The Ministry of Justice of Ukraine adopted Order No. 3168/5 dated November 18, 2025, "On the Resumption of Publishing Information from the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Formations in the Form of Open Data." The document was adopted pursuant to the Law of Ukraine No. 4576-IX and provides for a phased return of access to data, which was restricted due to martial law and security risks.
This concerns the resumption of publishing information from the Unified State Register (USR) in accordance with the list of open data approved back in 2016. Currently, the public portal of the register displays only basic information about legal entities, while information regarding registered addresses, history of changes, types of activity, ownership structure, and ultimate beneficial owners remains inaccessible.
The Order is an important step toward returning the state registration system to standards of transparency, accountability, and openness, which align with open data principles and Ukraine’s commitments within European integration processes. At the same time, the document is being adopted under conditions of ongoing martial law, which necessitates a particularly careful balance between publicity and security.
Restoring USR open data is critically important for the activities of civil society organizations, journalists, donors, and business. Along with the positive consequences of opening the register, security risks remain. The publicity of information about managers and registered addresses of organizations, particularly in frontline regions, may increase vulnerability to persecution, information operations, and cyberattacks.
To maintain a balance between openness and security, it is advisable to:
- implement a differentiated approach to data publication depending on its sensitivity;
- conduct an independent cybersecurity audit of the registry infrastructure before fully restoring access;
- provide for phased or delayed opening of specific datasets for organizations operating in high-risk conditions.
Detailed analysis of the Order is available at the link.
______________________________________________________________________
Institutional support for UCIPR activities is provided by East Europe Foundation within the framework of the "Phoenix: The Power of Communities" project, with the support of the European Union. The content of the created materials is the sole responsibility of UCIPR and does not necessarily reflect the position of East Europe Foundation and the EU.