LEGAL REGULATION OF THE TREATMENT OF STRAY ANIMALS IN THE CONTEXT OF THE RUSSIAN–UKRAINIAN WAR AND UKRAINE'S POST-WAR RECOVERY

The trauma unit of the Balakliia hospital in Kharkiv oblast reports between five and ten people a day with animal bites, sometimes whole families. There are now many stray animals, and their frequent contact with wild animals has raised the risk of rabies, the traumatologist Oleksandr Kovalchuk told the WHO Regional Office for Europe in December 2025 (World Health Organization Regional Office for Europe 2025).

The subject may look peripheral to the war's central concerns. That impression is deceptive. Stray animals are the issue where the powers of territorial communities (hromadas), the system of rabies prophylaxis, the legal regime of the occupied territories and Ukraine's European integration commitments converge. They are therefore an accurate indicator of the state's capacity to give effect to its own legal prescriptions under crisis conditions.

The war's impact on animals is both direct and indirect. Direct harm – death and injury from shelling, mined territory, destroyed habitats, zoological facilities, farms and shelters, the unavailability of veterinary care – is largely attributable to the aggressor state, and national law can do little about it. Indirect harm develops gradually: the collapse of state veterinary control, reduced funding, personnel losses, fragmented enforcement practice, and a growing number of stray animals produced by mass internal displacement. This second category can be mitigated by domestic means – through powers, funding, administrative procedure and oversight – irrespective of when hostilities end or whether international compensation mechanisms materialise. It is the part of the problem Ukraine can address itself, and the subject of what follows.

The foundational act is the Law of Ukraine "On the Protection of Animals from Cruelty" No. 3447-IV of 21 February 2006 (Verkhovna Rada of Ukraine 2006). Article 1 defines stray animals as domestic animals left without human care or forming semi-free groupings capable of breeding outside human control. Article 24 governs their capture by specialised services: a captured animal is held at a quarantine facility for seven days and then returned to its owner, transferred to a shelter or to a civil-society organisation, or released at the place of capture.

That last model – release after sterilisation, vaccination and identification (CNVR, in Ukrainian practice OSVV) – has become the principal legal mechanism for regulating stray animal numbers. The construction has an institutional defect, however. Article 24 ties the creation of the necessary infrastructure to local self-government bodies, which "may" establish municipal services under local programmes financed from local budgets. The law provides no effective mechanism for compelling a local self-government body to do so. There is a duty of the state to secure the proper treatment of stray animals and no way to compel a particular public authority to discharge it.

Before the full-scale invasion, FOUR PAWS estimated up to 200,000 stray dogs in Ukraine and probably considerably more cats (FOUR PAWS International 2025); no unified official statistics exist (Eurogroup for Animals n.d.). Already before 24 February 2022, then, the Ukrainian model combined a detailed regulation of permissible treatment with weak mechanisms for securing performance of the corresponding public duties.

Tellingly, the key implementing act was adopted during the war. Cabinet of Ministers Resolution No. 720 of 24 June 2022 approved the Procedure for regulating animal numbers: capture methods, a prohibition on injurious methods, a duty on the local self-government body to publish a capture plan at least seven calendar days in advance, and quarterly reporting on animals captured, sterilised, vaccinated and returned, as well as those that died, with the causes of death (Cabinet of Ministers of Ukraine 2022).

The Procedure presupposes a functioning hromada website, an operating council, a municipal enterprise, a veterinary licence, a budget line and physical access to the territory. The war forced  some changes: evacuation from front-line hromadas, a sharp rise in the number of stray animals, destroyed municipal and veterinary infrastructure, and the shift of administrative priorities towards defence. The result is a norm formally in force and in fact unimplemented.

The epizootic background is serious. In the first half of 2025, 671 positive rabies cases in animals were recorded across 562 localities, most often in cats (224), dogs (216) and red foxes (89) (Ukrinform 2025). These figures do not by themselves establish a causal link with non-implementation, but they show the risk  associated with it.

Where the state does not reach, volunteers work, often foreign ones. A representative of the German organisation Tiernothilfe Ukraine e.V. describes the pattern: the free state anti-rabies vaccine "Rabistar" exists and is meant to be issued to state veterinarians for the annual vaccination of their district, but the civil-society organisation struggles to obtain it and has to buy its own; sterilisation costs from UAH 800 at a private clinic in Sloviansk and around UAH 1,500 in Kyiv, while the nearest state facility serving the residents of Lyman and Sviatohirsk does not operate at full capacity (Anti-Crisis Media Centre 2024). Access to humane population regulation is determined by the ability to pay.

In the temporarily occupied territories the question shifts into international humanitarian law. Article 43 of the 1907 Hague Regulations obliges the occupant to take the measures within its power to restore and ensure, as far as possible, public order and civil life, while respecting the laws in force in the country unless absolutely prevented from doing so (Hague Convention IV 1907, art. 43). Veterinary administration and rabies prophylaxis fall within that duty: "civil life" is read broadly, as covering public health and the ordinary functioning of social services.

According to accounts by residents of occupied Mariupol cited by the Anti-Crisis Media Centre, packs of stray dogs move freely through the city, rabies vaccines are unavailable, and the occupation administration neither runs sterilisation programmes nor organises shelters (Anti-Crisis Media Centre 2025). These reports cannot be verified independently. Yet the impossibility of verification carries its own legal significance: without access to occupied territory the actual state of the system cannot be recorded, and no evidentiary basis can be built either for future compensation mechanisms or for assessing epizootic risk at de-occupation.

Two consequences of administrative inaction deserve more attention than they receive. The first one is the erosion of trust in public institutions. If a hromada adopts capture and population-regulation programmes for years without implementing them, the public obligation ceases to be perceived as an obligation at all, and confidence in the state's ability to carry out its own decisions decays with it.

The second issue concerns the reintegration of the liberated territories. A failure to resolve the problem in good time complicates the return of the population: people come back to settlements without veterinary infrastructure or the necessary means of prevention, and with far more animals than before. Sanitary and epizootic safety turns out to be not a consequence of the recovery of a territory but one of its preconditions.

The institutional means of correction already exist. The EU opened accession negotiations with Ukraine on 25 June 2024. The obligation to approximate animal welfare legislation predates that step, under Article 64(1) of the Association Agreement, but the negotiation process makes conformity with EU law a subject of systematic assessment. Regulation (EU) 2024/792 establishing the Ukraine Facility provides support of up to EUR 50 billion for 2024–2027 and includes animal welfare among the areas covered (European Union 2024).

The national infrastructure is developing in parallel. Cabinet of Ministers Resolution No. 1171 of 3 November 2023 launched a two-year pilot project on the identification and registration of domestic animals, initially on a voluntary basis (Cabinet of Ministers of Ukraine 2023); since May 2025, registration in the Unified State Register of Domestic Animals has been available through the Administrative Service Centres.

The register matters well beyond the technical recording of animals. Abandoning an animal without care has been prohibited since 2021 and may, where the statutory conditions are met, entail liability under Article 299 of the Criminal Code of Ukraine. Without identification, however, the owner cannot reliably be established, a lost animal cannot be distinguished from an abandoned one, and neither the scale of the problem nor the harm caused can be documented. Identification and registration are therefore mechanisms for attributing responsibility and part of the evidentiary infrastructure of public administration.

The problem lies less in the content of individual norms than in the construction of the legal regulation. The wartime and post-war period requires a distinct regime that accounts for destroyed administrative infrastructure, scarce resources and heightened epizootic risk.

First, the regulation of stray animal numbers must cease to be an optional local programme and become a delegated power, backed by an earmarked subvention and measurable indicators – sterilisation and vaccination coverage per thousand inhabitants, for example. As long as the activity is framed through "may", in a front-line hromada it will depend on whatever resources and local political will happen to be available.

Second, the law must legalise and institutionalise what already happens in practice. In the de-occupied and front-line territories, mobile veterinary teams and civil-society organisations largely perform functions that would otherwise fall to the public administration. They need a simplified procedure of admission to that activity and a mechanism for the gratuitous transfer of state stocks of anti-rabies vaccine with subsequent reporting.

Third, the issue of stray animals should be treated not only as a question of animal protection but as an element of sanitary and epizootic safety. Rabies does not recognise administrative or de facto lines of demarcation. After de-occupation, the risks accumulated in the temporarily occupied territories will become a common problem for Ukraine and, in the longer term, for the EU. Solving it will fall to the same local self-government bodies that today already face the consequences of the war without sufficient funding or a clearly formulated duty to act.

Post-war regulation must therefore be built around a working system of public obligation, funding, oversight, and inter-agency cooperation. 

1. World Health Organization Regional Office for Europe. 2025. “Ukraine: Rabies Is Now an Increasing Threat in Frontline Regions.” December 5. Accessed August 10, 2026. www.who.int/europe/news/item/05-12-2025-ukraine--rabies-is-now-an-increasing-threat-in-frontline-regions.

2. Verkhovna Rada of Ukraine. 2006. Law of Ukraine “On the Protection of Animals from Cruelty” of 21 February 2006, No. 3447-IV (in Ukrainian). Accessed August 10, 2026. zakon.rada.gov.ua/laws/show/3447-15.

3. FOUR PAWS International. 2025. “Stray Animal Care in Ukraine.” January 28. Accessed August 10, 2026. www.four-paws.org/campaigns-topics/topics/help-for-stray-animals/stray-animal-care-in-ukraine.

4. Eurogroup for Animals. n.d. “Ukraine.” Areas of Concern. Accessed August 10, 2026. www.eurogroupforanimals.org/what-we-do/areas-of-concern/ukraine.

5. Cabinet of Ministers of Ukraine. 2022. Resolution of 24 June 2022 No. 720 “On Approval of the Procedure for Regulating the Number of Animals Not Kept by Humans but Existing in Conditions Wholly or Partly Created by Human Activity, and of Stray Animals” (in Ukrainian). Accessed August 10, 2026. zakon.rada.gov.ua/laws/show/720-2022-%D0%BF.

6. Ukrinform. 2025. “This Year in Ukraine Most Rabies Cases Were Detected among Foxes, Dogs and Cats” (in Ukrainian). July 17. Accessed August 10, 2026. www.ukrinform.ua/rubric-society/4015908-v-ukraini-cogoric-najbilse-vipadkiv-skazu-viavili-sered-lisic-sobak-ta-kotiv.html.

7. Anti-Crisis Media Centre. 2024. “Stray Animals in Front-Line Regions: What the Problems Are and How the State Can Help” (in Ukrainian). Interview with Liudmyla Yurashko (Tiernothilfe Ukraine e.V.). April. Accessed August 10, 2026. acmc.ua/bezprytulni-tvaryny-u-pryfrontovyh-regionah-yaki-problemy-ta-yak-derzhava-mozhe-dopomogty/.

8. Anti-Crisis Media Centre. 2025. “Stray Dogs Are One of the Main Threats in Occupied Mariupol” (in Ukrainian). May 26. Accessed August 10, 2026. acmc.ua/bezprytulni-sobaky-odna-z-golovnyh-zagroz-u-okupovanomu-mariupoli/.

9. Cabinet of Ministers of Ukraine. 2023. Resolution of 3 November 2023 No. 1171 “On the Implementation of a Pilot Project for the Identification and/or Registration of Domestic Animals” (in Ukrainian). Accessed August 10, 2026. zakon.rada.gov.ua/laws/show/1171-2023-%D0%BF.

10. Hague Convention IV. 1907. Convention Respecting the Laws and Customs of War on Land and Its Annex: Regulations Concerning the Laws and Customs of War on Land. The Hague, October 18, 1907. Art. 43. ICRC IHL Databases: Treaties, States Parties and Commentaries. Accessed August 13, 2026. ihl-databases.icrc.org/en/ihl-treaties/hague-conv-iv-1907/regulations-art-43.

11. European Union. 2024. Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 Establishing the Ukraine Facility. OJ L, 2024/792, 29.2.2024.