State Enterprise (SE) «Document,» an entity under the State Migration Service of Ukraine (SMSU), has engaged a private intermediary — Financial Company «Payment Center «HERZ» LLC — to process payments for passport issuance and other administrative services. Amid a surge in demand for travel documents among Ukrainians abroad, the company, linked to businessman Kostiantyn Tkach, charges a fee of 3% + 10 UAH on every transaction without offering applicants alternative payment methods on-site.
Following the start of the full-scale invasion, the workload at SE «Document» grew significantly as millions of Ukrainian refugees sought legal status and updated passports. However, citizens turning to the state enterprise face a lack of payment options. During application processing, applicants are provided with payment details routing exclusively through the «HERZ» platform, effectively preventing the use of other payment services on the spot.
No public contract between the state enterprise and the payment intermediary is available in the public domain. The fee structure is confirmed solely through the company’s internal tariffs on its website. Nevertheless, in late 2024, Olena Kyselyova, Commercial Director of FC «HERZ» LLC, publicly cited the launch of payment processing for SE «Document» as one of the company’s key achievements of the year.
The partnership between the state enterprise and Kostiantyn Tkach’s group of companies comes alongside recurring scrutiny from law enforcement. The Bureau of Economic Security (BES) has repeatedly opened criminal proceedings under Article 212 of the Criminal Code of Ukraine (tax evasion). Investigations involving companies in the group have been ongoing since 2021–2022, with searches conducted at the group’s Odesa office as recently as July.
Concurrently, the State Audit Service of Ukraine uncovered financial violations totaling 71 million UAH at SE «Document.» These included unjustified bonuses and allowances, as well as procurement irregularities exceeding 52 million UAH conducted without proper competitive procedures.
Industry experts point out that numerous payment gateways with lower fees operate in the market, including LiqPay (typically 1.5–2.75%), Portmone, WayForPay, EasyPay, and NovaPay. Additionally, direct wire payments via banking apps like Privat24, monobank, or Oschad 24/7 offer viable alternatives. A working model already exists within the Ministry of Internal Affairs Service Centers, which implemented an in-house «Payment Hub» that generates a single QR code payable through any banking application.
«Given the massive cash flow — with SE ‘Document’ delivering services for the SMSU worth over 1 billion UAH — passing through a single payment intermediary, combined with ongoing criminal investigations into ‘HERZ’ and documented violations inside SE ‘Document’, anti-corruption authorities including NABU, SBU, DBR, and the State Financial Monitoring Service have clear grounds to investigate the terms of this collaboration, commission structures, and potential money laundering or abuse of office.»
The scale of processing volume exceeding 1 billion UAH, paired with exclusive transaction routing and ongoing regulatory findings, underlines the need for a comprehensive audit by oversight authorities to ensure transparency in state-managed public services.