The Ministry of Education and Science wants to introduce a new system for registering preschool and school-age children: why this is upsetting parents
21 April 11:05
The Ministry of Education and Science is holding discussions regarding amendments to the Procedure for Keeping Records of Preschool- and School-Age Children, Pupils, and Students. The changes entail that educational institutions will require parents to provide tax identification numbers (RNOKPP or passport series and number in case of refusal to provide RNOKPP) in order to improve the identification of each child, establish a link with parents in the AIKOM system, and, based on verification, collect confidential information from all registries about the child’s parents to create a digital profile of the child and their parents.
Facebook user Laura Selivanova is asking parents to participate in this discussion to prevent the implementation of this new measure, reports "Komersant Ukrainian".
“Filling out parents’ digital profiles with information about their income, property, debts, place of work, health status, social status, etc., is illegal! The result of such actions will be the segregation of children and their parents based on social ranking, with all the ensuing consequences,” the woman’s post states.
According to her, these changes violate the right to privacy of private and family life (Article 32 of the Constitution of Ukraine) and the voluntary nature of participation in digital experiments (Article 28 of the Constitution of Ukraine). In effect, children of parents who object to digital profiling of themselves and their children (which is prohibited by Convention 108) are, in violation of Article 22 of the Constitution, deprived of the right to accessible education, which is guaranteed to them by Article 53 of the Constitution of Ukraine.
“The creation of a digital dossier for each student and their parents constitutes an unlawful overreach of authority by the educational institution! Therefore, such changes must be immediately and irrevocably rejected,” emphasizes Lora Selivanova.
“You can write your comments and demands and send them to the Ministry of Education and Science’s mailing address and/or in printed, signed, and scanned form to the specified email address: [email protected],” she added.
The deadline for submitting appeals is April 23, 2026.
“Write to the Ministry of Education and Science and to the email address, post in public forums. Tag the Ministry of Education and Science so they take notice. Take action!” urges Laura Selivanova.
She also provided a sample letter with a legal analysis on her profile for concerned parents. According to the author of the letter, the Ministry’s new policy may violate a number of Ukrainians’ rights:
1. Lack of legislative authority (Article 19 of the Constitution of Ukraine).
State authorities and their officials are obligated to act only on the basis of and within the limits of the powers provided for by the Constitution and laws of Ukraine. No law of Ukraine (whether “On Education” or “On General Secondary Education”) grants the Ministry of Education and Science the right to collect parents’ tax identification numbers (RNOKPP). A resolution of the Cabinet of Ministers is a subordinate legislative act; it cannot create new obligations for citizens that are not specified in the law.
2. Misuse of the AIKOM system.
The AIKOM system was created for educational management, not for financial or property monitoring of families. The requirement to provide parents’ TINs for “identification” is excessive. A student’s name and date of birth are sufficient for identification within the educational process. Any “verification” through third-party registries (tax, property) constitutes unlawful profiling, which is prohibited by Convention 108.
3. Violation of the principle of legal certainty.
The changes provide for the collection of confidential data without a clearly defined purpose for its further use. This poses a threat to the data security of millions of Ukrainians amid martial law and the digital vulnerability of systems.
4. Discrimination based on “digital loyalty” (Articles 21 and 24 of the Constitution of Ukraine).
The attempt to make the provision of a RNOICP a mandatory requirement for a child’s registration effectively deprives those who protect their privacy of the right to education. This creates an artificial segregation of citizens into “digitized” and “undesirable” groups.
