas, healthcare services are available but subject to varying degrees of limitation, and staffing levels remain below 90 per cent.

In the Pervomaisk hromada, following the start of the full-scale war, health posts in the villages of Kvitneve, Blahodatne, Zasillia, and Novoselivka ceased operations due to damage. However, family doctors continue to operate in Pervomaisk, Bilozirka, and Novomykolaivka, and health posts remain operational in the villages of Kyselivka and Partyzanske. Staffing levels in healthcare facilities stand at 75 per cent.

In the Kremenchuk hromada, four healthcare facilities were reorganised between 2022 and October 2025, and physician staffing levels are at 76 per cent. In the Velyka Pysarivka hromada, one outpatient clinic was destroyed and two damaged; six health posts and an administrative building were destroyed. Nevertheless, healthcare services are provided by reorganised healthcare institutions. The hromada also faces a staffing shortage: physician staffing is at 60 per cent, while mid-level medical staff staffing stands at 70 per cent.

In the Izium hromada, the number of healthcare facilities has halved: of four facilities previously operating, only two remain functional. One facility ceased operations, while another was relocated to a different hromada.

A significant reduction in healthcare facilities has also been recorded in the frontline city of Kramatorsk. Of the seven healthcare institutions that operated in the city prior to the full-scale invasion, only two currently remain operational: the Municipal Non-Profit Enterprise Primary Healthcare Centre No. 1 (providing primary healthcare services through a network of outpatient clinics) and the Municipal Non-Profit Enterprise City Hospital No. 2, which now concentrates all specialised medical services. A major challenge for Kramatorsk is staffing: physicians account for only 40 per cent of the required staffing level, and mid-level medical personnel for 56 per cent.

Similar challenges are observed in the Kherson hromada. Prior to the full-scale invasion, 32 healthcare facilities operated in the hromada; as of October 2025, 30 of them (94 per cent) had sustained various types of damage as a result of Russian shelling. In addition, reorganisation has been completed in four healthcare facilities, while six others are undergoing optimisation and reorganisation, primarily involving legal consolidation. The number of healthcare workers has also decreased significantly: approximately 37 per cent of the medical workforce compared to early 2022 remains in the city. However, due to institutional reorganisation, the overall staffing level is estimated at around 80 per cent, according to the Department of Health of the Kherson Regional State Administration. There is a shortage of specialised medical professionals, particularly in surgical specialties.

In the Novomykolaivka hromada, the number of healthcare facilities has not decreased since the start of the full-scale invasion; facilities have not been reorganised and were not damaged by Russian shelling. However, there is a shortage of medical personnel, particularly specialised professionals, while staffing levels in general medical services stand at 88 per cent. A similar situation exists in the Nikopol hromada, where the number of healthcare facilities has remained unchanged: the city has 13 outpatient clinics, but staffing levels remain insufficient. At the same time, in 2025 repairs were carried out and new equipment was procured for City Hospital No. 4.

In the Snovsk and Pivdenne hromadas, the number of healthcare facilities has not changed compared to the pre-war period; however, staffing shortages persist. In the Snovsk hromada, physician staffing stands at 71 per cent, while mid-level medical staff staffing reaches 100 per cent. In the Pivdenne hromada, overall staffing levels across healthcare facilities amount to 87 per cent, with several vacant positions remaining in both healthcare institutions.

Indicator 23. Uninterrupted functioning of the State Treasury Service

Passed the audit: 10 / Failed the audit: 1

In 10 out of 11 hromadas, local offices of the State Treasury Service of Ukraine are operational and fully perform their functions. As of 1 October 2025, no arrears were recorded in the payment of salaries or other protected budget expenditures in these hromadas.

Due to threats to the life and health of staff, the State Treasury Office of the Kherson hromada is currently not operating at its legal address in the city of Kherson; its work is carried out remotely and from other regions. As of 1 October 2025, wage arrears existed for budget-funded institutions financed from the budget of the Kherson City Territorial Hromada. This concerns the Out-of-Town Health and Recreation Facility “I. Holubets Health Camp”, located in the temporarily occupied city of Skadovsk.

Indicator 24. Functioning of Pension Fund offices

Passed the audit: 11 / Failed the audit: 0

In 9 out of 11 hromadas, Pension Fund offices operate at pre-war levels. In the Velyka Pysarivka hromada, the Pension Fund office does not operate; residents apply to service centres in other cities (Okhtyrka and Trostianets) or use online services. In the Kherson hromada, a Pension Fund service centre is operational, but its work is restricted due to frequent air raid alerts and security threats.

Indicator 25. Functioning of public transport

Passed the audit: 10 / Failed the audit: 1

Only one hromada — Velyka Pysarivka — has no public transport or suburban connections at all. However, public transport did not operate in the hromada even prior to the full-scale invasion, and suburban services previously provided by two carriers have now been suspended.

The highest assessment for public transport performance under the defined criteria was awarded to 5 out of 11 hromadas. Nevertheless, each of them has specific characteristics, primarily shaped by security challenges. In the Pivdenne and Kremenchuk hromadas, the number of public transport routes increased during the full-scale invasion (from 1 to 4 routes in Pivdenne, and from 37 to 40 routes in Kremenchuk, although 4 of these are currently not operational).

A particularly specific situation exists in the frontline Kramatorsk and Nikopol hromadas. Both hromadas are subject to daily shelling; however, during the audit period, public transport continued to operate at full capacity. In Nikopol, the number of urban routes has not changed compared to the pre-war period. In Kramatorsk, 20 urban routes operate, consolidated due to overlaps between certain routes. During the audit period, public transport operations in the Kramatorsk hromada were assessed at the highest level, as Kramatorsk effectively functions as a major logistics hub for Donetsk Oblast. At the time of the audit, train services from the Kramatorsk hromada operated actively to various regions of the country.

However, after the audit was completed, on 5 November it was announced that trains and suburban rail services would temporarily cease operations to Donetsk Oblast, including Sloviansk and Kramatorsk, due to security risks. The Donetsk Regional Military Administration organised shuttle buses between Kramatorsk and Sloviansk and a temporary terminal station. In addition, due to active hostilities, bus services on the Kramatorsk–Dnipro route via Pokrovsk and Dobropillia have been suspended. The Sloviansk–Kharkiv road, which passes through the city of Izium, is also considered particularly dangerous due to the threat posed by drones. In practice, the only relatively safe road routes to Kramatorsk are the regional roads Kramatorsk–Barvinkove–Lozova and Kramatorsk–Oleksandrivka.

Urban and suburban transport services are also limited in the Pervomaisk, Snovsk, Izium, Kherson, and Novomykolaivka hromadas. In the Pervomaisk hromada, intercity transport on certain sections is unsafe due to mine hazards, while urban bus services did not operate even prior to the full-scale invasion. In the Novomykolaivka hromada, transport connections are restricted due to security challenges, although intercity routes remain available. In the Snovsk hromada, suburban routes do not operate due to the absence of approved carriers; however, on-demand taxi services are available. From November 2024 to August 2025, the humanitarian mission Proliska operated in the hromada, providing passenger transport to neighbouring hromadas.

In the Izium hromada, nine temporary bus routes are currently in operation — eight fewer than at the beginning of 2022.

In the Kherson hromada, public transport continues to operate, but the number of routes has been reduced due to both constant shelling and a significant decline in the city’s population. Russian forces regularly shell transport infrastructure in Kherson, resulting in the destruction and damage of trolleybuses and buses.

Block 4. Democratic Processes

Only two hromadas passed the audit under the “Democratic Processes” block — Kremenchuk and Pivdenne. These hromadas demonstrate a sufficient level of capacity and resilience to restore democratic processes.

For the majority of hromadas, the key barriers identified were:

• Bans on peaceful assemblies — in 5 hromadas: Novomykolaivka, Kherson, Velyka Pysarivka, Kramatorsk, and Nikopol;
   
• Inoperability of a large share of electoral infrastructure — in 4 hromadas: Nikopol, Izium, Velyka Pysarivka, and Pervomaisk. In the Kherson hromada, information on the condition of polling stations is unavailable;
   
• Limited capacity to recruit Precinct Election Commission (PEC) members due to significant population decline and the prevalence of distance learning — in 5 hromadas: Kherson, Izium, Velyka Pysarivka, Kramatorsk, and Nikopol;
   
• Low levels of political engagement — in 7 hromadas: Velyka Pysarivka, Kramatorsk, Nikopol, Izium, Novomykolaivka, Olevsk, and Snovsk.

The state of democratic processes is largely determined by the geography of the war: frontline and de-occupied hromadas demonstrate the weakest performance.

At the same time, even under these challenging conditions, all hromadas have retained governance capacity. Local self-government bodies or military administrations continue to ensure continuity of governance. The media landscape remains functional, and the civic sector continues to operate, adapting its activities to current needs — ranging from humanitarian response in frontline hromadas to a broader scope of activities in relatively safer areas.

Indicator 26. Availability and condition of electoral infrastructure

Passed the audit: 6 / Failed the audit: 5

An assessment of the suitability of Precinct Election Commission (PEC) premises in the 11 hromadas reveals significant disparities in their condition. In four hromadas — Kremenchuk, Pivdenne, Olevsk, and Novomykolaivka — all PEC premises are suitable for use, and previously damaged facilities have been fully restored. In the Snovsk hromada, 88 per cent of premises remain suitable, while 12 per cent require replacement or repair.

The most challenging situation is observed in hromadas located in active combat zones or those that were de-occupied. In the Kramatorsk hromada, 75 per cent of PEC premises are suitable, while one quarter require restoration. In four hromadas, the share of suitable premises is critically low — ranging from 25 to 43 per cent. These are the Nikopol (43 per cent), Izium (40 per cent), Velyka Pysarivka (30 per cent), and Pervomaisk (25 per cent) hromadas. Moreover, these hromadas lack alternative premises to replace unfit polling stations.

In certain cases — in particular in the Velyka Pysarivka, Kramatorsk, and Nikopol hromadas — it is not even possible to determine prospects for replacing or restoring damaged facilities. The Nikopol hromada is carrying out partial repairs (installing OSB boards on windows and using banners and tarpaulins for roofs), but full restoration or technical assessment of destroyed premises will only be possible after the end of the war. For the Kherson city hromada, information is unavailable due to security restrictions, which makes it impossible to assess the condition of electoral infrastructure.

The current situation demonstrates significant risks for the organisation of elections and underscores the need for flexible solutions that take security conditions into account.

Table 4. Condition of polling stations in hromadas

Indicator 27. Ability to hold peaceful assemblies

Passed the audit: 6 / Failed the audit: 5

The holding of peaceful assemblies is an important element of the exercise of citizens’ constitutional rights and a necessary precondition for the functioning of democratic institutions. The unobstructed exercise of this right is also an additional indicator of improvements in the security situation within a hromada. Under the legal regime of martial law, mass events are subject to general restrictions, which directly affect the possibility of holding them. For this reason, 6 of the hromadas studied received 0.5 points for this indicator, while 5 hromadas received 0 points.

At the same time, the existence of martial law does not automatically imply a complete ban on peaceful assemblies. The nature of restrictions also depends on decisions taken by regional military authorities, which establish procedures for holding (or restricting) public events in light of current security risks. The practice of such decisions varies significantly between regions, primarily due to differing threat levels, proximity to the frontline, intensity of shelling, and related factors.

In addition, restrictions may also be introduced at the level of individual hromadas or districts by decision of military administrations, where the local security situation requires additional restrictive measures. The strictest restrictions were recorded in the Novomykolaivka, Kherson, Velyka Pysarivka, Kramatorsk, and Nikopol hromadas. In these cases, a complete ban on mass events is linked to proximity to active combat zones or regular shelling. The situation remains particularly critical in the Kherson and Nikopol hromadas, where drone attacks and artillery shelling mean that any mass gathering poses a significant risk to human life.

More moderate restrictions are characteristic of the Snovsk, Izium, Kremenchuk, Pivdenne, Pervomaisk, and Olevsk hromadas. In these hromadas, mass events are possible subject to prior written approval from military administrations and, in some cases, with the involvement of special coordination commissions. The restrictions are primarily procedural in nature: deadlines for advance notification are set (from 3 to 7 days), responsible authorities are designated, and specific security parameters are defined. For example, in the Kremenchuk urban hromada, over the past six months civic organisations have applied to local authorities eight times for permission to hold public events.

An analysis of the situation in the 11 hromadas studied shows that the ability to hold peaceful assemblies during martial law depends substantially on the security context, decisions of military administrations, and local practices for approving mass events. At present, no hromada has the capacity to hold public events in a pre-war format, and the level of restrictions ranges from a complete ban to permission subject to additional approvals.

Indicator 28. Proper functioning of the State Register of Voters

Passed the audit: 10 / Failed the audit: 1

Following the start of the full-scale invasion, and in order to protect voters’ personal data, the Central Election Commission (CEC) suspended the operation of the automated information and communication system State Register of Voters. In 2023–2024, after strengthening the Commission’s information infrastructure, the operation of the Register was restored, but only with regard to the periodic updating (regular renewal) of the Register’s database and the accounting of permanent polling stations. Full restoration of the functioning of the automated information and communication system of the Register — including public electronic services and public access enabling voter interaction with the Register — had not been completed at the time the audits were conducted. As a result, all hromadas received 0.5 points for this indicator, except for the Kherson urban hromada, which received 0 points.

The assessment of the Register’s operation is also influenced by the institutional capacity of the voter register maintenance units serving the 11 hromadas studied, particularly their staffing and material–technical capacity. The most severe situation was recorded in the Kherson urban hromada, where all three units serving the hromada are not functioning due to active hostilities.

A further six units are experiencing staff shortages. These are the units responsible for updating data for the Kramatorsk, Nikopol, and Kremenchuk urban hromadas, as well as the Pervomaisk, Velyka Pysarivka, and Novomykolaivka settlement hromadas. The most acute shortage is in the voter register unit of the Kramatorsk City Council, where only 34% of staff positions are filled (2 employees out of the required 6).

All units are provided with premises for their work; however, the premises of the voter register units of the Kramatorsk and Izium city councils do not comply with the requirements established by the Commission (CEC Resolution No. 572 of 20 December 2007). In Kramatorsk, the unit is not equipped with a door featuring a coded lock. In Izium, the problems are significantly more extensive, likely linked to the occupation of the hromada in 2022. In particular, the following deficiencies were identified:

• absence of a metal cabinet for storing documents, hardware and software identification tools, key information carriers, and cryptographic information protection tools;
• absence of an automatic fire alarm system;
• absence of a security alarm system;
• absence of metal bars or protective shutters on windows;
• absence of a door with a coded lock;
• active network equipment and cryptographic information protection tools are not placed in a separate communications cabinet.

Indicator 29. Updating data in the State Register of Voters

Passed the audit: 10 / Failed the audit: 1

The periodic updating of voters’ personal data is carried out in accordance with the procedure defined in Article 22 of the Law of Ukraine On the State Register of Voters. Designated state bodies and local institutions are required to submit information on changes to voters’ personal data to the relevant voter register units on a monthly basis by the 5th day of each month.

The study showed that the periodic updating of the Register’s database is conducted in compliance with legal requirements in all hromadas except two — Kramatorsk and Kherson. According to the CEC, in the Kherson hromada no periodic updating of personal data takes place, as the voter register units are not functioning.

In the Kramatorsk hromada, periodic updating is carried out only partially: the Kramatorsk City Court and the Department of Labour and Social Protection of the Population of the Kramatorsk City Council do not submit information required to make the relevant changes to the database of the automated information and communication system State Register of Voters.

Indicator 30. Activities of political parties

Passed the audit: 4 / Failed the audit: 7

olitical activity is one of the key markers of the state of democratic life in hromadas. An active political environment — from holding public events to the functioning of party offices and local branches — indicates the presence of political competition and the preconditions for restoring electoral processes.

Within the audit, we assessed whether political parties engage in public activity in the hromada: whether they hold events, work with voters, involve affiliated organisations and initiatives; whether local party representations function (offices, reception rooms, branches, local leaders); and whether they carry out statutory activities, including information campaigns, volunteer work, or other activities that require resources and a physical presence in the hromada.

Political activity in the hromadas studied remains predominantly low, largely due to martial law, restrictions on mass events, and the overall security context. In most hromadas, parties do not conduct systematic public activities, do not organise events, and do not demonstrate active work of their local branches. Political activity is limited to isolated initiatives by individual councillors or civil society organisations affiliated with political parties.

The lowest level of political life is characteristic of hromadas located in the combat zone — Velyka Pysarivka, Kramatorsk, Nikopol, Izium, and Novomykolaivka. In these hromadas, mass events are prohibited, there are no requests from parties to public authorities to hold events, and party branches either do not function or are focused exclusively on humanitarian and volunteer activities.

At the same time, in the Kherson hromada, political activity is largely limited to information and awareness-raising work on mine safety issues, state programmes, and informing the public about the activities of political leaders.

No political activity has been recorded in hromadas with a comparatively better security situation either — Snovsk and Olevsk. In Kremenchuk, Pivdenne, and Pervomaisk, political life also remains minimal. Although individual councillors or party representatives implement social and volunteer initiatives, public political activity takes place irregularly and on a limited scale.

Indicator 31. Functioning of local authorities

Passed the audit: 10 / Failed the audit: 1

An analysis of the 11 surveyed hromadas shows that, despite the prolonged application of martial law, proximity to the front line, and significant security challenges, none of the hromadas has lost its governance capacity. In most hromadas, managerial powers continue to be exercised by local self-government bodies elected in 2020. At the same time, in de-occupied and frontline hromadas — Kherson, Izium, Pervomaisk, Velyka Pysarivka, and Kramatorsk — some or all local self-government functions have been assumed by military administrations. Despite the temporary nature of these structures, their introduction ensures continuity of governance under complex security conditions.

All hromadas adopted their 2025 budgets within the required timeframe before the start of the new calendar year, which is an important marker of institutional resilience. Budgets were approved both by decisions of councils and by orders of military administrations.

At the same time, the staffing situation within hromada authorities is uneven. The highest level of staffing (87–100%) is observed in the Pivdenne, Kremenchuk, Pervomaisk, Olevsk, and Snovsk hromadas, allowing them to fully perform administrative functions. A moderate staff shortage (80–89%) is characteristic of the Novomykolaivka, Izium, and Nikopol hromadas. In contrast, the Kherson, Velyka Pysarivka, and Kramatorsk hromadas operate under conditions of a significant staff shortage (60–65%), which likely complicates operational processes and increases the workload on employees.

Indicator 32. Functioning of local media

Passed the audit: 11 / Failed the audit: 0

Despite martial law, security threats, and restrictions on journalists, most local media outlets in the surveyed hromadas have retained their functionality. Some editorial teams reduced the frequency of print publications, optimised staffing, or partially relocated; however, overall, the media landscape has adapted to wartime conditions and continues to provide uninterrupted coverage of events.

The role of online media, Telegram channels, bloggers, and citizen journalism has increased, as they actively disseminate local news and enhance residents’ access to information. In hromadas where few or no local media operated even before the war, this access is compensated for by regional media and official government resources.

The study showed that the most difficult media situation has developed in the Izium and Velyka Pysarivka hromadas: only one editorial office operates in each, in a relocated or hybrid format. In Izium, local radio was destroyed, while in Velyka Pysarivka the newspaper Vorskla continues to be published under extremely difficult conditions in an active combat zone.

It is also important to note that journalists’ work is associated with constant risks and is often complicated by the destruction of media infrastructure. The situation in the Kherson hromada is particularly illustrative: journalists work under the threat of shelling and mine danger, and some media workers have already been injured.

Nevertheless, information resilience in the hromadas remains high. Media outlets continue to fulfil their role and support democratic processes even under wartime conditions.

Indicator 33. Capacity to recruit Precinct Election Commission (PEC) members

Passed the audit: 6 / Failed the audit: 5

This indicator is an important marker of the socio-demographic condition of hromadas and makes it possible to assess their capacity to ensure the formation of Precinct Election Commissions. The assessment of the potential to recruit PEC members is based on indirect but indicative parameters. These include the format of education in educational institutions, staffing levels in educational, cultural, and communal institutions, as well as population dynamics compared with pre-war figures. A combined analysis of these factors makes it possible to determine whether a hromada has sufficient human resources to organise the electoral process.

Hromadas with sufficient capacity. This group includes the Novomykolaivka, Snovsk, Kremenchuk, Pivdenne, and Olevsk hromadas. In these hromadas, education takes place offline or in a blended format, and most cultural and communal institutions have retained between 80% and 100% of their pre-war staff. For example, the Kremenchuk and Pivdenne hromadas demonstrate high staffing levels (90–99% of specialists across various sectors). The Novomykolaivka and Snovsk hromadas retain 88–94% of their pre-war population, while in the Olevsk hromada the population has even increased slightly — by 1.7%.

The Pervomaisk hromada stands out somewhat within this group. Despite a sharp population decline (to 44%), the preservation of more than 60% of staff in key sectors and the presence of blended learning allow the hromada to receive a medium score.

Hromadas with low capacity. This group includes the Kherson, Izium, Velyka Pysarivka, Kramatorsk, and Nikopol hromadas. A common factor for these hromadas is that schooling takes place exclusively online. This automatically reduces the potential to recruit PEC members, as it reflects persistently high security risks. The most critical situation is observed in the Kherson hromada, where less than 25% of the pre-war population remains, the majority being elderly people. In the Izium and Kramatorsk hromadas, less than 70% of the pre-war population remains, and education is possible only online.

The Velyka Pysarivka hromada retains 31% of its 2022 population and has critically low staffing levels in the cultural sector (less than 45%). In the Nikopol hromada, approximately 52% of the population remains, and the educational process takes place entirely online.

The potential to recruit members of Precinct Election Commissions is medium or high in hromadas where a sufficient population remains, education is conducted offline or in a blended format, and educational, cultural, and communal institutions are adequately staffed. In contrast, hromadas with fully online education, significant demographic losses, and reduced human resources demonstrate a critically low capacity to form PECs, which may become a major challenge for the organisation of post-war elections.

Indicator 34. Functioning of local general courts in the hromada

Passed the audit: 9 / Failed the audit: 2

The analysis of the state of justice in the hromadas reveals significant unevenness in the capacity of the judicial system to ensure citizens’ access to judicial protection. The functioning of courts is influenced by three main factors: changes in territorial jurisdiction, staffing levels, and external circumstances related to the security situation and the condition of infrastructure.

Changes in territorial jurisdiction have become one of the key barriers to access to justice. In three hromadas — Izium, Velyka Pysarivka, and Kramatorsk — local courts have lost the ability to administer justice within their own territory, and their cases have been transferred to other courts. For residents, this means considerably more complex logistics, increased time costs, and reduced timeliness of case consideration. The situation is particularly difficult in the case of Kramatorsk, whose cases were transferred to the Dnipropetrovsk District Court. This court operates under critical overload: it serves the jurisdiction of four courts of Donetsk Oblast simultaneously, with only 11 judges instead of the 37 required under judicial workload standards.

Staffing levels also vary across hromadas. Courts in the Pivdenne, Pervomaisk, and Novomykolaivka hromadas have sufficient staffing, allowing them to comply with procedural time limits. In the Snovsk and Kremenchuk hromadas, staffing levels range between 80% and 90%, which generally enables stable operation.

At the same time, in a number of courts staffing shortages have reached critical levels. In the Olevsk hromada, staffing stands at only 40%, leading to delays in case consideration. The Nikopol City and District Court, which operates under conditions of regular shelling, has 6 judges instead of the required 16 and seven vacant positions in the court administration; its workload is among the highest of all the hromadas studied.

Infrastructure damage has been recorded in courts in three hromadas. The building of the Vitovskyi Court, which serves the Pervomaisk hromada, has sustained Category II damage, while the Nikopol court was affected by a shell impact near the court premises. In addition, windows were shattered in the Novomykolaivka District Court as a result of shelling in 2025. Despite this, courts continue to administer justice and take measures to ensure the safety of trial participants.

Air raid alerts are a factor that systematically disrupts court hearings. Ten of the twelve courts are forced to interrupt hearings during “air raid” signals, while two decide on adjournments by agreement of the parties. Some institutions use basement premises as shelters, while others follow the “two walls” rule. This slows down proceedings but demonstrates the system’s adaptability to wartime conditions.

Despite all limitations, no hromada has been left without access to judicial protection. All courts, regardless of the scale of damage or staffing losses, continue to function and seek to comply with statutory deadlines. The state of justice across hromadas is fragmented, yet the system as a whole remains functional.

Indicator 35. Activities of civil society organisations and initiatives

Passed the audit: 7 / Failed the audit: 4

The civil society sector in most of the hromadas studied is actively operating and remains an important element in supporting democratic processes. Civil society organisations primarily focus on war-related issues, while in the most affected and frontline hromadas they are almost exclusively concentrated on providing humanitarian and legal assistance to residents.

In the Kherson, Izium, Velyka Pysarivka, Kramatorsk, Nikopol, and Novomykolaivka hromadas, an active role in public life is assumed by humanitarian organisations, volunteer initiatives, and international partners. In these hromadas, mass events are often impossible due to imposed restrictions or the level of security risk; as a result, the public activity of civil society organisations is minimal and largely limited to crisis response.

By contrast, in safer hromadas (Kremenchuk, Pivdenne, and Snovsk), the scope of civil society activity is much broader and includes cultural and youth events, gender initiatives, sports programmes, educational projects, inclusion development, and support for entrepreneurship. Such organisations help sustain vibrant civic life even during wartime.

In hromadas where the civil society sector is less developed (for example, Pervomaisk), the main resources for sustaining civic activity remain partnerships with international organisations and local initiatives aimed at restoring public spaces and strengthening social cohesion.