Collusive Defense over 400 Million UAH: Luhansk Regional Military Administration and State Housing Agency Jointly Lock Beneficiary Records for 20 Working Days

On the final submission date for subsidized housing loan applications, both state fund managers issued matching administrative delays to block transparency requests from rights monitors.

On October 9, 2026 — the deadline for submitting applications under the revised 350-million-UAH regional housing credit scheme, extended by Luhansk Regional Military Administration (OVA) Head Oleksiy Kharchenko — both public fund managers simultaneously withheld key financial expenditure records.

The Luhansk Regional State Administration's Department of Information Policy and the board of the State Specialized Financial Institution "State Fund for Support of Youth Housing Construction" (Derzhmolodzhytlo) issued concurrent statutory notifications extending their deadline to process public records requests filed by the Association « DE L'AUTRE CÔTÉ DU DIALOGUE » to 20 working days.

The inquiries demanded the release of the complete beneficiary roster for 401.7 million UAH in mortgage obligations written off through the non-public "Registry № 2" using budget balances taken from the destroyed municipality of Lysychansk, as well as official session minutes from the 2026 "Transparency and Accountability" regional monitoring group.

Institutional Coordination: Kyiv and Dnipro Align Strategies

An analysis of the official correspondence demonstrates coordinated procedures between two nominally separate public agencies:

• Luhansk Regional Military Administration: letter dated 09.10.2026 № 04/3-43/957, executed by Acting Director of the Department of Information Policy Roman Mamedov. Legal basis: processing a "large volume of information" pursuant to Article 20, Part 4, of the Law of Ukraine "On Access to Public Information". The review period was deferred to late October 2026.
• State Agency "Derzhmolodzhytlo": letter dated 09.10.2026 № 1977/005, signed by Management Board Chairman Mykola Marchuk. Legal basis: claims the six-point request necessitates searching through a "significant volume of data". The processing window was identically extended by 20 working days.

Both decisions were issued on October 9, on the final day of the statutory five-day processing period following registration of the initial requests on October 2. Neither agency delivered the underlying records on the merits, delaying full transparency until after the current application intake cycle concludes.

Nature of the Withheld Records

The filings requested accounting and administrative documentation, the existence of which was formally acknowledged on September 22, 2026, by Luhansk Regional Administration Reintegration Directorate Head Lyudmyla Didenko (Letter № 1410/02.01-16):

• "Registry № 2" Covering 401.7 Million UAH: records showing 176 families received public subsidies offsetting 50% to 99.5% of their mortgage principal. Of this total, 127 recipients were selected from a closed list reserved for residents of four districts occupied since 2014, while citizens displaced during the 2022 invasion (Lysychansk, Sievierodonetsk, Rubizhne, Popasna) were excluded.
• Regional Housing Directorate Transmittal Letter to Derzhmolodzhytlo: the instrument through which the regional administration sent the payment roster to the state agency to disburse funds.
• Official Minutes of the "Transparency and Accountability" Panel: voting records and session logs detailing resource allocations and the designation of critical-enterprise exemptions by administrative leadership.

Withholding these records beyond the standard five-day statutory window violates Article 6, Part 5, of the Law of Ukraine "On Access to Public Information," which mandates that access to information regarding the disposal of budgetary funds—including the names of individual recipients—cannot be restricted.

Legal Consequences and Next Steps

This coordinated delay establishes clear grounds for legal intervention across three procedural tracks:

1. Evidentiary Support for NABU Inquiries: the concurrent issuance of letters № 04/3-43/957 and № 1977/005 documents administrative coordination to conceal evidentiary records related to large-scale public fund allocations (Articles 191 and 364 of the Criminal Code of Ukraine).
2. Administrative Offense Proceedings: the unjustified extension of disclosure deadlines in the absence of technical search obstacles meets the statutory threshold of Article 212-3, Part 2, of the Code of Ukraine on Administrative Offenses (KUpAP). A formal administrative complaint has been prepared for the Parliamentary Commissioner for Human Rights.
3. Compelled Production in Administrative Court: with administrative remedies through the Ministry of Justice exhausted following its formal refusal on October 6, 2026 (Letter № 22798/25418/23/26/7 regarding Order № 452), these obstruction notices are being added to the judicial challenge, alongside a formal motion for judicial subpoena and compelled disclosure pursuant to Article 80 of the Code of Administrative Procedure of Ukraine.