The share of those suppliers of Ukraine’s State Operator For Non-Lethal Acquisition (DOT) that had been affected by restrictive measures due to contract violations does not exceed 1%. As of June 2025, there were only seven of them.
The relevant statement was made by Deputy Head of the Reorganization Commission for the State Operator For Non-Lethal Acquisition (DOT) Dmytro Bihunets in a commentary to Ukrinform.
“We have a really low percentage of contract non-fulfillment, if we take all the companies that DOT is working with. Speaking of the unique cases of restrictive measures, it is about 1%. Between October 2024 and June 2025, there were only seven companies that we were forced to exclude from the list of suppliers for certain reasons,” Bihunets told.
In his words, from the moment of the decision to exclude the company from DOT-organized procurements, the company has five days to appeal it. If the decision is confirmed, the supplier is disqualified for a period of one calendar year.
The most common reasons for the application of restrictive measures are the supply of low-quality products and failure to fulfill the contract.
“Firstly, contract non-fulfillment, i.e. when no contracted goods were delivered. Secondly, the supply of poor-quality or counterfeit products, i.e. products not confirmed by relevant documents. There are cases of violation of anti-corruption requirements. For example, when a supplier at some stage uses raw materials originating from an aggressor country, Belarus or Iran. This is also an automatic basis for the application of restrictive sanctions,” Bihunets explained.
At the same time, the procedure allows companies to remove restrictive measures and return to the list of suppliers. For this purpose, they need to pay all penalties imposed by DOT, waive any legal claims against the state-owned enterprise (if any), and undertake anti-corruption obligations to comply with DOT’s anti-corruption programme.
“If these three conditions are met, the supplier may have the restrictive measures lifted early, but not earlier than three months after their application. If, after being reinstated on the list, the supplier commits a similar act again within a year, a more stringent approach will be applied to them,” Bihunets added.
Currently, a similar ‘sanctions track’ is being developed for unscrupulous suppliers of weapons and military equipment acquired via the Defense Procurement Agency (DPA). However, there are application nuances here, as the most important thing is to maintain continuous supplies.
A reminder that the Ukrainian Defense Ministry and the Ukrainian Council of Defence Industry agreed on joint steps in the field of ensuring the quality of defense products. Further interaction between the ministry and the private sector will include the implementation of quality management systems at privately-owned enterprises in accordance with military standards, which are identical to those of NATO’s Allied Quality Assurance Publications (AQAP) series.
Photo: DOT
Source: Share of unscrupulous suppliers for Ukraine’s DOT not exceed 1%
