The Centre of Expertise on Multilevel Government at the Congress of local and regional authorities has prepared an Opinion CEMG/LEX(2003)5 in response to requests from the Ukrainian Government and Parliament. 

While the document refers to the issue included in a draft law No. 13150, “On Amendments to Certain Legislative Acts of Ukraine on Ensuring Legality in Activities of Local Self-Government Bodies and Officials” (No. 13150 of 3 April 2025), it neither examines this draft law nor refers to any of its provisions.

There are no European standards that specifically recommend for or against introducing such a database and the experience of European states in this respect varies considerably. While there is a trend towards greater transparency and accountability in the activities and decision-making processes of all levels of government, including local ones, and the introduction of this Register could be seen as following this trend, the Opinion notes that, if it is not created properly, the Register could conflict with some of the obligations undertaken by Ukraine when it ratified the European Charter on Local Self-Government. 

Therefore, should the decision be made to introduce a register, the Opinion advises the Ukrainian authorities to:

• Make publication in this Register automatic. If there were any possibility for central authorities or other bodies to block or delay publication, this could represent an ex ante supervision and could violate the Charter.
• Make such publication a very simple and easy process for local authorities.
• Ensure that the proportionality principle enshrined in Art. 8.3 of the Charter is observed. The frequency and depth of supervision should depend on the importance of the interests that supervision is supposed to protect, rather than on how easily information concerning local decisions can be accessed. 

Moreover, the Opinion recommends that: 

• If the Register is created, the obligation to publish local decisions in it should replace the obligation to transmit them to the supervisory authority.
• The content and management of the Register should align with the provisions of the General Data Protection Regulation (GDPR). 
• Supervisors should undergo proper training, capacity building and oversight to prevent any abuse of power. 

 Opinion on the establishment of a Unified State Register of Acts of Local Self-Government in Ukraine