Healthcare & Lobbying: Key takeaways from the expert session with Lidiia Sanzharovska, EBA Health Care Committee

26/ 09/ 2025

The Health Care Committee of the European Business Association held an expert discussion on the practical application of the Law of Ukraine “On Lobbying” No. 3606-IX and on business preparation for the launch of the Transparency Register on 1 September 2025. The session’s speaker was Lidiia Sanzharovska, Associate Partner at Legal Alliance Law Firm. Member companies of the EBA received a practical interpretation of Law No. 3606-IX, which came into effect on 1 September 2025. The speaker outlined what does and does not constitute lobbying, the roles of participants in this process (lobbyist, client, lobbying organisation, subject of legislative initiative), as well as the key principles of regulating the field. Participants also discussed: the distinction between expert involvement in public consultations and other events versus lobbying activities, clarification of registration requirements in the Transparency Register “prior to commencing lobbying”, the scope of data disclosure and periodic reporting obligations, mandatory record-keeping of interactions with public authorities. The session focused not only on clarifying the provisions of the law, but also on practical steps for preparing for the new requirements and reviewing specific cases of engagement with government authorities. An operational framework for applying the Law and the Transparency Register was presented: defining subjects, objects, spheres and subject matter of lobbying, registration and reporting requirements in the Register, and other principles of ethical and transparent interaction with public authorities. The session provided participants with a clearer understanding of the new requirements and general guidance for their further implementation. We continue our systematic work and extend our gratitude to Lidiia Sanzharovska and all participants for the discussion. The Committee will further support member companies in adapting to the new requirements and ensure the effective implementation of lobbying legislation in close cooperation with the EBA Committee on Lobbying and Transparent Policies.

Member companies of the EBA received a practical interpretation of Law No. 3606-IX, which came into effect on 1 September 2025. The speaker outlined what does and does not constitute lobbying, the roles of participants in this process (lobbyist, client, lobbying organisation, subject of legislative initiative), as well as the key principles of regulating the field. Participants also discussed:

the distinction between expert involvement in public consultations and other events versus lobbying activities,
clarification of registration requirements in the Transparency Register “prior to commencing lobbying”,
the scope of data disclosure and periodic reporting obligations,
mandatory record-keeping of interactions with public authorities.

The session focused not only on clarifying the provisions of the law, but also on practical steps for preparing for the new requirements and reviewing specific cases of engagement with government authorities. An operational framework for applying the Law and the Transparency Register was presented: defining subjects, objects, spheres and subject matter of lobbying, registration and reporting requirements in the Register, and other principles of ethical and transparent interaction with public authorities. The session provided participants with a clearer understanding of the new requirements and general guidance for their further implementation.

We continue our systematic work and extend our gratitude to Lidiia Sanzharovska and all participants for the discussion. The Committee will further support member companies in adapting to the new requirements and ensure the effective implementation of lobbying legislation in close cooperation with the EBA Committee on Lobbying and Transparent Policies.