Energy and Tax Policy Dominate as Ukraine's New Lobbying Law Takes Effect

Ukraine's Lobbying Law: A New Regulatory Framework

According to Главком: A landmark piece of legislation, Ukraine's Law on Lobbying (No. 3606-IX), came into force on September 1, 2025, alongside the launch of the public Transparency Register. These measures mark a significant step toward formalizing and monitoring lobbying activities in the country. By December 31, 2025, 132 lobbying entities had been registered, with the first mandatory reporting period concluding on February 1, 2026. According to official data, the most heavily lobbied sectors are energy and fiscal policy.

The Ukrainian parliament, the Verkhovna Rada, passed the law on February 23, 2024, with 236 votes in favor, and President Volodymyr Zelenskyy signed it into law on March 12, 2024. However, its implementation was delayed, with the effective date pushed back to September 1, 2025. The bill was introduced by the government under Prime Minister Denys Shmyhal, and the lead committee was the Committee on Legal Policy, chaired by Denys Maslov. Enacting lobbying regulations was part of the European Commission's recommendations to Ukraine from November 2023.

Lobbying Activity Statistics

As of September 30, 2025, the register contained 73 entities, a number that grew to 132 by December 31. Of these, 152 were in active status, 17 had their status terminated, and 4 had their status suspended. A total of 86 legal entities, 85 individuals, and 2 foreign representative offices were registered. The most common spending bracket for lobbying activities was "up to 100,000 UAH," cited over 150 times.

Among the first legally registered lobbyists in Ukraine are notable companies including:

• Philip Morris Ukraine
• British American Tobacco
• ArcelorMittal Kryvyi Rih
• Oschadbank

The first mandatory reporting period ended on February 1, 2026, documenting 317 instances of interaction with officials. The average number of interactions per active entity was 8.1, with a median of 6. All analyzed reports confirmed that no contributions were made to political parties. In total, 298 lobbying subjects, 272 objects, 380 communications, 10 contracts, and 168 clients were recorded.

The energy and housing-utilities sector was the most lobbied, accounting for 28.5% of all mentions. Fiscal and tax policy followed with 24.6%, and healthcare had approximately 54 mentions. During the reporting period, 114 officials formally interacted with lobbyists. Oleksandr Kovalchuk and Danylo Hetmantsev were the most frequently mentioned recipients of lobbying efforts, with 31 and 24 mentions, respectively.

Dmytro Buzanov noted: "The first reports showed that the energy and housing-utilities sectors are being lobbied the most actively."

The reports also confirmed that 100% of entities made no contributions to political parties. The National Agency on Corruption Prevention (NACP) identified violations by 7 entities for failing to submit reports, and as of May 2026, two court decisions had imposed fines totaling 850 UAH.

In 2024, Ukraine spent $62,500 on lobbying in the United States, compared to $461,200 spent by Russia and $245,200 by Poland. Between 2022 and 2024, Ukraine's total lobbying expenditures in the U.S. exceeded $5.4 million. Oschadbank, a 100% state-owned bank, is also registered as a lobbying entity, indicating the public sector's involvement in this activity.

The implementation of the Law on Lobbying and the launch of the Transparency Register represent a major advance for transparency in governance and for reducing corruption risks in Ukraine. The growing number of registered lobbying entities reflects both the intensification of this process and the willingness of businesses and other organizations to engage openly with state institutions. The initial reports, which detail the scope of lobbying activities, can serve as a foundation for further refining the legal framework in this area.

As Ukraine navigates the complexities of its new lobbying framework, the upcoming mandatory lobbying disclosure requirements set to begin in July 2026 will further shape the landscape. This initiative is expected to enhance transparency and accountability within lobbying practices, building upon the foundation established by the recent law.