The RPR Coalition supports the statement of the National Ukrainian Youth Association regarding the draft law on amendments to the Law of Ukraine “On the Basic Principles of Youth Policy” and some other laws to promote the development of youth policy (registry No. 12298).

The text of this draft law was registered without prior discussion or debate directly with young people, including those in communities, and public organizations working with youth. Such an approach is non-inclusive and unacceptable from the perspective of the principles of the Council of Europe and the European Union regarding youth participation in decision-making processes.

Proposals for the creation of youth councils under ministries, other central executive authorities, enterprises, institutions, and organizations of state and municipal ownership discredit youth councils as a tool for youth participation and as an advisory body. Such changes will lead to the mass creation of formal youth councils controlled by the leadership of these ministries and institutions, simulating youth policy. We draw attention to the negative experience of the effectiveness of existing youth councils under ministries, which were established without considering principles of transparency and openness.

We consider the proposals for the formation and operation of the so-called “Youth Council under the Cabinet of Ministers of Ukraine” to be threatening. Its composition is proposed to include only representatives of youth councils under ministries, the Youth Affairs Council under the President of Ukraine, members of the Ukrainian Parliament (selected by the relevant committee), and the Minister of Youth and Sports. In practice, such a composition will not represent the views of Ukrainian youth but rather a one-sided position of government and state bodies. We categorically oppose the exclusion of representatives of youth public organizations, student self-government bodies, and local youth councils from this body – this violates the principle of equality and broad representation of various youth communities.

This position contradicts the vision outlined in documents developed by youth policy experts under the coordination of the RPR Coalition.

We also do not support the further existence and financing of the state institution “All-Ukrainian Youth Center.” Youth centers should be oriented not toward “coordination from Kyiv” but toward the needs of local communities. Despite repeated calls from civil society, over the past five years, a supervisory board for the All-Ukrainian Youth Center has not been created.

The draft law emphasizes that the Ukrainian Youth Fund is accountable and subordinate to the Ministry of Youth and Sports. On the contrary, we want to emphasize that the fund will only be effective if its activities are independent of the Ministry of Youth and Sports, having the status of a budgetary funds manager and an independent supervisory board separate from the Ministry of Youth and Sports.

The argument of the draft law’s initiators that this law supposedly unblocks the financing of the Ukrainian Youth Fund from the State Budget of Ukraine is manipulative since the Law of Ukraine “On the Basic Principles of Youth Policy” already provides for such funding. However, it has been blocked by the Resolution of the Cabinet of Ministers of Ukraine dated February 28, 2023, No. 182 “Certain Issues of the Ukrainian Youth Fund,” according to paragraph 3 of which, for the duration of martial law in Ukraine or in certain localities, and for six months after its termination or cancellation, the Ukrainian Youth Fund provides budget grants from international technical assistance projects and other sources not prohibited by law. The state budget only covers the maintenance of the Ukrainian Youth Fund’s directorate.

Thus, unblocking budget funding for budget grants does not require the adoption of this law.

At the same time, we note that no financial or economic calculations have been provided for the draft law, registry No. 12298.

In our opinion, the Law of Ukraine “On the Basic Principles of Youth Policy” requires fundamental changes that are not mentioned in draft law registry No. 12298. In particular, we draw attention to the following issues:

1. The lack of real, diverse institutional support for the activities of youth public organizations.
2. The need to lower the upper age limit for youth in Ukraine from 35 years to 24-27 years. In most EU countries with real youth guarantees and effective youth policy, such an age limit allows resources to be focused on those who need them most.
3. Recognition and systematic support for the category of youth leaders. In addition to youth workers, developed EU countries also recognize a second category—youth leaders, who grow within organizations of democratic governance over the years and contribute to their development.
4. The law should promote principles of integrity. Real democratic governance in youth work and youth policy is increasingly being replaced by imitative statements and demonstrative declarations.
5. All regional youth centers should primarily serve as educational bases with campsites for youth leaders and youth workers from communities, rather than merely creating the appearance of activity for a small number of young people or functioning as event agencies.
6. Real, rather than nominal, youth rights. The essence of youth guarantees should not be just another declaration of rights but the definition of mandatory functions for government bodies regarding youth work support, particularly in the Law of Ukraine on Local Self-Government.
7. Given martial law and the ongoing threat from the Moscow aggressor, changes to the law on the principles of youth policy should also include the terms and meanings defined by the Law of Ukraine “On the Basic Principles of State Policy in the Sphere of Establishing Ukrainian National and Civic Identity.” The amendments to the Law should introduce mechanisms for real participation of children and youth in youth work in Ukraine, and the format of youth policy should at the very least encourage them to remain Ukrainians.

NUMO supports the need to update the Law of Ukraine “On the Basic Principles of Youth Policy” but believes that draft law registry No. 12298, in its proposed form, will only create additional corruption risks and an illusion of youth policy reform through the use of budgetary funds.

Additionally, we inform you that the public association “National Ukrainian Youth Association” has planned to develop a new version of the Law of Ukraine that would regulate the formation and implementation of youth policy with the direct participation of youth public organizations and discussions of legislative changes among youth at the local level.

We urge you not to support draft law registry No. 12298, given the violations of youth participation principles in decision-making about youth during its preparation, as well as its reinforcement of the existing status quo.