In brief, the Law of Ukraine “On Amendments to the Civil Code of Ukraine and Certain Other Laws of Ukraine Regarding the Specifics of Providing Information from Public Electronic Registers Administered by the Ministry of Justice of Ukraine and Certain Other Public Electronic Registers” dated August 21, 2025, No. 4576-IX, introduces new provisions in two key areas:
- It allows enterprises of the defense sector to register their legal address as the location for official communication and document delivery. This option will take effect in two months — from November 18, 2025.
- It establishes the possibility to restrict access by individuals and legal entities to state registers in parts containing information related to national security and defense, upon request of a competent state authority or in accordance with the procedure determined by the Government. This will also take effect on November 18, 2025.
1. Legal addresses for defense enterprises
With respect to the first direction, it is worth emphasizing that, as a rule, the registered location of a legal entity is its place of business or the office from which its activities are managed. However, the amendments introduced by the Law grant defense enterprises the right and recommendation to use the registered address solely for communication and correspondence purposes.
This option is introduced for the duration of martial law and for one year after its termination, and it is formulated as a recommendation to take measures for making related amendments to the Register by January 16, 2026.
Naturally, like any law, this Law may raise numerous questions, particularly among the entities whose relations it regulates. Most of these questions concern potential pitfalls, loopholes for abuse, and possible advantages.
An unambiguous advantage for defense sector enterprises is the recognition of their right and ability not to disclose their actual place of business or the location of their governing body (even though the existing legislation did not expressly prohibit such practice, it also did not clearly establish such a right).
However, from a strictly formal-legal perspective, these provisions of the Law cannot be considered a generally binding rule of conduct established, sanctioned, and enforced by the state. It should be recognized that, in certain cases, some normative acts may contain recommendatory provisions, and in international law, there are many recommendations of international organizations that later form the basis for customary legal norms. Nevertheless, establishing a recommendation within a law is not a typical form of regulating specific legal relations.
Furthermore, there remains an open question of how exactly this provision aligns with other laws governing activities in the defense-industrial sector — particularly the Laws of Ukraine “On Management of State Property Objects,” “On the Specifics of Reforming Defense Industry Enterprises of State Ownership,” “On Economic Activity in the Armed Forces of Ukraine,” “On Accounting and Financial Reporting,” and “On State Secrets.”
This is especially relevant regarding classification requirements for state secrets and other disclosure obligations applicable to state-owned enterprises. It is also worth noting that while not all defense sector enterprises are state-owned, a significant portion of them are.
In summary, there is a clear need to further refine the legislative framework concerning the specific features of the activities of defense sector enterprises, since their operations must be adequately protected from external and internal threats.
2. Restriction of access to public registers
Regarding the second area, the Law establishes a rule that access to certain public registers — including those concerning industrial designs, trademarks, layouts of semiconductor products, property rights to real estate, copyright and related rights, and other public registers — may be restricted upon request of a competent authority and/or in accordance with procedures defined by the Cabinet of Ministers of Ukraine, if such information relates to national security and defense.
This provision applies for the duration of martial law and one year after its termination.
It should be noted that, although this matter is subject to further regulation at the level of the Cabinet of Ministers of Ukraine, it is not of a recommendatory nature — that is, such information will indeed be restricted, albeit under procedures to be established by the Government.
This provision strengthens and expands the existing legislation governing the restriction of access to public registers in the field of national security and defense — in particular, the Law of Ukraine “On Economic Activity in the Armed Forces of Ukraine”, regarding the registration of military units as business entities.
In general, these changes can be viewed as having a predominantly positive effect, although the dependency of access restrictions on the requests of specific competent authorities in certain areas may cast doubt on the universality of this norm.
Conclusion
Overall, the Law represents a positive legislative development aimed at enhancing the security and protection of the defense-industrial sector — a key priority of state policy during wartime.
However, it does not yet comprehensively regulate all the relevant legal relations, and therefore, further legislative refinement remains necessary.