On 1 September 2025, the Law of Ukraine No. 3606-IX “On Lobbying” entered into force. From now on, any activity falling under the definition of “lobbying” may only be carried out subject to prior registration in the Transparency Register, administered by the National Agency on Corruption Prevention (NACP). The Register has already been launched and is available for use here.
Key novelties for business
The Law introduces a number of mandatory requirements, in particular:
- mandatory registration of lobbying activity – both individuals and legal entities under private law that are pre-registered in the Transparency Register may act as lobbying entities
- rules of interaction with public authorities – the law sets standards of communication between business and state bodies, methods and principles of lobbying
- regular reporting – lobbying entities must submit reports on lobbying activity twice a year
- contractual requirements – material terms of a lobbying agreement are now legally established
- sanctions – administrative fines apply in case of violations
The Code of Ukraine on Administrative Offences (CUAO) has been supplemented with Articles 18846-1 and 18846-2, which provide for liability for:
- carrying out lobbying without obtaining the status of a lobbying entity
- failure to submit or late submission of reports to the Transparency Register
Fines range from UAH 850 to UAH 34,000, depending on the type of violation committed.
Activities that do not constitute lobbying
The Law clearly defines activities that do not fall under the legal regime of lobbying. These include, but are not limited to:
- activities in the sphere of media and electronic communications
- activities of public associations and other non-profit organizations, aimed at influencing state authorities, provided such activities are not connected with commercial interests
- personal representation by an individual or a legal entity of their own interests in relations with public authorities (except where such representation is of a commercial nature or carried out by a lobbying entity)
- professional activities of attorneys in terms of defence, representation, and provision of other types of legal assistance to a client
The full list of exceptions is provided in Article 3 of the Law.
Ethical standards
Along with the Law, the Rules of Ethical Conduct of Lobbying Entities, approved by Resolution of the Cabinet of Ministers of Ukraine No. 1128 of 1 October 2024, also entered into force.
The NACP is responsible for maintaining the Transparency Register and exercising state oversight in the field of lobbying. The Agency has already published a number of official clarifications on the application of the new legislation, available at the link.
What this means for business:
- companies and individuals planning to engage in activities that may qualify as lobbying should review existing and planned communication practices with public authorities
- when required, proceed with registration in the Transparency Register and develop internal Lobbying Compliance policies, including reporting procedures and rules of interaction with public bodies
- review and update lobbying agreement templates to include the material terms prescribed by law
For further information, please contact Asters' Managing Partner Oleksiy Didkovskiy and Partner Yuna Potomkina.
