Ukrainian legislation establishes liability for illegal lobbying and for violations of legislation in this field. The Code of Ukraine on Administrative Offences (CUAO) provides for administrative sanctions in the form of fines and prohibition from engaging in lobbying activities.
Individuals are held administratively liable, in case of committing relevant offences, if they engage in lobbying without acquiring the status of a lobbying entity, or if their status has been terminated or suspended, as well as natural persons and heads of legal entities registered in accordance with the procedure established by the Law of Ukraine “On Lobbying” as lobbying entities.
Illegal lobbying (Article 18846-1 of the CUAO) by a person who has not obtained the status of a lobbyist or whose lobbyist status has been terminated or suspended entails a fine ranging from 50 to 100 tax-free minimum incomes of citizens, which in 2025 equals UAH 850 – 1,700.
If a person commits this offence repeatedly within a year, they may be fined from 200 to 500 tax-free minimum incomes of citizens (UAH 3,400 – 8,500 as of 2025).
If a person, when acquiring the status of a lobbyist, fails to disclose circumstances that exclude the possibility of being a lobbying entity, this entails a fine ranging from 500 to 1,000 tax-free minimum incomes of citizens (UAH 8,500 – 17,000 in 2025).
It should be noted that such circumstances include acquiring the status of a lobbyist by a person who is not entitled to act as a lobbying entity.
For violations of lobbying legislation (Article 18846-2 of the CUAO), in particular, for failure to submit or late submission of a lobbying report to the Transparency Register (the Register), a lobbyist must pay a fine ranging from 50 to 100 tax-free minimum incomes of citizens, which this year amounts to UAH 850 – 1,700.
For repeated commission of this offence within a year, a fine ranging from 300 to 400 tax-free minimum incomes of citizens (UAH 5,100 – 6,800) is imposed, along with a one-year ban on lobbying activities.
Failure to submit or late submission to the NACP of an application for suspension or termination of lobbyist status, or for exclusion from the Register of information about a person conducting lobbying on behalf of a legal entity, entails a fine ranging from 100 to 300 tax-free minimum incomes of citizens (UAH 1,700 – 5,100).
If the circumstances specified in Part 4 of Article 10 of the Law arise, the lobbying entity is obliged to terminate or suspend its status within fifteen days, depending on the circumstances that have arisen. If such circumstances concern a lobbyist conducting lobbying on behalf of a legal entity, the entity (company) is obliged to remove information about such a person from the Register within the specified period.
Violation of restrictions regarding the subject matter of lobbying, conducting lobbying in the commercial interests of a person who cannot act as a beneficiary, at the request of a person who has no right to be a client, or payment for lobbying with funds that cannot be used as a source of its financing, entails a fine ranging from 1,000 to 2,000 tax-free minimum incomes of citizens (UAH 17,000 – 34,000).
For reference: fines are calculated in tax-free minimum incomes of citizens (hereinafter – TFMI). As of 2025, 1 TFMI for administrative fines equals UAH 17.
As a reminder, lobbying is a legal instrument for businesses and society to influence decision-making by public authorities. At the same time, it requires clear rules and transparency to remain an open and democratic process. An important component of this process is avoiding conflicts of interest during lobbying. The legislation establishes clear restrictions to prevent conflicts of interest and abuse of influence. This means that not everyone can obtain lobbyist status.
