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Reforming the administrative and territorial structure of Ukraine within the process of decentralization has a number of unresolved issues. The second stage of the reform related to the formation of administrative and territorial units of the subregional level has now begun. The plan of 136 new districts approved by the Verkhovna Rada of Ukraine provoked a lively discussion both in the regions and in the expert community. The study analyses the approaches of scholars to the creation of administrative units of the subregional level in Ukraine in order to switch to a three-level model of territorial division. The article provides the arguments for and against the creation of new administrative and territorial units of the subregional level in Ukraine. The existence de facto in Ukraine of a number of inter-district territorial systems in various spheres – education, medicine, tax service – has been proved. Based on the analysis of quantitative criteria, written in the methodology for the creation of new districts, it was defined that they met the NUTS-3 level of the territorial division standard of the European Union countries. A comparative analysis of schemes for dividing the country into districts, which were developed by different Governments of Ukraine, and the network of districts approved by the Verkhovna Rada in 2020 was carried out. The article presents reasons for the increase in the number of new districts from 102 to 129 and then to 136 units, primarily due to the extension of their network in the temporarily occupied territories of Donbas and Crimea, as well as under pressure from regional representatives. The complexity of the issue of forming a network of new districts and their centres are described on the example of Chernihiv region. It is determined that the average population of the project district in Ukraine is 303 thousand people, the population of the centre of administrative units of the subregional level, 130 thousand people. The significant disparities (from 58 to 362 times) in the population of new districts and their centres were defined. Based on the calculations, it was found that 26,5 % of new districts have less population than that determined by the methodology of forming administrative units of the subregional level (150 thousand people). The situation with the population of district centres is similar. Almost 50 % of subregional centres approved by the Verkhovna Rada of Ukraine account for less than 50 thousand people, which may be an obstacle to form high-quality human resources of the executive bodies. It is defined that the competition between cities for the status of the new district centre is due to the desire of local elites to retain control over certain areas. The ambiguous attitude to the issue of creating administrative units of the subregional level on ethnic grounds (Bolhrad and Berehovo districts) among experts and regional elites is pointed out. The list of personnel, financial, property issues that need to be resolved in order to build an effective executive branch in Ukraine at the subregional level has been determined.

SUBREGIONAL LEVEL OF ADMINISTRATIVE AND TERRITORIAL REFORM IN UKRAINE: DEBATABLE ASPECTS