NACP takes business proposals into account in official clarifications of the aw of Ukraine “On Lobbying”

08/ 06/ 2026

The European Business Association’s Lobbying and Transparent Policies Committee contributed to the development of the official clarifications on the application of the Law of Ukraine “On Lobbying”, recently approved and published by the National Agency on Corruption Prevention (NACP). As part of the consultations on the draft clarifications, the Association’s Committee submitted proposals aimed at ensuring a clearer and more practical application of the new lobbying legislation. The Committee’s experts also contributed to identifying and compiling a list of problematic issues which, in the opinion of the business community, required official interpretation by the NACP. We are pleased to note that one of the key business proposals was incorporated into the final version of the clarifications. In particular, paragraph 2.7 was amended to clarify that employee remuneration expenses incurred by a lobbying entity are not considered lobbying expenses and therefore do not need to be reflected in lobbying reports. This helps eliminate legal uncertainty regarding the scope of reporting obligations for lobbying entities and reduces the risk of ambiguous interpretation of the legislation. The consideration of this proposal marks an important step towards establishing transparent, clear, and proportionate lobbying rules in Ukraine. At the same time, the published clarifications will contribute to the consistent application of the Law of Ukraine “On Lobbying” and enhance legal certainty for businesses. The European Business Association is grateful to the NACP for its openness to dialogue and for taking the business community’s position into account during the preparation of the official clarifications. The Association’s Lobbying and Transparent Policies Committee will continue to actively contribute to improving the regulatory framework in the field of lobbying and developing transparent mechanisms for interaction between business and the government. Should you require any additional information, please contact Viktoriia Kulykova, EBA Committees Team Lead, at [email protected].

As part of the consultations on the draft clarifications, the Association’s Committee submitted proposals aimed at ensuring a clearer and more practical application of the new lobbying legislation. The Committee’s experts also contributed to identifying and compiling a list of problematic issues which, in the opinion of the business community, required official interpretation by the NACP.

We are pleased to note that one of the key business proposals was incorporated into the final version of the clarifications. In particular, paragraph 2.7 was amended to clarify that employee remuneration expenses incurred by a lobbying entity are not considered lobbying expenses and therefore do not need to be reflected in lobbying reports. This helps eliminate legal uncertainty regarding the scope of reporting obligations for lobbying entities and reduces the risk of ambiguous interpretation of the legislation.

The consideration of this proposal marks an important step towards establishing transparent, clear, and proportionate lobbying rules in Ukraine. At the same time, the published clarifications will contribute to the consistent application of the Law of Ukraine “On Lobbying” and enhance legal certainty for businesses.

The European Business Association is grateful to the NACP for its openness to dialogue and for taking the business community’s position into account during the preparation of the official clarifications. The Association’s Lobbying and Transparent Policies Committee will continue to actively contribute to improving the regulatory framework in the field of lobbying and developing transparent mechanisms for interaction between business and the government.

Should you require any additional information, please contact Viktoriia Kulykova, EBA Committees Team Lead, at [email protected].