Ukraine has brought into force a law that limits open (public) access to a range of state registers for the duration of wartime. The measure is framed as a security step to reduce data-sensitivity risks while keeping core government and market services running.
What’s affected
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Public access to key registers (e.g., companies, real estate, land and other state databases) is suspended or significantly throttled for non-authorized users.
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Full access remains for government bodies, law enforcement, courts, notaries/registrars and other actors designated by the Cabinet of Ministers.
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Businesses and citizens can still obtain extracts and confirmations through authorized channels (e.g., via notaries, accredited registrars, or upon verified e-requests), but routine open lookups may be unavailable.
Why it matters for business
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KYC / Due Diligence: Open searches will be slower; investors should plan for notarized extracts, certified copies and official responses instead of self-service lookups.
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Real-estate & M&A closings: Title and corporate checks will rely more on notarial access and registry officers’ requests; build extra time into closing checklists.
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Compliance & audits: Keep internal copies of statutory docs (charter, beneficial owners, land/title extracts) up to date; request refreshed documents from counterparties early.
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Data protection: Companies holding registry-derived datasets should review storage and sharing practices to align with tightened rules.
Practical checklist for investors and CFOs
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Add 3–7 business days buffer to DD timelines for registry extracts and certificates.
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Use notaries/registrars for priority queries; ask for time-stamped extracts.
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In contracts, include reps & warranties on corporate authority, asset title, and no-encumbrance, plus a covenant to provide updated registry docs upon request.
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For real estate, pair registry extracts with BTI/technical passports, cadastral maps, and municipal confirmations.
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Maintain a secure archive of counterparties’ documents; version and date every file.
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If your process uses API integrations or scrapers, switch to official request flows until open interfaces are restored.
Outlook
The restrictions are expected to remain until security risks ease. The government may calibrate access (e.g., via verified eID, paid extracts, or vetted API gateways) to balance transparency and resilience. Companies that adapt their DD/KYC playbooks now will face fewer delays in deals, banking onboarding, and compliance checks.
