Resolution No. 869 of the Cabinet of Ministers of Ukraine dated 1 July 2026 regulated the procedure for the provision of state subsidies for school meals in 2026 by amending the Procedure and Conditions approved by Resolution No. 1456 of the Cabinet of Ministers of Ukraine dated 27 December 2024. From 1 September 2026, the categorisation principle is abolished, and free, once-daily hot meals funded from the state budget will be provided to all schoolchildren in Grades 1–11 (12) of general secondary education institutions where teaching is organised on a full-time or blended basis, as well as to children under educational supervision (provided that lessons take place at the educational institution). For communities near the front line (in particular, in Dnipropetrovsk, Zaporizhzhia, Mykolaiv, Odesa, Sumy, Kharkiv, Kherson, and Chernihiv regions), which have been providing meals for all grades since last year through local programmes and assistance from the UN World Food Programme, this change will not cause any significant disruption.
The total amount of the state subsidy allocated in the State Budget of Ukraine for the provision of hot meals to schoolchildren in Grades 1–11 for 2026 is UAH 14.4 billion, of which UAH 8.5 billion has been allocated for September–December 2026. By Resolution No. 869 of the Cabinet of Ministers of Ukraine dated 1 July 2026, UAH 7.45 billion was allocated between the regional budgets and the city of Kyiv for the period September–November 2026.
Therefore, when organising procurement procedures, special attention should be paid to the amendments to Resolution No. 1178 of the Cabinet of Ministers of Ukraine dated 12 October 2022, which come into force on 1 September 2026. In particular, a negotiated procurement procedure is introduced instead of the direct conclusion of contracts under paragraph 13; the minimum period for the submission of tender bids in open tenders is set at no less than 15 days; and the mandatory threshold for the use of open tenders or the Prozorro Market catalogue has been raised to UAH 200,000 for goods and services. To ensure the continuity of food supplies at the start of the new academic year or during transitional periods, communities can exercise their right to extend existing food procurement contracts by up to 20% of the original value (according to the Law “On Public Procurement”) or purchase food quickly via the electronic catalogues of the Centralised Procurement Organisations . Communities that have entered into long-term food supply contracts by 1 September 2026 must check whether the terms of those contracts allow for an increase in the number of service recipients without breaching public procurement legislation.
In the case of catering or outsourced meal provision, the state subsidy covers only the cost of food (ingredients) within the prescribed limits – UAH 50 for Grades 1–4 (or UAH 35 in the UN World Food Programme zone) and UAH 60 for Grades 5–11. Services relating to food preparation, delivery, logistics, chefs’ wages, and the supplier’s profit are funded from the local budget. In the service performance reports, the supplier is required to itemise the cost of food ingredients and the cost of related services as separate line items. If the total cost of the outsourced service exceeds the maximum limit (for example, in a frontline community the cost is UAH 90, of which UAH 60 is for food and UAH 30 is for the service), the subsidy and the UN World Food Programme will cover only the maximum amount of UAH 50, whilst the remaining 10 UAH for food and 30 UAH for the service (totalling 40 UAH) will be paid from the local budget. The legal distinction between the types of procurement should also be borne in mind: whilst in contracts for the supply of foods, the unit price may be adjusted in the event of market price fluctuations, no such price adjustment is provided for in long-term contracts for the procurement of catering services.
An important administrative step for local governments is the adoption of a resolution by the local council to approve the cost of school meals. The regional state administration allocates subsidies to communities based on the cost specified in the resolution of the local council. If the council approves a cost of UAH 40 per portion for senior grades with a permitted standard of UAH 60, the subsidy from the regional budget will be allocated at a rate of UAH 40, and the community will lose the difference. The cost specified in the resolution must correspond to the actual estimated requirement within the range of UAH 50–60 (depending on the grade). With regard to the requirements of the State Service of Ukraine for Food Safety and Consumer Protection, educational establishments and suppliers do not need to urgently review their HACCP (Hazard Analysis and Critical Control Points) systems by 1 September – adjustments to HACCP procedures are planned throughout the academic year. However, HACCP should include measures to ensure that the correct storage temperatures for perishable foods are maintained during power cuts and that alternative power sources are used.
Meanwhile, communities should bear in mind that the maximum allowable costs for food do not automatically cover the actual expenses. In a number of communities, due to inflation, logistical challenges, the remoteness of localities, or the need to meet food quality standards, the actual cost of the food component already exceeds the set limits of UAH 50 or 60. In other words, the cost of school meals may exceed the established limits, but the difference from the approved maximum amounts is covered by the local budget. Local governments therefore need to assess the financial implications in advance and determine a mechanism to cover the difference using local budget funds, review the cost of meals, optimise menus in line with the standards set out in Resolution No. 305 of the Cabinet of Ministers of Ukraine dated 24 March 2021, or change the model for organising school meals. Failure to address this issue may lead to a shortfall in budgetary allocations already in the middle of the academic year or to the need to amend the local budget.
In case of a forced suspension of full-time schooling or a sudden switch by a general secondary school to distance learning due to a security situation, purchased foods shall be written off on the basis of a report by the quality control or internal commission of the school, according to Resolution of the Cabinet of Ministers of Ukraine No. 305 dated 24 March 2021, without the need for a separate decision by the council. If ready-made meals (catering) have already been delivered to the school during an emergency, the food is served to the children in the bomb shelter. If there is a prolonged power cut or shelling, Resolution of the Cabinet of Ministers of Ukraine No. 305 dated 24 March 2021 permits the use of subsidy funds to purchase ready-made food products (catering items) in line with the list set out in Annex 16 to this Resolution of the Cabinet of Ministers of Ukraine.
Where there is a shortage of places in the dining hall, Resolution No. 809 of the Cabinet of Ministers of Ukraine dated 24 June 2026 permits the use of adapted premises (classrooms, recreation rooms, bomb shelters) provided that five mandatory requirements are met: hand washing, wet cleaning, ventilation, waste collection, and the use of thermal containers. By 1 September, communities should decide on the cost of meals and make provision for co-funding the services.
In the nutshell, it is important for communities to remember that the obligation to provide meals for children from priority groups remains unconditional and a priority. Along with this, Resolution No. 869 of the Cabinet of Ministers of Ukraine dated 1 July 2026 grants communities the right and a real opportunity to provide free hot meals to all students in Grades 1–11. However, exercising this right requires common sense and a pragmatic approach: it is necessary to assess actual attendance figures whilst recognising that some secondary school students will, for objective reasons, choose not to eat school meals.
In order to ensure that the funds cover real needs, the subsidies are first allocated to the regional state administrations. Regional administrations will redistribute resources between communities after verifying the actual number of students in general secondary education institutions in the AIKOM system – based on the results of monitoring conducted after 15 September and after 15 November – in order to receive (where necessary) additional funding from the reserve of UAH 1.05 billion, it is therefore essential to ensure that data is entered into the AIKOM system in a timely manner. By 1 December, communities must submit their estimated requirements for 2027 to the Regional State Administration and submit monthly reports in line with the Annex to Order No. 1456 on the Procedure and Conditions for the Allocation of Subsidies from the State Budget to Local Budgets for the Provision of Meals to Students in General Secondary Education Institutions, based on three organisational models: community-based catering, catering, and outsourcing.
This flexible approach will help prevent the accumulation of unused funds and ensure that state support is channelled to where children really need it. At present, the relevant ministries (the Ministry of Education and Science and the Ministry of Economy) are preparing a series of clarifications on the application of public procurement legislation in the context of the above-mentioned changes and taking into account key questions raised by communities.
Detailed information on the expansion of the free school meals programme from 1 September 2026, the updated rules for implementing the reform, the challenges that communities face, practical solutions for organising free meals for students, and answers to topical questions from representatives of communities are available in the webinar recording at this link.
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