Strengthening state supervision over compliance with legislation in the field of electronic communications

November 11, 2025 Draft Law No. 14197 regarding the strengthening of control in the field of electronic communications was registered in the Verkhovna Rada.

The purpose of the Draft Law is to improve the procedure for state supervision (control) over compliance with legislation in the spheres of electronic communications and radio frequency spectrum under conditions of emergency and martial law. These changes are aimed at ensuring the prompt response of the NCEC to non-compliance by providers with critically important orders of the NCM.

The current Law of Ukraine “On Electronic Communications” has significant gaps that slow down the regulator’s reaction during the war, which is critical for ensuring the resilience of communications in Ukraine.

The Draft Law provides for three main changes:

  • New Grounds for Unscheduled Inspections The NCEC will be able to decide on an unscheduled inspection in two critical cases:
    Receipt of a reasoned appeal with supporting documents from the Ministry of Digital Transformation regarding violations of legislation under conditions of emergency / martial law;
    For the purpose of checking compliance by providers with NCM orders under conditions of emergency or martial law.
  • Introduction of Administrative and Economic Sanctions (Fines)
    It is proposed to establish direct liability for non-compliance with the order of an authorized NCEC official and/or non-compliance with an NCM order.

    Fines are differentiated depending on the size of the enterprise:

    – Micro and small businesses:
    The fine for the first violation will be 1,000 untaxed minimal incomes (17,000 UAH), and for a repeat violation within a year — 2,000 untaxed minimal incomes (34,000 UAH);

    – Medium enterprises:
    The fine will increase to 2,000 untaxed minimal incomes (34,000 UAH), and a repeat violation — to 5,000 untaxed minimal incomes (85,000 UAH);

    – Large enterprises:
    Fines will amount to 5,000 untaxed minimal incomes (85,000 UAH) and 10,000 untaxed minimal incomes (170,000 UAH) respectively.

  • Restoration of the Obligation to Submit Reports.

The Draft Law is of critical importance for increasing the resilience and manageability of Ukrainian electronic communication networks under martial law. It will allow the NCEC to respond promptly to non-compliance with NCM orders, reducing the time for applying sanctions from over 6 months to several weeks/days.

The changes are aimed at increasing the resilience of communications, establishing clear control procedures for the execution of critically important orders, and ensuring stable and predictable conditions for the functioning of the industry.

We will closely monitor further developments in this area and will report on them in future Legal News.