SBU Inspections and Card Blocking: When IDPs Can Actually Lose Their Pension
In Ukraine, internally displaced persons (IDPs) who receive an old-age pension may be eligible for living assistance. However, the right to such payments is not automatic and depends on income level, family composition, and certain exceptions provided by government regulations. In 2026, there is a limit of UAH 10,380 per recipient, which determines the right to continue payments.
"Judicial and Legal Newspaper" explains how the pension is taken into account, which categories have exceptions, and when assistance may be discontinued.
Legal basis for IDP payments
According to the Procedure for providing living assistance to internally displaced persons, approved by the Resolution of the Cabinet of Ministers of Ukraine dated March 20, 2022, No. 332, assistance is assigned and extended for six-month periods provided the income criteria are met. The document states: "living assistance to internally displaced persons is extended for the next six-month period if the average monthly total income per recipient in the family does not exceed the established amount."
Effectively, the key criterion is the average monthly total income calculated over the last three months.
Currently, monthly support amounts to 2,000 UAH for adults and 3,000 UAH for children and persons with disabilities. Funds are allocated to each family member who has official IDP status and is registered in the Unified Information Database.
What income qualifies for payments in 2026
The calculation uses the subsistence minimum for persons who lost working capacity, set as of January 1 of the respective year. In 2026, this amount is 2,595 UAH.
Thus, the income limit is calculated as: 2,595 UAH × 4 = 10,380 UAH
This means that IDP assistance can be extended if the average monthly income per person in the family does not exceed 10,380 UAH. The resolution also emphasizes: "the average monthly total income is defined as the total income of all family members divided by the number of persons in the family." This income includes pensions, salaries, and other social payments.
Can one receive both a pension and IDP assistance simultaneously?
The issue of pension provision for this category is of special social importance, as it concerns the right to social protection of the most vulnerable citizens of Ukraine – persons who have reached retirement age and/or receive other types of pension payments and find themselves in difficult life circumstances related to armed aggression, destruction or damage of property, temporary occupation of their place of residence, or changes in place and living conditions.
Receiving an old-age pension is not a basis for automatic refusal of IDP assistance. However, the pension is considered part of the total income. That is, if its amount together with other income exceeds the established threshold, IDP payments are stopped or not extended for the next period.
Thus, the critical factor is not the fact of receiving a pension but its amount.
Important exception: when income is not checked
Resolution No. 332 provides a list of categories for which assistance may be extended without income assessment. In particular, assistance is extended without considering the total family income for:
- pensioners whose pension does not exceed 10,380 UAH;
- persons with disabilities of groups I and II;
- children with disabilities under 18 years old;
- orphans and children deprived of parental care, as well as persons from their number up to 23 years old;
- foster parents, adoptive parents, and guardians (custodians).
Thus, a simplified mechanism for extending assistance applies to pensioners with low pensions.
How this works in practice
The system effectively distinguishes two situations:
- Small pension (up to 10,380 UAH). In this case, IDP assistance may be extended without additional income assessment.
- Pension exceeds or together with other income exceeds the threshold. Assistance is not assigned or is stopped after checking the average monthly income. Social protection authorities consider all official income, including pensions, benefits, and other payments.
The income verification mechanism is implemented to ensure targeted assistance is provided primarily to those IDPs who are truly in difficult financial conditions. As stated in the Cabinet of Ministers' social policy approach: "state support is provided based on the principles of targeting and social justice." This means payments are not universal but depend on the financial condition of the family.
Can IDP pension payments be stopped due to failure to undergo physical identification?
Physical identification is one of the procedures that certain categories of pensioners, including internally displaced persons, must undergo. If a pensioner does not pass this check, JSC "State Savings Bank of Ukraine" has the right to temporarily suspend withdrawal operations on the account where the pension is credited.
After identity confirmation, access to funds is restored the next day following identification. At the same time, blocking operations on the bank account does not mean automatic termination of pension payments.
The grounds on which the Pension Fund authorities may stop pension payments are clearly defined in Part One of Article 49 of the Law of Ukraine "On Compulsory State Pension Insurance" No. 1058-IV. These include:
- pension assigned based on documents with false or unreliable information;
- death of the pensioner;
- non-receipt of pension payments for six consecutive months;
- other cases explicitly provided by law.
Importantly, this list does not include failure to undergo physical identification or verification of the actual place of residence of the internally displaced person.
The Supreme Court drew attention to this in reviewing model case No. 805/402/18. The Court emphasized that the pension is a constitutional guarantee of social protection acquired through labor activity. Therefore, the state may stop payments only in cases explicitly defined by law.
According to a copy of a letter from the Bakhmut United Pension Fund Administration of Donetsk region included in the case materials, the plaintiff's pension "was suspended due to verification based on SBU lists related to checking the actual place of residence."
At the same time, Law No. 1058-IV does not provide for suspension or termination of pension payments due to verification based on SBU lists related to checking the actual place of residence. This means the Pension Fund authorities cannot independently expand the grounds or stop pension payments for other reasons, even if related to inspections or verifications.
The Supreme Court's legal position applies to similar disputes if the person: is a citizen of Ukraine; has IDP status confirmed by the relevant certificate; receives a pension under Law No. 1058-IV; is forced to take additional actions to resume payments; and the Pension Fund does not dispute the person's right to receive a pension.
Thus, failure to undergo physical identification may lead to temporary restriction of access to funds in the bank account but is not, by itself, a legally provided ground for stopping pension payments. This position was confirmed by the Supreme Court in its ruling dated May 3, 2018, in model case No. 805/402/18, which continues to be used by courts in similar disputes.
In conclusion, it should be noted that receiving both an old-age pension and IDP payments in Ukraine is possible, but only if the established income level is observed. The pension is included in the total income calculation, so its amount directly affects the right to continue assistance.
At the same time, a simplified regime applies to certain categories of pensioners, under which assistance may be extended without income verification if the pension does not exceed 10,380 UAH. Thus, the key factor remains not the status of the pensioner or IDP, but the actual financial condition of the family.
Subscribe to our Telegram channel t.me/sudua and to Google News SUD.UA, as well as to our VIBER and WhatsApp pages, on Facebook and Instagram to stay updated on the most important events.
