A moment when the unseen became visible. The first lobbyist report: who, how much, and for what is paid to influence power in Ukraine
September 1, 2025, should be marked as a special date in the modern political history of Ukraine. On this very day, the Law of Ukraine “On Lobbying” No. 3606-IX officially came into effect in the country, and the National Agency on Corruption Prevention (NACP) simultaneously launched a public information and communication system called the “Transparency Register.” For the first time in all the years of independence, the state obtained a legal, formalized mechanism for recording what previously occurred primarily in the corridors of ministries, the offices of people’s deputies, and at closed events of industry associations. We are talking about the influence of commercial entities on the process of adopting laws, resolutions, and other acts.
As of December 31, 2025, 132 individuals had acquired the official status of lobbying entities, and in the following months, the number of registered entities in the Transparency Register exceeded 170. The first mandatory lobbying activity reporting campaign in Ukraine’s history concluded on February 1, 2026, and its results provide us with an unprecedented opportunity to see a map of real influence on the Ukrainian government – with specific company names, official surnames, bill numbers, and declared expenditure ranges. The initial conclusions from this map compel a close look at both the strengths of the Ukrainian model and its obvious shortcomings.
The first reports indicated that the most actively lobbied sectors were energy and housing and communal services (about 28.5% of all mentions in Opendatabot’s analysis), financial and tax policy (approximately 24.6%), and healthcare. The registered lobbyists most frequently contacted the head of the Verkhovna Rada Committee on Finance, Tax, and Customs Policy, Daniil Getmantsev, and among the country’s first legal lobbyists were such prominent players as Philip Morris Ukraine, British American Tobacco, ArcelorMittal Kryvyi Rih, retailers Aurora and Metro Cash & Carry, pharmaceutical giants AstraZeneca and Roche, and – significantly for Ukrainian specifics – the state-owned Oschadbank.
This longread compiles all available information from the first lobbying reporting period: from specific figures to industry cases, ratings of officials-interlocutors, and structural gaps in the system.
Contents
- Legislative Framework: The Genesis of the Lobbying Law
- Transparency Register
- First Reporting Campaign: Results
- Most Interesting Sectors for Lobbyists
- Largest Lobbyists
- Who Lobbyists Contact Most Frequently
- Oschadbank Case: A State Bank Among Lobbyists
- GR Agencies and Law Firms
- Tobacco Lobbyists
- Code of Ethics for Lobbyists
- The Ukrainian Lobbying Model: A Comparison with Global Practice
- Public Discussion and Civil Society Reaction
- The Lobbying Market in Ukraine: Gaps, Challenges, and Grey Areas
Legislative Framework: The Genesis of the Lobbying Law
The Law of Ukraine “On Lobbying” No. 3606-IX, initially Bill No. 10337 with the working title “On Honest Lobbying,” was adopted by the Verkhovna Rada on February 23, 2024, with 236 votes from people’s deputies. President Volodymyr Zelenskyy signed the document on March 12, 2024, and its formal effective date was March 14 of the same year. However, the actual implementation of the law was postponed for eighteen months until September 1, 2025, to allow the NACP to technically deploy the Transparency Register and conduct explanatory work with potential market participants.
The government initiated the bill: the then-Prime Minister Denys Shmyhal introduced the document. The relevant parliamentary committee that accompanied the bill was the Verkhovna Rada Committee on Legal Policy, chaired by People’s Deputy Denys Maslov. In parallel with the main lobbying law, the Verkhovna Rada adopted Law No. 3620-IX “On Amendments to the Code of Ukraine on Administrative Offenses Regarding the Establishment of Liability for Violation of Legislation in the Field of Lobbying,” which supplemented the Code of Administrative Offenses with specific articles on fines for non-compliance with the new regulations.
Two key subordinate acts of the Cabinet of Ministers supplement this framework. Firstly, Resolution No. 1128 of October 1, 2024, approved the Rules of Ethical Conduct for Lobbying Entities – a framework document on integrity, transparency, and conflict of interest prevention. Secondly, Resolution No. 1175 of October 16, 2024, approved the Regulations on the Transparency Register, which details the technical aspects of the system’s operation, reporting format, registration procedures, and grounds for suspending or terminating lobbyist status.
It is important to understand the context in which the law was adopted. The introduction of lobbying regulation was included in the list of four additional recommendations from the European Commission in the November 2023 enlargement package – the same recommendations whose fulfillment opened Ukraine’s path to the official start of negotiations for EU membership. This was publicly confirmed by the head of the NACP, Viktor Pavlushchyk. Furthermore, lobbying regulation is stipulated in the Anti-Oligarchic Action Plan, the Anti-Corruption Strategy for 2021–2025, and the recommendations of the Group of States Against Corruption (GRECO) within its Fourth Evaluation Round. In the 2025 enlargement report, published on November 4, 2025, Ukraine received the best assessments in three years, but the European Commission specifically called for “resolutely eliminating pressure on anti-corruption bodies and civil society.” Moreover, even at the stage of drafting the first version of the bill, the European Commission itself cautioned the Ukrainian side that lobbying regulation should not restrict the legitimate activities of civil society, and this remark was one of the reasons for the subsequent narrowing of definitions.
What is Lobbying Under Ukrainian Law
The law defines lobbying as influencing or attempting to influence the object of lobbying – i.e., law-making entities (Verkhovna Rada, President, Cabinet of Ministers, central executive bodies, local self-government bodies), which is carried out in the commercial interests of a beneficiary, for remuneration or with reimbursement of expenses, and concerns a specific subject, which can be a defined regulatory legal act.
The law immediately outlines the scope of activities that are not considered lobbying. These include advocacy activities of public organizations (provided they do not have a commercial beneficiary), participation in public consultations, journalism, political party activities, scientific activities, diplomacy, international technical assistance, and advocacy activities.
The entities of lobbying can be individuals with full civil capacity, Ukrainian legal entities, and foreign companies with representative offices in Ukraine. The law also establishes a clear list of individuals to whom lobbying is prohibited: these include current civil servants, individuals who have been in public service within the last year, individuals with outstanding or unexpunged corruption convictions, as well as citizens and legal entities of the Russian Federation and the Republic of Belarus. This is the so-called “cooling-off period,” intended to reduce the risk of former officials being used as “conduits” for private interests.
Transparency Register: Architecture and Operational Parameters
The NACP acts as the administrator and holder of the Transparency Register. The system was launched on September 1, 2025, with its technical deployment funded not by the state budget but by the Eurasia Foundation within the UK Digit program, supported by the UK government. The Register consists of two logically distinct parts. The public part provides free open access to search functions, dashboards, and full versions of reports – thus implementing the transparency principle for a wide audience: journalists, researchers, representatives of civil society, businesses, and officials themselves. The electronic cabinet, in turn, is designed for lobbying entities themselves: here they register (exclusively using a qualified electronic signature (QES)), submit reports, and notify about the cessation or suspension of their status.
Reporting is mandatory and submitted twice a year: by January 31 (for the period July-December of the previous year) and by July 31 (for the period January-June of the current year). The reports record information about the lobbyist, their clients and ultimate beneficiaries, lobbying sectors and objects (i.e., specific government bodies and officials), declared expenses within legally defined ranges, facts of communication with officials, and importantly – information on the absence or presence of contributions to political parties and election funds. This last point is crucial: it is intended to prevent the scheme where lobbying influence is monetized through party financing.
The registration dynamics in the first months of the system’s operation were increasing: as of September 30, 2025, there were 73 entities in the Register; as of October 9 – 84; as of November 13 – 101 (of which 51 were legal entities and 50 were individuals, with the total number of individuals authorized to lobby on behalf of entities exceeding 190); by the end of November, the number reached 110. As of December 31, 2025, 132 individuals had acquired the official status of a lobbying entity, five of whom had ceased their activities by that time, and one had suspended them. The most popular lobbying sectors at the time of registration were financial, banking, tax, and customs policy (76 entities), economic development (74), and legal policy (70). The least popular sector was “Youth and Sports,” with only 36 registered entities.
First Reporting Campaign: An Overall Picture Based on Reports
The reporting campaign for the second half of 2025 concluded on February 1, 2026, and its results allow us to view the legal lobbying market from a quantitative, not just nominal, perspective. An analysis of submitted reports, available in the Transparency Register (processed through the NotebookLM system based on official extracts), allows us to identify several layers of data.
The total number of entities registered in the Transparency Register at the time of analyzing the reporting period reached 173. Of these, 152 (88%) were actively operating, 17 (10%) had ceased their status, and 4 (2%) had their status suspended. By entity type, the distribution was almost even: 86 legal entities (50%), 85 individuals (49%), and two foreign representative offices (1%). Such a share of individuals is an important indicator: almost half of the registered lobbyists are not large corporations or industry associations, but individual professionals who officially provide GR (government relations) services or represent interests as consultants.
A separate block of analysis concerns expenses. There is no single aggregated sum of expenses in hryvnias across the entire Register, as the law requires expenses to be declared not precisely but within defined price ranges. The most common range, which encompassed the vast majority of entities (over 150 mentions in various spheres of influence), was “up to UAH 100,000” for specific lobbying subjects. High budgets – ranging from UAH 100,000 to UAH 1 million – were recorded in strategic sectors: tobacco (JTI Ukraine, Ukrtutun association), gas extraction (Gas Producers Association of Ukraine, GPAU), wind energy (Ukrainian Wind Energy Association, UWEA), and the agricultural sector (All-Ukrainian Agrarian Council, AAC). Particularly large budgets were reached by contracts with external lobbying firms: GOOD POLITICS LLC and HILLMONT PARTNERS LLC declared the price of individual contracts in the range of UAH 1 to 10 million, although the actual amounts received for the reporting period were in some cases less than the full contract volume. Due to the use of ranges, it is impossible to accurately calculate the average budget per entity, but the median expense for one lobbying subject firmly remains within UAH 100,000.
The first reports showed that energy and housing and communal services are the most actively lobbied sectors
Communication with authorities is the most interesting layer of data, as it reveals the actual intensity of influence. In 39 analyzed detailed reports, approximately 317 instances of interaction with officials were recorded: these include personal meetings, participation in events involving officials, and written proposals. The average per active entity is approximately 8.1 interactions, with a median of 6. This discrepancy between the average and median values indicates a classic “long tail” distribution: a small group of highly active lobbyists – the European Business Association (EBA), the Gas Producers Association of Ukraine, ArcelorMittal Kryvyi Rih – conducts dozens of meetings per reporting period, while a significant portion of entities limits themselves to only one to three documented contacts.
The indicator concerning political financing deserves special mention. One hundred percent of the analyzed reports contain identical official confirmation: “During the reporting period, no contributions were made to support political parties or election funds.” No exceptions were recorded in the provided sources. On one hand, this confirms the compliance of entities with one of the key requirements of the law to avoid creating financial dependence of officials and parties on lobbyists. On the other hand, the complete uniformity of such an indicator remains a matter of trust: the law does not provide a separate mechanism for cross-checking lobbyists’ declarations with party financing disclosures, so a hundred percent “zero” may reflect the actual state of affairs, or it could simply be a standard formula used by everyone without exception. This is one of the areas where the NACP and investigative journalists will have to develop verification methodologies.
A separate data slice, released by the NACP and further analyzed by Opendatabot: the reports recorded 298 lobbying subjects, 272 objects, 380 communications with officials in “responsible and particularly responsible” positions, 10 lobbying service agreements, and 168 clients and beneficiaries. The most lobbied sector was energy and housing and communal services (about 28.5% of mentions), financial and tax policy (about 24.6%), and healthcare (about 54 mentions). Approximately 114 officials officially interacted with lobbyists.
Sectoral Overview: Where Influence Actually Happens
Energy and Housing and Communal Services
Energy became the most active lobbying sector in the first reporting period, which is logical: the industry is at the epicenter of post-war challenges – from restoring destroyed infrastructure to integrating into the European energy market and transitioning to renewable energy sources (RES). Regulatory decisions here simultaneously concern tariffs, the investment climate, infrastructure access, and the structural reform of state-owned companies.
Among the most active lobbying entities are the Ukrainian Wind Energy Association (UWEA), representing the interests of companies such as DTEK RES LLC and Elementum Energy LLC. Working alongside is the Gas Producers Association of Ukraine (GPAU), defending the interests of Ukrgazvydobuvannya JSC, DTEK Naftogaz LLC, and other players. The third influential player is the European-Ukrainian Energy Agency (EUEA), which unites foreign (Scatec Solar, Emergy) and Ukrainian companies. PJSC ArcelorMittal Kryvyi Rih (as a major electricity consumer), the Polish energy concern Orlen S.A., the Union of Ukrainian Entrepreneurs (UUE), and a number of individuals acted as independently registered entities.
The lobbying subjects in this sector are extremely specific. These include Bills No. 14089 and No. 14090 on facilitating the restoration of energy infrastructure, issues concerning the electricity transmission service tariff for the state company Ukrenergo for 2026, Bill No. 13219 on competitive conditions for renewable energy production, Bill No. 14216 on restoring the solvency of state energy enterprises, as well as amendments to legislation on investments in green energy and private nuclear generation.
The recipients of lobbying efforts are primarily a narrow circle of individuals who specialize in energy at the Cabinet of Ministers and parliamentary levels. The head of the Verkhovna Rada Committee on Energy and Housing and Communal Services, Andriy Gerus, is a record holder for the number of recorded interactions in this sector (at least 12). Among other key interlocutors are the acting Minister of Energy, Artem Nekrasov, the First Vice Prime Minister, and from July 2025, the Head of Government, Yulia Svyrydenko, the Chairman of the National Energy and Utilities Regulatory Commission (NEURC), Yuriy Vlasenko, and representatives of Ukrenergo. Most entities declare expenses “up to UAH 100,000” per lobbying subject, but UWEA and GPAU, given the scale of their interests, have moved to the next range – from UAH 100,000 to UAH 1 million.
Healthcare and Medicine
The second major area of active lobbying is healthcare. Here, attention is focused on the regulation of the pharmaceutical market, tobacco and nicotine-containing products, and technical regulations for medical devices. This is the segment where the interests of four powerful groups intersect: international pharmaceutical companies, tobacco giants, producers of alternative nicotine products, and distribution operators.
Among the legal entities, the Public Union “Association of Innovators in Pharmaceuticals” (AIPM) stands out, representing the interests of corporations such as Takeda, Sanofi, Roche, and Pfizer. Independently registered pharmaceutical giants include Sanofi-Aventis Ukraine, AstraZeneca Ukraine, and Roche Ukraine. In addition to them, the European Business Association (through its Healthcare Committee and Tobacco Committee), the Union of Ukrainian Entrepreneurs (in the interests of tobacco companies), and VYGIDNA POKUPKA LLC (Aurora retail chain) are active in healthcare.
Specific lobbying subjects in healthcare cover Bill No. 14110-d on regulating nicotine-containing products, Law “On Medicinal Products” No. 2469-IX, Resolution No. 439 on regulating drug prices, issues of synchronizing the Reimbursement List and the National Price Catalog, Law No. 4122-IX on the circulation of dietary supplements, as well as technical regulations for in vitro diagnostic medical devices.
Among the officials-interlocutors, the key recipient is the Chairman of the Verkhovna Rada Committee on Health of the Nation, Medical Care, and Health Insurance, Mykhailo Radutskyi. Active communications are also recorded with the leadership of the Ministry of Health: Minister Viktor Liashko, Deputy Ministers Edem Adamanov and Maryna Slobodnichenko. Contacts with Iryna Vereshchuk, a representative of the Office of the President, were also recorded – primarily concerning the circulation of dietary supplements and marketing services. The typical expenditure level here is up to UAH 100,000, however, Roche Ukraine declared expenses in the range of UAH 100,000 to UAH 1 million for innovative therapy financing issues.
Tax Policy and Customs Regulation
Tax policy is a sector that concentrates the greatest “nerve” of Ukrainian regulatory policy, and it is here that one of the highest intensities of communication has been recorded. Two groups dominate this sector: the tobacco industry, for which excise and customs regulation is a matter of life and death, and the technology sector, comprising residents of the “Diia City” regime.
Among tobacco players in the Transparency Register, all key manufacturers are registered: PRJSC Philip Morris Ukraine, JTI Ukraine JSC (JTI brand), BAT Ukraine Sales & Marketing LLC (BAT brand), PRJSC V.A.T.-Pryluky (BAT’s Ukrainian production), and the Ukrtutun Association. The IT sector is represented by the Association of Diia City Residents, lobbying the interests of companies like Uklon, Glovo, Megogo, and others. A separate but important segment is professional GR firms: GOOD POLITICS LLC and Ader Haber Government Affairs LLC, which work for corporate clients and do not hide the commercial nature of their services.
The list of specific lobbying subjects in the tax sphere includes Bill No. 14245 on tobacco raw material control (key for the entire industry), the “e-Excise” system and issues of its deferral, Bill No. 14025 on automatic exchange of tax information, Bill No. 14097 on taxation of bank profits in 2026, and Bill No. 14023 on simplifying primary document requirements. Looking at this list, a fundamental conclusion becomes obvious: lobbying in the fiscal sphere is not the “general position” of business, but a struggle for specific norms of specific acts, each of which has a precisely calculated impact on the industry’s profitability.
The main recipient of lobbying in the tax sphere is the Chairman of the Verkhovna Rada Committee on Finance, Tax, and Customs Policy, Daniil Getmantsev – dozens of interactions with all key entities have been recorded with him. An active interlocutor is also Getmantsev’s deputy, Oleksandr Kovalchuk, Minister of Digital Transformation Mykhailo Fedorov, and the acting head of the State Tax Service, Lesya Karnaukh, with whom lobbyists met primarily regarding excise policy and state budget parameters. Expenses of individual entities in this sphere range from up to UAH 100,000 in the vast majority of cases to the “UAH 1 to 10 million” range for individual contracts with lobbying firms.
Agriculture
The agricultural sector has traditionally been one of the most politically active in Ukraine, and the Transparency Register only confirms this. Lobbying activities here are concentrated around three major blocks: export opportunities, land regulation, and state support for producers.
The most prominent lobbying entities are the Public Union “All-Ukrainian Agrarian Council” (AAC), the Ukrainian Grain Association (UGA), Nestle Ukraine LLC, Myronivskyi Hliboprodukt LLC (MHP – through external lobbyist Global Solution Partners LLC), and the EBA – through its specialized Agrochemical and Food Committees. Subjects of interest include issues of agricultural product exports (particularly soybeans, rapeseed, and general exports to the EU), Bills No. 14117, No. 7577, and No. 5274-D on beekeeping development and agricultural sector support, Bill No. 13312 on support for agricultural producers, issues of land tax fixation and the return of agricultural lands from various forms of use, Law No. 2718-IX on materials and articles intended to come into contact with foodstuffs, as well as regulation of pesticide circulation.
The key recipient of agricultural lobbying is Taras Vysotskyi, First Deputy Minister of Economy, Environment, and Agricultural Policy of Ukraine, with whom most contacts from the AAC, EBA, and other agricultural entities are recorded. Verkhovna Rada Speaker Ruslan Stefanchuk is a recipient in matters of soybean and rapeseed exports (an issue with both economic and political dimensions). Serhiy Tkachuk, Head of the State Service of Ukraine on Food Safety and Consumer Protection, is the primary recipient for issues of veterinary restrictions and imports. The AAC declared expenses in the range of UAH 100,000 to UAH 1 million for agricultural and tax policy directions; other entities typically stay within UAH 100,000.
Major Players of the First Reporting Period
Leaders by Expense Volume
Among the entities that declared the highest lobbying expenses for the reporting period, professional lobbying firms are primarily featured. HILLMONT PARTNERS LLC declared receiving an amount in the range of UAH 1 to 10 million under a contract with YOU SERVICES UKRAINE LLC, which is the Ukrainian business of the international service platform Bolt. GOOD POLITICS LLC declared a contract with BRITISH AMERICAN TOBACCO SALES & MARKETING UKRAINE LLC in the same range – UAH 1 to 10 million. GLOBAL SOLUTION PARTNERS LLC – a contract with MYRONIVSKYI HLIPOPRODUKT JSC (MHP) also in the range of UAH 1 to 10 million. This is the upper segment of the market where the price of one contract can equal the annual payroll of an average editorial office or a small consulting firm.
In the “UAH 100,000 to UAH 1 million” segment are independent players operating without intermediaries: JTI Ukraine JSC (JTI) for financial and law enforcement policy directions, Philip Morris Ukraine PRJC – in the area of law enforcement, Ukrtutun Association – for financial and customs policy, Gas Producers Association of Ukraine (GPAU) – on subsoil use and energy issues, and All-Ukrainian Agrarian Council (AAC) – on agricultural and tax policy.
Leaders by Intensity of Contacts
A separate ranking is based on the number of documented communication instances with officials. The European Business Association (EBA) leads here: over 50 interactions with dozens of officials were recorded, including Taras Vysotskyi, Oleh Bondarenko, Daniil Getmantsev, Maryna Slobodnichenko, and many others. EBA is the clearest example of “umbrella” lobbying: one association consolidates the positions of dozens of member companies and approaches the government on behalf of the collective.
The second position is held by ArcelorMittal Kryvyi Rih PJSC – 22 interactions, of which 10 were in person with Dmytro Kisilevskyi, Deputy Head of the Parliamentary Committee on Economic Development, 4 with Andriy Teliupa, and another 2 with Yulia Svyrydenko. This case is indicative of how a large private corporation – the largest mining and metallurgical plant owned by a foreign investor – lobbies directly, without intermediaries, concentrating its communication on a very narrow circle of officials from the relevant committee.
The third position is occupied by Ader Haber Government Affairs LLC – 18 interactions, mainly with members of the Verkhovna Rada Committee on Education (Serhiy Babak and others – a total of 11 individuals) and the NACP leadership. Following are British American Tobacco Sales & Marketing Ukraine with 15 interactions (Oleksandr Kovalchuk – 4 times, Daniil Getmantsev – 3, Maksym Krym – 2, and others) and JTI Ukraine with 13 interactions (Oleksandr Kovalchuk – 4, Daniil Getmantsev – 2, Maksym Krym – 2). The Public Union “Ukrainian Food Retail Alliance” had 12 interactions (Zoryana Stetsyuk – 3, Daniil Getmantsev – 3, Oleksiy Sobolev – 2).
Most Frequent Recipients of Lobbying
Looking at lobbying from the opposite side – from the government’s perspective – the ranking of the most frequently mentioned officials appears as follows. As of the second half of 2025, the first place is taken by Oleksandr Kovalchuk, Deputy Head of the Parliamentary Tax Committee and People’s Deputy – 31 mentions as a recipient (tobacco companies and agricultural entities actively communicated with him). In second place is Daniil Getmantsev, Head of the Tax Committee, with 24 mentions (recipient for the tobacco industry, IT, retail, and banks). Third is Andriy Gerus, Head of the Energy Committee, with about 13 mentions (issues of green energy and tariffs). Fourth is Taras Vysotskyi, First Deputy Minister of Agrarian Policy, and now Minister of Economy, with about 12 mentions (issues of export and food regulation). Fifth is Oleh Bondarenko, Head of the Environmental Committee, with about 12 mentions (waste management and subsoil resources).
Among other active recipients are Dmytro Kisilevskyi (about 11 mentions, industrial policy and economic development), Maksym Krym – Deputy Prosecutor General (about 8 mentions, mainly regarding the fight against the illegal market of excisable goods), Zoryana Stetsyuk – Deputy Minister of Digital Transformation (about 7 mentions, mainly regarding the implementation of the “e-Excise” system).
It is noteworthy that among the leading recipients of lobbying are primarily the heads and deputy heads of parliamentary sectoral committees, rather than ministers. This indirectly confirms an important hypothesis: the key point of influence in the Ukrainian regulatory model is the parliamentary stage of decision-making, not government processing. In other words, in the “Cabinet of Ministers – Rada – President” triangle, sectoral lobbyists primarily approach the Rada.
Lobbyists paid the most attention to the head of the parliamentary tax committee Daniil Getmantsev and his deputy Oleksandr Kovalchuk Photo: ukrnews.live
Oschadbank Case: A State Bank Among Lobbyists
The fact that Joint Stock Company “Oschadbank,” 100% of whose shares are state-owned, registered in the Transparency Register deserves special attention. Oschadbank lobbied for its own commercial interests regarding several specific acts: National Bank of Ukraine Resolution No. 179 on the procedure for opening privatization accounts, Law of Ukraine “On Banks and Banking Activities” No. 2121-III, and Government Resolution No. 779 on programs to enhance the state’s defense capabilities. The objects of lobbying were the National Bank and the Ministry of Defense.
This case raises a conceptual question: can a state bank lobby other state structures, and if so, how does this align with the prohibitions for persons connected with government bodies enshrined in the Law “On Lobbying”? Formally, a legal entity with state participation does not fall under the restrictions for civil servants, but the spirit of the law – about clearly distinct “private” and “public” interests – is clearly blurred in this case. This is a challenge that will have to be resolved either through judicial practice or through further legislative amendments.
GR Agencies and Law Firms
The reports feature professional lobbying and law firms with clearly indicated client-beneficiaries. GOOD POLITICS LLC works for BAT Ukraine (tobacco). HILLMONT PARTNERS LLC – for Bolt (through its Ukrainian legal entity YOU SERVICES UKRAINE LLC). ADER HABER GOVERNMENT AFFAIRS LLC – for BAT Ukraine and SIGMUND FREUD UNIVERSITY UKRAINE. GLOBAL SOLUTION PARTNERS LLC – for Red Bull GmbH and MHP. ARZINGER LOBBYING SOLUTIONS LLC is highlighted separately, having declared lobbying for amendments to the Law “On Lobbying” in its own interests, which is detailed further below. Individual Iryna Shapovalova lobbied the interests of the Ukrainian Lobbying Association.
Tobacco Industry: A Complete Register
Tobacco companies are the most concentrated, financially powerful, and consistent group of lobbyists in the Transparency Register. Each of the four global players with a significant presence in Ukraine registered independently, and all of them lobbied a similar, though not identical, set of acts.
“Philip Morris Ukraine” lobbied Bill No. 14245 (tobacco raw material control), Bill No. 14097 (taxation of banks – an unexpected subject for a tobacco company, but related to general tax reform), the “e-Excise” system, and the regulation of nicotine products (Bill No. 14110). JTI Ukraine – the implementation of video surveillance in warehouses (Ministry of Finance Order No. 608), the opening of the license register, Bills No. 13628, No. 14245, No. 9364 (liability for illegal circulation). BAT (through its legal entity V.A.T.-Pryluky) – Government Resolution No. 1481 (quotas and licensing), deferral of “e-Excise,” Bill No. 14245, combating illegal trade (No. 9364). Imperial Tobacco – amendments to the procedure for video surveillance systems, introduction of a tobacco sample library, Bills No. 14245, No. 9364, No. 14161. The Ukrtutun Association acts as an “umbrella” for the entire industry, lobbying the draft “On Packaging and Packaging Waste,” amendments to the list of precursors, and the launch of the “e-Excise” system.
Rules of Ethical Conduct and Conflict of Interest
Cabinet of Ministers Resolution No. 1128 of October 1, 2024, approved the Rules of Ethical Conduct for Lobbying Entities – a framework document that supplements the provisions of the Law “On Lobbying” with behavioral standards and aims to foster what the NACP calls a “culture of honest influence” among Ukrainian entities in this field.
The Rules formulate several fundamental requirements.
First – **Integrity and Honesty**: Lobbying entities are obliged to be honest and ethical in their activities, respecting democratic values and public good. The document explicitly prohibits the use of threats, blackmail, inducing officials to abuse influence, or inciting them to violate legislation.
Second – **Transparency and Openness**: Lobbyists must act transparently, provide truthful information about their activities, and not mislead lobbying objects (i.e., officials) regarding the sector, subject of lobbying, or ultimate beneficiaries. During each contact with an official, a lobbyist is obliged to state their surname, inform about the fact of lobbying, and name those whose commercial interests they represent.
Third – **Conflict of Interest Prevention**: This is defined as a contradiction between the commercial interests of beneficiaries and the duties of a lobbyist; entities are obliged to take measures to resolve such conflicts in accordance with the contract and internal rules, and officials, in turn, must avoid situations that place them in dependence on lobbyists.
A separate section of the Rules concerns **gifts, hospitality, and financing**. Lobbyists are strictly prohibited from offering, promising, or providing any undue benefit to officials, and officials are obliged to refuse such offers – both for themselves and for close persons. Officials, in turn, are prohibited from making any promises to lobbyists regarding the final outcomes of regulatory act reviews, and the price of a lobbying contract cannot be made dependent on the result – meaning success fees, contracts based on the passage of a law, are not allowed. All settlements between a client and a lobbyist must be made exclusively in non-cash form. Financing lobbying with funds from state or local budgets, as well as funds from entities from the Russian Federation, sanctioned individuals, or foreign aggressor states, is prohibited. Entities report the absence of contributions to political parties or election funds, and all one hundred percent of analyzed reports contain the relevant confirmation.
The **”cooling-off period”** mechanism deserves special attention, intended to prevent the use of former officials as “conduits” for private interests. A person authorized to perform state functions (ministers, deputies, civil servants) cannot be a lobbying entity either during their tenure or for one year after dismissal. Political parties and candidates for elected office cannot be lobbying entities at all. The registration data of legal entities must include the surnames of the directors, founders, and individuals directly involved in influencing, which allows the NACP and civil society to track cases where lobbying is carried out by individuals with an obvious “political trail.”
Regarding sanctions, the law provides for a three-tier scale of measures. In case of violations (e.g., inaccurate data in a report), the NACP provides 10 working days for their correction through an order. If an administrative penalty of prohibition of lobbying activities is applied to an entity, the lobbyist’s status in the Register is suspended. If a court establishes intentional violation of restrictions on sources of financing or beneficiaries, the status is terminated; re-registration is possible no earlier than two years later. As of the reporting period, as noted above, 17 entities ceased their activities and 4 had their status suspended. The sources do not provide a list of violators with specific ethical offenses, but the very existence of several suspended statuses indicates the beginning of practical application of sanction mechanisms. Separately, the NACP prepared and submitted to the courts the first protocols against seven entities for failure to submit or late submission of reports; as of May 2026, at least two court decisions imposed a fine of UAH 850 (50 non-taxable minimum incomes) plus court fees.
The first reports showed that energy and housing and communal services are the most actively lobbied sectors in Ukraine
International Context: The Ukrainian Model in Perspective
The European Union’s Transparency Register has been operating since 2021 based on an interinstitutional agreement among three institutions – the European Parliament, the Council of the EU, and the European Commission; according to the official EU Transparency Register portal, over 12,000 interest representatives are registered. Since September 1, 2025, new rules have been in effect in the European Union, requiring registration for meetings with the heads of the European Parliament and the European Commission. In the United States, the Lobbying Disclosure Act of 1995 (as amended in 2007 by the Honest Leadership and Open Government Act) requires quarterly reporting; according to the US Senate Secretariat, the registration threshold is $3,500 per quarter for lobbying firms per client and $16,000 per quarter for in-house lobbyists, with civil penalties of up to $200,000 for violations. However, enforcement in the US is rare: according to a US Government Accountability Office report (GAO-25-107523), in 2024, the Department of Justice took only one civil action – a settlement with a $65,000 fine, and the largest LDA settlement in history was $125,000 (against Carmen Group). Lithuania has had a law since 2001 with cross-checking (both lobbyists and officials report), Poland since 2003 and 2006 (a narrow definition of “professional lobbying” that leaves gaps).
The Ukrainian Register meets the basic standards of the Organisation for Economic Co-operation and Development (OECD): an open register, a code of ethics, mandatory reporting. However, it falls short of best practices in two key areas: first, the absence of mandatory reporting by officials (so-called “bilateral transparency,” which exists in Lithuania); second, expenses are declared in ranges rather than exact amounts, which significantly limits the ability to analyze the real scale of lobbying.
Public Discussion and Civil Society Reaction
The first draft of the bill was opposed by a coalition of public organizations, including Transparency International Ukraine, OPORA Civic Network, Dejure Foundation, International Renaissance Foundation, Zmina Human Rights Center, and the Center for Democracy and Rule of Law. Appeals mentioned “over 250 NGOs.” They warned that a broad definition could lead to classifying public activists as “lobbyists” – similar to the Russian law on “foreign agents.” By the second reading, the term “advocacy” was removed from the text, and the activities of non-governmental organizations were excluded from the scope of the law (except in cases where they have direct commercial interests).
Businesses – primarily the EBA and the American Chamber of Commerce in Ukraine (ACC) – generally supported the law given its transparency and integrationist nature but requested a 12-month delay in the application of sanctions (Bill No. 13340-1). According to a survey conducted by the EBA among its member companies, 71% of government relations specialists at the time of the survey were not registered in the Register, and 58% of them did not consider their activities to be lobbying in the terms of the law. This indicates that a portion of the market is still distancing itself from official status, either due to a misunderstanding of definitions or a conscious calculation not to fall under regulatory burden.
After the law was adopted, two professional structures emerged on the market: the Ukrainian Lobbying Association (ULA) headed by Hanna Lachikhina, and the National Association of Lobbyists of Ukraine (NALU), led by Chairman Oleksiy Shevchuk and officially presented on September 16, 2025, with representative offices in London, Zurich, and Brussels. NALU positions itself as a self-regulatory organization for the industry and is developing a professional standard for “lobbyist” and a separate Classifier of Economic Activities (CEA) code.
Gaps, Challenges, and Grey Areas
An analysis of the Transparency Register data for the second half of 2025 allows us to identify several structural gaps in the system at both the legislative and enforcement levels.
First and most obvious – the absence of “bilateral transparency.” The law obliges lobbyists to report, but it does not oblige officials and deputies to register meetings with lobbyists or their calendars. This fundamentally distinguishes the Ukrainian model from the Lithuanian one, where cross-checking is the basis of the system. As long as officials do not report their side of the communication, journalists and civil society are forced to rely on the one-sided testimony of lobbyists.
Second – a broad list of exceptions from the law’s scope. Article 3 of the Law “On Lobbying” contains an extensive list of activities not considered lobbying: activities in the media sphere, scientific activities, representation of interests by diplomatic service bodies, work of associations of local self-government bodies. These exceptions open up opportunities for influential groups to present their activities as “expert assistance” or “scientific development” and thus avoid registration.
Third – the vagueness of lobbying subjects. Some entities use maximally general formulations. Reports include lobbying subjects like “company’s humanitarian sphere,” “pharmaceutical policy,” or simply “bills and regulatory legal acts” – without specifying specific act numbers. This significantly complicates understanding which specific norm was attempted to be influenced and reduces the analytical value of reporting.
Fourth – the “Other” interaction format. A significant portion of contacts (over 40% in some reports) are marked as “Other,” which allows for not detailing the nature of the communication: whether it was a personal meeting, a phone call, a messenger message, or an incidental interaction at the sidelines of an industry event. Such categorization contradicts the principle of openness.
Fifth – broad financial ranges. Because reporting is submitted in ranges (“up to UAH 100,000,” “UAH 100,000 to UAH 1 million,” “UAH 1 to 10 million”), an entity that spent UAH 500 on stationery and an entity that spent UAH 99,000 on organizing an event appear the same in the Register. This fundamentally limits the ability of analysts and journalists to reconstruct the real budgets of lobbying campaigns.
Sixth – mismatch between expenses and number of contacts. The Register features entities with abnormally low expenses and extremely high activity, which may indicate incomplete financial reporting. ArcelorMittal Kryvyi Rih PJSC recorded 22 interactions (10 of which were in person with Deputy Committee Chairman Dmytro Kisilevskyi), yet indicated expenses of only “up to UAH 100,000” across all directions. The German-Ukrainian Chamber of Industry and Commerce (AHK Ukraine) lobbied at the level of Prime Minister Denys Shmyhal and Ministers Yulia Svyrydenko and Oleksiy Sobolev, but also declared expenses in the minimal “up to UAH 100,000” range. A possible explanation is that entities declare only direct operational expenses (printing, logistics, hall rentals), ignoring the cost of work time for in-house government relations specialists or experts. Although the law formally requires reporting all sums necessary for lobbying activities, the interpretation of this provision is currently unclear.
Seventh – the mildness of the Rules of Ethical Conduct. Resolution No. 1128 is based on general formulations (“respect democratic values,” “act with integrity”), leaving the NACP with extremely broad discretion. On one hand, this gives the Agency flexibility in complex cases. On the other hand, it creates legal uncertainty for the lobbying entities themselves, as the boundaries of the permissible and prohibited are blurred.
Eighth – the conceptual case of Oschadbank. As shown above, a state bank registered as a lobbyist, despite the general logic of the law on separating private interests from public functions. This creates a conflict of interest that has not yet received a judicial or regulatory response.
Ninth – “shadow lobbying.” The law does not address direct bribery of deputies and does not cover lobbying through grants, media, and think tanks. Therefore, even a fully populated Transparency Register will overlook a significant portion of real influence on power.
Tenth – lack of taxation mechanism. Currently, the “lobbyist” profession lacks a well-thought-out taxation model, meaning a portion of legal lobbying activities will be “dissolved” within codes for legal services, consulting services, or public association activities, complicating macro-economic assessment of the industry.
Lobbying the Lobbying Law Itself
One of the most interesting effects of the first reporting campaign is the confirmed fact that lobbyists themselves are actively trying to change the rules of the game for their market. Reports recorded lobbying of Bill No. 13339 “On Amendments to the Law of Ukraine ‘On Lobbying’ Regarding Clarification of Certain Provisions.” The European Business Association, through its specialized Committee on Lobbying, officially interacted with the Head of the Verkhovna Rada Legal Committee, Denys Maslov, and the NACP leadership regarding this project. Professional lobbying firms, including GOOD POLITICS LLC and ARZINGER LOBBYING SOLUTIONS LLC, also declared lobbying for amendments to the relevant law in their own commercial interests. This indicates an attempt by the professional community to soften the regulatory burden, clarify terminology, or change certain restrictions.
Given the nature of the market, such meta-activity is entirely expected: lobbyists, who have just become subject to regulation, naturally seek to influence the parameters of the regulation itself. However, from the perspective of democratic hygiene, this process must be as public as possible, otherwise, there is a risk of “corridor” rewriting of the law, which itself is intended to combat “corridor” practices.
International Dimension in Reports
International issues are widely represented in the reports through the prism of sanctions policy, export control, and post-war reconstruction. Polish company Orlen S.A. declared lobbying for the subject “Synchronization of Ukraine’s Sanctions Policy with the European Union’s Sanctions Policy.” The EBA lobbied for the abolition of export duties on oilseeds (Bill No. 14055). The Ukrainian Grain Association actively worked on issues of exports to the EU and exports of soybeans and rapeseed, interacting with Ruslan Stefanchuk and Yulia Svyrydenko. ArcelorMittal Kryvyi Rih lobbied for a ban on the export of scrap metal – an issue with both economic and security dimensions.
The European-Ukrainian Energy Agency lobbied for issues related to “Recovery of Communities and Public Infrastructure.” The EBA promoted the implementation of BIM technologies (Building Information Modeling, i.e., information modeling of buildings; Bill No. 6383) for digitizing post-war reconstruction processes at all stages of object lifecycle. Individual Mykola Portnyi reported lobbying in the interests of LogicPower Plus LLC regarding the “company’s humanitarian sphere.” ADER HABER LLC lobbied for legislative changes in connection with the ratification of the Istanbul Convention (Council of Europe Convention on preventing violence against women and domestic violence).
A separate figure that provides scale for the international context: according to Opendatabot, in 2024, Ukraine officially spent approximately $62,500 on lobbying in the United States, while the Russian Federation spent approximately $461,200 – seven times more. Poland spent $245,200. From the beginning of the full-scale invasion in 2022 to 2024, Ukraine spent over $5.4 million on lobbying in the US. This contrast is important not only in itself but also because it shows that domestic lobbying regulation is only one part of the story; the other part is the ability of the Ukrainian state and the Ukrainian private sector to effectively represent their interests abroad.
First Lessons and What the Next Reporting Campaign Will Show
The initial results of the Transparency Register’s operation allow us to draw several preliminary conclusions. First, the infrastructure has started working and is already producing useful data – this is a historical fact in itself for Ukraine. Second, the vast majority of registered entities are real participants in the lobbying market – tobacco companies, pharma giants, agricultural associations, GR firms. Third, the central points of influence turned out to be the heads and deputy heads of parliamentary sectoral committees, primarily tax and energy. Fourth, the professional lobbying firm market has begun to legitimize and emerge from the shadows.
At the same time, the first report exposed systemic weaknesses mentioned above. It is already evident that the next reporting campaign (based on the results of the first half of 2026, due by July 31, 2026) will be crucial – both in terms of the number of registered entities and the quality of report completion.
Several markers are worth close monitoring. Will the number of registered entities continue to grow? If so, will the 71% of government relations specialists who still don’t consider their activities lobbying join? Will new court decisions appear, and will fines exceed the symbolic UAH 850? Will amendments be made to the law to introduce “bilateral transparency”? Will the NACP identify specific examples of inaccurate data, and will there be at least one case of status termination for intentional violation? If the answers are positive, the first report can be considered the starting point of a real reform. If not – it will remain an important but largely symbolic event.
Dmytro Buzanov, lawyer, lobbyist, for “Glavcom”