The draft act bears the rule that cancellation of a certificate is a ground for suspension of pension payments. According to the law, a returning of the person to the previous place of residence or departure for permanent residence abroad is a basis for cancellation of the IDP certificate, and not pensions or other social benefits. Ukraine already has a negative experience of discrimination pensioners by place of their residence.

It is worth to recall that the decision of the European Court of Human Rights in the case "against Pichkur" Ukraine was obliged to pay 5 thousand Euros to citizen Pichkur because the government has not paid him a pension in view of his physical absence in Ukraine. However, the changes, proposed by the government, may cause serious concern in terms of respect for the legitimate rights of internally displaced people. Thus, the project approved two orders: the appointment (renewal) of social to IDPs and control over such payments. In draft documents at government level act the term "suspension" is being fixed; there is no such a term in  any law of Ukraine. Exhaustive list of grounds for refusal in the appointment of any social benefits are established by special laws of Ukraine which shall be approved by the parliament and signed by the President of Ukraine, and thus, under the Constitution they have supreme legal force as compared to the acts of the government.

Fixation the procedures of "suspension" on the level of decree of the Cabinet of Ministers of Ukraine will lead to a feasibility of ungrounded, illegal and unconstitutional schemes to control population migration and violate citizens' rights to social protection.

In addition, first payment after the "suspension" a person will receive only two months following the Commission's decision. Social benefits for two months before their renewal shall not be carried out. The issue of renewal of social payments for all months remains only at the discretion of the Commission and not in two months. Repeated appointment of payments to whom it was suspended because of cancelled certificate, may be done only in six months after suspension. These provisions are likely to introduce a mechanism of punishment of internally displaced people for what they can afford to freely move around the country. It should be emphasized that these warnings and restrictions are not provided for any other group of citizens of Ukraine.

Draft orders propose to allow to the so-called "mobile groups" to check the actual residence of immigrants and make by results of inspections survey Acts on material and living conditions of the family. For the purposes of "mobile groups" shall include representatives of the migration service, which according to recent changes in the law do not carry out any work with displaced populations; Security Service of Ukraine, National police. Such a proposed structure of "mobile group" raises serious concerns, because the inclusion of their composition representatives of law enforcement bodies, which by their legal nature are not involved in social work with the population, mean only one thing: Government still believes that immigrants are criminals and constantly suspects them of committing any crimes.

Moreover, by results of such inspections survey Acts on material and living conditions of the family would be composed and on this basis will people will be appointed a pension or other social aid services, which is discrimination against displaced persons. However, for any other categories of pensioners for to get a pension there is no need to be checked by some "mobile teams" or provide evidence of their material conditions of living.

The draft regulations do not set limits inspection of place of residence of IDPs, which will lead to abuses in places where it occurred during March - June of current year when local authorities independently determine what, where and how to check in persons. For example, in Berdiansk on the City Council site there was placed an online lists of all persons with their residential addresses and calls for local people to help check displaced persons.

Draft laws do not take into account appeals of right activists concerning "separation" of terms of pensions payments, social benefits and financial assistance to IDPs for leasing a house, appointed pursuant to Government Resolution № 505 of October 1, 2014. In the draft pensions and other social benefits are controlled at the level of payments for rental housing IDPs, which is unacceptable and discriminatory. For other citizens, are not subject to inspections of their current location when receiving pensions. The ECHR noted that the pension age is a form of social security, which is primarily concerned with pre-employment and labor merits person and is not to be dependent on her residence.

In the draft orders there appeared of a new term "Commission on appointment (renewal) of  social payments to internally displaced persons," but none of these projects is not about the legal nature of such a commission, its mandate, required composition, the body responsible for its formation, rights and duties of the Commission, the status of its decisions.

At the same time, the Commission assumes such a wide range of powers, including the question relating the appointment to the person of any social payments and benefits. The government must pay very careful attention to establishment of such kind of bodies because its decision will affect two million of our citizens.

Furthermore, the public discussion of the draft act is not carried out, and the draft law explanatory memorandum of the Ministry of Social Policy states that it does not require public discussion.  Decree of the Cabinet of Ministers of Ukraine of November 3, 2010 № 996 "On public participation in the forming and implementation of state policy" approved the order of the public consultation on the forming and implementation of the state policy.

Paragraph 12 of this Order stipulates that mandatory consultations with the public in the form of public discussion and/or electronic public consultations on the draft legal acts concerning constitutional rights, freedoms and responsibilities of citizens. The term of such public consultation is determined by executive authority and must constitute at least 15 calendar days. This draft concerns the lives of nearly 2 million citizens of Ukraine and directly affect their vital interests, and therefore requires public discussion and consultation with the IDPs themselves.

In addition, it should be recalled that the Committee on human rights, national minorities and interethnic relations has appealed to the Prime Minister of Ukraine Vladimir Hroisman with a request to send an authorized representative - a member of the Cabinet of Ministers of Ukraine to report on this issue, including the implementation of Recommendations of the parliamentary hearings on "On the conditions of adherence of the rights of internally displaced persons and citizens of Ukraine residing in the temporarily occupied territory of Ukraine and temporarily uncontrolled territory in the area of ??anti-terrorist operation", on the Committee meeting be held June 15, 2016.