We would like to share our analysis following the publication by the National Agency on Corruption Prevention (NAZK) of statistical data based on lobbying disclosures for the second half of 2025. The data were released within the Transparency Register and reflect the first practical parameters of how the lobbying framework, new for Ukraine, is functioning.
The published statistics provide insight into who the most active lobbying subjects are, which public authorities they engage with, the policy areas where lobbying activity is concentrated, and the basic financial characteristics of concluded contracts. Among the most common lobbying areas are financial, banking, tax and customs policy, as well as economic development, energy, environmental policy, and healthcare.
By the number of contacts and lobbying matters, activity is concentrated among a limited group of subjects, including business associations, sectoral organizations, and individual large companies. At the same time, the primary objects of interaction remain the Verkhovna Rada of Ukraine, ministries, and other central executive authorities, indicating a strong focus of lobbying activity at the national level.
Financial indicators show a differentiated structure of contracts and expenditures. When contract values are grouped into two aggregated categories — up to UAH 100,000 and above UAH 100,000 — the majority of contracts (60%) fall into the category exceeding UAH 100,000. At the same time, most reported lobbying expenditures are concentrated in the lowest price range, which points to a cautious approach to spending and a gradual entry of the market into formalized regulatory frameworks.
The structure of interest representation also deserves attention. In some cases, subjects lobby their own commercial interests, while in others they act on behalf of clients or beneficiaries. The balance between these models varies across subjects and policy areas, indicating that no single dominant practice has yet emerged.
At the same time, these data have clear limitations for broader conclusions. The statistics cover only one reporting period and do not allow for identifying stable trends, behavioral changes, or the effectiveness of lobbying tools. Such conclusions will require data accumulated over several reporting cycles and comparative analysis.
Overall, the statistics published by NAZK capture an early stage of institutionalization of the lobbying market in Ukraine and create a foundation for further observation of its development within a formalized and transparent framework.
The full set of statistics is available on the official NAZK Transparency Register dashboard:
https://transparency.nazk.gov.ua/dashboard
