Monitoring of public procurement in the Kherson region in January 2026



In January 2026, 182 procurements were announced in the Kherson region. Contracts were concluded under 131 procedures for UAH 39,905,468.08; 41 have not yet taken place, and 10 were at the stage of conclusion at the time of writing the report.

It should be noted that in this report, we analyzed only procedures carried out through the electronic system Prozorro; direct contracts not conducted through the system were not included in the calculations.

Details by sector

  • Educational institutions conducted 6 procurements for UAH 4,771,556.45.
  • Military units, police, and courts conducted 9 procurements for UAH 1,295,693.97.
  • Municipal enterprises conducted 8 procurements for UAH 2,554,658.34.
  • Village councils conducted 9 procurements for UAH 417,4634.34.
  • Administrations (city, regional, departments) conducted 7 purchases for UAH 1,044,633.02.
  • Social sphere (Pension Fund, employment centers) conducted 4 purchases for UAH 259,190.75.
  • The Main Department of State Tax Service in the Kherson region conducted 1 purchase for UAH 1,361,295.00.
  • Healthcare institutions conducted 87 purchases for UAH 24,206,859.94.

What interesting things did we see?

Catering for medical institutions: concentration of funds and "winners' refusals"

Among all tenders, healthcare institutions conducted 87 successful purchases for UAH 24,206,859.94. This is 47.8% of all announced tenders (87 out of 182) and 66.4% of all concluded contracts (87 out of 131).

That is, in fact, two-thirds of the contracts this month fell in the medical segment.

Food products: almost the entire budget was received by two individual entrepreneurs

Of the 87 purchases in medical institutions, 39 are food products for UAH 3,840,666.73 (≈ 15.9% of the amount of all medical purchases).

Within the “food” segment, the picture is even more concentrated:

  • Individual entrepreneur Kulish won 20 tenders for UAH 2,480,534.18 (64.6% of the food amount)
  • Individual entrepreneur Lykhatskyi won in 14 tenders for UAH 1,082,456.95 (28.2%)
  • The other 5 purchases together — UAH 277,675.60 (7.2%) between TERNOVSKYY KHLIBZAVOD LLC, PRODENERGO LLC, Individual entrepreneur Kochergin,  KSK LOGISTIK LLC, and EXPERT-SERVICE M LLC.

In fact, two individual entrepreneurs account for 92.8% of the funds allocated to food products for medical institutions in the Kherson region per month. Against this background, any recurring “non-standard” scenarios in the purchases of these suppliers become not a private story, but a market marker. In a frontline region with a limited number of suppliers, such concentration is particularly sensitive.

In Prozorro, the customer has the right to reject the winner if he has refused in writing to conclude a contract on the terms of the request (including the draft contract). This is expressly provided for in clause 64 of the Procedure approved by the Cabinet of Ministers of Ukraine, Resolution No. 822.

That is, one refusal may have normal reasons: logistics, an error in the price, the impossibility of fulfilling the conditions, etc.

But when refusals are repeated serially — and each time one wins, then refuses and the contract is drawn up by another — it is no longer about “randomness”, but about a model of behavior that affects the budget.

Individual entrepreneur Lykhatsky: repeated refusals after being determined the winner

In January 2026, we identified at least 17 procurements in which individual entrepreneur Lykhatsky A.V. submitted the lowest offer and was declared the winner. Still, he then refused in writing to conclude the contract “on the terms of the request for proposals from suppliers”, after which the customer concluded a contract with the next participant, individual entrepreneur Kulish I.V.

This is not one “random” story, but a recurring scenario with the same wording for the reason for the winner's rejection (letter/written refusal).

In the cases below, after Lykhatsky’s refusals, Kulish signed 17 contracts using the same mechanism.

The total difference between Lykhatsky’s offers and the actually signed contracts with Kulish in these 17 procurements is approximately UAH 146,127.02.

In most cases, the wording of the reason for the rejection was identical — the winner’s written refusal to sign the contract.

Against the backdrop of Lykhatsky's serial refusals, it is Kulish who becomes the "beneficiary of the second step" - he receives contracts as the next participant after the winner is rejected.

Kulish already accounts for 64.6% of the food in medical purchases per month. In addition, some of its contracts arise not through “normal competition” but through re-signing after the winner’s refusal.

Formally, such behavior does not exceed current procedures; however, its systematic repetition in an environment where the market is actually controlled by two main suppliers calls into question the actual level of competition and the economic efficiency of allocating budget resources.

When the situation works in the opposite direction, Kulish refuses

At the same time, the analysis shows that the described behavior model is not one-sided. In January 2026, at least 10 procedures were also recorded in which the individual entrepreneur Kulish I.V. submitted the lowest offer, was recognized as the winner of the selection, but then, in writing, refused to conclude a contract on the terms specified by the customer in the request for proposals for suppliers.

As a result, the customers used the same procedural mechanism: they rejected the winner's offer and concluded contracts with the next participant, who, in these cases, was the individual entrepreneur Lykhatsky A.V.

In the cases below, after the refusals of Kulish, Lykhatsky concluded 10 contracts:

The total difference between Kulish's price offers and the actually signed contracts with Lykhatsky in these procurements is approximately UAH 62,789.35.

Thus, a mirror image of the scenario is recorded: in some procedures, the winner refuses, and the next-ranked participant receives the contract, while the supplier role signs the contract in writing, leading to rotation. Formally, such actions correspond to the procurement procedure; however, their systematic nature within the segment, where the bulk of funds is concentrated with two suppliers, indicates a specific model of market functioning, in which even permissible procedural decisions can affect the final cost of contracts and the actual level of competition.

Who are these individual entrepreneurs?

Individual entrepreneur Kulish Iryna Valeriivna was registered on May 21, 2025, in  Kherson. During her work in 2025, she concluded contracts totaling more than UAH 5.57 million. In the first weeks of 2026 alone, she already concluded contracts for more than UAH 6.23 million. The main customers are medical institutions in the Kherson and Mykolaiv regions, indicating a rapid increase in supply volumes in the budgetary institutions segment.

Individual entrepreneur Lykhatsky Andrii Volodymyrovych was registered on July 17, 2025, and quickly became an active participant in public procurement. In 2025, he received contracts for UAH 1.32 million, while by the beginning of 2026, he already had more than UAH 3.35 million. As in the case of individual entrepreneur Kulish, the key customers are medical institutions of the Kherson and Mykolaiv regions.

Thus, both suppliers, registered several months apart and already in the first year of operation, operate budget contracts worth millions of hryvnias and hold a dominant share in the food supply segment for medical institutions in the region.

Conclusion

Taken together, the analyzed cases demonstrate that in January 2026, a recurring practice was formed in the segment of food purchases for medical institutions in the Kherson region, which can be conditionally described as “cross-refusals”. In at least 27 procedures, one of the two key suppliers was determined to be the winner based on the lowest offer. Still, after the selection was completed, he refused to conclude the contract in writing, which led to the signing of a contract with the next participant. At the same time, the roles of individual entrepreneurs Lykhatsky and Kulish in different procurements changed.

In all 27 procedures, customers did not receive the lowest-priced offer.

The total difference between the lowest offers and the contracts actually concluded in these procedures is approximately UAH 208.9 thousand. On the scale of each individual procurement, this difference may seem insignificant; however, its systematic repetition within one month and across one segment creates a stable additional financial effect and affects the final procurement cost for budgetary institutions.

Formally, all recorded actions complied with the prescribed procedures, and the fact of the winner's refusal is not a violation. At the same time, the mass and mirror repetition of such a scenario in a segment where the main amounts of funds are concentrated with two suppliers calls into question the actual level of competition. It indicates the presence of a market model in which even formally competitive procedures do not always provide the minimum price for the customer.

Download the interactive report at the link.

This material has been produced with the support of the European Endowment for Democracy (EED). Its contents do not necessarily reflect the official opinion of EED. Responsibility for the information and views expressed in this publication lies entirely with the author(s).

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