Transparency above all: how Ukrainian lobbyists are preparing to work in a new way from September 1
29 August 2025 13:21
ANALYSIS
The Ukrainian parliament has long been a place where many things can be decided. Unofficially. On the sidelines, in the offices of parliamentary committees or, say, somewhere near these buildings – in cafes and restaurants. Now it will be possible to do all this officially – in Ukraine from September 1 the Law “On Lobbyist Activity” really starts to work and the Register of Transparency is launched, in which lobbyists must register and report on their transactions. How it will work – "Komersant Ukrainian" found out.
In August, the Ukrainian business community urged the parliament to finalize the law on lobbying and clarify some of its provisions that allow for different interpretations, as well as to postpone the introduction of liability for violation of the requirements of this law. But as it happens, lobbyists have so far failed to lobby for such innovations. The business community does not make a big deal out of it – there is a law and its requirements must be fulfilled. But they do not give up their intentions to postpone the introduction of liability. Says Victoria Kulikova, head of the Committees Department of the European Business Association.
“Most companies have not yet seen how the Transparency Register works, what information can and should be entered there. There may also be a lot of questions to the NAPC, which will be able to give official explanations after September 1, so in such a situation to immediately introduce responsibility for the fact that someone has incorrectly fulfilled some requirement, and you can simply misunderstand it, as far as I am concerned, it is quite critical. That is why we are planning, for our part, from the European Business Association to once again appeal to the deputies regarding the postponement of liability”,
– notes Victoria Kulikova.
There are more than enough reasons to clarify the provisions of the Law “On Lobbying Activities” itself.
Questions without precise answers
Judging by the fact that the draft Law No. 13339, which was supposed to amend the Law on Lobbying and which has not yet received the attention of deputies, proposes almost three dozen clarifications and amendments, we can conclude that there are still enough ambiguous points in lobbying activities. Anna Lachikhina, Chairman of the Board of the Ukrainian Lobbying Association, draws attention to some of them.
“Several questions remain unanswered. Now it is defined that lobbying is an attempt, for example, to change the law, to make amendments or to make it impossible to make some decision. But if we are talking, for example, about allocation of state funding or creation of some additional budget programs, there is a question: whether it is considered lobbying”,
– notes the expert.
There are also questions regarding the relevant activities of public organizations.
“For example, those public organizations, which are industry associations, carry out lobbying activities. But being in the status of a public organization, they are not obliged by law to record this information. Although there are several key signs, and if there is commercial interest, there is influence on legislation and people act in the interests of their customer, then it is, in fact, lobbying activity. That is, all this still has to be clarified and undergo a certain evolutionary process”,
– anna Lachikhina notes.
It is about the evolution of the attitude of those who are not ready to recognize themselves as lobbyists. But the European Business Association believes: if, for example, a public organization is engaged in lobbying, it should recognize itself as a lobbyist, register, be in equal conditions as all others. At the same time, the Association notes: if there is actually a “stick” in the form of responsibility, there should be a “carrot”, i.e. advantages for those who will recognize themselves as lobbyists. Says Victoria Kulikova, Head of the Committees Department of the European Business Association.
“We had an idea that this yet unvoted bill on amendments to the Law on Lobbying Activities should provide some additional advantages for registered lobbyists. For example, simplified access to the premises of the state authorities, some improved conditions for informing, to provide for such a form as a lobbying request, so that companies would be interested to register and recognize themselves as lobbyists”,
– notes Victoria Kulikova.
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Transparency above all
In the coming days, those who consider themselves lobbyists will be able to declare it officially. This opportunity will be provided by the Register of Transparency, the functioning and administration of which is ensured by the National Agency for the Prevention of Corruption. It is there that Ukrainian lobbyists will report on their activities, clients and financial expenditures. Access to the Transparency Register with all its data will be open and publicly available. The start of the Transparency Register will also mean that the NAPC will have powers of control and monitoring. Anna Lachikhina, Head of the Board of the Ukrainian Lobbying Association, reminds about this and at the same time reassures those who are ready to declare themselves as lobbyists.
“We estimate that at least until the end of the year, or even the first six months, everyone will only get used to it, master the functionality. There may be mistakes, but, again, there is certainly no liability for a simple mistake in information or something like that. And there will be an opportunity to correct the data in the registry if such errors appear. This is a kind of first step to make the interaction between business and the authorities even more transparent. Therefore, I urge everyone to get actively involved and register in the registry during the first year,” says Anna Lachikhina,
– says Anna Lachikhina.
According to her, the more people will use the register, the faster it will be possible to understand what and where will need improvement.
The European Business Association reminds that the requirements of the law on lobbying and the need for registration apply to all those who in one way or another submit proposals to regulations in their own commercial interests or in the commercial interests of their beneficiaries. And since many people claim that they are not lobbying, but advocacy, it is necessary to clarify such points to the NAPC and all other institutions involved. Victoria Kulikova, Head of the EBA Committees Department, continues.
“If you systematically propose some legislative changes and meet with the objects of lobbying, i.e. state bodies – it falls under the lobbying activity, and the company must recognize it, register, record everything and report. But, on the other hand, not every communication with representatives of state bodies is lobbying. If a company solves problems with the tax authorities or customs, say, regarding the declaration of the customs value of some goods – this is not lobbying. You are just solving your individual problems. We need to understand all this. And for this purpose, you need to conduct training, trainings for your employees,” the specialist notes,
– notes the specialist.
Head of the Board of the Ukrainian Lobbying Association Anna Lachikhina also explained how lobbying activities will be controlled:
“It should be a two-way process, where the responsibility will lie not only on lobbyists themselves, but also on the objects of lobbying, that is, first of all, on people’s deputies, since they are engaged in law-making activities and are considered an object of lobbying according to this law. Logically, before meeting with people who want to discuss certain legislative issues with them, they should check whether these people, who are actually engaged in lobbying activities, are in this Register of Transparency”.
Thus additional control would have to be created, the expert explains.
“But there is also the NAPC – a body that can accept reports of violations that can come from anyone. Further monitoring, clarification of all the circumstances, and then can already come really administrative responsibility, if a person did not register a certain communication in the register, or himself in time did not register.”
– anna Lachikhina notes.
More work – more opportunities
For many companies that fall under the criteria of lobbying activities, it will not be a problem to declare themselves in the Transparency Register. For example, the European Business Association notes that they will register and report, and reminds that they have never hidden that they are engaged in lobbying. Victoria Kulikova, head of the EBA’s Committees Department, continues.
“Of course, we will register our employees who communicate with state authorities as representatives of the association. If we talk about the content of our work, nothing much will change, because we have always communicated with state authorities transparently, responsibly, in accordance with the best international practices and standards. But we will have to submit a lot of additional reports, to establish internal processes, because in fact we submit reports for half a year. And everything has to be written down: with whom we met, on what regulations, etc.”,
– noted Victoria Kulikova.
The reports of the Good Politics communication agency will also be available in the Transparency Register. It explicitly states that it is engaged in lobbying and communications. Maxim Dzhigun, co-founder and CEO of Good Politics, tells us.
“We want to proactively promote this topic ourselves, to register and to be accountable, because we are a company that strives for openness, we definitely interact always in a transparent and friendly way with the Ukrainian authorities. And we want to register in September as a company that is generally engaged in such activities and that can at any time engage in the promotion of a specific legislative initiative”,
– maxim Dzhygun noted.
He believes that the great advantage of lobbying is that it helps to make more balanced decisions.
“As the experience of all states shows, lobbying from small to large business should be a working tool that should work in the interests, first of all, of business, but also of society as a whole. It is one thing when there is some business monopolist who can agree on something and it works in favor of one company. It is another thing when there is an open lobbying market, where there is an open approach and access for all players who can compete with positions, visions and ideas of how it should be. And so those businesses that are in that system, that are active, they will always win.”
Who else will benefit from the introduction of new rules of lobbying activity is Ukrainian citizens. In a few months everyone will be able to dive into the Register of Transparency and learn, perhaps, a lot of interesting things about who, what and for how much lobbies, as well as about the customers of lobbying services and beneficiaries – those in whose interests something is lobbied. Recall, the Register of Transparency will be open and publicly available.
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Sergiy Vasylevych
