The State Voter Register is often perceived as a purely technical database necessary for organising elections. In reality, however, it is an institutional reflection of the demographic state of society, its mobility, and the state’s ability to interact with its citizens. Any changes in the structure of the population — internal and external migration, the consequences of war, socio-economic transformations — are reflected in the Register in one way or another.

This is precisely why the question of its relevance today goes beyond technical administration. It is not just about the accuracy of the data, but also about creating a model capable of ensuring the exercise of citizens’ electoral rights regardless of their status and place of residence. In this context, the quality of the electoral process depends on events long before polling day.

Elections begin with the Register

The State Voter Register is a fundamental element in ensuring citizens’ electoral rights. It is precisely through the Register that a voter’s polling station is determined. Essentially, it is an automated system that continuously stores and processes data on Ukrainian voters.

The accuracy of voter data is of particular importance today, especially in the context of political discussions regarding a possible referendum on a peace agreement with the aggressor state. For the results to be legitimate, at least half of the voters included in the State Voter Register must take part in the referendum — and so the accuracy of the Register itself could have a decisive impact.

Equally important is the role of the Register in organising post-war elections. This involves not only ensuring the electoral rights of millions of citizens, but also planning the electoral infrastructure, determining the number of polling stations and producing voting ballots. All this has a financial dimension too — according to the Central Election Commission’s estimates, holding a two-round nationwide presidential election could cost up to 7 billion UAH. Given limited resources, such expenditure requires particular justification.

Hasty preparations for electoral processes can lead not only to the inefficient use of funds, but also to a decline in confidence in the results of elections or a referendum.

The State Voter Register in its current form was officially established in 2007 with the adoption of the relevant Law of Ukraine. The Register was fully launched in 2009. Prior to the introduction of a single database, voter registration was fragmented and took place only during election campaigns — voter lists were compiled by working groups within district and city administrations.

Consequently, according to the OSCE/ODIHR (Office for Democratic Institutions and Human Rights) report on the observation of the 2004 presidential election, the electoral registers contained systematic errors — they included the names of deceased persons, entries were often duplicated, and changes of address were not taken into account. In many districts, these inaccuracies were widespread. This is precisely why the creation of the Voter Register was an important institutional step in reforming the electoral process in Ukraine.

At the same time, it is important to understand: The Register does not generate new information about voters. It records citizens who are eligible to vote in accordance with the Constitution of Ukraine and updates their details based on data received from other state bodies.

In particular, the Register receives data on citizens reaching the age of 18, death, change of residence, registration with a consulate abroad, or the establishment of a fact of inability to move independently. The key element remains the address of registration or declared place of residence, as this is what determines the polling station.

Although a voter may change their electoral address and vote at a different polling station, this requires them to take the initiative themselves. By default, the system links the voter to their place of registration.

The Register’s operating model is logical and institutionally consistent. At the same time, the question is whether it corresponds to the reality of a country experiencing mass internal and external migration.

Why updating the State Register of Voters has become necessary

Issues with the accuracy of the electoral roll were not new. For example, during the 2019 presidential election, OPORA observers noted that some voters who had reached the age of 18 were not included in the lists, that the names of deceased persons appeared on the lists, inaccuracies in personal data (particularly following a change of surname), and a failure to update data on citizens who had changed their place of registration.

These issues were primarily caused by the improper transfer of information from the relevant public administration bodies to the Register, as well as, to some extent, by shortcomings in the work of the bodies responsible for maintaining the SRV at the local level, particularly in the areas of communication and interagency cooperation.

The outbreak of the war in 2014 created fundamentally new challenges for the Register, which were significantly exacerbated following the full-scale invasion. The war has substantially altered the demographic situation and the geographical distribution of millions of citizens.

Several groups of voters can be identified as having the greatest impact on the relevance of electoral data:

  • officially registered internally displaced persons — approximately 4.6 million, of whom an estimated 3.8 million are voters;
  • citizens who have moved without a formal change of status (due to the destruction of their homes, the security situation, economic reasons, etc.);
  • citizens who have left the country — according to various estimates, between 5 and 9 million;
  • citizens who have remained in or moved to the temporarily occupied territories;
  • citizens who have gone missing under special circumstances — over 90,000;
  • citizens involved in the defence of the state — up to 1 million.

It is important to understand that the state aims to ensure the most comprehensive coverage of voters in the Register — currently, it contains a total of around 34 million people. The Register holds data on voters in the territories occupied since 2014. In particular, it includes around 1.5 million voters in Crimea, over 650,000 — in Donetsk and around 340,000 — in Luhansk. Sometimes abnormal situations arise: for example, over 42,000 voters in the temporarily occupied territories are over 100 years old, and more than 1,000 are over 115 years old.

Why does this data remain in the Register? The reason lies in the fundamental principle of universal suffrage. The Register covers all citizens of Ukraine who have the right to vote, regardless of their place of residence or stay.

The Central Election Commission consistently opposes the selective exclusion of individuals from the Register, as this could set a dangerous precedent for future interference in the system. In essence, it is a question of balancing data accuracy with the safeguarding of electoral rights. This is precisely why voters in the temporarily occupied territories remain in the Register until their status changes within Ukrainian jurisdiction — for example, through registration of residence, civil status documents or a change of electoral address.

It is also worth noting that following the start of the full-scale invasion, the Register temporarily ceased operations. However, according to the Central Election Commission, the system had been prepared in advance for such scenarios, which prevented any leakage of voters’ personal data.

The restoration of the Register’s operations took place in stages. By the end of 2023, periodic database updates had resumed, with information from data-providing bodies having been accumulated during the downtime and subsequently entered by the Registry’s administrative departments.

The State Register of Voters resumed full operation on 1 January 2026 — from that point onwards, voters were once again able to interact with the Register’s administrative bodies, submit applications, update their details and change their electoral address.

Despite this, the system’s institutional capacity remains uneven. Some of the departments responsible for maintaining the Register have been relocated, whilst others are still not operational. In particular, in the Kherson region, not a single department responsible for maintaining the State Register of Voters is operational, although other bodies responsible for providing data for it are functioning. The process of launching these departments in the Kherson region is still ongoing and depends largely on the initiative of local authorities.

What do Ukraine’s international partners say about the State Register of Voters?

The issue of updating the State Register of Voters is increasingly becoming a focus of attention for Ukraine’s international partners, who regard its audit and updating as one of the key priorities of electoral reform.

Such attention also has a very practical dimension in terms of European integration. The Roadmap on the Functioning of Democratic Institutions stipulates that, by the fourth quarter of 2026, the State Register of Voters and its electronic services must be operational, taking into account security factors and cyber security requirements.

However, the priorities of international partners differ somewhat. While the OSCE/ODIHR recommendations largely concerned the removal of barriers to the exercise of the right to vote and the improvement of procedures, recent documents from the European Commission have explicitly raised the issue of auditing and updating the State Register of Voters.

The OSCE/ODIHR recommendations following the 2015–2020 elections consistently emphasised that the residence registration system should not restrict citizens’ access to voting. In particular, these recommendations addressed the need to simplify procedures for temporarily changing one’s polling station and electoral address, to extend the deadlines for submitting relevant applications, to give voters more time to update their details, to better inform citizens about the possibility of verifying their information in the Register, and to respond appropriately to potential abuses of the registration procedures.

The Venice Commission, for its part, drew attention to procedural safeguards: any changes to voter data must be accompanied by proper notification and the possibility of appeal, and the transparency of the Register must be balanced with the protection of personal data.

The European Commission’s approach has become more substantive over time. Whilst the 2023–2024 reports focused primarily on implementing OSCE/ODIHR recommendations and preparing amendments to update the Register, the 2025 report explicitly identified the audit and update of the State Register of Voters as one of the most urgent tasks in preparation for the first post-war elections.

However, the very raising of the question of auditing the Register inevitably leads to the next, far more complex set of issues: what exactly, in wartime conditions, should be considered an audit of the State Register of Voters, what data can be verified or clarified, and what tools are available to do so at all?

At the same time, an audit of the State Register of Voters cannot be reduced to a mechanical “cleansing” of the database. In practice, it may encompass several interrelated levels: data quality checks, cross-register verification of information, analysis of update procedures, and, where necessary, a technical assessment of the system’s functioning. In addition, selective external or public audits and public verification of voter lists compiled on the basis of the State Register of Voters may be carried out.

In the Ukrainian context, an audit should rather entail a comprehensive check of the quality of the Register, the sources of its filling, the validity of electoral addresses, and the system’s ability to correctly compile voter lists for future elections. At the same time, the key task is not to remove voters from the Register, but to identify inaccuracies, outdated records, anomalies and data requiring clarification without violating electoral rights.

That is why, in order to conduct an audit of the State Register of Voters, Ukraine must first answer at least a few fundamental questions:

  • what exactly will be the subject of the audit — the entire State Register of Voters database or specific categories of data;
  • which state registers and bodies may be involved in verifying the information;
  • whether it is possible to automatically update certain data and where additional safeguards should be put in place;
  • how to avoid incorrect exclusion from the Register or restrictions on voting rights;
  • what mechanisms will exist for voters themselves to correct their data;
  • how to address the situation regarding IDPs, citizens abroad, voters from the temporarily occupied territories and military personnel;
  • who exactly will conduct the audit and what level of public and independent oversight will be involved;
  • as well as how much time, resources and legislative changes this will require.

Therefore, the issue today is no longer simply whether the State Register of Voters needs updating, but what the model for its audit should be, so as to simultaneously improve the quality of the Register, maintain trust in it and avoid creating new risks to electoral rights.

OPORA will provide information in subsequent articles on the approaches to auditing voter registers applied in different countries, as well as the steps already being taken in Ukraine to update the State Register of Voters in the context of preparing for the post-war electoral process.

 The project is being implemented by the Civil Network OPORA

with financial support from the German Federal Foreign Office.