Construction of Protective Structures in Ukraine 2025: Complete Guide to DBN, Design, and Legal Responsibility

The current security situation in Ukraine has fundamentally changed approaches to civil protection, transforming it from a theoretical discipline into an urgent national priority. The construction of new, modern, and effective protective structures has become a fundamental aspect of urban planning, public safety, and corporate responsibility. This transformation requires all participants in the construction process — from architects and engineers to developers and property owners — to have a deep understanding of the complex and dynamic regulatory framework.

The regulatory landscape has undergone a complete overhaul with the adoption of the fundamental document — DBN V.2.2-5:2023 “Protective Structures of Civil Protection.” These norms, which came into effect on November 1, 2023, replaced the outdated standard DBN V.2.2.5-97 and marked a complete revision of approaches to designing and constructing shelters.

Special attention should be paid to regulations relevant for 2025. The regulatory framework is not static; it is constantly improving based on practical experience gained. Of key importance are Amendment No. 1 and especially Amendment No. 2 to DBN V.2.2-5:2023. The latter, which comes into effect on April 1, 2025, introduces critically important updates regarding emergency exits, fire safety, and life support systems.

This article is a comprehensive professional guide designed to navigate the complex technical and legal requirements for constructing compliant and effective protective structures in Ukraine as of 2025. It provides detailed analysis of key regulatory documents, procedural stages, and legal responsibility, serving as a roadmap for all involved in creating safe spaces for citizens.

Section 1: Classification and Scope of 2025 Standards

Understanding the classification of protective structures and the scope of application of state building codes is the first and most important step in any project related to civil protection. DBN V.2.2-5:2023 establishes a clear hierarchy and terminology that defines the level of protection, structural features, and engineering equipment for each type of facility.

1.1. Key Concepts and Classification

The regulatory framework defines three main types of protective structures subject to regulation, each with its specific purpose and level of protection:

1. Shelter: This is a hermetic structure that provides the highest level of population protection. It is designed to protect against hazardous factors arising from emergencies, military actions, or terrorist acts, including the effects of nuclear weapons (shock wave, penetrating radiation, light radiation), as well as bacteriological (biological) and chemical substances. The key feature of a shelter is its hermeticity and the presence of complex life support systems, such as filter-ventilation units (FVU) for air purification and air regeneration systems.
2. Anti-radiation shelter (ARS): This is a non-hermetic structure whose main function is to protect the population from external ionizing radiation arising from radioactive contamination of the area. ARS also provides protection against conventional weapons, shock waves, and fragments. Its design and engineering systems are less complex compared to shelters.
3. Dual-purpose structure (DPS): This is a structure that in peacetime is used for economic, cultural, or domestic needs (for example, underground parking, shopping centers, sports halls, subway stations), but is designed in such a way that in case of an emergency it can perform the protective functions of a shelter or anti-radiation shelter. The DPS concept is key to modern urban development, as it allows integrating protective infrastructure into the daily life of the city, ensuring its effective use and maintenance.

It should be noted that there are also simplest shelters (basements, ground floors), which do not fall under the strict requirements of DBN V.2.2-5:2023 for new construction, but separate recommendations from the State Emergency Service exist for their arrangement. This guide focuses on the first three categories, which require formal design, expertise, and construction in accordance with current standards.

1.2. Scope of Application of DBN V.2.2-5:2023

The state building codes DBN V.2.2-5:2023 are mandatory for application in the following cases:

1. New construction and reconstruction of civil protection structures (shelters, ARS) and dual-purpose structures.
2. Design of protective structures as part of residential and public buildings, including facilities with mass occupancy, such as schools, kindergartens, healthcare institutions, and other critical infrastructure objects.
3. The standards may be partially or fully used for designing major repairs of existing protective structures to restore their operational performance and protective properties.

Exceptions: It is important to note that the requirements of these standards do not apply to the design of structures intended for sheltering personnel of military units of the Armed Forces of Ukraine, which are regulated by separate departmental standards.

The regulatory framework is a dynamic, adaptive system. The rapid adoption of DBN V.2.2-5:2023 at the end of 2023 and subsequent implementation of Amendment No. 1 and Amendment No. 2 over a short period indicates that the state is actively codifying lessons learned from real combat actions. This is not a static set of rules, but a living document that evolves. For example, Amendment No. 2, which becomes mandatory in April 2025, introduces extremely practical updates regarding backup power for communication systems and fire safety for diesel generators. These changes directly respond to vulnerabilities identified during prolonged attacks: loss of communication and fire risks from improvised power sources. This means that industry professionals cannot rely on one-time study of standards; they must continuously monitor updates from the Ministry of Development of Communities, Territories and Infrastructure of Ukraine. For developers and designers, this means that design plans must be flexible and future-oriented. A project that complies with standards at the beginning of lengthy construction may require modification to comply with new rules that appear before its completion.

Table 1: Classification and main characteristics of protective structures

Section 2: Architectural-Planning and Structural Requirements

Compliance with architectural-planning and structural requirements is the foundation for creating an effective and safe protective structure. DBN V.2.2-5:2023 establishes detailed and strict rules regarding facility placement, internal planning, and structural strength.

2.1. Placement Requirements

The correct choice of location for protective structure construction is critical for its functionality and people’s safety. Standards establish the following key criteria:

1. Accessibility radius: Structures should be located within walking distance from residential buildings, workplaces, and public facilities. The specific radius is determined by urban planning documentation, but general guidelines are up to 300-500 meters depending on development density.
2. Protection from secondary damage factors: The facility must be maximally protected from potential flooding by groundwater or rainwater. It should also be located outside zones of possible debris that may form as a result of destruction of neighboring, especially high-rise, buildings.
3. Placement prohibitions: It is categorically prohibited to place protective structures under industrial and warehouse premises where tanks with hazardous chemical liquids, furnaces with molten metals, or other objects are located, the destruction of which may lead to release of hazardous substances and injury to people in the shelter.

2.2. Spatial Planning Solutions

The internal organization of shelter space must ensure not only protection, but also the possibility of prolonged and relatively comfortable stay for people.

1. Room composition: The design must obligatorily provide for clear zoning. The structure includes:
   • Main rooms for direct sheltering of people.
   • Sanitary-hygienic facilities (toilets, washbasins).
   • Rooms for ventilation equipment (filter-ventilation chambers).
   • Rooms for autonomous power sources (diesel power plants).
   • Medical posts or sanitary post areas.
2. Area and height standards:
   • Minimum area per person in main shelter rooms is 0.6 m². This standard does not include area occupied by corridors, toilets, and technical rooms.
   • For educational institutions (schools, kindergartens), an increased recommended standard is established — 1.0 m² per person, taking into account children’s needs for more space.
   • Minimum room height from floor to ceiling must be at least 2.0 meters.
3. Space arrangement: Standards also regulate seating space dimensions (at least 0.45×0.45 m per person) and lying spaces (0.55×1.8 m). This allows designers to accurately calculate the real capacity of the structure.
4. Evacuation routes: The width of corridors and ramps used for evacuation is a critical parameter. It must be at least 1.8 m for new construction and 1.5 m for reconstruction.

2.3. Structural Requirements and Loads

Load-bearing and enclosing structures are the main element providing the protective properties of the structure. They must be designed to withstand extreme loads.

1. Protection against threats: Structures (foundations, walls, floors) must provide protection against a complex of damaging factors: shock wave action, penetrating radiation, light radiation, and radioactive contamination of the area.
2. Design loads: DBN V.2.2-5:2023 contains detailed calculation methods and tabular data that define shelter classes and ARS groups depending on the excess pressure in the air shock wave front that they must withstand. These parameters are initial data for structural engineers when choosing materials and calculating cross-sections of structural elements.
3. Specialized protective elements: To ensure hermeticity (in shelters) and protect the internal volume from shock wave penetration, the design must include special structures:
   • Protective-hermetic and hermetic doors, gates, hatches: They have a special design that ensures tight fit and ability to withstand design loads.
   • Airlock chambers: These are intermediate rooms between the external environment and the main shelter room, equipped with two hermetic doors. They allow people to enter and exit without violating the hermeticity of the main volume.

Table 2: Design loads and protection classes (based on DBN V.2.2-5:2023 data)

Section 3: Key Changes 2025: Detailed Analysis of Amendment No. 2 to DBN V.2.2-5:2023

Amendment No. 2 to DBN V.2.2-5:2023, which comes into effect on April 1, 2025, is the most current and important evolution of safety standards. It is based on practical experience gained under real threat conditions and introduces a series of critical clarifications and new requirements. Compliance with its provisions is mandatory for all projects developed and implemented from this date.

3.1. Revolution in Emergency Exit Requirements

Amendment No. 2 introduces significant differentiation and detail of evacuation route requirements depending on structure capacity, allowing for more flexible and justified design solutions.

1. For structures with capacity up to 15 people inclusive: Significant simplification has been introduced, which has great practical significance for small facilities. Now it is allowed to arrange only one main entrance provided there is an alternative emergency exit in the form of a protective hatch. Requirements for such a hatch are clearly regulated:
   • It must be located on the opposite side from the main entrance.
   • Must open outward to avoid blocking from inside.
   • Minimum clear dimensions are established: 0.6×0.9 m for ceiling hatches and 0.8×1.5 m for hatches in external walls. This provides a practical and economically effective solution for small private or corporate shelters.
2. For structures with capacity of 16 people and more: Requirements remain strict. The structure must have at least one emergency exit located outside zones of possible debris from neighboring buildings. This is a critical safety measure that prevents situations where people are blocked inside the shelter by debris from destroyed structures.

3.2. Guaranteed Communication and Information

One of the key innovations is strengthening requirements for information resilience and communications, reflecting understanding of the importance of information in crisis situations.

1. A new, strict requirement has been established regarding provision of backup or alternative power supply for all electronic communication infrastructure. This applies to communication systems, signal-loudspeaker devices, and electronic information boards. Autonomous operation of these systems must be ensured for at least 48 hours.
2. The design must obligatorily provide for ensuring access to the Internet, including through wireless access points (Wi-Fi), which must cover the entire territory of the structure.

These changes mark a paradigm shift from the concept of primitive bunkers to modern civil infrastructure. 48-hour communication autonomy and mandatory Wi-Fi are not just about survival; they are about maintaining situational awareness, psychological comfort, and connection with the outside world during crisis. This is recognition that information is as critical a resource as air and water. Previous standards focused on structural strength and basic life support. Amendment No. 2 adds a new level: information and communication resilience. This transforms shelters from passive waiting spaces to active hubs where people can receive updates and reduce psychological stress from isolation. For designers, this significantly complicates and increases the cost of the engineering part of the project, requiring not only a generator, but also uninterruptible power supplies (UPS), reliable cable infrastructure, and backup systems for communication equipment.

3.3. Enhanced Fire Safety and Engineering Networks

Amendment No. 2 also introduces important clarifications regarding fire safety and engineering communications routing.

1. Diesel power plants: Walls separating diesel generator rooms from areas where people stay must now be continuous fire-resistant type 1. This significantly increases the level of protection from fire that may occur as a result of generator operation.
2. Sewerage: A common practical problem when integrating shelters into existing buildings has been resolved. The amendment now clearly allows routing of internal sewerage networks through protective structure premises, but under strict condition: pipes must be placed in protective boxes or casings that provide both protection from damage and access for maintenance (cleaning, inspection).

Section 4: Integration of Related Standards: Inclusivity and Fire Safety

Designing a modern protective structure cannot be limited only to the requirements of DBN V.2.2-5:2023. This is a complex task requiring harmonious integration of standards from other key areas — inclusivity and fire safety. Non-compliance with these standards makes the project non-compliant with legislation and impossible to implement.

4.1. Inclusivity as an Unconditional Priority (DBN V.2.2-40)

Ensuring accessibility for persons with reduced mobility (PRM) is not a recommendation, but an unconditional legislative requirement when designing any public spaces, including protective structures. The standards of DBN V.2.2-40 “Inclusivity of buildings and structures” establish specific parameters that must be considered.

1. Practical implementation of accessibility:
   • Entrances and movement paths: The design must provide barrier-free access. This means no thresholds or their minimal height (no more than 1.5 cm) with beveled edges. Any stairs on PRM movement paths must be duplicated by ramps with standard slope or other lifting devices. The width of corridors and passages must be sufficient for maneuvering in a wheelchair (minimum 1.5-1.8 m).
   • Sanitary facilities: The shelter must obligatorily include at least one universal sanitary-hygienic facility accessible to people in wheelchairs, calculated as one such facility per every 200 people.
   • Navigation and information: For people with vision and hearing impairments, it is necessary to provide visual and tactile navigation systems. This includes contrast marking of first and last steps on stairs, tactile strips on floors, information signs with Braille script, and visual notification systems.

The latest updates to these standards are contained in Amendment No. 2 to DBN V.2.2-40:2018, approved at the end of 2024, emphasizing the state’s continued attention to inclusivity issues.

4.2. Comprehensive Fire Safety (DBN V.1.1-7)

A protective structure, like any other construction object, must comply with general fire safety requirements established in DBN V.1.1-7 “Fire safety of construction objects”.

1. Key aspects of fire safety:
   • Fire resistance of structures: All building materials used in the shelter are classified according to combustibility indicators (NG — non-combustible, G — combustible). Load-bearing and enclosing structures (walls, floors, columns) must have standardized fire resistance class (for example, REI 180), guaranteeing preservation of their load-bearing capacity (R), integrity (E), and thermal insulation capacity (I) for a specified time during fire.
   • Fire barriers: If the shelter is built into a larger building (for example, residential complex or office center), it must be separated into a separate fire compartment. This is achieved through fire walls and floors of type 1, which prevent fire spread from the main building to the shelter and vice versa.
   • Evacuation: The design must ensure safe and quick evacuation of people. The number, dimensions, and location of evacuation exits are clearly regulated by standards to avoid crowding. Evacuation routes must always be free, smoke-free, and properly marked.

The mandatory integration of three complex DBNs (Civil Protection, Inclusivity, Fire Safety) creates an extremely complex design task. It is practically impossible for one architect or engineer to be an expert in all three areas. This leads to situations where requirements of different standards may contradict each other: for example, heavy blast-resistant doors that comply with DBN V.2.2-5 may be extremely difficult for a person with disabilities to open, contradicting DBN V.2.2-40; or fire exits that must open easily from inside must be hermetic according to shelter requirements. This complexity explains why the state created specialized certification “Building expert in engineering and technical measures of civil protection”. The role of this expert is to be an integrator who at the design and expertise stage guarantees that the final project harmonizes these potentially contradictory requirements into a unified, compliant, and functional solution. This indicates the end of simplified approaches to shelter design and requires involvement of highly specialized consultants from the very beginning of project work.

Section 5: Project Implementation Procedure: from Idea to Commissioning

Construction of a protective structure is a strictly regulated process that requires passing through several mandatory stages, from developing design documentation to official commissioning of the facility and taking it into account.

5.1. Design Stage

At the initial stage, all key decisions are made that will determine the compliance of the future structure with regulatory requirements.

1. Design documentation for construction of facilities that require protective structures must contain a separate, mandatory section — “engineering and technical measures of civil protection”.
2. The presence of such a section is imperative for facilities that by consequence class belong to medium (CC2) and significant (CC3). This particularly applies to facilities where more than 50 physical persons will be permanently present or more than 100 persons periodically. This category includes most residential complexes, office centers, commercial and educational institutions.

5.2. Mandatory Project Expertise

No protective structure construction project can be approved without passing comprehensive state expertise.

1. According to legislation, all construction projects are subject to expertise for compliance with state building codes.
2. For protective structure projects, expertise has a special focus. It checks the quality of design solutions regarding compliance with strength, reliability, operational safety requirements, as well as standards of fire, technogenic safety and civil protection.
3. As mentioned earlier, this expertise must be conducted with participation of a certified “Building expert in engineering and technical measures of civil protection”. A positive expert report is a mandatory condition for obtaining a construction permit.

5.3. Approval and Obtaining Construction Permit

After successful passage of expertise, the project is submitted for approval to authorized bodies.

1. Depending on the facility specifics, design documentation may require additional approval from the local territorial body of the State Emergency Service of Ukraine (SES), especially regarding compliance with planning solutions and inclusion of the structure in the community’s protective structures fund.
2. Having received a positive expertise conclusion, the construction customer submits an application for obtaining a permit to perform construction work. This procedure is carried out electronically through the Unified State Electronic System in Construction (USESC).

5.4. Commissioning and Registration

Completion of construction work does not mean automatic readiness of the structure for use. The facility must undergo commissioning procedure.

1. The process includes conducting technical inventory, preparing facility readiness act, and inspection by relevant control bodies, including representatives of SES and State Architectural and Construction Inspectorate (SACI).
2. Based on inspection results, the customer receives a commissioning certificate (for CC2 and CC3 facilities) or registers a corresponding declaration.
3. After official commissioning, the structure is entered into the civil protection structures fund and registered with local authorities and SES, receiving its unique number.

Section 6: Legal Responsibility of Owners and Balance Holders

Creating a protective structure imposes not only financial but also serious legal obligations on its owner or balance holder. Ukrainian legislation establishes strict responsibility for improper maintenance and failure to provide access to shelters, which can range from significant fines to criminal punishment.

6.1. Obligations of Owners and Balance Holders

Key obligations imposed on responsible persons include:

1. Maintaining readiness: Protective structures fund facilities must be maintained in a condition that allows bringing them to readiness for intended use within established timeframes. This means regular maintenance of engineering systems, checking structural condition and availability of necessary inventory.
2. Ensuring unimpeded access: Owners are obligated to ensure round-the-clock and unimpeded access of citizens to shelters during “Air raid alert” signal. Any obstacles, such as locked doors, cluttered passages, or payment requirements for entry, are direct violations of law.
3. Proper marking: Shelter locations must be clearly marked with signs and direction indicators. A sign must be placed near the entrance indicating the shelter number, its balance holder, key storage location, and contacts of the responsible person.
4. Organizational measures for employers: Heads of enterprises, institutions, and organizations are obligated to develop internal instructions for personnel actions during alerts and appoint by order a responsible person for shelter operation, who ensures its timely opening and evacuation organization.

6.2. Types and Levels of Responsibility

Legislation clearly distinguishes administrative and criminal responsibility for violations in civil protection sphere.

1. Administrative responsibility (Code of Ukraine on Administrative Offenses):
   • For failure to ensure unimpeded access of citizens to shelter (Article 175-3 CUAOf), a fine is imposed in the amount of 1,700 to 3,400 UAH.
   • For violation of maintenance and operation requirements that led to shelter unreadiness for intended use, the fine is 2,250 to 5,100 UAH.
   • Repeated commission of any of these violations within a year carries a much stricter fine — 5,100 to 8,500 UAH.
2. Criminal responsibility (Criminal Code of Ukraine):
   • This is the strictest type of responsibility that occurs in case of severe consequences. According to Article 270-2 CCU, if violation of established legislative requirements regarding maintenance of protective structures fund objects or failure to provide access to them during alerts led to death of people or other severe consequences (for example, serious bodily injuries), the guilty official faces imprisonment for 3 to 8 years.

The legal framework deliberately personalizes risk, targeting specific individuals holding leadership positions. Key is the term “balance holder”. This is not abstract corporate responsibility; it can be a school principal, company general director, or condominium board chairman. If workplace shelter is absent or inaccessible, the employer cannot apply sanctions to the employee for leaving the workplace to seek safety. Instead, the employer himself may be held responsible for failure to provide safe working conditions. The combination of administrative fines and real risk of imprisonment creates a powerful incentive for compliance that goes beyond simple financial calculation. This forces leaders to treat civil protection as a top operational priority, on par with financial reporting or occupational safety, requiring investment not only in construction but also in constant maintenance, staff training, and development of clear operational procedures.

Conclusion

The regulatory landscape of 2025, formed by DBN V.2.2-5:2023 and its subsequent amendments, represents a fundamental modernization of approaches to creating civil protection facilities in Ukraine. There has been a final departure from outdated Soviet concepts in favor of creating multifunctional, technologically resilient, and most importantly, human-centered safe spaces.

Key conclusions for all participants in the construction process are awareness of three fundamental changes. First, mandatory integration of inclusivity standards (DBN V.2.2-40) and fire safety (DBN V.1.1-7) transforms shelter design into a complex multidisciplinary task. Second, increased technical requirements, especially regarding autonomy of life support and communication systems (Amendment No. 2), require more complex engineering solutions and significant investments. Third, strict personal responsibility, including criminal, is placed on owners and balance holders for maintaining structures in proper condition and ensuring access to them.

For developers, architects, and property owners, success in the new regulatory environment requires a proactive approach. Early involvement of highly specialized experts in engineering and technical measures of civil protection, accessibility, and fire safety is no longer an option but an absolute necessity for navigating the complex approval process and minimizing significant legal and financial risks. The era of simple “bunkers” has definitively ended; the future belongs to integrated, resilient, and accessible protective infrastructure for all.