Panel A of table 1 shows that our frame includes 75,571 farmers, more than double the 36,184 in the Form 29 survey as used by SSSU. Of these, 21% are legal entities, 11% FOPs, and 68% individuals overall with the latter concentrated in the farm size class below 50 ha of which 82% are individuals and 9% each FOPs and legal entities. Legal entities dominate for larger farm size classes, making up 58%, 76%, and 97% of those in the 50-120, 120-500, and > 500 ha group, respectively. Coverage in terms of farm numbers by the SAR is better than that of Form 29 for the below 120 ha group (with 3.8 and 1.1 times the number of farms in the < 50 and 50-120 ha) but worse above 120 ha with SAR containing only 0.62 and 0.44 times the number of operations in the 120-500 and the >500 ha group, respectively.

Table 1 panel B illustrates that the farms covered by Form 29 and SAR cultivate 27.85 and 11.6 million hectares, respectively with 25% of Form 29 area in ACUs and 25% in AACs. While they comprise less than a quarter of the number of registered farms, legal entities operate more than 90% of the area registered in SAR overall (33%, 64%, 83%, and 97% of area in the <50, 50-120, 120-500, and > 500 ha groups, respectively). The total area registered in SAR amounts to 42% of the area in Form 29 at the national level and 150%, 127%, 67%, and 37% of which in the <50, 50-120, 120-500, and > 500 ha groups, respectively.<sup>12</sup> To quantify the extent of informality in Ukraine’s agriculture sector, we use crop maps for 2020 elaborated using the methodology described in Kussul _et al._ (2017); Shelestov _et al._ (2017), and Shelestov _et al._ (2020) to identify the total area cultivated with crops in 2020 and then compare this area to what is covered by Form 29 as well as SAR.<sup>13</sup> Table 1 panels C and D highlight that, based on these maps, Ukraine’s total cultivated area amounts to 45.73 million ha, 33.87 mn ha in ACUs and 11.86 mn ha in AACs. With 27.8 mn. ha (21 mn ha in ACUs and 6.8 mn ha in AACs), SSSU’s Form 29 thus covers 61% of the country’s cultivated area in 2020, leaving an estimated 39% of cultivated area in informality.

Using enterprise IDs to match farms between SAR and Form 29 suggests that 7.5 mn ha nationally (6.4 mn. ha in ACUs and 1.1 mn ha in AACs) is cultivated by farms included both in SAR and Form 29 while 3.36 mn. ha, almost all in ACUs, are registered in SAR only. This suggests that in the 3-month period from Aug. 12 to Oct. 15, 2022, registration in SAR reduced the amount of land cultivated informally by 3.36 mn. ha or about 7% of the total. Still, 14.5 mn. ha, more than the total agricultural area of Poland or Germany, are cultivated by farmers that are neither part of SSSU’s sample frame nor registered in SAR, implying that this land is not reflected in any official statistics.

> 12 As a plausibility check, we compare mean farm sizes between Form 29 and SAR. For the above 50 ha group, average farm size in SAR is 803 ha compared to 934 ha and 999 ha for ACU and AAC, respectively, in Form 29 and the corresponding figures for farms greater than 500 ha are 2,834, 2,255, and 2,137 ha, respectively, for SAR and Form 29 in ACUs and AACs. 13 As area cultivated in 2022 is likely to have been affected by the conflict and to avoid bias that might arise from the fact that 2021 was an exceptional year with very favorable growing conditions, we use both satellite imagery and Form 29 data from 2020. Area cultivated excludes forest, bare land, wet land, water, and areas with artificial (built up) cover.

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