Register of Damage RD4U: category C1.5 for NGOs with damaged non-residential property

A Ukrainian NGO, charitable foundation or religious organisation that owns a damaged or destroyed non-residential building can file a claim with the international Register of Damage for Ukraine (RD4U) under category C1.5. This category covers non-residential real property whose purpose is not to generate profit, and only the value of destroyed property or the cost of its repair or reconstruction.

On 30 September 2026 the Register opened all 43 claim categories, so every type of damage now has a route to the international mechanism. Inclusion of a claim in the Register is not compensation yet, but without properly gathered documents the claim will not be included. Below we explain who can file a C1.5 claim, what evidence is needed and what to prepare in an NGO’s accounting records.

What has changed

The Register of Damage completed the phased launch of its claims system that began on 2 April 2024. All categories are now open: 21 for individuals, 11 for legal entities and 11 for the State of Ukraine. According to the Register, by 30 September 2026 it had received 195,000 claims, more than 65,000 of which had been recorded.

The rules for category C1.5 “Damage or destruction of non-residential real property (not related to business losses)” were adopted by the Board of the Register on 6 September 2024 and approved by the Conference of Participants on 6 November 2024. Instructions for claimants: Register of Damage for Ukraine, category C1.5.

Key rules of the category:

• The claimant is a legal entity that owns non-residential real property in Ukraine within its internationally recognised borders, including territorial waters.
• The property must have been damaged or destroyed on or after 24 February 2022 as a result of the armed aggression against Ukraine.
• “Not related to business losses” means non-residential real property whose purpose is not to generate profit.
• Only the value of destroyed property or the cost of repairing or rebuilding damaged property can be claimed. Other losses claimed in this category will not be recorded.
• A legal entity files only through a representative. The director or chair listed in the registration record is, as a rule, deemed the representative and may appoint others.
• Claims are filed through the Diia portal. The Board of the Register decides on inclusion, and that decision does not award compensation: a future compensation mechanism will consider it.

Who is affected

• NGOs and unions that own an office, centre, club, shelter or other non-residential building;
• charitable foundations that own warehouses, rehabilitation or social centres;
• religious organisations whose places of worship or other non-residential buildings were damaged;
• NGOs that rent premises: under the C1.5 rules the owner files the claim, so a tenant should coordinate with the owner.

What to do and by when

The C1.5 rules do not set a separate filing deadline. Evidence gets lost over time, though, so it is worth collecting it now.

1. Prove ownership: an extract from the State Register of Real Property Rights, or, if the right is not registered, evidence of registration attempts and refusals.
2. Collect documents on the event: date, type and description, photos, video, certificates from the competent authorities.
3. Prepare documents from Ukraine’s national Register of Damaged and Destroyed Property if a claim was filed there: registration number, commission inspection act, technical inspection report, valuation act and valuation report.
4. Determine the approximate claim amount. The form asks about an expert damage assessment, the value of the property before 24 February 2022, evidence of repair works and their cost.
5. Record any compensation already determined or paid by Ukraine through its authorised bodies: the form asks about this too.
6. Formalise the representative’s authority if the claim will be filed by someone other than the director in the registration record.
7. Check files before filing: they must open, be readable and free of malware. A claim can be saved as a draft and completed later.

Common mistakes and risks

• Claiming lost income or other costs. C1.5 accepts only the value of the property or the repair cost. Other types of damage need a different claim category.
• The tenant files the claim. The category rules refer to the owner. A rented building is not the tenant’s property.
• Ownership not registered. If the right is not in the State Register of Real Property Rights, the form asks for evidence of registration attempts and refusals.
• Incomplete or false data. A false or falsified claim may be found manifestly unfounded and not recorded.
• Repairs without documents. If the NGO has already repaired the building with donor funds, without contracts, acts and payment orders the repair cost cannot be proven either in the claim or to the donor.

What the auditor and the donor will check

For an auditor, a damaged NGO building is a matter of accounting and evidence. We check whether a stocktake was carried out after the event, whether its results were recorded, and whether the data on the property agree across the accounting registers, the State Register of Real Property Rights and the claim to the Register of Damage. If a donor funded the repairs, it will want to see that the same amount is not claimed twice: as a project cost in the donor report and as damage in the claim without reflecting the funding received. The C1.5 form asks directly about compensation determined and received from Ukraine, so the answers in the claim and the books must match.

FAQ

How we help

We help NGOs put the accounting for damaged property in order, carry out a stocktake and collect accounting evidence of value and repairs that will be needed both for the claim and for the donor. See accounting for NGOs, stocktaking and NGO audit. For NGO accountants and managers we run free webinars for NGOs.

Prepared by the MK Audit team