Restricted Access to State Registers During Wartime: Law No. 4576-IX Comes into Force

Law No. 4576-IX “On Amendments to the Civil Code of Ukraine and Certain Other Laws Regarding the Specifics of Providing Information from Public Electronic Registers…” has been published and entered into force. The law restricts access to certain state registers with respect to data related to defense and security, and introduces special rules concerning the registered addresses of defense companies. It was adopted on 21 August 2025, and most of its provisions will take effect on 18 November 2025.

Who Is Affected?

1. Defense companies (engaged in the production, modernization, or disposal of defense products; performance of defense-related works or services; contractors under state defense procurement contracts; participants in international military-technical cooperation; suppliers of dual-use goods).
2. All legal entities owning real estate.
3. Applicants and users of intellectual property (IP) registers.

Key Changes

“Contact address” = “registered office” for defense companies

For the duration of martial law and one year thereafter, defense sector enterprises may list in the Unified State Register (USR) a “contact address” (used for official correspondence from authorities) instead of their actual office or production site. Legally, this address will be deemed the company’s “registered office” under the Civil Code. The law also recommends that such entities update their data in the USR within 60 days from the effective date.

Temporary restrictions on open data in IP registers

In the Trademark Register, Industrial Designs Register, Layouts of Semiconductor Products Register, as well as the State Registers of Inventions and Utility Models, access to entries related to national security and defense may be restricted. Such restrictions apply during martial law and for one year thereafter, upon request of an authorized state body and according to procedures to be adopted by the Cabinet of Ministers. At the same time, the Ukrainian National Office for Intellectual Property and Innovations (UANIPIO) will continue to provide this information upon written requests from government bodies and law enforcement agencies designated by the Cabinet.

State Real Estate Register: changes to electronic extracts

Electronic extracts concerning legal entities’ property will no longer display the precise address of the asset (only the state/Autonomous Republic of Crimea/region will remain visible), nor the cadastral numbers of land plots. Additional restrictions on access to such information will be introduced by the Cabinet of Ministers.

What Businesses Should Do Now

• Real estate transactions: Note that electronic extracts will no longer contain exact addresses or cadastral numbers for legal entities’ property. Adjust due diligence processes to include alternative evidence of location/identification of land plots.

• Defense contractors: Prepare to update USR data (contact address as the registered office) within 60 days after 18 November 2025. Review internal correspondence handling procedures to ensure reliable receipt of official communications at the new address.

• IP portfolio holders: Audit applications/registrations potentially falling into the “defense” category (linked to national security and defense). Set up channels for obtaining relevant data from UANIPIO via authorized requests.