Lobbying in Ukraine for Business

The Law of Ukraine “On Lobbying” No. 3606-IX of 23 February 2024 has been in effect since 1 September 2025. Not every engagement with a public authority is lobbying. The Law covers activity aimed at influencing a lobbying target in relation to a normative legal act where it is carried out either in a beneficiary’s commercial interests for remuneration or reimbursement of actual expenses, or in the person’s own commercial interests. A person or entity carrying out such activity must obtain lobbying-entity status in the NACP Transparency Register before starting.

This article is intended for foreign and Ukrainian companies, business associations, law firms and government-relations teams that engage with Ukrainian public authorities on the preparation or amendment of normative legal acts.

1. What Counts as Lobbying in Ukraine

2. When a Business Must Register

3. What Is Not Lobbying in Ukraine

4. Who May Act as a Lobbying Entity

5. The Transparency Register and Reporting

6. Restrictions, Prohibitions and Liability

7. What Foreign Companies and Investors Should Know

8. Practical Checklist for Business

9. Frequently Asked Questions

How DLF Can Help

1. What Counts as Lobbying in Ukraine

Article 1 defines lobbying as activity aimed at influencing, or attempting to influence, a lobbying target in a beneficiary’s commercial interests — for direct or indirect remuneration and/or reimbursement of the actual expenses necessary for the activity — or in the person’s own commercial interests, where the activity concerns a lobbying subject matter.

For a practical assessment, four questions should be asked:

1. Who is being influenced? A lobbying target is a subject of law-making activity and/or a subject of law-making initiative. The concept is not limited to Parliament.
2. Is there a commercial interest? The Law refers to money or other property, personal advantages, privileges, or other material or non-material benefits connected with business activity.
3. What is the influence about? The lobbying subject matter is a normative legal act: its planning, drafting, adoption or issuance, amendment, repeal, or refraining from those actions.
4. Whose commercial interest is pursued? Where the activity is conducted in a beneficiary’s commercial interests, the statutory definition links it to remuneration and/or reimbursement of actual expenses. The Law separately covers lobbying in a person’s own commercial interests, so the involvement of an external paid consultant is not a prerequisite.

In its official guidance on applying the lobbying legislation, the National Agency on Corruption Prevention (NACP) explains that lobbying targets may include the Cabinet of Ministers, ministries, other bodies empowered to issue normative legal acts, and local self-government bodies. Executive-branch engagement can therefore constitute lobbying when the influence concerns a normative legal act. An individual administrative decision, by contrast, does not itself meet the statutory subject-matter requirement.

Key statutory concepts:

• lobbying entity — a natural or legal person conducting lobbying on the grounds and in the manner prescribed by the Law;
• lobbying client — a foreign state, a natural or legal person, or a group of such persons that has concluded an agreement for lobbying services;
• lobbying beneficiary — a foreign state, a natural or legal person, or a group of such persons in whose commercial interests lobbying is conducted;
• lobbying target — a subject of law-making activity and/or law-making initiative;
• lobbying subject matter — a normative legal act in respect of which influence is exercised.

2. When a Business Must Register

If the activity falls within the statutory definition of lobbying, lobbying-entity status must be obtained before the activity begins.

Registration takes place in the NACP Transparency Register. Information that must be entered in the Register must be updated within 10 days from the date of the change.

Where lobbying is carried out for a client, the basic legal instrument is a written agreement for lobbying services. The essential terms of such an agreement include information on:

• the lobbying subject matter;
• the beneficiary;
• the lobbying target and sector;
• the term of the agreement;
• the price, if the agreement is for remuneration.

The Law prohibits success-based remuneration: payment may not be contingent on the result of lobbying. The Law also recognises situations in which lobbying may be carried out without a lobbying-services agreement, including lobbying in one’s own commercial interests and certain cases involving public associations and other non-profit organisations.

3. What Is Not Lobbying in Ukraine

Article 3 identifies activities that are not treated as lobbying. The following distinctions are particularly relevant for companies and advisers:

The label attached to a service — “government relations”, “advocacy” or “legal support” — is not decisive. A law firm representing a client in court or in an administrative proceeding does not become a lobbying entity merely because it interacts with a public authority. A separate paid mandate aimed at influencing the content of a specific normative legal act may qualify as lobbying.

4. Who May Act as a Lobbying Entity

The categories eligible to obtain lobbying-entity status include:

• natural persons with full legal capacity;
• private-law legal entities registered in Ukraine;
• foreign legal entities that have a representative office registered in Ukraine.

A foreign company without a Ukrainian representative office does not fall within the foreign-entity eligibility category expressly identified by the Law. Before carrying out lobbying itself, such a company should determine the appropriate form of presence in Ukraine or engage a separately registered lobbying entity.

The Law also identifies categories of persons that cannot obtain lobbying-entity status, including:

• specified serving public officials and persons during the one-year period after leaving the relevant office;
• a natural person whose conviction for a criminal offence has not been extinguished or expunged in accordance with law (except a rehabilitated person), or who has been subject to an administrative penalty for a corruption-related offence or to an administrative penalty in the form of a prohibition on lobbying;
• a natural person declared legally incapable by a court or whose civil capacity has been restricted, as well as a natural person who has not attained full civil capacity;
• citizens of an aggressor state and persons permanently resident there;
• persons and entities subject to the sanctions-related restrictions specified by law;
• legal entities (their participants and ultimate beneficial owners) with links to an aggressor state specified by the Law;
• political parties, religious organisations, specified media-sector entities and election candidates;
• state authorities, local self-government bodies and other public-law entities covered by the statutory restriction;
• legal entities subject to statutory restrictions related to criminal offences.

5. The Transparency Register and Reporting

The Transparency Register has operated since 1 September 2025. Its creation and operation are governed by Cabinet of Ministers of Ukraine Resolution “Certain issues of the creation and operation of the Transparency Register” No. 1175 of 15 October 2024. The Register is public, while specified personal data are restricted from public access.

According to NACP’s first-year review, as of 31 August 2026 the Register contained 205 lobbying entities, of which 167 had active status.

Reports are filed twice a year:

A report includes, among other information:

• identification details of the lobbying entity;
• client and beneficiary details;
• lobbying subject matter, target and sector;
• the date of conclusion and term of each lobbying agreement, as well as its price within the following brackets:
• up to UAH 100,000 (approximately USD 2,250);
• UAH 100,001–1,000,000 (approximately USD 2,250–22,500);
• UAH 1,000,001–10,000,000 (approximately USD 22,500–225,000);
• over UAH 10,000,000 (over approximately USD 225,000);
• funds received, reported within the statutory brackets;
• expenditure by lobbying sector;
• information on meetings and communications during which lobbying was conducted with lobbying targets holding responsible or particularly responsible positions within the meaning of the Law of Ukraine “On Prevention of Corruption”;
• information required by the Law on contributions to political parties and election funds.

The Register discloses the applicable price bracket rather than the exact contractual remuneration. Approximate USD equivalents in this article are based on the official NBU exchange rate for 9 September 2026.

6. Restrictions, Prohibitions and Liability

Prohibited Lobbying Subject Matters

Regardless of registration status, the Law prohibits lobbying concerning:

• declaration of general or partial mobilisation;
• introduction of martial law in Ukraine or in particular areas of Ukraine;
• introduction of a state of emergency in Ukraine or in particular areas of Ukraine;
• declaration, upon submission by the President of Ukraine, of a state of war and conclusion of peace;
• use of the Armed Forces of Ukraine and other military formations established in accordance with Ukrainian law;
• changes to the territory of Ukraine;
• amnesties;
• designation of specific localities as zones of ecological emergency.

These restrictions also apply during martial law. Lobbying-entity status does not permit lobbying on a prohibited subject matter.

Prohibited Clients, Beneficiaries and Funding Sources

The Law restricts lobbying for specified categories of clients and beneficiaries, including persons with prohibited links to an aggressor state and persons subject to sanctions restrictions specified by law.

Certain funding sources are also prohibited, including funds from an aggressor state and entities under its control, as well as state and local budget funds. If circumstances specified in Article 12 arise, the lobbying entity must immediately suspend the relevant lobbying and take the necessary steps to terminate the lobbying agreement.

Administrative Liability

The Law of Ukraine “On amendments to the Code of Ukraine on Administrative Offences regarding the establishment of liability for violations of legislation in the field of lobbying” No. 3620-IX of 21 March 2024 introduced administrative liability for unlawful lobbying and other violations of lobbying legislation.

Article 188-46-1 of the Code of Ukraine on Administrative Offences — unlawful lobbying:

Article 188-46-2 — violations of lobbying legislation:

Authorised NACP officials draw up administrative offence protocols for these violations.

7. What Foreign Companies and Investors Should Know

A foreign legal entity may obtain lobbying-entity status if it has a representative office registered in Ukraine and satisfies the other statutory requirements. A foreign company without such a representative office should determine before starting activity whether it needs a Ukrainian presence or should engage a separate registered lobbying entity.

Companies with potential links to an aggressor state or sanctioned persons should review their ownership structure, clients, beneficiaries and funding sources before entering into a lobbying-services agreement or starting lobbying activity.

Donors and international organisations. Activity within international technical-assistance programmes may fall within a statutory exclusion. The precise programme scope should be compared with the actual activity and contractual model.

Business associations. Non-commercial advocacy does not become lobbying merely because it involves engagement with public authorities. At the same time, non-profit status does not by itself exclude the application of the Law where the actual activity meets the statutory lobbying definition.

Anti-corruption rules remain separate. Transparency Register status does not replace compliance with the Law of Ukraine “On Prevention of Corruption” No. 1700-VII of 14 October 2014, conflict-of-interest rules, prohibitions on undue advantage, sanctions requirements, or other applicable compliance duties.

8. Practical Checklist for Business

Before starting lobbying or government-relations activity:

1. Does the activity meet the lobbying definition? Identify the target, commercial interest, normative legal act concerned, and whether the activity is performed for a beneficiary for remuneration or in the company’s own commercial interests.

2. Does a statutory exclusion apply? Review professional legal activity, public consultations, international technical assistance, civil-society advocacy and the other Article 3 exclusions.

3. Is the person or entity eligible? Check sanctions and aggressor-state restrictions, the post-public-service cooling-off period and, for a foreign legal entity, the existence of a Ukrainian representative office.

4. Is the addressee a lobbying target? Determine whether it is a subject of law-making activity or law-making initiative. The Cabinet of Ministers, ministries, regulators and local self-government bodies can be lobbying targets in relation to normative legal acts.

5. Is the subject matter permitted? Exclude any matter on which Article 8 expressly prohibits lobbying.

6. Obtain status before starting. Submit the required information to the Transparency Register.

7. Use a written agreement where required. Include the statutory essential terms and do not use success-based remuneration.

8. Screen the client, beneficiary and funding. Perform sanctions screening and review links to an aggressor state.

9. Prepare for reporting. Organise data for the 31 July and 31 January deadlines and keep records of lobbying subject matters and reportable interactions.

10. Update registered information. Report changes within the statutory period.

11. Review anti-corruption requirements separately. Lobbying status does not replace anti-corruption, sanctions or conflict-of-interest compliance.

9. Frequently Asked Questions

Does a company representing only its own interests in the legislative process need to register?

It may. If a company influences a subject of law-making activity in relation to a normative legal act in its own commercial interests, the activity may constitute lobbying even without an external consultant or separate remuneration. An application for an individual administrative decision, rather than a normative legal act, does not satisfy the lobbying subject-matter element.

Does the Law apply to law firms and GR consultants?

It depends on the actual service. Independent professional activity of an advocate — defence, representation and other legal assistance — falls within a statutory exclusion. A separate paid mandate to influence a normative legal act in a client’s commercial interests may constitute lobbying and require the relevant status.

Is participation in public consultations on draft legislation considered lobbying?

Not automatically. Participation in public discussion of a draft normative legal act is outside the lobbying definition, except where it is carried out by a lobbying entity under an agreement for lobbying services. The contractual context and actual role of the participant therefore matter.

Can foreign companies without a registered representative office in Ukraine register as lobbying entities?

The statutory foreign-entity category covers a foreign legal entity that has a representative office registered in Ukraine. A foreign company without such a representative office does not fall within that expressly identified category and should establish an appropriate operating model before carrying out lobbying itself.

What are the consequences of lobbying without registration?

Lobbying without acquiring status, or after termination or suspension of status, carries a fine of UAH 850–1,700 (approximately USD 20–40). A repeat violation within one year carries UAH 3,400–8,500 (approximately USD 75–190). Lobbying without notifying circumstances that prevent acquisition of the status carries UAH 8,500–17,000 (approximately USD 190–380).

Can engagement with executive authorities constitute lobbying?

Yes. The Law is not limited to Parliament and uses the broader concept of a subject of law-making activity. NACP guidance includes the Cabinet of Ministers, ministries, other bodies empowered to issue normative legal acts and local self-government bodies. The lobbying subject matter must, however, be a normative legal act; an individual administrative decision is not enough.

How DLF Can Help

DLF attorneys-at-law supports foreign companies, business associations, consultants and GR teams on lobbying and public-authority engagement in Ukraine: from assessing whether a proposed activity constitutes lobbying and choosing an operating model to drafting lobbying-services agreements, Transparency Register registration and reporting, client and beneficiary screening, and assessment of sanctions and anti-corruption risks. Related matters are handled by our Corporate Law / M&A and Contract Law practices.

Igor Dronov, Counsel — DLF attorneys-at-law

Contact: +380 44 384 24 54, info@dlf.ua.

This material is intended for general information. The application of the approaches described depends on the circumstances of the specific situation and requires a separate legal assessment.