Objections to a Response to a Statement of Defence in Ukraine: Time Limit, Content and a Template

Objections are the defendant’s last document in the exchange of statements on the merits of the case: statement of claim – statement of defence – response to the statement of defence – objections. In them, the defendant answers what the claimant wrote in the response to the statement of defence. Below: who files objections and when, what to include, a template structure and the differences between civil, commercial and administrative proceedings. How the earlier documents are prepared is explained in our articles “Statement of Defence in Ukraine” and “Response to a Statement of Defence in Ukraine”.

What objections are

Objections are one of the statements on the merits of the case, alongside the statement of claim, the statement of defence, the response to the statement of defence and explanations of a third party (part 2 of Article 174 of the Civil Procedure Code of Ukraine (CPC)). Participants set out their claims, objections, arguments, explanations and considerations in writing exclusively in statements on the merits of the case (part 1 of Article 174 CPC).

In the objections, the defendant sets out their explanations, considerations and arguments on the explanations, considerations and arguments given by the claimant in the response to the statement of defence, and the reasons for accepting or rejecting them (part 1 of Article 180 CPC). The objections are signed by the defendant or their representative (part 2 of Article 180 CPC).

Filing objections is not mandatory: filing statements on the merits of the case is a right of the participants (part 4 of Article 174 CPC). However, in the simplified procedure the court examines the evidence and the written explanations set out in the statements on the merits of the case (part 8 of Article 279 CPC) – so the objections may be the defendant’s last opportunity to answer the claimant’s new arguments in writing.

“Objections to the statement of defence” or “to the statement of claim” – is that right?

No – these are common but inaccurate names. The defendant contests the claim in the statement of defence (part 1 of Article 178 CPC). The claimant answers the statement of defence in the response to the statement of defence (part 1 of Article 179 CPC). The defendant then files objections to the claimant’s response (part 1 of Article 180 CPC). In other words, the document “against the statement of claim” is the statement of defence, and the one “against the statement of defence” is the response to it.

Time limit

Objections are filed within the time limit set by the court. The court must set it so that the other participants receive the objections in good time before the hearing on the merits begins (part 4 of Article 180 CPC).

In the simplified procedure, the court sets the time limit for objections in the ruling opening proceedings (part 2 of Article 278 CPC). The first court hearing is held no later than thirty days from the opening of proceedings; if the objections were not filed before it for good reasons, the court may adjourn the hearing on a party’s motion to give additional time for them (part 4 of Article 279 CPC).

Running out of time? File an application to extend the time limit before it expires: a time limit set by the court may be extended on a participant’s application or on the court’s own initiative (part 2 of Article 127 CPC). Documents filed after a procedural time limit has expired are left without consideration, except in cases provided for by the code (part 2 of Article 126 CPC).

What to include in the objections

The rules of parts 3–5 of Article 178 CPC, established for the statement of defence, apply to objections (part 3 of Article 180 CPC). So the objections should state:

• the claimant’s name and the case number (item 1 of part 3 of Article 178 CPC);
• the defendant’s details: full name, registered address or place of residence (stay), postcode, EDRPOU code, individual tax number (RNOKPP), if any, or passport number and series, means of communication, email address (if any), and whether the defendant has an electronic cabinet (item 2 of part 3 of Article 178 CPC);
• if the defendant accepts the claim in full or in part – which claims are accepted (item 3 of part 3 of Article 178 CPC);
• the arguments in the response with which the defendant agrees (item 4 of part 3 of Article 178 CPC);
• objections to the claimant’s explanations and arguments with which the defendant disagrees, with references to evidence and legal provisions (item 5 of part 3 of Article 178 CPC);
• a list of the documents and evidence attached, and of evidence that cannot be submitted, with the reasons (item 6 of part 3 of Article 178 CPC);
• where needed – objections to the amount of the claimant’s legal costs and a preliminary estimate of the defendant’s own costs (items 7 and 8 of part 3 of Article 178 CPC).

Copies, evidence and accepting circumstances

• a copy of the objections and the attached documents is sent (provided) to the other participants at the same time as they are filed with the court, and documents confirming this are attached (part 4 and item 2 of part 5 of Article 178, read with part 3 of Article 180 CPC);
• if you file the objections electronically, proof of sending them to the other participants is mandatory: they are sent to their electronic cabinets, and if a participant has no cabinet or nothing is known about one, in paper form by letter with a list of contents (part 7 of Article 43 CPC);
• the defendant must submit evidence together with the statement of defence (part 3 of Article 83 CPC); evidence not submitted within the time limit is not accepted unless the person shows that they could not submit it in time for reasons beyond their control (part 8 of Article 83 CPC) – so for any new evidence, explain expressly why it was not submitted with the statement of defence;
• be careful when accepting circumstances: circumstances accepted in statements on the merits of the case do not need to be proven unless the court has reasonable doubts about their accuracy or the voluntariness of the acceptance (part 1 of Article 82 CPC), and the court accepts a withdrawal of such acceptance only in the cases set out in part 2 of Article 82 CPC.

What happens if you do not file objections

The code sets no separate consequences for objections like those for the statement of defence (deciding the case on the materials available – part 8 of Article 178 CPC): part 3 of Article 180 CPC extends to objections only parts 3–5 of Article 178. But the claimant’s arguments in the response will then remain without a written answer from the defendant.

The CPC does not provide for a separate statement on the merits in reply to objections. The court may allow a participant to submit additional explanations on a particular issue that has arisen in the case if it considers this necessary (part 5 of Article 174 CPC).

Template structure of objections

• Heading: name of the court; case number; judge; the claimant; the defendant – details under item 2 of part 3 of Article 178 CPC; other participants in the case.
• Title: “Objections” (you may specify: “to the response to the statement of defence”).
• Introduction: “On ___ the defendant received the claimant’s response to the statement of defence in case No. ___. These objections are filed within the time limit set by the court’s ruling of ___.”
• Arguments of the claimant that the defendant accepts (if any).
• Objections, point by point: “The claimant’s argument that ___ is unfounded because ___ (evidence: ___; legal provision: ___).”
• Evidence (if any): what it is and why it was not submitted together with the statement of defence (part 8 of Article 83 CPC).
• Legal costs: objections to the amount of the claimant’s costs, a preliminary estimate of the defendant’s own costs (if any).
• Request: “The defendant maintains the position set out in the statement of defence and asks the court to dismiss the claim.”
• Attachments: list of evidence (if any); documents confirming that copies were sent to the other participants; a document confirming the representative’s authority if it is not yet in the case file.
• Date and signature.

Commercial and administrative proceedings

• CommPC. Objections are governed by Article 167 of the Code of Commercial Procedure of Ukraine (CommPC): content and time limit – as under the CPC (parts 1 and 4 of Article 167 CommPC); in the simplified procedure, the time limit is set in the ruling opening proceedings (part 2 of Article 251 CommPC). However, the CommPC extends to objections the rules of parts 3–6 of Article 165, including part 4: if the statement of defence does not indicate that the defendant disagrees with a circumstance on which the claim is based, the defendant loses the right to dispute it at the hearing on the merits, save for the exceptions provided (part 3 of Article 167, part 4 of Article 165 CommPC). So in a commercial case, state your disagreement with every circumstance already in the statement of defence, and in the objections answer each new argument of the claimant expressly.
• CAP. Objections are governed by Article 164 of the Code of Administrative Procedure of Ukraine (CAP): content and time limit – as under the CPC, and the rules of parts 2–4 of Article 162 CAP apply to objections (parts 1–3 of Article 164 CAP). In the simplified procedure, the time limit is set in the ruling opening proceedings (part 2 of Article 261 CAP). The court may allow additional explanations on a particular issue in the same way as in civil proceedings (part 5 of Article 159 CAP).

This material is general in nature and is not a substitute for advice on your specific situation; the law is stated as at November 2026.

Need to answer the claimant’s arguments? An advocate will prepare the objections and your position in the case → Civil and commercial disputes · Commercial disputes · Administrative disputes