Head of Medical Law Practice
Specializes in medical, corporate, and migration law. Has extensive experience working with medical and pharmaceutical businesses, particularly in licensing, circulation of medicines, and comprehensive legal support of healthcare institutions, including corporate, tax, and employment matters, as well as market entry projects of foreign companies into Ukraine.
Development of Documents on Safe Space, Shelter and Operations During an Air Raid Alert
The division of air raid alerts into yellow and red threat levels has fundamentally changed the rules governing the operation of commercial facilities and businesses in Ukraine. Every business entity — regardless of its legal form — is now required to formally declare the availability of a shelter or establish a safe space, place 100 × 60 cm signs on façades and approve local staff response procedures.
Prikhodko & Partners provides comprehensive legal support for businesses by preparing a complete package of internal documentation on a turnkey basis under Resolutions of the Cabinet of Ministers of Ukraine No. 1092, No. 1128 and No. 1158. We adapt orders, regulations, lease agreements and evacuation routes to the actual business processes of shopping and entertainment centres, business centres, industrial and service companies, sole proprietors, as well as private clinics and medical centres.
Who must have documents on safe space, shelter availability and operations during an air raid alert?
The new civil defence and occupational safety requirements apply to all property operators and employers. We prepare specialised legal solutions for all categories of clients:
- owners of shopping centres and retail facilities;
- owners of business centres and office property;
- business owners, including LLCs, enterprises and service businesses;
- sole proprietors with employees;
- owners and managers of medical facilities, including clinics, diagnostic and rehabilitation centres, and doctors operating as sole proprietors.
Large visitor flows require a clear allocation of responsibility between the management company of a shopping centre and its tenants, including shops, supermarkets and food establishments. The documentation governs building-wide voice announcements, the opening of evacuation exits and access to underground parking or safe areas within the building’s spatial and planning layout.
As the operator of the building, the owner of a business centre must calculate protected areas taking into account the maximum blast overpressure indicator in kilopascals, declare a safe space, install entrance signs and coordinate safety procedures with tenant companies.
Companies acquire the legal right to continue operating during the yellow threat level, including a drone threat, provided that there is a shelter, dual-purpose structure or declared safe space. Where there is no shelter, we formalise the legal basis for continuing operations through minutes of the general meeting of the workforce.
Owners of shops, cafés, beauty salons, pharmacies, dental and cosmetology consulting rooms located in residential or commercial buildings have the same obligations as large businesses under Article 153 of the Labour Code of Ukraine to provide safe working conditions. We prepare a compact package of orders and instructions without unnecessary bureaucracy.
A special sector-specific procedure under Resolution of the Cabinet of Ministers of Ukraine No. 1158 applies to healthcare. We specify the list of continuous medical processes, including operations, anaesthesia, resuscitation and CT/MRI under sedation, which do not stop even during the red threat level, and formalise the provision of medical assistance in shelters without breaching the Ministry of Health licensing conditions.
How businesses operate under different threat levels: yellow and red regimes under Resolutions No. 1092 and No. 1158
Resolution of the Cabinet of Ministers of Ukraine No. 1092 dated 4 September 2026, as amended by Resolution No. 1128, replaced the approach under which every air raid alert paralysed economic activity by dividing warning signals into two threat levels.
| Regulatory criterion | Yellow level (drone threat) | Red level (missile / large-scale threat) |
|---|---|---|
| Audible warning signal | “Attention Everyone” siren for 30 seconds + voice announcement of the yellow level | “Attention Everyone” siren for 1 minute + voice announcement of the red threat level. |
| Operation of businesses, sole proprietors, shopping centres and business centres | Operations do not stop. Businesses continue operating normally where there is a shelter, safe space or agreement with the workforce. Visitors may remain on the premises at their own discretion. | Customer service and work in unprotected areas stop. Staff and clients move to a shelter or equipped safe space using the approved route. |
| Specific rules for medical facilities (Resolution No. 1158) | The clinic continues routine scheduled appointments in its normal consulting rooms while ensuring free access to the shelter at the patient’s request. | No new scheduled appointments or diagnostic procedures are started. Operations, mechanical ventilation and continuous medical procedures continue in protected premises. |
The operator of a shopping centre or business centre and every employer must ensure that warning signals are communicated immediately to all staff and visitors.
Why a business owner, shopping centre owner or clinic cannot rely on a generic online template
A formal order stating that “everyone must go to the shelter during an air raid alert” or a client waiver stating “I have no claims” will not be sufficient during inspections. The reasons include:
- No private shelter. Most sole proprietors, offices, small clinics and street-retail businesses do not have their own bomb shelter. Resolution No. 1092 allows such facilities to operate legally during the yellow threat level only subject to two conditions: minutes of the general meeting of the workforce being executed, with this option available for up to 3 months, and a safe space being arranged within the premises as the most protected area under the applicable rules and requirements.
- Conflict between the landlord (business centre/shopping centre) and the tenant. If shopping centre security closes an entrance or blocks access to the car park during an alert while the internal order of the sole proprietor or tenant company requires evacuation to that very location, the employer that failed to coordinate a realistic route may bear responsibility in the event of a tragedy.
- Continuous medical and manufacturing processes. A clinic cannot immediately stop surgery, haemodialysis or childbirth, and a business may not be able to stop continuous manufacturing or leave it unattended. The procedure must clearly identify which employees remain at their workplace and how that workplace is protected.
List of documents on safe space and shelter that we prepare on a turnkey basis
The construction experts and specialists in employment and medical law at Prikhodko & Partners audit your facility and prepare an individual package of documents:
- Order of the manager or sole proprietor “On the Organisation of Work During an Air Raid Alert”. This introduces operating regimes for yellow and red threat levels and appoints persons responsible for alerts, opening shelters and assisting people with reduced mobility.
- Regulations governing the operation of an enterprise / shopping centre / business centre / medical facility during an air raid alert. These set out step-by-step procedures for management, security staff, sales staff, office employees or doctors, as well as the procedure for resuming work and serving waiting customers after the all-clear.
- Documents concerning the inspection and designation of a “Safe Space”. Legal formalisation of the most protected areas within the building’s spatial and planning layout, including corridors behind two load-bearing walls, basement levels and reinforced halls, in accordance with Resolution of the Cabinet of Ministers of Ukraine No. 1092, as amended by No. 1128, DBN requirements and civil defence regulations.
- Minutes of the general meeting of the workforce and signature registration sheet. A mandatory document for businesses, sole proprietors and clinics whose premises do not have a shelter and which provides the legal basis for operations during the yellow threat level.
- Evacuation route and engineering marking scheme. This covers the movement of employees, clients and people with reduced mobility, as well as the specification for mandatory 100 × 60 cm façade signs stating “Facility Provided with a Shelter”, “Facility Provided with a Safe Space” or “Facility Not Provided with a Shelter”.
- Guidance notes and information boards for visitors, clients and tenants. Documents for publicly declaring a safe space and explaining visitors’ right to remain at the facility during the yellow level at their own discretion.
Special section for medical facilities under Resolution No. 1158:
- a list of continuous medical processes and response procedures for outpatient care, inpatient care, operating theatres and diagnostics;
- voluntary informed patient consent to the provision/continuation of medical care during an air raid alert;
- confirmation that the patient has been informed of the procedures to be followed during an air raid alert.
Legal liability of the business owner, building operator and manager
Resolutions of the Cabinet of Ministers of Ukraine No. 1092, No. 1128 and No. 1158 do not repeal employment law, occupational safety requirements or civil defence rules.
Under Article 153 of the Labour Code of Ukraine, the obligation to provide safe and harmless working conditions rests directly with the employer, including the director of an LLC, a sole proprietor or the head of a clinic.
If an employee or visitor is injured during a missile or drone attack on the premises of a business centre, shopping centre, shop or medical facility, law enforcement authorities will check:
- whether local orders and response procedures for yellow and red threat levels have been approved;
- whether minutes of the workforce meeting have been executed where the facility operates without a shelter;
- whether employees have acknowledged the instructions and routes by personal signature;
- whether briefings and training have been conducted;
- whether the decision to keep an employee at their workplace during a threat was justified.
Where there is a causal link between a breach of occupational safety and civil defence requirements, such as the absence of procedures, a locked safe space, forcing staff to work during the red threat level or the absence of a shelter sign, and injury or death, criminal liability may arise for the manager, for example under Article 271 of the Criminal Code of Ukraine. Professional preparation of documentation by lawyers and construction experts removes these risks and creates reliable legal protection for the business owner.
How to order turnkey document preparation from Prikhodko & Partners
We work with businesses, commercial property and medical facilities throughout Ukraine online or at our office in Kyiv, at the Parus Business Centre:
- Facility audit: we analyse the specifics of your business, including NACE (KVED), staffing and working hours, the BTI technical passport for the premises, lease agreements and the availability of basement floors, parking areas or other zones that may be used as a safe space.
- Agreement of the safety model: we determine the appropriate status of the facility — provided with a shelter / safe space / operation by agreement with the workforce — and agree procedures for stopping or continuing processes.
- Preparation of the complete document package: we draft orders, regulations, meeting minutes, route schemes, forms for employees, visitors and clients/patients, and update occupational safety instructions.
- Implementation support: we provide a clear checklist for conducting briefings against signature and installing 100 × 60 cm signs.
Do not wait for an inspection or a critical incident. Submit an enquiry on the website or call us now — the specialist lawyers at Prikhodko & Partners will prepare documentation on safe space and shelter tailored to the specifics of your business.
Calculate the cost of services
1 question
Have an order and staff response procedures for different threat levels been approved?
2 question
Does your premises or building have a shelter or designated safe space?
3 question
Do you have inspection documents and calculations for identifying the safe space?
4 question
Do you have manufacturing or medical processes that cannot be safely stopped immediately?
How can a business, shop, office or clinic legally continue operating during an air raid alert if it does not have its own shelter?
Under Resolution of the Cabinet of Ministers of Ukraine No. 1092, business entities whose premises do not have a temporary or permanent shelter may continue operating during the yellow threat level provided that this is formally agreed with the workforce and documented by Minutes of the General Meeting. This arrangement applies until a shelter is provided, but no later than 4 December 2026 (the Cabinet of Ministers plans to extend this period). At the same time, the employer or building operator must designate a safe space within the premises, arrange for its inspection and ensure that the relevant documents confirming compliance with statutory requirements are available.
What is a “safe space” and how is it different from a shelter?
A safe space is the most protected internal area within a building or structure that is not a certified civil defence protective structure or dual-purpose structure. It is arranged within existing premises to protect staff and visitors from the indirect effects of weapons, including fragments and blast waves. The existence of a safe space is declared by the owner of a shopping and entertainment centre, business centre, enterprise or clinic where documents are available confirming that the premises have been inspected for compliance with the established safe-space requirements.
Who is responsible for safety and the 100 × 60 cm signs in shopping centres and business centres — the building owner or the tenant (sole proprietor/LLC)?
Under Resolution of the Cabinet of Ministers of Ukraine No. 1092, both parties are responsible for informing people and providing air raid alerts: the building owner (shopping centre or business centre) and the business renting premises there. The centre owner places 100 × 60 cm signs on the façade stating whether a shelter or safe space is available and activates the general siren.
At the same time, each tenant, whether an LLC or sole proprietor, must approve its own internal documents — an Order and Regulations governing staff actions during an air raid alert — and coordinate them with the overall evacuation plan of the shopping centre or business centre.
How much does turnkey preparation of a package of documents on safe space and operations during an air raid alert cost?
The cost of preparing the documentation depends on the type of facility and scale of operations. A basic local package is prepared for a sole proprietor and a small office or consulting room, whereas shopping centres, business centres, manufacturing companies and multidisciplinary medical facilities require a more detailed audit of processes, response procedures and evacuation routes under Resolution No. 1158.
Telegram
Viber
WhatsApp
Facebook
Instagram