Lobbying in Ukraine: a legal tool of influence with clear rules and sanctions

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Oleksii Shevchuk, Partner, Spokesperson at Barristers Law Firm, Chairman of the Board of the Association of Lobbyists of Ukraine.

In Ukraine, lobbying is gradually becoming a normal part of the democratic process. It enables businesses and civil society organizations to openly influence how decisions are made within the government. The Law of Ukraine “On Lobbying” establishes clear rules of the game—who may engage in lobbying, which methods are permitted, and what liability is imposed for violations. The goal is simple: to make this process transparent, fair, and conducive to the country’s development rather than shadow interests. As of autumn 2025, the highest concentration of lobbying activity is in the spheres of economic development, as well as legal, financial, tax, and customs policy.

When we talk about lobbying, we mean influencing various regulatory legal acts—the documents that define rules and decisions in the country. Lobbying can concern all stages of work with such acts: from their planning and drafting to amendments or even repeal. The main idea of the process is to convey the position of business or the public to authorities so that these interests are taken into account in state policy.

At the same time, the law clearly outlines topics that cannot be lobbied at all. These primarily include issues related to national security and emergency situations. This covers decisions on mobilization, imposition of martial or emergency law, declaration of war or conclusion of peace, use of the Armed Forces, changes to Ukraine’s territory, designation of environmental disaster zones, or granting amnesty. Such areas are considered too sensitive, and the state protects them from any private influence to avoid risks to sovereignty and national security.

Lobbying methods: from communication to public campaigns

Lobbying in Ukraine, as in Western countries, is based on fundamental principles—it must be lawful, transparent, professional, and ethical. The law explains in detail how one may influence decision-making. First and foremost, this includes direct communication with officials or other responsible persons, where a lobbyist conveys the position of their organization or client. In addition, various informational materials are widely used—analytics, research, proposals, or explanatory documents that may be distributed directly or through media or the internet.

Participation in events and policy-related discussions also plays an important role, as does the organization of one’s own events or public campaigns that help draw attention to a particular issue. Lobbyists may invite government representatives to discussions, conferences, or other platforms where arguments can be presented more broadly. Overall, the law allows the use of various methods of influence, provided they do not contradict the Constitution or Ukrainian legislation. This enables interests to be represented openly and effectively, without leaving the legal framework.

Who cannot engage in lobbying?

To prevent abuse and conflicts of interest, the law strictly limits the individuals and organizations that may obtain lobbyist status. First of all, this applies to active public officials and those who left office less than a year ago—clearly to prevent the use of official connections for private purposes. Individuals with unexpunged convictions, corruption-related offenses, legally limited legal capacity, or those who have not reached adulthood are also excluded.

A separate restriction concerns citizens and residents of Russia, as well as companies connected to or registered in that country. Similarly, entities associated with terrorist activities, sanctioned individuals and organizations, and those failing to comply with international anti–money laundering standards are also barred. The law also blocks access for legal entities whose beneficial owners fall into any of these prohibited categories.

State bodies, local self-government bodies, public-law institutions, media outlets, political parties, religious organizations, and electoral candidates are also prohibited from lobbying. Restrictions also apply to companies that have faced criminal sanctions within the previous five years. All of this creates safeguards that prevent lobbying from becoming a field for manipulation or hidden influence, preserving it as a civilized and regulated tool.

Liability for violations: fines and prohibitions

Violations of lobbying regulations in Ukraine are not limited to moral condemnation—specific administrative liability is provided. All fines are calculated based on the non-taxable minimum income of citizens, so even seemingly small sanctions may turn into significant sums:

Offense (Article of the Code of Administrative Offenses) Description Fine (NMDG) Fine (UAH, 2025) Additional consequences
Illegal lobbying (Art. 188-46-1) Lobbying without status or with suspended/terminated status 50–100 850–1700
Repeated illegal lobbying within a year 200–500 3400–8500
Concealment of circumstances excluding lobbyist status Upon obtaining status 500–1000 8500–17000
Violation of lobbying legislation (Art. 188-46-2) Failure to submit/late submission of report to Transparency Register 50–100 850–1700
Repeated reporting violation within a year 300–400 5100–6800 One-year ban on lobbying
Failure to submit/late submission of application to suspend/terminate status Or to be removed from the Register 100–300 1700–5100
Violation of restrictions on lobbying subjects Or lobbying in the interests of an ineligible beneficiary/client, unlawful financing 1000–2000 17000–34000

The most frequent violations involve concealment of information, operating without proper registration, or attempts to influence officials in prohibited ways. In such cases, fines are imposed, and sometimes temporary bans on lobbying activities. The state signals clearly: lobbying is allowed, but only openly, transparently, and within established rules. This deters those who might try to use lobbying as a tool of pressure or hidden influence, while also protecting trust in the mechanism itself.

These sanctions highlight the importance of transparency and ethics in lobbying activities.

Lobbying in Ukraine, regulated by a special law, promotes a balance of interests in society but requires strict adherence to the rules. Experts note that effective implementation of these norms can strengthen trust in government and stimulate economic development.

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