Registration procedures in Ukraine during the Martial Law


On 24 February 2022, due to the Russian invasion, Ukraine declared the martial law regime. To protect the information of the Unified State Registry of Legal Entities, Individual Entrepreneurs and Civic Organisations and the State Registry of Proprietary Rights to the Immovable Property, the Ukrainian government has suspended their operation and closed access for all registrars and notaries. At the same time, the Ministry of Justice of Ukraine is authorised to approve a list of specific notaries and public registrars who will be allowed to conduct registration actions. The relevant ministry’s order is expected soon.

The registration procedure has also been amended, in particular:

  • the registrars will be allowed to carry out registration actions irrespectively of the location of the property or a company/entrepreneur/organisation;
  • the payment of the registration fees may be confirmed by an electronic copy or even print-screened copy of a receipt;
  • notarisation of signatures on documents is not required if a person signs the document in the presence of the registrar;
  • documents for registration of legal entities and private entrepreneurs may be provided by e-mail or other means of electronic communication.

Notaries’ activity regulations have been also amended. Notaries are obliged to suspend all ongoing notarial acts in favour of citizens of the Russian Federation, Russian companies, or companies whose ultimate beneficial owners or shareholders owning 10% or more of the company’s charter capital are Russian citizens or companies. If these persons or companies apply for a notarial act, such applications must be rejected by the notary. The ban on notarisation for Russian related persons or companies will be in place until the Parliament of Ukraine passes a special law regulating the respective relations.

In order to avoid potential problems due to the shortage of special notarial forms, i.e. numerated paper sheets with watermarks and other sources of protection, the government has allowed the use of plain paper sheets in regions under attack for issuing the following notarised documents: powers of attorney and wills, applications and other documents, on which the law requires a person’s certified signature.

The above temporary measures were introduced by Resolutions of the Cabinet of Ministers of Ukraine No. 164 of 28 February 2022 and No. 209 of 6 March 2022.