“From January 1, 2025, professional lobbying was officially introduced in Ukraine, but the normative act is valid without supportive mechanisms: the transparency register is planned to be activated by September, and financial sanctions for violations in this area can be delayed by 2026. Yulia Malich, Bolt Public Policy Head and Representative of the Ukrainian Lobbying Association (ULA), explains what challenges have arisen […]”, – WRITE: Businessua.com.ua
From January 1, 2025, professional lobbying was officially introduced in Ukraine, but the normative act is valid without supportive mechanisms: a transparency register plan to activate By September, financial sanctions for violations in this area can be delayed by 2026.
Yulia Malich, Bolt Public Policy Head and Representative of the Ukrainian Lobbying Association (ULA), explains what challenges have arisen through a new law and what actions are possible in the context of legal uncertainty.
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In Ukraine, it is no wonder that “lobbying exists, but formally it is not.” From January 1, 2025 it is no longer humor: Law No. 3606-IX “On Lobbying” came into force. This is the first act that legalizes the activity of lobbyists and removes it from the shadow.
However, irony is that the law is activated without functioning infrastructure. The NAPC system, which will require the publication of customer data, costs and activities of lobbyists, plan to launch by September 1, and the fines for offenses are proposed to postpone by September 2026.
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Thus, we received the year of “transition” to adapt to new norms.
In Brussels without registration at EU Transparency Registry you will not get even to the first floor of the European Parliament. The system has been operating for more than a decade, fixing all the details – from customers to finances and meetings.
Ukrainian legislation brings us closer to these standards. For those who consider reporting a burden, it is actually a ticket to the European political space.
What does it mean “report” According to the law, lobbyists are obliged to provide data every six months: customer information, interests, budgets and contacts with officials. Even the five-minute online meeting is subject to fixing.
The term “meeting and other forms of communication” leaves space for interpretations. Calls, correspondences, informal conversations – all of which can potentially require reporting. Where is the boundary?
The law does not specify, and there are no official instructions from the NAPC yet. The resolution of this issue rests with the company and individuals.
It is also clear that the reports should include lobbying. But what exactly: organization of activities, research or other instruments of influence?
Is it only central organs? The objects of regulation are all entities that form normative acts: from government to local authorities. Kyiv Architectural Department, Regional Administrations or Village Councils – all fall under reporting. The key is not geography or level, but the availability of authority in rulemaking.
What, for example, is with a foreign director who is in contact with the Ukrainian Minister for the Investment Project?
The law does not require residence, so such a person must either register or transfer the authority to a local representative. But the legal mechanisms of this process are not yet clear.
Transparency Registry: Current Status In the fall of 2024, the Cabinet approved the Regulations on the Register. The document describes the structure of the base, but does not explain its functioning.
Will APIs for integration, which formats will be maintained, can you test mass data download? NAPC promises a convenient interface, but only statements and promises are available.
Open questions:
- Customer privacy. How to combine the requirement of disclosure of beneficiaries with non -disclosure agreements?
- Informal conversations. Is Small Talk Lobbying? According to the NAPC – yes, if there is a subject, object and subject of influence.
- International communications. Do you record online calls between foreign experts? Yes, provided there are three criteria.
Why is a regulator’s dialogue important In July 2025, there was a discussion between NAPC and ULA. The preparation of explanations and educational measures has been agreed. It turned out that the law provides for responsibility for illegal activity. Moreover, social networks can be a source of information about violators.
Parliament twice postponed the question: first the law, then penalties. This gives time to adaptation, but reduces incentives for registration.
The risk is a closed circle: without registration, the system does not function, no system – no one to control.
EU experience is also imperfect. In 2024, the auditors found gaps in Transparency Register. This is an educational example for Ukraine: the effectiveness depends on the openness of the calendars of officials and their readiness to work through the register.
Three steps for business:
Transparency is a sign of mature democracy. Lobbyists are not afraid of open work, but require clear rules. While clarification of the law and the development of tools, the key is to form internal standards for the start of the system.
The functional register of transparency will be a step to the accountable political process. And lobbyists will be able to say: “Yes, we influence the solution. And we do it open. ”
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