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New registered address confirmation requirements for Ukrainian companies

12/ 11/ 2026
  On 14 October 2026, the Verkhovna Rada of Ukraine adopted Law of Ukraine No. 5020-IX “On the Valuation of Property” (“Law No. 5020-IX”). The law aims to improve the property valuation system, align it with international standards, and enhance the transparency and quality of valuation-related activities. Among other things, Law No. 5020-IX introduces specific requirements for confirming the legal grounds for utilizing real estate following the incorporation of a company and any associated change of its registered address. This Legal Alert provides an overview of the key changes introduced under Law No. 5020-IX in the sphere of the state registration of legal entities along with the practical implications for businesses. General overview. Law No. 5020-IX became effective on 27 October 2026, albeit most of its provisions will enter into force on 27 April 2028 and 27 October 2029. However, the amendments to the Law of Ukraine “On the State Registration of Legal Entities, Individual Entrepreneurs and Public Organizations” No. 755-IV, dated 15 May 2003, have already entered into force, i.e., these amendments are effective since 27 October 2026. Changes to state registration requirements. Starting from 27 October 2026 state registrars must verify the legal grounds for the use of real estate listed as the registered address of a Ukrainian legal entity. The right to use, or title to, such real estate must be held by: the founder (or at least one of the founders) of the legal entity – in the case of the legal entitys incorporation; or the legal entity itself – in the case of a change of its registered address. The verification procedure to be applied by the state registrar depends on the type of right authorizing the use of the given real estate, namely: Incorporation of a new legal entity Title or other proprietary right derived from title The state registrar determines the respective founder’s right authorizing the use of the real estate based on the information included in the State Register of Proprietary Rights to Real Estate (the “Real Estate Register”). If the real estate is owned by the founder, the Real Estate Register must contain the relevant title entry. If the real estate is used by the founder (e.g., based on a lease agreement), the Real Estate Register must contain the relevant entry on the right to use the real estate. Lease, sublease or loan-for-use agreement relating to a building or other capital structure not subject to mandatory notarization (e.g., with a lease term of less than 3 years) The state registrar verifies: the original agreement between the founder and the owner of the property (lessor/lender) or a notarized copy thereof; and the information included in the Real Estate Register confirming that the lessor/lender owns the relevant real estate. Change of an existing legal entity’s registered address Title or other proprietary right derived from title The state registrar verifies the legal entity’s relevant right based on the information contained in the Real Estate Register. If the real estate is owned by the respective legal entity, the Real Estate Register must contain the relevant title entry. If the real estate is used by the legal entity (e.g., based on a lease agreement), the Real Estate Register must contain the relevant entry on the right to use the real estate. Lease, sublease or loan-for-use agreement relating to a building or other capital structure not subject to mandatory notarization (e.g., with a lease term of less than 3 years) The state registrar verifies: the original agreement between the legal entity and the owner of the property (lessor/lender) or a notarized copy thereof; and the information included in the Real Estate Register confirming that the lessor/lender owns the relevant real estate. State registration shall not be carried out if the applicant fails to evidence a legitimate right to use the given real estate as the registered address of the legal entity. The above requirements do not apply to registration actions carried out with respect to state or municipal authorities. ! Note 1: if a legal entity utilizes real estate based on a sublease agreement, the applicant must demonstrate to the state registrar that the lessor has the right to sublease relevant real estate under the said sublease agreement. This implies a need to also produce for the state registrar a copy of the respective lease agreement between the lessor and the ultimate owner of the real estate; the latters title must be duly registered with the Real Estate Register. Associated confidentiality and commercial concerns will thus need to be taken into account by the users/owners of the corresponding real estate. ! Note 2: where a new legal entity is being incorporated by a non-resident founder, the associated preparatory work should be carried out in advance. Specifically, the non-resident must enter into a lease agreement with a local lessor holding title or a registered right to use the real estate where the newly incorporated legal entity will be registered. This accordingly implies a need to carry out the relevant negotiations, to obtain a notarized and legalized power of attorney from the non-resident, and to sign the relevant lease agreement between the local lessor and non-resident founder prior to proceeding with the state registration of the subsidiary legal entity. Once a new legal entity is registered, it may be prudent to assign the given lease agreement from non-resident founder to newly legal entity so as not to increase the risk of permanent establishment for non-resident. Practical implications. The new rules effectively close a loophole that previously enabled legal entities to be registered at addresses without the right to use the respective real estate. Prior to submitting documents to the state registrar, it is advisable to: check that the title to the real estate is registered with the Real Estate Register (otherwise even a valid lease, sublease or loan-for-use agreement will not be sufficient for state registration); ensure that the lease, sublease or loan-for-use agreement is concluded with the proper parties (a legal entity or the founder or the legal entity, as applicable); prepare an original or a notarized copy of the relevant agreement for submission to the state registrar; where the founder of a new legal entity is a resident, it is also recommended to re-conclude the lease agreement between the newly incorporated legal entity and the relevant lessor in order to avoid any tax risks for the resident founder. Contacts For further information, please contact: Olena Kuchynska, Partner, Head of Corporate and M&A, Energy & Natural Resources, Kyiv, [email protected] Mykola Lykhoglyad, Managing Associate, [email protected] Khrystyna Kulynych, Junior Associate, [email protected]  The above does not constitute legal advice and does not create an attorney-client relationship between Kinstellar and any recipient. It is meant for marketing purposes only. The material cannot be circulated to any other person or published in any way without our consent. We retain no liability for the contents of this paper however it may be used by any recipient.

On 14 October 2026, the Verkhovna Rada of Ukraine adopted Law of Ukraine No. 5020-IX “On the Valuation of Property” (“Law No. 5020-IX”). The law aims to improve the property valuation system, align it with international standards, and enhance the transparency and quality of valuation-related activities.

Among other things, Law No. 5020-IX introduces specific requirements for confirming the legal grounds for utilizing real estate following the incorporation of a company and any associated change of its registered address.

This Legal Alert provides an overview of the key changes introduced under Law No. 5020-IX in the sphere of the state registration of legal entities along with the practical implications for businesses.

General overview

Law No. 5020-IX became effective on 27 October 2026, albeit most of its provisions will enter into force on 27 April 2028 and 27 October 2029.

However, the amendments to the Law of Ukraine “On the State Registration of Legal Entities, Individual Entrepreneurs and Public Organizations” No. 755-IV, dated 15 May 2003, have already entered into force, i.e., these amendments are effective since 27 October 2026.

Changes to state registration requirements

Starting from 27 October 2026 state registrars must verify the legal grounds for the use of real estate listed as the registered address of a Ukrainian legal entity.

The right to use, or title to, such real estate must be held by:

  • the founder (or at least one of the founders) of the legal entity – in the case of the legal entity’s incorporation; or
  • the legal entity itself – in the case of a change of its registered address.

The verification procedure to be applied by the state registrar depends on the type of right authorizing the use of the given real estate, namely:

Incorporation of a new legal entity

Title or other proprietary right derived from title

The state registrar determines the respective founder’s right authorizing the use of the real estate based on the information included in the State Register of Proprietary Rights to Real Estate (the “Real Estate Register”).

If the real estate is owned by the founder, the Real Estate Register must contain the relevant title entry.

If the real estate is used by the founder (e.g., based on a lease agreement), the Real Estate Register must contain the relevant entry on the right to use the real estate.

Lease, sublease or loan-for-use agreement relating to a building or other capital structure not subject to mandatory notarization (e.g., with a lease term of less than 3 years)

The state registrar verifies:

  • the original agreement between the founder and the owner of the property (lessor/lender) or a notarized copy thereof; and
  • the information included in the Real Estate Register confirming that the lessor/lender owns the relevant real estate.

Change of an existing legal entity’s registered address

Title or other proprietary right derived from title

The state registrar verifies the legal entity’s relevant right based on the information contained in the Real Estate Register.

If the real estate is owned by the respective legal entity, the Real Estate Register must contain the relevant title entry.

If the real estate is used by the legal entity (e.g., based on a lease agreement), the Real Estate Register must contain the relevant entry on the right to use the real estate.

Lease, sublease or loan-for-use agreement relating to a building or other capital structure not subject to mandatory notarization (e.g., with a lease term of less than 3 years)

The state registrar verifies:

  • the original agreement between the legal entity and the owner of the property (lessor/lender) or a notarized copy thereof; and
  • the information included in the Real Estate Register confirming that the lessor/lender owns the relevant real estate.

State registration shall not be carried out if the applicant fails to evidence a legitimate right to use the given real estate as the registered address of the legal entity.

The above requirements do not apply to registration actions carried out with respect to state or municipal authorities.

! Note 1: if a legal entity utilizes real estate based on a sublease agreement, the applicant must demonstrate to the state registrar that the lessor has the right to sublease relevant real estate under the said sublease agreement. This implies a need to also produce for the state registrar a copy of the respective lease agreement between the lessor and the ultimate owner of the real estate; the latter’s title must be duly registered with the Real Estate Register. Associated confidentiality and commercial concerns will thus need to be taken into account by the users/owners of the corresponding real estate.

! Note 2: where a new legal entity is being incorporated by a non-resident founder, the associated preparatory work should be carried out in advance. Specifically, the non-resident must enter into a lease agreement with a local lessor holding title or a registered right to use the real estate where the newly incorporated legal entity will be registered. This accordingly implies a need to carry out the relevant negotiations, to obtain a notarized and legalized power of attorney from the non-resident, and to sign the relevant lease agreement between the local lessor and non-resident founder prior to proceeding with the state registration of the subsidiary legal entity. Once a new legal entity is registered, it may be prudent to assign the given lease agreement from non-resident founder to newly legal entity so as not to increase the risk of permanent establishment for non-resident.

Practical implications

The new rules effectively close a loophole that previously enabled legal entities to be registered at addresses without the right to use the respective real estate.

Prior to submitting documents to the state registrar, it is advisable to:

  • check that the title to the real estate is registered with the Real Estate Register (otherwise even a valid lease, sublease or loan-for-use agreement will not be sufficient for state registration);
  • ensure that the lease, sublease or loan-for-use agreement is concluded with the proper parties (a legal entity or the founder or the legal entity, as applicable);
  • prepare an original or a notarized copy of the relevant agreement for submission to the state registrar;
  • where the founder of a new legal entity is a resident, it is also recommended to re-conclude the lease agreement between the newly incorporated legal entity and the relevant lessor in order to avoid any tax risks for the resident founder.

Contacts

For further information, please contact:

The above does not constitute legal advice and does not create an attorney-client relationship between Kinstellar and any recipient. It is meant for marketing purposes only. The material cannot be circulated to any other person or published in any way without our consent. We retain no liability for the contents of this paper however it may be used by any recipient.

This material is provided by a member company or partner organization of the European Business Association as part of an informational collaboration. The Association is not responsible for the accuracy, completeness, or reliability of the information presented. The views, opinions, and recommendations expressed in this material are solely those of the authors and do not reflect the official position of the European Business Association.

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