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How Ukraine Is Making Open Data Policy More Transparent

Access to public information allows citizens, journalists, and businesses to better understand how governments operate. Ukraine has made significant progress in publishing open data across sectors such as public finance, infrastructure, land use, and business registries. Yet there is a blind spot in the country’s open data policies: currently, there is no clear way to verify whether institutions are actually publishing all of the data required by law.

To address this challenge, Ukraine’s Better Regulation Delivery Office (BRDO), with support from the Open Government Partnership (OGP) through the EU-funded Integrity Programme for the Eastern Partnership, created a tool that monitors how government institutions implement the national open data law. By comparing legal requirements with what is actually published on the national open data portal, the system helps oversight bodies and the public better understand how government agencies are following through on the country’s commitment to transparency.

A Legal Framework for Transparency

Ukraine’s open data ecosystem is built around Cabinet of Ministers Resolution No. 835, which requires government institutions to publish hundreds of datasets on the national open data portal. Today, the regulation covers more than 900 datasets across government institutions.

These datasets include information critical to public accountability and economic activity, such as:

  • Business and tax registries, which allow companies to follow due diligence processes and journalists to investigate ownership structures to prevent and detect financial fraud and misconduct;
  • Public finance and procurement data, which help track how government funds are spent, and
  • Construction, land, and environmental data, which support the planning and monitoring of infrastructure and natural resources.

Some datasets have become particularly valuable for citizens and businesses. For example, the car registration registry allows users to verify vehicle ownership and license plate information, which are then used in applications that help drivers pay traffic fines. The State Tax Service and State Statistics Service also publish financial statements of companies, including limited liability companies. While financial reporting for publicly listed companies is common globally, Ukraine has relatively broad public access to company financial statements, including for many private companies. This information supports economic research, investigative journalism, and market analysis.

Ukraine’s current legal framework and efforts to publish hundreds of datasets are notable, especially during the war. To build upon this progress, the next challenge for Ukraine is to verify that government institutions are actually disclosing all of the data that is required by law. Thanks to the work of BRDO, the country has begun to address this gap.

Turning Data Requirements into a Monitoring System

Before this initiative, Ukraine had both legislation and infrastructure supporting open data, but lacked a clear mechanism to verify compliance.

Government institutions are required to publish datasets on the national portal, but verifying compliance was time-consuming. Oversight bodies, journalists, and civil society organizations could see the portal and review the legal requirements, but it was difficult to quickly determine which institutions were meeting their obligations.

As Ihor Samokhodskyi, ICT Sector Head at BRDO, explains: “You could see the portal. You could read the Resolution. But you couldn’t easily see which agencies were compliant, which datasets were missing, or whether the data was updated and machine-readable.”

To close this gap, BRDO created a system that compares the requirements of Resolution No. 835 with the datasets actually published on the national open data portal.

The tool tracks several key indicators, including:

  • compliance rates by government institution,
  • whether datasets are published in machine-readable formats,
  • whether datasets are updated according to legal requirements, and
  • how often datasets are downloaded and reused.

By organizing this information in a clear and accessible way, the system allows users to better understand how open data policies are actually being implemented across government institutions.

Early Signs of Impact

The monitoring system also provides the first comprehensive picture of how open data legislation is implemented across government institutions.

As of November 2025, the BRDO tool found that:

  • Only 19 data holders (22%) publish all required datasets.
  • Just 7 data holders (8%) update all required datasets on time.

These figures establish a baseline for tracking improvements in transparency across government institutions.
In September 2025, the Cabinet of Ministers updated Resolution No. 835 to expand transparency requirements. The initiative expanded the number of government agencies required to publish open data (from 76 to 97) and introduced new mandatory datasets, requiring these agencies to publish additional types of information that had not previously been required to be made public. While this temporarily lowered compliance rates as institutions adapted to the new requirements, it also strengthened the overall framework for transparency.

The monitoring system has already helped encourage improvements. For example, the National Commission for State Regulation of Energy and Public Utilities and the National Agency on Corruption Prevention increased the number of datasets they publish after their compliance levels became visible through the system.

The most important achievement of this initiative has been making it easier for the Parliamentary Commissioner for Human Rights to oversee compliance with open data legislation. The monitoring system now allows staff to proactively identify institutions that may not be meeting their data obligations and investigate potential issues more quickly. In some cases, institutions have legitimate reasons for delays, such as technical issues with the national portal. In others, agencies may simply not be aware of their obligations.

The Commissioner has the authority to issue binding instructions requiring institutions to publish missing datasets or address compliance gaps. Thanks to the monitoring system, the office has identified around ten institutions that were not complying with Resolution No. 835 and sent official notices requesting corrective action.

One example involved the Accounting Chamber of Ukraine, which registered on the open data portal and began publishing datasets after being contacted by the Ombudsman. Among the newly released information was a dataset containing all Accounting Chamber decisions over the past ten years. This structured dataset made it significantly easier for users to search for specific decisions.

Looking Ahead

Ukraine’s experience highlights an important lesson for the open government community: transparency reforms require not only data publication but also mechanisms that ensure policies are implemented.

As Samokhodskyi notes: “Transparency isn’t only about publishing more data. It’s about making the policy process itself visible—so that everyone can see the gap between commitment and delivery.”

BRDO’s monitoring system has strengthened how Ukraine implements its open data policy. By making compliance easier to track, the initiative helps institutions improve transparency practices, supports oversight bodies in their work, and ensures that open data commitments translate into real accountability.

As Ukraine continues strengthening its open data ecosystem, this approach demonstrates how digital tools can turn transparency laws into practical systems that support better governance and public trust.

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