Ukrainian Police IDs Lack Legal Force: Ministry of Justice Confirms Order Was Never Registered

The official response from the Ministry of Justice of Ukraine dated October 9, 2025, contains a critical clarification: Order No. 347 of the Ministry of Internal Affairs, dated April 26, 2017 — which regulates the procedure for the production and issuance of service IDs to officers of the National Police — was never submitted for state registration and, accordingly, was never registered by the Ministry of Justice. This means that the mentioned normative legal act has no legal force.

According to current legislation — particularly the Regulation on State Registration of Normative Legal Acts, approved by Cabinet of Ministers Resolution No. 731 dated December 28, 1992 — all acts issued by ministries and central executive authorities that affect the rights, freedoms, or responsibilities of citizens must undergo mandatory state registration. Without such registration, a normative legal act cannot be applied and is considered legally null and void.

Therefore, the police are currently using service IDs that were issued based on an order which lacks proper legal authority. These documents cannot be considered legitimate identification confirming state authority. In essence, they are internal documents that have not passed legal validation and thus carry no external legitimacy.

This situation casts doubt not only on the legality of the document itself, but also on any police actions that rely solely on the presentation of such IDs. Ukrainian citizens have the right to know the legal basis for any demands made upon them, and they have the right to reject the authority of those who cannot present legally recognized identification.

As such, the situation described in the Justice Ministry’s letter confirms that the current system of police identification is based on a normative act that lacks legal force. And this is not just a bureaucratic technicality — it is a matter of fundamental legitimacy and rule of law.

It should be emphasized that the Resolution of the Cabinet of Ministers of Ukraine dated December 28, 1992, No. 731 “On Approval of the Regulation on State Registration of Normative Legal Acts of Ministries and Other Executive Authorities” is included in the list of acts to be repealed under the new Resolution of the Cabinet of Ministers of Ukraine dated December 10, 2024, No. 1537.

Although it remains formally in force de jure until the new procedure enters into effect, its cancellation has already been stipulated and is linked to the enactment of the Law of Ukraine “On Law-Making Activity” No. 3354-IX dated July 5, 2023. This creates a situation of legal uncertainty, in which the validity of the old resolution is purely formal, while the new mechanism has not yet entered into force.