Public registers access restriction: new regulations under Draft Law № 11533

On 17th of September 2025 President of Ukraine signed Draft Law № 11533 (the “Law”), amending the Civil Code and several laws regarding the specifics of access to public electronic registers. The Law enters into force two months following the day of its publication (certain provisions shall take effect one day after publication). As for today, the Law has not been published.

Key alterations:

1. Defence sector legal entities may register a nominal address in the Unified State Register instead of their real address.
2. Access to information about Intelectual Property objects shall be restricted, in case such objects are related to National Security and Defence sector.
3. Access to information about location of immovable property in ownership of legal entities shall be restricted. Such a restriction, however, distributes its effect on all legal entities not limited to Defence sector and does not affect property in ownership of an individual.

In details

Defence sector Legal entities’ locations

Legal entities of Defence sector shall now be allowed to register a nominal address of their location instead of a real address in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Associations (the “USR”). This address shall be then used for communication with public authorities and for obtaining documents and other correspondence.

Legal entities are considered as related to Defence sector in case they conduct activities like following:

• development, production, modernisation, disposal, and supply of military or dual-use products;
• perform work and/or provide services for Defence purposes;
• act as contractors under state contracts in the field of Defence procurement and/or participate in military-technical cooperation activities between Ukraine and foreign countries.

It is recommended by the Law for mentioned Legal entities to apply required adjustments in USR during 60 days after the Law enters into force.

Intellectual Property registers access restriction

Access to state registers of Intellectual Property objects (inventions, utility models, industrial designs, trademarks, topographies of integrated circuits, and copyrights) shall be restricted, if such objects are related to National Security and Defence.

Described restriction shall be put into effect upon the application of an authorised state body in accordance with the regulation that Cabinet of Ministers of Ukraine has to develop in 2 months after the Law’s publication.

Information from corresponding registers shall be provided only on the basis of a written request from authorised state body or law enforcement body.

Immovable property information access restriction

Access to information about registered rights to immovable property and their encumbrances for individuals and/or legal entities shall be restricted as well. In particular, information about registered rights to immovable property and their encumbrances, which is provided to individuals and legal entities in electronic form, regarding to location of immovable property will contain only data on the state, the Autonomous Republic of Crimea or the region and will not include data on the cadastral number of land plot.

The established restrictions shall be effective over the course of martial law and during 1 year after it’s cessation or cancellation.

Final remarks

As final, it is crucial to mention, that the Draft Law № 11533 overall has driven experts and the public into discussion. In particular, number of experts consider access resrtriction to certain information as an important action to ensure National Security and Defence in the state of war. Meanwhile, critics indicate that established restrictions may hinder access to information for journalists, investigators and public organisations, which can affect transparency and accountability of public authorities.