The obligation to submit regulated information has been renewed

The National Securities and Stock Market Commission (the “NSSMC”) has taken measures to mitigate the adverse effects of the military aggression of the Russian Federation against Ukraine and to maintain the stability of the capital markets.

To this end, the NSSMC issued Resolution No. 28/21/1933/K03 dated 6 March 2025, titled “On Disclosure of Regulated Information by Securities Issuers, Persons Providing Collateral for Such Securities, and Corporate Rights Advisors During Martial Law in Ukraine” (the “Resolution”).

The Resolution entered into force on 1 April 2025 and introduces the following key provisions:

Revocation of the previous Resolution

The NSSMC revokes its earlier Resolution No. 98 dated 24 January 2024 (as amended), which governed the disclosure of regulated information during martial law.

As a reminder, under the revoked resolution, during the period of martial law, issuers, persons providing collateral for such securities, and corporate rights advisors were allowed not to comply with the deadlines for the disclosure of regular regulated information (including financial statements and significant event notices) but were still required to disclose specific information.

Disclosure Requirement (2021-2024)

By 30 September 2025, securities issuers, collateral for such securities and corporate rights advisers must disclose regular information for the 2021, 2022, 2023, and 2024 financial years (in case of non-disclosure) in accordance with the Law of Ukraine “On Capital Markets and Organised Commodity Markets” (the "Law") and the Regulation on Disclosure of Information by Issuers of Securities and Persons Providing Collateral for Such Securities, approved by the NSSMC Resolution No. 608 dated 6 June 2023 (the "Regulation No. 608").

Interim disclosure requirement (Q1 & Q2 2025)

Securities issuers and persons providing collateral for such securities that are subject to the obligation to disclose interim information must disclose interim financial reporting for the first and second quarters of 2025 (in case of non-disclosure) in accordance with the Law and Regulation No. 608 by 30 September 2025.

Transition to standard quarterly reporting from Q3 2025

Starting from the third quarter of 2025 securities issuers and persons providing collateral for such securities that are subject to the obligation to disclose interim information must disclose interim information pursuant to the Law and Regulation No. 608.

Legal Consequences

Starting from 1 January 2026, fines for violations of the requirements for disclosure of regulated information will gradually increase to reach UAH 22 million for officials and UAH 110 million for legal entities in 2030, but not more than 5% of the annual turnover.

In 2026, the amount of the fine will be up to UAH 4.4 million for officials and up to UAH 22 million for legal entities.

---

Conclusions & Recommendations

In view of the above, we recommend conducting an internal audit of information disclosures (if any) for 2021–2024, preparing and submitting missing reports by 30 September 2025.

Issuers, persons providing collateral for such securities, and corporate rights advisers should treat this as a material compliance matter requiring operational attention.