CEDEM and UCIPR appeal to the Ministry of Justice: urge not to close access to the state registers

August 22, 2022

The Centre for Democracy and Rule of Law and the Ukrainian Center for Independent Political Research call urge to abandon the idea of completely closing state registries during martial law. In particular, the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations; register of VAT payers, financial statements of companies, compiled and submitted in accordance with the Law of Ukraine “On Accounting and Financial Reporting in Ukraine” and several others.

Such a proposal is described in the draft resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolutions of the Cabinet of Ministers of Ukraine dated October 21, 2015 No. 835 and dated November 30, 2016 No. 867”. The document provides for the termination of disclosure of 141 sets of data contained in open databases (registers), administered by state authorities, local self-governments and enterprises, where the state is a shareholder.

After all, the expert analysis of the draft resolution revealed a number of risks for NGOs and charitable organizations and communities. 

NGOs sent their appeal to the Ministry of Digital Transformation of Ukraine, which had previously initiated a public discussion of the draft.

Instead, the signatories propose to choose alternative approaches to the protection of data from open state registers in the conditions of war. These include: restricting access to registers in territories where active hostilities are ongoing; installing additional software mechanisms to protect data from unauthorized access; enabling access exclusively through qualified electronic signature identifiers/bank ID, etc.

Also, CEDEM and UCIPR expressed their willingness to cooperate and jointly implement the recommendations provided.

Read the letter from NGOs here.

Read the analysis of the draft resolution of the Cabinet of Ministers here.