On 1 April 2025, Resolution of the National Securities and Stock Market Commission of Ukraine (“Commission”) No. 28/21/1933/K03 dated 6 March 2025 (“Resolution”) entered into force. The Resolution establishes a new procedure for the disclosure of regulated information by securities issuers during martial law.
In particular, the Resolution repeals the Commission’s previous Resolution No. 98 dated 24 January 2024, which had temporarily exempted issuers from the obligation to disclose regulated information.
Key changes for issuers:
- by 30 September 2025, issuers must disclose annual regulated information for the 2021-2024 reporting years and interim information for Q1 and Q2 of 2025; and
- starting from Q3 2025, regulated information must be disclosed in accordance with standard requirements.
Liability for non-compliance
Until 1 January 2026, failure to submit, incomplete submission, or submission of inaccurate regulated information may result in financial penalties ranging from UAH17,000 to UAH85,000.
However, from 1 January 2026, significantly higher fines will apply for breaches of disclosure requirements: up to UAH22 million for company officials and up to UAH110 million for legal entities (but not exceeding 5% of annual turnover).
During the transitional period from 2026 to 2030, reducing coefficients (ranging from 0.2 to 0.8) will apply to facilitate the gradual implementation of the new fine amounts.
Recommended next steps
Given the substantial volume of information subject to disclosure – outlined in the reporting forms established by the Regulation approved by Commission Resolution No. 608 dated 6 June 2023 – we recommend that issuers begin preparing the relevant reports as early as possible to ensure timely disclosure of regulated information and minimise the risk of financial penalties.
By Mykola Stetsenko, Managing Partner, and Andriy Romanchuk, Partner, Avellum
