UNLA Debunks the Myth: Reporting Meetings with Lobbyists Is Not a General Requirement
The Ukrainian National Lobbyists Association (UNLA) has observed a widespread dissemination of misinformation regarding the obligation to declare meetings with lobbyists. The most common myth is that lawmakers and other stakeholders are required to declare virtually all contacts with representatives of the lobbying industry. This claim does not correspond to the legal reality.
The analytical component of lobbyst.com.ua, developed using artificial intelligence and agent-based models with the participation of lobbyist and attorney Dmytro Buzanov, enabled the Ukrainian National Lobbyists Association to systematically analyze declaration practices. The results show that the market is in a state of systemic failure.
According to the analysis, up to 85% of active lobbyists—both individuals and legal entities—commit significant violations in their understanding of their own responsibilities. The key problem lies in a misinterpretation of the very nature of lobbying.
The law defines a clear list of lobbying targets, as well as the grounds under which there is an obligation to declare such interactions. Not every meeting, conversation, or participation in a public event falls under these criteria. Furthermore, the lobbying targets themselves are not required to declare such contacts and do not submit corresponding reports to the NACP.
Thus, a significant portion of the declared “meetings” do not, in fact, constitute lobbying in the legal sense. These involve participation in forums, working discussions, or general debates without any indication of efforts to promote a specific legislative or regulatory act.
A telling example is when certain organizations report hundreds of contacts with members of parliament or representatives of the executive branch. Such data creates the illusion of active lobbying, but in most cases does not meet the criteria established by law and does not give rise to a legal obligation to declare such contacts.
The UNLA emphasizes that establishing proper lobbying practices in Ukraine is impossible without strict adherence to regulatory definitions. Widespread “overcaution”—such as declaring every single meeting—not only skews the statistics but also undermines trust in the institution of lobbying as a whole.
The Association continues to monitor the market using artificial intelligence tools and urges market participants to focus on the legal substance of their actions rather than on the mere accumulation of reports.
