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Photo Insertion into a Ukrainian Internal Passport (at Age 25 / 45)
Inserting a photograph into the booklet-format Ukrainian internal passport is a mandatory procedure upon reaching the age of 25 or 45. The photo insertion is carried out by the State Migration Service of Ukraine after the passport is forwarded to the territorial authority of Ukraine.
Poland Documents provides assistance in preparing and submitting documents in accordance with the established legal procedure and current requirements.
The final decision on the insertion of the photograph is made by the authorised authority of Ukraine.
Read the detailed explanation of the procedure here
Why Choose Us:
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Preliminary assessment of the situation and verification of compliance with mandatory deadlines
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Preparation of documents and drafting of submissions in accordance with established procedures
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Assistance with forwarding the passport for photo insertion to the State Migration Service of Ukraine
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Verification of document processing accuracy and informing the client about the progress of the procedure
Required Documents
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Ukrainian internal passport (booklet format) — original
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Taxpayer Registration Number (RNOKPP / TIN)
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Two photographs meeting official specifications for passport insertion
Requirements for photographs and the list of documents may be clarified by the relevant consular authority depending on the applicant’s individual circumstances.
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Ukrainian Passport Without Photo Abroad: Photo Insertion and Cabinet Resolution No. 1202
Updated: February 2026
Many citizens of Ukraine residing in Poland and the EU face a specific challenge regarding a Ukrainian passport without photo abroad: upon reaching the age of 25 or 45, it is mandatory to update the photograph in the 1994-format Ukrainian internal passport booklet. However, attempts to perform this procedure at a consulate or DP “Dokument” typically result in a refusal.
In this article, we examine the legal conflict: why, according to Cabinet of Ministers Resolution No. 1202, your passport remains valid without the photo, yet foreign banks (Revolut, Santander) may reject it, and why the most reliable strategic solution abroad is the exchange for a Ukrainian ID card.
Who will find this article useful:
- ✓ Holders of passport booklets who have reached the age of 25 or 45.
- ✓ Individuals who received notifications from banks regarding the need to update data.
- ✓ Citizens planning to enter Ukraine with an expired photo.
Regulatory Framework: Resolution No. 1202
The legal status of a passport without a contemporary photo is regulated by the Cabinet of Ministers of Ukraine Resolution No. 1202 of 21 October 2022.
“…1994-format passports of a citizen of Ukraine into which a photograph has not been inserted upon reaching the age of 25 or 45… are documents that certify identity and confirm Ukrainian citizenship.”
Critical clarification on deadlines:
This norm applies to passports where the deadline for photo insertion occurred within 30 days prior to 24.02.2022 or during the period of martial law.
- 🔗 Source: Resolution No. 1202 on zakon.rada.gov.ua
Why a Ukrainian passport without photo abroad is perceived differently (Banks, Notaries, Offices)
It is essential to distinguish between the document’s legal status within Ukraine and its perception abroad. Resolution No. 1202 has direct authority for Ukrainian state bodies, police, and checkpoints. Your passport is not invalid.
However, outside Ukraine (in Poland, Germany, etc.), different document verification standards apply, and foreign institutions are not obliged to recognize the nuances of Ukrainian wartime resolutions:
Banking Compliance
European banks (Revolut, PKO, Santander) and fintech services utilize automated identity verification systems. If the passport photo was taken at age 25 and the client is now 45, facial recognition systems will reject the document for failing to match the owner. Consequently, a strategic legal audit of the situation is often required, despite the document’s legitimacy in Ukraine.
Notarial Actions
Foreign notaries may refuse to certify a signature if they cannot visually identify the individual based on an outdated photo. They are guided by the principle of visual control rather than Ukrainian legislation.
Is it possible to perform photo insertion at a consulate?
Neither diplomatic missions (Consulates) nor foreign branches of DP “Dokument” provide photo insertion services for the internal passport booklet.
- Reason: The 1994-format booklets are being phased out. The state has not delegated the authority or technical means (stamps, forms) for servicing outdated paper passports abroad.
Risks of using a passport without an updated photo abroad
- Refusal of banking services (KYC procedures)
- Blocking of active accounts
- Refusal to perform notarial acts
- Inability to register at administrative offices (refusal to accept documents)
- Difficulties in obtaining loans or installment plans
- Problems with verification in fintech services
The most reliable solution: Exchange for an ID card
If you reach the age of 25 or 45 while abroad, the most reliable legal method to achieve legal regularisation of your internal document is the exchange of the passport booklet for a Ukrainian ID card.
| Service | Where to Apply | Result |
|---|---|---|
| Exchange of “Booklet” for ID | DP “Dokument” (Warsaw, Krakow, Wroclaw, Gdansk) | Issuance of a modern biometric document with a current photograph. |
Important: Upon exchange, the old passport is confiscated. The new ID card fully complies with international verification standards, resolving compliance risk issues with banks and services.
Frequently Asked Questions (FAQ)
Is my passport booklet without a photo valid?
Yes. According to Cabinet Resolution No. 1202, a passport booklet where the photo insertion deadline occurred 30 days before 24.02.2022 or later remains a valid document for the period of martial law and 30 days after its termination.
Can I be refused entry to Ukraine due to the absence of a photo?
No. The State Border Guard Service of Ukraine is obliged to permit the citizen to enter, as the document is legally valid. The absence of a recent photo is not grounds for refusal of entry to the homeland.
Is such a passport valid outside Ukraine (EU)?
Legally — yes, it confirms citizenship. Practically — foreign institutions (banks, notaries, social services) often refuse to accept it as they cannot conduct visual identity verification with an outdated photo.
Is there a fine for a missing photo during martial law?
No. The deadlines for photo insertion have been officially extended, so administrative liability (fines) for delays during this period is not applied.
Can I perform photo insertion in Ukraine?
Yes. Within Ukraine, this service is available and operates normally through Administrative Service Centres or territorial units of the State Migration Service of Ukraine.
Can I insert a photo at a consulate or DP “Dokument” abroad?
No. Officially, this is impossible. Diplomatic missions and foreign branches of the passport service do not have the authority or technical capability to service 1994-format paper passports.
Is it mandatory to exchange the passport booklet for an ID card?
No, legislation does not mandate a forced exchange if the passport is not damaged. However, abroad, exchanging for an ID card is the only way to update the photograph.
Will a foreign bank accept a passport without a photo?
There is a high probability of refusal. Banking compliance systems and fintech applications (Revolut, Wise) require a current photo for biometric matching. Old passports often fail automated verification.
What should I do if the bank blocked my account due to the passport?
Referencing Resolution No. 1202 is ineffective, as it is an internal Ukrainian act. The solution is to provide the bank with another document featuring a current photo (international passport) or to obtain a new ID card.
Will a notary accept an old passport without a photo?
A Ukrainian notary — yes (legally obliged). A foreign notary has the right to refuse if they doubt the client’s identity due to the mismatch between the photo and current appearance.
What are the deadlines for updating after martial law is lifted?
You will need to insert a photo or exchange the passport for an ID card within 30 calendar days from the moment martial law is officially canceled or terminated.
Is it easier to resolve issues abroad with an ID card?
Yes. The ID card meets ICAO standards for machine-readable documents, contains a current digitized photo, and a Machine Readable Zone (MRZ), eliminating issues during inspections in the EU.
Conclusion
Ukrainian legislation (Resolution No. 1202) protects citizens by extending the validity of old passports without photos during the period of martial law. Legally, you remain in possession of a valid document.
However, practical reality in Europe dictates its own conditions. Banks, digital services, and state authorities of EU countries require current biometric identification. Physical photo insertion abroad is impossible.
Therefore, if you plan to reside abroad long-term and wish to avoid account blockages, the most reliable strategic solution is the planned replacement of the outdated “booklet” with a modern ID card through DP “Dokument” services.
If you have already encountered a refusal of service, if a bank rejected your document, or if you need to determine a future legal regularisation strategy, our specialists can help find a solution. In complex cases, a detailed situational analysis is conducted first to select the optimal path.
Professional Support
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DISCLAIMER: Information is current as of February 2026. Poland Documents is not a government body. Services are advisory in nature.
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Source: Poland Documents