In April of last year, the Verkhovna Rada adopted in the first reading draft law No. 11082, which was intended to modernize the institution of citizens’ appeals and clearly distinguish it from the Law “On Administrative Procedure.”

However, preparation for the second reading took place behind closed doors, and the comparative table published ten months later only confirmed the experts’ concerns: the document reintroduced a number of irrational — and in some cases, openly Soviet-era — provisions. This was emphasized by Viktor Tymoshchuk, Deputy Head of the Board at the Centre of Policy and Legal Reform (CPLR).

So what are the risks of the new version, and why does it contradict Ukraine’s European integration commitments? The expert from the Reanimation Package of Reforms Coalition explains.

In April 2024, the government’s draft law “On Citizens’ Appeals” (register No. 11082) passed its first reading. It was meant to clearly separate its subject of regulation from that of the Law “On Administrative Procedure” (LAP) and originally included important elements of de-Sovietization and rationalization of the system of citizens’ appeals.

Unfortunately, the balanced concept of the initial draft was not preserved. In January 2025, the relevant parliamentary committee finalized it for the second reading. Because this work was done in a non-transparent manner, experts could only learn informally that the text had been substantially worsened.

Finally, ten months (!) after the committee’s meeting and decision, the comparative table for the draft law “On Citizens’ Appeals” was published — confirming what had been unofficially known since January.

The version recommended for the second reading brings back irrational Soviet remnants, including:

• The obligation for all enterprises, institutions, and organizations (including private entities), as well as civil society organizations and media outlets, to consider citizens’ appeals;

• Confusion between different types of appeals by re-introducing “applications,” “petitions,” and “complaints” into this draft law, although its very purpose was to separate them from the LAP — since applications and complaints are already covered by administrative procedure;

• The Soviet-style right “to be present during the consideration of one’s appeal”;

• The Soviet-style right “to familiarize oneself with the materials of the appeal’s review”;

• The right to appeal a response.

It seems that lawmakers still do not realize that:

• Citizens’ rights are already ensured by another law — “On Administrative Procedure,” which regulates the handling of applications and complaints and provides all necessary guarantees for individuals.

• The law “On Citizens’ Appeals” should instead cover only proposals and suggestions. Within that scope, such guarantees are unjustified, irrational, and at times even absurd — because it is impossible to appeal a “response” rather than an administrative decision.

If adopted in this form, one should not be surprised if:

• The European Union refuses to credit this law toward Ukraine’s progress (it is mentioned specifically alongside the LAP in the EU Enlargement Report on Ukraine 2024). This would mean another year or two of corrections, as the law’s main purpose was to distinguish its subject matter from that of the LAP.

• Government bodies — ministries, the Verkhovna Rada, the Secretariat of the Cabinet of Ministers, the Office of the President, etc. — will waste enormous time handling irrelevant or inadequate appeals (as, unfortunately, most are), especially given the excessive “guarantees” the law now contains.

This mistake must not be allowed.
The parliamentary committee should revisit the draft law and ensure its proper quality.

Originally published on the website of the Centre of Policy and Legal Reform.