News digest | October 2026
Contents
Corporate Law practice
New requirements for confirming the registered address of legal entities apply from 27 October
On 27 October 2026, amendments to the legislation governing the state registration of legal entities entered into force under Law of Ukraine No. 5020-IX “On Property Valuation” of 14 October 2026.
When registering the incorporation of a legal entity, the state registrar must now verify that at least one founder has a legal basis for using the real estate at the address specified as the entity’s registered address. Where an existing legal entity changes its registered address, the registrar must verify that the legal entity itself has such a legal basis.
Where the legal basis for use is a lease, sublease or loan-for-use agreement for a building or other permanent structure that is not required by law to be notarised, the check is carried out on the basis of that agreement and information from the State Register of Proprietary Rights to Immovable Property. The registrar must establish whether the property is owned by the landlord or lender.
Failure to establish a legal basis for using the property now constitutes a new ground for refusing state registration.
The amendments should be taken into account when incorporating legal entities in Ukraine, including entities with foreign founders, and when planning changes to the registered addresses of existing companies.
Legal framework for collective investment institutions amended
On 4 October 2026, certain provisions of Law of Ukraine No. 4962-IX of 2 September 2026 entered into force, amending the legal framework governing collective investment institutions.
In particular, the amendments change the conditions for the participation of individuals in venture and qualified collective investment institutions. The threshold for an individual to participate in a venture fund is now at least UAH 1.8 million (previously 1,500 minimum monthly wages as at 1 January 2014), and participation requires ownership of the fund’s securities with the corresponding nominal value. At the same time, the minimum participation amount for individuals in qualified collective investment institutions, previously UAH 121,800, has been abolished.
From the same date, the law expressly allows qualified collective investment institutions to invest in domestic government bonds in addition to assets of their selected qualifying asset class and cash. In addition, the restrictions on asset management companies taking out loans and credits repayable from the assets of collective investment institutions have been relaxed: the cap has been raised from 10 to 20 per cent of net asset value, and the maximum term has been extended from three months to five years.
Most of the other amendments, including those governing the absorption and merger of collective investment institutions and the conversion, consolidation and splitting of their securities, will take effect on 3 January 2027.
The Law requires the National Securities and Stock Market Commission to bring its regulations into line with the Law within six months of its publication.
The National Securities and Stock Market Commission has already announced that it is preparing guidance on the practical application of the new requirements and has begun updating the relevant secondary legislation.
Ukraine proposes a new framework for investment funds based on European standards
On 12 October 2026, Draft Law No. 16137 “On Investment Funds” was registered with the Verkhovna Rada of Ukraine. The draft aims to comprehensively update the legislation governing collective investment and align it more closely with European Union standards.
Prepared with the support of the World Bank, the draft law provides for new types of investment funds, including public funds operating under the UCITS framework and alternative investment funds regulated in accordance with the AIFMD. It also envisages the development of venture, social and long-term investment funds in line with relevant EU regulations.
The proposed reform is intended to create new mechanisms for attracting private capital, broaden investment opportunities and strengthen investor protection. For Ukrainian businesses, this could provide additional sources of finance for investment projects and support the development of the domestic capital market.
As at the end of October 2026, the draft law remains under consideration by the relevant parliamentary committee.
Litigation and Dispute Resolution practice
Inheritance of a share in an LLC: an heir may challenge resolutions of the general meeting adopted before the heir’s admission to the company – Commercial Cassation Court
Resolutions of the general meeting adopted unilaterally by a participant whose share does not provide the required number of votes prescribed by law or by the articles of association are invalid. When determining the required number of votes, the votes attributable to a deceased participant’s share must be taken into account, except where resolutions are adopted in the cases provided for by Article 23 of the Law of Ukraine “On Limited and Additional Liability Companies”.
This conclusion was reached by the Supreme Court, sitting as a panel of judges of the Commercial Cassation Court, in its judgment of 3 September 2026 in case No. 908/2470/21.
In the case under review, the company had two participants holding 50% shares each, while its articles of association required more than 60% of votes for the general meeting to be quorate and to adopt resolutions on all matters. Following the death of one of the participants, who had also served as the company’s director, the other participant unilaterally held a general meeting at which he dismissed the deceased from the post of director, appointed himself acting director, removed the deceased from the Unified State Register as an authorised signatory and authorised himself to file the relevant changes with the Unified State Register.
The son of the deceased participant, having obtained a certificate of inheritance under a will in respect of the share in the authorised capital and having filed an application for admission to the company, challenged those resolutions. The court of first instance and the appellate court declared them invalid and cancelled the state registration of changes carried out on their basis.
Leaving the lower courts’ decisions unchanged, the Commercial Cassation Court drew attention to the need to distinguish between the right to a share in the authorised capital and the corporate rights of a participant. The right to a share, as a proprietary right, forms part of the estate and vests in the heir from the time the succession opens. By contrast, the right to participate in the company, as a corporate right, is not inherited and arises only after the heir is admitted to the company.
Accordingly, prior to acquiring the status of a participant, the heir does not yet hold corporate rights, but is already the owner of the inherited share and is entitled to be admitted to the company. This gives rise to a legally protected interest on the heir’s part in ensuring that, during the period before corporate rights are acquired, resolutions of the general meeting are adopted in accordance with the law and the articles of association. The heir may therefore challenge resolutions of the general meeting adopted prior to the heir’s admission to the company where such resolutions infringe that legitimate interest.
The Commercial Cassation Court agreed with the lower courts’ conclusions that the resolutions of the LLC’s general meeting had been adopted without the required number of votes. The articles of association required more than 60% of votes for the meeting to be quorate and to adopt resolutions, whereas the resolutions had been passed by a participant holding only 50%. At the same time, the votes attributable to a deceased participant’s share may be disregarded only in the cases expressly provided for by law – when deciding on the expulsion of such a participant from the company (where the deceased’s share is less than 50% and the heirs have not applied for admission) or when adopting resolutions relating to the liquidation of the company where the deceased’s share is 50% or more. No such circumstances were present in this case, and the votes of the deceased participant therefore had to be counted when determining the required number of votes. Accordingly, for LLC participants and heirs, this means that following the death of a participant holding a share without which there is no quorum, another participant cannot unilaterally replace the director or adopt other resolutions outside the exceptions set out in Article 23 of the Law, and the heir is entitled to challenge such resolutions in order to protect the inherited share.
Military registration: automatic re-registration of persons previously excluded from military registration held unlawful – Sixth Administrative Court of Appeal
A person who has been declared unfit for military service and excluded from military registration cannot be automatically placed back on the register on the basis of data from state registers without the prior decision first being reviewed in accordance with the procedure established by law.
This conclusion was reached by the Sixth Administrative Court of Appeal in its judgment of 16 September 2026 in case No. 320/31215/25.
In the case under review, a citizen who had previously been declared unfit for military service and excluded from military registration was automatically placed back on the register. This was done on the basis of clauses 17 and 17-1 of the Procedure for Implementing the Pilot Project on Automatic Verification and Checking of Information on Conscripts, Persons Liable for Military Service and Reservists, approved by Resolution No. 932 of the Cabinet of Ministers of Ukraine of 16 August 2024, which provided for the automatic military registration of men aged between 25 and 60 on the basis of data from state registers without referral to a military medical commission.
The court of first instance dismissed the claim, treating such automation as a purely technical procedure.
The appellate court disagreed with this approach and stressed that legislation distinguishes between removal from military registration and exclusion from military registration, with each procedure governed by its own distinct legal grounds. Deficiencies in maintaining the “Oberih” register cannot give rise to adverse legal consequences for citizens, and the absence of a record of a person’s exclusion from registration in the register does not mean that the earlier decision has ceased to have effect. Following its review, the appellate court set aside the decision of the court of first instance, declared clauses 17 and 17-1 of the Procedure unlawful and invalid, and ordered the Cabinet of Ministers of Ukraine to bring the regulatory framework into conformity with the Law of Ukraine “On Military Duty and Military Service” and to establish a mechanism for cancelling the automatic registration of the relevant persons. By rulings of the Administrative Cassation Court within the Supreme Court of 22 October 2026, cassation proceedings were opened upon the cassation appeal of the Cabinet of Ministers of Ukraine, while the application to suspend the operation and enforcement of the appellate court’s judgment pending completion of its cassation review was refused. Accordingly, for citizens previously excluded from military registration on health grounds, as well as for employers maintaining personal military registration records, this means that the automatic appearance of the status of a person liable for military service in the “Oberih” register without a review of the military medical commission’s decision does not reinstate military duty and may be challenged.
Acceptance of inheritance from abroad: an application may be submitted by post without travelling to Ukraine in person – Ministry of Justice
An heir staying abroad may submit an application for acceptance of an inheritance without appearing in person before a notary in Ukraine, by sending the application by post with a certified signature within the six-month time limit.
The relevant clarification was published by the Ministry of Justice of Ukraine on 12 October 2026.
The Ministry of Justice recalled that, pursuant to Article 1270(1) of the Civil Code of Ukraine, a period of six months is established for accepting an inheritance, running from the time the succession opens, and that, pursuant to Article 1269(2) of the Code, an application for acceptance of an inheritance must be submitted personally by an heir who did not reside permanently with the deceased at the time the succession opened. The authenticity of the heir’s signature on such an application may be certified either by a consular post of Ukraine or by a foreign notary; in the latter case, depending on the country concerned, an apostille or consular legalisation, together with a Ukrainian translation, may be required. The application is sent by post to a notary in Ukraine, and where it is dispatched before the expiry of the statutory period, it is deemed to have been submitted in time.
Once the application has been submitted, the heir may issue a power of attorney to a representative to file documents and obtain the certificate of inheritance; however, a representative cannot submit the application for acceptance of the inheritance itself on the heir’s behalf.
The Ministry of Justice emphasised that staying abroad does not in itself guarantee that an additional period for accepting the inheritance will be granted. Accordingly, for heirs staying abroad, this means that the application should be certified and dispatched to a notary before the expiry of six months from the date on which the succession opened, without relying on submission through a representative or on a court-ordered extension of the time limit.
ASVP update: parties’ access to enforcement proceedings materials is now provided exclusively via the electronic cabinet using a QES – SE “NAIS”
Access identifiers no longer allow parties to view case materials on the website of the Automated Enforcement Proceedings System (ASVP); instead, parties obtain such access exclusively through the electronic cabinet following authentication with a qualified electronic signature (QES).
The relevant update to the ASVP software was announced by State Enterprise “National Information Systems” on 26 October 2026.
The changes have been introduced pursuant to Law of Ukraine No. 4833-IX of 7 April 2026 “On Amendments to Certain Legislative Acts of Ukraine Regarding the Improvement of the Procedure for Enforcing Court Decisions and Decisions of Other Authorities and the Digitalisation of Certain Stages of Enforcement Proceedings”, which entered into force on 23 October 2026. As noted in our April 2026 digest, this Law marked the transition to electronic interaction in enforcement proceedings. A new tab, “Electronic Cabinet of a Party to Enforcement Proceedings”, has been added to the ASVP website, where a user must enter the proceedings number in the field “ASVP Enforcement Proceedings Registration Number”, authenticate using a qualified electronic signature, and sign or confirm consent to inspect the proceedings materials. Thereafter, the user gains access to all documents available in the system for those proceedings.
The signed consent to inspect the materials is stored in the relevant proceedings under the “Scanned Copies” tab, in the “Scanned Copies to the Enforcement Document” section, and the parties may view it on the ASVP website under the “Other Documents” tab of the respective enforcement proceedings. Accordingly, for creditors, debtors and their representatives, this means that monitoring enforcement proceedings – including those opened previously – now requires a qualified electronic signature, whereas previously issued access identifiers have lost their practical utility.
Tax Law Practice | TAX ALERT
Law on VAT on international parcels has come into force
On October 23, 2026, Law of Ukraine No. 5025-IX dated October 15, 2026 “On Amendments to the Tax Code of Ukraine regarding the Specifics of Value Added Tax Taxation of Distance Sales of Goods Moved (Sent) across the Customs Border of Ukraine in International Postal and Express Shipments” partially came into force.
We have previously written about the adoption of this law, after which it was signed by the President of Ukraine and officially published.
It should be noted that the main changes concern the abolition of the €150 limit on the total value of goods imported into the customs territory of Ukraine by e-commerce platforms and their intermediaries for recipients who are natural persons, with a view to subjecting such goods to VAT.
Despite the law having come into force, the updated taxation rules will only apply 45 days after the publication of the decision of the Cabinet of Ministers of Ukraine on the possibility of their introduction, but not earlier than July 1, 2027.
Taxation of income from digital platforms: law has come into force
On October 23, 2026, Law of Ukraine No. 4903-IX dated June 9, 2026 “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine regarding the Introduction of the International Automatic Exchange of Information on Income Received through Digital Platforms and the Taxation of Such Income” came into force.
We have previously written about the adoption of this law by parliament.
It should be noted that this law introduces a special tax regime for income of individuals received through digital platforms, in particular from the sale of goods, the provision of transport and delivery services, as well as the rental of property.
Such income will be taxed at a combined rate of 10 % within an annual limit of 834 minimum wages (this amount currently stands at 7,211,598 UAH), and the tax will be withheld and paid to the budget by platform operators acting as tax agents. At the same time, income from the sale of goods through platforms will not be taxed if its annual amount does not exceed the equivalent of €2,000.
The new taxation rules will apply to income received from January 1, 2027.
Ukraine has joined the international agreement on data exchange regarding digital platforms
On October 29, 2026, the Ministry of Finance of Ukraine announced that the State Tax Service of Ukraine, as the competent authority of Ukraine, had joined the Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived through Digital Platforms (DPI MCAA).
Accession to the DPI MCAA is part of a major update of the rules for taxing income received through digital platforms, which are being introduced from January 1, 2027.
As stated by the Ministry of Finance of Ukraine, this agreement creates a legal basis for the automatic exchange of the relevant information between Ukraine and partner foreign jurisdictions.
Tax relief in territories of hostilities: draft law registered
On October 29, 2026, draft law No. 16200 “On Amendments to the Tax Code of Ukraine and Other Laws of Ukraine regarding Support for Business Entities and Persons Ensuring Vital Activities in Territories of Hostilities” was registered with the Verkhovna Rada of Ukraine.
It proposes, in particular, to set the corporate income tax rate at 9 % for taxpayers carrying out activities in territories of possible and/or active hostilities included in the List of Territories Where Hostilities Are (Were) Conducted or Temporarily Occupied by the russian federation.
This rate would apply during martial law and for two years from the date of its termination or cancellation, provided that, for the previous calendar year, at least 90 % of the total amount of local taxes paid by the taxpayer was credited to the local budgets of territorial communities located in such territories.
In addition, it is proposed to exempt from personal income tax salaries, monetary allowances, supplements, bonuses and other payments accrued to persons who have acquired the status of a participant in ensuring vital activities in territories of hostilities, for the confirmed periods during which they actually and personally performed their duties in territories of active hostilities.
This exemption would not apply to income for periods of remote work or work from home from another territory, the performance of one-off tasks without actual presence in the relevant territories, or merely formal employment, service or other legal relationships.
If adopted, the relevant law will come into force on the first day of the month following the month of its publication.
Updates to taxation rules in the electricity market: draft law registered
On October 22, 2026, draft law No. 16174 “On Amendments to the Tax Code of Ukraine regarding Alignment with EU Legislation and Changes to the Conditions of Indirect Taxation of Electricity Market Participants in order to Facilitate the Coupling of Electricity Markets in accordance with the Principles of Energy Community Law” was registered with the Verkhovna Rada of Ukraine.
We have previously written about this document whilst it was being reviewed by the Ministry of Finance of Ukraine.
The main proposals relate to the VAT rules governing the supply of electricity. In particular, it is planned to introduce the status of a taxable dealer, determine the place of supply of electricity, as well as exempt the import of electricity from VAT.
In addition, the draft law provides for updated excise tax rules. In particular, it is proposed to set the excise tax rate on electricity at €2.8 per 1 MWh.
Tax relief for entrepreneurial grants: draft law
On October 20, 2026, draft law No. 16169 “On Amendments to the Tax Code of Ukraine regarding the Introduction of the Entrepreneurial Grant as an Instrument for Supporting and Developing Business Entities” was registered with the Verkhovna Rada of Ukraine.
It proposes to introduce the concept of “entrepreneurial grants”, which may be provided by foreign governmental and non-governmental organisations, international organisations, donor institutions and their representative offices in Ukraine, public associations, charitable organisations, as well as local self-government bodies.
It is proposed to extend to entrepreneurial grants the taxation rules currently established for budget grants, in particular:
- the adjustment of the financial result of a corporate income tax payer by the amounts of grants included in the relevant income and expenses;
- the exclusion of such grants from the total monthly (annual) taxable income of an individual, with the functions of a tax agent being assigned to the grant provider.
If a grant is not used for its intended purpose, the relevant amount will be subject to taxation, and the taxpayer will be required to report it in the annual tax return and pay the tax independently;
- the exclusion of such grants, provided that they are used for their intended purpose, from the income of sole traders under the general taxation system and persons engaged in independent professional activities, as well as single tax payers of the first to third groups.
If adopted, the relevant law will come into force on the day following its publication and will take effect six months after its entry into force.
Tax implications of damage to property as a result of armed aggression: information letter of STS
On October 23, 2026, the State Tax Service of Ukraine published information letter No. 4/2026 “Tax Implications of the Destruction of and Damage to Property of Legal Entities as a Result of the Armed Aggression of the russian federation: Answers to Topical Questions”.
It systematises clarifications on the tax implications of the destruction of or damage to fixed assets, goods and other property as a result of the armed aggression of the russian federation.
The clarifications provided in the letter include, in particular, the following:
- the liquidation of fixed assets as a result of force majeure circumstances is not considered a supply for VAT purposes, provided that it is properly documented;
- force majeure circumstances may be confirmed, in particular, by a certificate of the Chamber of Commerce and Industry of Ukraine, a fire report or a relevant extract from the Unified Register of Pre-Trial Investigations;
- VAT amounts on destroyed/lost goods that were included in the tax credit upon their purchase are not included in the budget refund, but are carried forward to the tax credit of subsequent reporting (tax) periods until fully offset;
- the lack of access to fixed assets located in temporarily occupied territories or territories of hostilities is not equivalent to their documented liquidation. Once access to such assets has been obtained, the taxpayer should carry out their inventory;
- the destruction of property does not rule out the possibility of suspension of the registration of tax invoices/adjustment calculations in the Unified Register of Tax Invoices.
The full text of the clarifications is available via the link.
Register of Large Taxpayers for 2027 was approved
On October 27, 2026, the State Tax Service of Ukraine published order No. 708 dated October 21, 2026 “On Approval of the Register of Large Taxpayers for 2027”.
It approves the list of large taxpayers assigned to the interregional offices of the STS for work with large taxpayers. However, the list itself has not been published.
According to the order, the registration (deregistration) of such taxpayers with the relevant territorial bodies of the STS must be ensured by January 4, 2027.
Dashboard of STS on single tax payers of the third group
On October 27, 2026, the State Tax Service of Ukraine announced the launch of the analytical dashboard “Single Tax of the Third Group”.
It contains data for 2024–2026 and makes it possible to analyse information on single tax payers of the third group, in particular:
- their number;
- the amounts of income declared by them;
- their distribution by tax rates, types of economic activity, regions and legal forms of business entities.
This dashboard has become the fourth analytical tool of this kind launched by the STS, following the dashboards on tax revenues of the general fund of the state budget, cash registers and software cash registers, and the tourist tax.
Criminal Law Practice
Transferring and dealing in payment instruments for fraud to be criminalised: the law has been adopted
On 28 October 2026, the Verkhovna Rada of Ukraine adopted the Law “On Amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine on the Protection of Citizens and Their Funds against Illegal Actions in respect of Payment Instruments, Bank Accounts and Electronic Money”, which supplements the Criminal Code of Ukraine with Article 200-1, “Transfer, receipt, purchase, storage or other obtaining of payment instruments for the purpose of committing a criminal offence”. As of 4 November 2026, the Law is awaiting the President’s signature and has not yet entered into force.
Once the Law enters into force, Article 200-1 of the Criminal Code of Ukraine will establish liability for the following actions:
- the transfer of a payment instrument or of individual account information, or the granting of access to them or to a bank and/or payment account or an electronic wallet, where such actions are committed for the commission of fraud or any other criminal offence by other persons – shall be punishable by a fine of three hundred to one thousand tax-free minimum incomes (UAH 5,100 to UAH 17,000);
- the receipt, purchase, storage or other obtaining of another person’s payment instrument or individual account information, obtaining access to them or to a bank and/or payment account or an electronic wallet, as well as their transfer, sale or the transportation of another person’s payment instrument, where such actions are committed for the same purpose – shall be punishable by a fine of three to five thousand tax-free minimum incomes (UAH 51,000 to UAH 85,000), or restriction of liberty for a term of up to three years, or imprisonment for a term of two to four years;
- any such actions as provided for by part 1 or 2 of this Article, when repeated or committed by an organised group, shall be punishable by a fine of five to ten thousand tax-free minimum incomes (UAH 85,000 to UAH 170,000) or imprisonment for a term of four to six years.
A person who has committed the criminal offence provided for by part 1 of that Article for the first time will be discharged from criminal liability. Two conditions must be met. First, before being served with a notice of suspicion, that person must have voluntarily reported what had occurred to the body or official empowered by law to serve a notice of suspicion. Second, he or she must have actively contributed to the uncovering and termination of the criminal offence committed by other persons using that payment instrument, individual account information, bank and/or payment account or electronic wallet.
The same Law restates Article 200 of the Criminal Code of Ukraine. In addition to the forgery and falsification of payment instructions, notifications, orders and t instruments, it will cover their misappropriation and theft, their obtaining by deception or abuse of trust, as well as the illegal obtaining of access to a bank or payment account or an electronic wallet. Whereas the version of Article 200 currently in force provides only for a fine, the new version also provides for restriction or deprivation of liberty.
Article 200, together with parts 2 and 3 of Article 200-1, has also been added to the lists set out in Articles 96-3 and 96-9 of the Criminal Code of Ukraine; accordingly, criminal law measures, up to and including liquidation, may be applied to a legal entity on whose behalf and in whose interests such actions were committed.
The Constitutional Court of Ukraine has held it constitutional that an investigating judge’s ruling refusing to revoke property attachment may not be challenged under appellate procedure
By Decision No. 12-р(II)/2026 of 14 October 2026, the Second Senate of the Constitutional Court of Ukraine declared clause 9 of part 1 and part 3 of Article 309 of the Criminal Procedure Code of Ukraine to conform with the Constitution of Ukraine (constitutional) in so far as they establish a restriction on the review, under appellate procedure during the pre-trial investigation, of an investigating judge’s ruling refusing to grant a motion to revoke property attachment.
The complainants argued that a ruling refusing to revoke property attachment is, in essence, a decision to attach property, since the consequences for the right of property are identical. The Constitutional Court, for its part, recalled that the Constitution guarantees appellate review of a case, not appellate review of judicial decisions in which an investigating judge or a court does not determine the case on the merits. The purpose of the restriction is to prevent the pre-trial investigation from being protracted, particularly through the repeated initiation of appellate review of an investigating judge’s rulings on the same issue.
An analysis of Articles 170 to 174 of the CPC led the Court to conclude that the absence of any possibility of appellate review of such a ruling is compensated for by other procedural guarantees of judicial protection of the right of property and of other bona fide possession of attached property, in particular:
- the obligation of the investigating judge to use the least onerous method of attaching property;
- the right to file a motion to revoke the attachment where there is no need for the continued application of that measure or where the attachment was ungrounded;
- the right to file a repeat motion of that kind where the grounds for the continued application of the measure have changed;
- the right of a person to challenge, under appellate procedure, a judicial decision concerning the attachment of property.
Urgent searches: the time-limit for applying to the investigative judge is to be capped at 72 hours
On 28 October 2026, the Verkhovna Rada of Ukraine adopted, in the first reading, Bill No. 15488-3, “On Amendments to the Criminal Procedure Code of Ukraine on Improving the Institutions of Conducting a Search in Urgent Cases and of the Registration of an Application or Report of a Criminal Offence Committed”.
Currently, part 3 of Article 233 of the CPC entitles the investigator or public prosecutor to enter a person’s home or any other premises in urgent circumstances before the investigating judge’s ruling, but does not specify when the investigator, inquiring officer, or public prosecutor must thereafter apply to the court.
If the Bill is adopted in its current wording and the resulting law enters into force, this must be done promptly, but no later than 72 hours. A motion for a search will be considered no later than three days after its receipt by the court, with the participation of the owner of the home or other possession in which the search was conducted and of the owner of the temporarily seized property, or their representatives, whom the investigating judge must notify in advance.
The investigating judge’s ruling authorising such a search, or refusing to authorise it, will be added to the list of rulings subject to being challenged under appellate procedure.
In addition, information will be entered in the Unified Register of Pre-Trial Investigations only based on applications and reports that contain sufficient information about circumstances that may indicate a criminal offence has been committed.
Healthcare Industries, Life Sciences and Pharmaceuticals
The Government approves a pilot scheme for transporting transplant organs by drone
On 15 October 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 1287, approving a pilot scheme for transporting organs for transplantation, blood samples for testing, and medical devices and medicinal products required for transplantation by unmanned aircraft during martial law.
The scheme envisages the transport of these consignments between healthcare institutions. Participating facilities may include healthcare providers of various forms of ownership that provide transplant services or carry out related activities.
Flights are subject to the applicable technical and safety requirements and must be coordinated with the bodies of the integrated civil-military air traffic management system. The Ministry of Health is the scheme’s coordinator. The transportation of human anatomical materials must comply with the relevant statutory requirements governing storage and carriage.
The Heart Institute of the Ministry of Health is among the pilot sites and has three specialised drones with a stated range of up to 700 kilometres. The scheme is intended to run during martial law, but for no longer than two years from the resolution’s entry into force.
The Government establishes a mechanism for launching the Ukrainian Pharmaceutical Agency
On 5 October 2026, the Ministry of Health of Ukraine announced the mechanism for launching the Ukrainian Pharmaceutical Agency (Ukrpharmagency), laid down in Cabinet of Ministers Resolution No. 1209 of 23 September 2026.
Under the selected model, Ukrpharmagency will be established by renaming the State Service of Ukraine on Medicines and Drugs Control, while retaining its functions, territorial bodies and staff. It is expected to begin operating under a revised regulatory model on 1 January 2027, alongside the implementation of the new Law of Ukraine “On Medicinal Products”.
The agency is expected to assume additional responsibilities currently exercised by the Ministry of Health, including the state registration (marketing authorisation) of medicinal products, assessment of registration dossiers, clinical trials, pharmacovigilance, licensing, inspections and quality control. It will also retain the existing functions of the State Service, including those relating to narcotic drugs, psychotropic substances and precursors, as well as the safety and quality of donated blood and blood components.
The resolution also allows specialist expert institutions to be engaged. The approach is intended to ensure continuity of regulatory procedures, which is particularly relevant to pharmaceutical manufacturers, marketing authorisation holders and clinical trial sponsors.
The Government simplifies quality control procedures for imported medicinal products
On 13 October 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 1254, amending the Procedure for State Quality Control of Medicinal Products Imported into Ukraine. The resolution entered into force on 16 October 2026.
The amendments allow an importer’s authorised person to verify that a consignment matches its accompanying documents and to inspect the outer transport packaging and the external and immediate packaging, with mandatory photographic records. The inspection results and photographs must be submitted to the State Service on Medicines and Drugs Control to obtain a quality clearance for the imported medicinal products.
A simplified visual inspection and notification procedure is also available where the same batch of a medicinal product is imported again. According to the Ministry of Health, this can reduce the relevant process to one working day.
The amendments also address quality clearance for medicinal products manufactured at facilities located in specified jurisdictions, including EU Member States, the United Kingdom, the United States, Canada, Switzerland, New Zealand, Australia, Japan and Israel. Where a GMP certificate issued by the competent authority of the relevant jurisdiction is available, a separate Ukrainian document confirming manufacturing compliance is not required. Special provisions are also introduced for laboratory testing of certain immunobiological products.
State quality control remains in place, and the quality and safety requirements have not been relaxed. Resolution No. 1254 is temporary and applies until the new Law of Ukraine No. 2469-IX “On Medicinal Products” is brought into effect.
Private healthcare providers gain access to specified categories of humanitarian aid
On 7 October 2026, Cabinet of Ministers Resolution No. 1218 of 30 September 2026 entered into force, introducing a pilot scheme governing the distribution and use of certain categories of humanitarian aid by private healthcare institutions and individual entrepreneurs.
The scheme is open to private healthcare providers and individual entrepreneurs that hold a medical practice licence and have entered into healthcare service contracts with the National Health Service of Ukraine (NHSU) under the Programme of Medical Guarantees. Eligible providers may receive the vaccines, medicinal products for specified infectious diseases, medical devices and consumables covered by the procedure.
Additional eligibility conditions apply to supplies for HIV infection and tuberculosis: the provider’s NHSU contract must cover the relevant service packages for diagnosing, treating or preventing those conditions. Supplies are distributed through the designated participants in the scheme on the basis of applications reflecting actual need.
The aid must be used solely for its intended purpose and provided to patients free of charge within the scope and term of the relevant NHSU contracts. Recipients must keep appropriate records and report receipts, distribution, use and remaining stocks through MedData within five working days of each relevant transaction.
The pilot scheme operates during martial law, but for no more than two years from the resolution’s entry into force.
Oleksandr Melnyk
Partner, Head of Corporate Law and M&A practice, Attorney at law
- Contacts
- 31/33 Kniaziv Ostrozkykh St, Zorianyi Business Center, Kyiv, Ukraine, 01010
- o.melnyk@golaw.ua
- +38 044 581 1220
- Recognitions
- Lexology Index: Client Choice 2026
- The Legal 500 2025
- IFLR1000 2025 (International Financial Law Review)
- Legal 500 Green Guide 2024
- 50 Leading Law Firms Ukraine 2026
Viktoriia Bublichenko
Partner, Head of Tax, Restructuring, Claims and Recoveries practice, Attorney at law
- Contacts
- 31/33 Kniaziv Ostrozkykh St, Zorianyi Business Center, Kyiv, Ukraine, 01010
- v.bublichenko@golaw.ua
- +38 044 581 1220
- Recognitions
- ITR World Tax 2026
- Lexology Index: Corporate Tax 2025
- IFLR 1000 2024
- 50 Leading Law Firms Ukraine 2026
Angelika Moiseeva
Partner, Attorney at law
- Contacts
- 31/33 Kniaziv Ostrozkykh St, Zorianyi Business Center, Kyiv, Ukraine, 01010
- a.moiseeva@golaw.ua
- +380 44 581 1220
- Recognitions
- The Legal 500 EMEA 2025
- Lexology Index: Business Crime Defence 2024
Nataliia Matviichuk
Head of Litigation and Dispute Resolution practice, Attorney at law
- Contacts
- 31/33 Kniaziv Ostrozkykh St, Zorianyi Business Center, Kyiv, Ukraine, 01010
- n.matviichuk@golaw.ua
- +38 044 581 1220
Igor Glushko
Partner, Head of Criminal Law and White Collar Defence practice, Attorney at law
- Contacts
- 31/33 Kniaziv Ostrozkykh St, Zorianyi Business Center, Kyiv, Ukraine, 01010
- i.glushko@golaw.ua
- +38 044 581 1220
- Recognitions
- The Legal 500 EMEA 2025
- 50 Leading Law Firms Ukraine 2026
Get in touch
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