As of September 1, two key legislative acts have officially come into force in Ukraine: Law No. 3606-IX “On Lobbying” and Law No. 3620-IX, which establishes administrative liability for violations in this field.
On February 23, 2024, the Verkhovna Rada approved the government’s draft law No. 10337 “On Ethical Lobbying.” The document clearly distinguishes between advocacy activities of civil society organizations and lobbying, exempting activists from the obligation to register in the Transparency Register, which applies only to direct lobbying entities.
The law also defines the areas to which it does not apply. These include the diplomatic representation of Ukraine’s interests abroad, the activities of political parties and the media, as well as the implementation of international technical assistance programs. Advocacy, participation in public consultations with the authorities, or peaceful assemblies are likewise not considered lobbying.
At the same time, a separate act — Law No. 3620-IX — strengthened oversight and introduced penalties for violations of lobbying rules. The Code of Administrative Offenses of Ukraine has been supplemented with articles that establish fines for unlawful lobbying activities — from UAH 850 to 1,700. If a lobbying entity conceals information that disqualifies it from operating in this field, the fine increases to UAH 8,500–17,000.
Additionally, failure to submit or late submission of reports to the Transparency Register carries fines ranging from UAH 850 to 1,700. The strictest sanctions — from UAH 17,000 to 34,000 — will apply to those who breach restrictions on the subject of lobbying, work on behalf of prohibited clients, or use unlawful sources of financing.
Importantly, the new legislation also introduces an additional sanction — a ban on lobbying activities. If a court issues such a ruling, it must be sent within three days to the National Agency on Corruption Prevention (NACP), which records the suspension of the lobbying entity’s status in the Transparency Register.
