Ukraine Legalises Lobbying: Step Toward Transparency

Ukraine is about to enter a new regulatory era with the upcoming implementation of its Law on Lobbying. For the first time, lobbying will be legalised and regulated, aligning Ukraine’s political-business interface closer to EU and US standards—but not without growing pains.

Under the new framework, any attempts to influence legislation, regulations, or state decision-making on behalf of business or interest groups must be declared through a newly established register of lobbyists, to be launched by the National Agency on Corruption Prevention (NACP). This is a substantial change in a country where informal networks and opaque influence often substituted for transparent policy advocacy.

Why It Matters

In Brussels and Washington, lobbying is recognised, disclosed, and—crucially—regulated. Ukraine, in contrast, has operated in a grey zone, where unofficial influence channels were often more effective than public consultation. Formalising lobbying not only enhances accountability but also reduces reputational risks for foreign investors operating in the country.

The new law:

• Defines who can and cannot lobby (e.g. foreign agents, media outlets, and public servants are excluded).

• Imposes administrative fines for undeclared lobbying—up to ₴170,000 (~$4,200).

• Requires businesses and lobbyists to file declarations of lobbying efforts and identify beneficiaries.

Business Concerns and Delays

Despite good intentions, implementation risks are real. Leading business associations, including the American Chamber of Commerce and European Business Association, have urged Parliament to delay sanctions and improve legal clarity, citing legal uncertainty and regulatory overload. Many fear that inadvertent non-compliance could trigger penalties, particularly for companies engaged in routine advocacy without prior experience in regulated lobbying environments.

Moreover, while the NACP promises clear guidance and a user-friendly portal, technical and procedural ambiguities remain, especially for multinational companies and law firms representing clients in policy matters.

Comparing Models: EU and US

• In the US, the Lobbying Disclosure Act (LDA) mandates public registration and quarterly reports for all paid lobbying activities targeting federal officials. Non-compliance can lead to civil penalties and reputational damage.

• The EU Transparency Register operates on a voluntary basis, but is de facto mandatory for engaging with European Commission officials. It covers interest representation across a wide policy spectrum.

Ukraine’s model borrows elements from both but goes further by threatening enforcement from day one—despite limited institutional experience.

What’s Next

Over the next six months, Ukraine’s public and private sectors will navigate a steep learning curve. If implemented constructively, this reform could decrease corruption risks, level the playing field, and support better governance. But if executed poorly or used punitively, it could discourage legitimate advocacy and stifle dialogue.

For international stakeholders, now is the time to:

• Map exposure to lobbying-related activities across local teams and consultants.

• Engage with the NACP to clarify grey zones and ensure compliance readiness.

• Monitor legal amendments, as business pressure may yet reshape the rollout.