Temporary restriction of access to data in public electronic registers and determination of the registered address of defense-sector legal entities

On 18 November 2025, Law No. 4576-IX entered into force, introducing amendments to the Civil Code of Ukraine and a number of laws governing access to information from public electronic registers.

For the duration of martial law and for one year after its termination, special legal regulations are established with regard to: (1) the procedure for determining the legal seat of certain legal entities in the defense sector; (2) the possibility of temporarily restricting access to information contained in public electronic registers concerning legal entities and intellectual property objects related to the safeguarding of national security and defense; and (3) narrowing the scope of information from the State Register of Proprietary Rights provided in electronic form.

These rules apply, in particular, to the enterprises that:

• carry out the development, production, modernization and disposal of military/defense products
• perform works and provide defense-related services or services in the interests of defense for the equipping and material support of the security and defense forces
• act as contractors under state defense procurement contracts
• supply military/defense and dual-use goods and provide military services within the framework of Ukraine’s military-technical cooperation with other states.

As a general rule, the legal seat of a legal entity is the place where it actually conducts its business activities or from which such activities are managed.

However, for the abovementioned legal entities, a special regulation applies during the period of martial law and for one year following its termination or cancellation. Under this temporary exception, such legal entities may indicate in the Unified State Register of Legal Entities, Private Entrepreneurs and Public Formations (USR) their legal seat registered at the address to be used for communication with them, including for receiving documents from state authorities and local self-government bodies (even if such address does not correspond to the place of actual business activity or management).

The Law also recommends that such entities update their location details in the register within 60 days.

In addition, the Law provides for the possibility of temporarily restricting access to information related to national security and defense contained in state intellectual property registers. This applies to industrial designs, trademarks, layouts of semiconductor products, inventions and utility models, as well as to information from the State Register of Certificates of Copyright Registration and the State Register of Agreements relating to an author’s rights, insofar as such information is connected with national security and defense.

Access to information on such objects may be restricted for the duration of martial law and for one year after its termination or cancellation, upon an application by an authorized state body and in accordance with the procedure established by the Cabinet of Ministers of Ukraine.

In the field of state registration of proprietary rights to immovable property and encumbrances thereon, the scope of electronically accessible information concerning objects owned by legal entities is reduced. Electronic records will no longer contain the exact address or cadastral number of a land plot, but only information indicating the state, the Autonomous Republic of Crimea or the relevant oblast (i.e., region).