01
Legal status
Attribution of the period spent under temporary protection and a move to a residence permit with a non-temporary purpose.
Joint legislative proposal by Ukrainian experts
National programme for the transition of Ukrainian displaced persons
From temporary protection to long-term residence, social integration and Dutch nationality
Lawyers from Ukraine working in the Netherlands have drafted a legislative initiative: a national route from temporary protection to a stable residence status with its own path to naturalisation. This is not a favour, but about properly regulating the legal position of people who have been living, working and paying taxes in the Netherlands for almost four years.
Joint legislative proposal · de lege ferenda
The document describes proposed legislative changes, not rights that already apply. It was drafted on 11 November 2026, revised on 12 November 2026, and still has to pass a constitutional, European, budgetary and administrative review before formal submission.
Core proposal
Counting the years of lawful residence under temporary protection towards naturalisation — through a targeted amendment to the Dutch Nationality Act (Article 8) — and creating a voluntary national route to stable residence, in the interest of both the displaced persons and the Netherlands.
Six directions
The programme combines six strands that reinforce each other.
02
Naturalisation
A legally regulated possibility of obtaining Dutch nationality after meeting established conditions, with the statutory period of residence as the reference.
03
Housing
From long-term municipal reception to suitable long-term housing, including the voluntary use of vacant buildings.
04
Work and education
Maintaining access to the labour market, entrepreneurship, vocational training and integration programmes.
05
Service provision
Municipal consultation points working with the IND that provide information but do not themselves decide on applications.
06
Costs and legal safeguards
A comparison of the costs of the current temporary reception system with long-term integration, plus safeguards for timely handling.
The figures behind the proposal
The substantiation rests on public statistics from CBS, WODC, SEO Economisch Onderzoek and Ipsos I&O.
43%
Would not return, not even for safety (another 37% unsure) — 75% would apply for a Dutch passport
78% → 42%
Dutch support for a «generous» reception policy (March 2022 → August 2024) — the window is narrowing
Legal foundation
The proposal builds on judgments that, in the authors’ view, compel clear procedural safeguards. They do not create an automatic right to nationality or a positive decision in an asylum case.
Court of Justice of the EU, C-249/25 (Jilin), 1 October 2026 ↗
ECLI:EU:C:2026:806 — general automatic suspension of the handling of asylum applications by persons falling under temporary protection.
District Court of The Hague, 16 October 2026 ↗
ECLI:NL:RBDHA:2026:30469 — long-term administrative deferral of applications costs the state money; a transparent long-term status addresses precisely that problem.
Administrative Law Chamber of the Council of State, 30 November 2022 ↗
ECLI:NL:RVS:2022:3353 — Article 47 of the EU Charter of Fundamental Rights guarantees a right to effective judicial protection; the state may not delay proceedings unnecessarily.
Proposed amendments
The proposal operates at two levels and contains fifteen concretely named provisions.
Dutch Nationality Act (Articles 7–10) ↗
Attribution of the period under temporary protection · special non-temporary residence purpose · special naturalisation procedure · multiple nationality and the duty to renounce · young people who reached adulthood in the Netherlands
Aliens Act 2000, Aliens Decree 2000, Aliens Circular 2000, Integration Act 2021 ↗
Residence permit with a non-temporary purpose · criteria, time limits and legal safeguards · naturalisation conditions · integration and its funding
Housing and vacancy legislation ↗
Long-term housing and protection of living conditions · deployment of vacant property · pilot in the Overbetuwe region
Phases
- Until March 2027
Legal and administrative preparation
Interdepartmental working group with the IND, VNG, the Ukrainian community, nationality-law specialists, DUO, housing organisations and human rights organisations; a roadmap for the Nationality Act and for ordinary Dutch legislation; an audit of the M35H procedure; safeguards for voluntariness and independent legal assistance.
- April – December 2027
Legislative package and pilots
Explanatory memorandum, draft legislation and budgets; feasibility testing; a pilot of information points in 20 municipalities, if budget and legal basis allow; alignment with the housing programmes.
- 2028
Possible entry into force of the new framework
If the amendments enter into force: phased access to the new permit. Naturalisation applications only where individual conditions are met. Regardless of the reform, the regular asylum procedure and housing standards continue to apply.
- 2029 – 2031
Evaluation and adjustment
Annual publication of processing times, costs, housing, participation and complaints; independent evaluation determines whether the criteria, funding or scope of the programme need adjustment.
Requests to the ministry
The authors ask the responsible ministries, the IND, VNG and other competent bodies to, among other things:
- Start an official discussion on a legislative package that creates a national route to stable residence, with separate attribution of the years of temporary protection for naturalisation.
- Give legal advice on an amendment to Article 8 of the Dutch Nationality Act and on a possible special transitional arrangement at Kingdom level.
- Examine a non-temporary residence purpose in the Aliens Act/Decree/Circular, with criteria, time limits and legal safeguards.
- Work out the procedure for Aruba, Curaçao and Sint Maarten to participate in nationality legislation, and assess the implications of Article 9 of the Nationality Act for multiple nationality.
- Communicate how many Ukrainian M35H applications remain undecided, how long processing takes and how the backlog will be cleared — and how the judgments of 16 October 2026 are being implemented.
- Invite Ukrainian organisations, including ULCNL, to the consultations on an equal procedural footing, and provide a written reply naming the responsible bodies, evaluation deadlines and follow-up steps.
The document itself
The full text of the proposal — fifteen provisions, the financial substantiation, the matrix of competences and the questions for formal legal review — is deliberately not published on this website. It is a working document that still requires testing, alignment and political discussion before it can be formally submitted. The text is available on request.
Prepared by: ULCNL Bennebroek (Ukrainian Legal Chamber in the Kingdom of the Netherlands) together with Key Legal Factors B.V. — legal analysis of 11 November 2026, revised version of 12 November 2026.
Help shape the details
The Chamber is looking for lawyers from Ukraine working in the Netherlands who want to contribute to the next phase: the legal drafting, the preparation of the consultations and the safeguarding of the procedural equality of Ukrainian organisations.