Bill No.11082: Repeal of the Old Citizens’ Appeals Law, New Procedure and Key Risks in 2025

Why was the repeal initiated
There are several reasons for preparing government bill No. 11082, which proposes to repeal the current law. First, between 2023 and 2025 Ukraine actively introduced a new approach to administrative management. The Law “On Administrative Procedure” came into force, significantly detailing the rights and duties of government authorities in administrative disputes, mechanisms for reviewing applications, complaints, etc. The Cabinet of Ministers and relevant MPs explain: the current law no longer meets the needs of a digital society, does not integrate extended capabilities of electronic appeals, does not regulate actions under increased wartime pressure, and practically duplicates rules that are now settled automatically by administrative procedure.

Content and features of the new bill
Bill No. 11082, instead of the Law on Citizens’ Appeals, proposes a new model of citizen-state interaction and clarifies the terminology of appeals.
It highlights four main types of appeals:

• statements to support the exercise of a person’s rights or interests;
• comments on the actions or inaction of state/municipal bodies;
• petitions for clarifications within an authority’s remit;
• complaints about responses or the review of appeals.

The government document excludes from regulation categories already covered by other laws (e.g., appeals within criminal, civil, or labor proceedings, appeals of administrative actions in court, administrative appeals, etc.). According to the authors, this will avoid duplication and legal confusion.

Potential advantages
Abolishing the old order and introducing the new one, according to reformers, should yield a number of benefits:

• Unification and simplification of the appeal review procedure: less bureaucracy in working with citizens.
• Digitalization and transparency: mass transition to electronic communications, reduction in review timeframes, monitoring of results via state registries.
• Compliance with European good administration standards, as a condition of Eurointegration.
• Streamlining for authorities, enabling more efficient allocation of human and material resources.
• Filtering out “technical” and manipulative appeals not aimed at resolving genuine issues.

Criticism and risks
However, lawyers and human rights defenders have already stated that the model change carries risks for civil society:

• The new bill details types of appeals but also narrows the substance and scope of the right compared to the Constitution. Critics note this may create a divide and unequal access to protection, where a person’s problem does not fit within the new categories.
• No guarantee of being present during appeal consideration, nor autonomous monitoring of officials’ decisions.
• Real risk of over-formalization: officials may refuse to review appeals on grounds of type or formal issues.
• Emergency and collective petitions mechanisms are not adequately regulated, posing potential harms in wartime.
• Some provisions allow the state to determine categories of information not subject to consideration, threatening future transparency and accountability.

Expert and public position
Human rights organizations and civil platforms urge the Verkhovna Rada not to pass the new act without broad public discussion and expert input. They note the risk of losing the petition mechanism, limiting public oversight of authorities, and reducing society’s role in local decision-making.

At the same time, the government and part of the expert community say updating procedures is inevitable and aligns with modern international trends in administrative law. They stress that the new law’s norms will integrate with the Law on Administrative Procedure, and disputes will be resolved by competent judicial bodies.

International experience
In the EU, Eastern Europe, and the Baltics, there are various models for citizen–public authority relations. The general trend is unification of administrative procedures, transition to e-document management, widescale creation of state online appeal portals, and tracking request status. Developed countries also prioritize the Ombudsman mechanism—an independent authority for challenging inaction or abuse by officials.

Experience in such countries shows: reducing paperwork and speeding up responses are possible only with true regulatory independence, strict deadlines, and mandatory public oversight of outcomes.

Conclusion: What to expect next
Consideration and likely approval by the Verkhovna Rada will change the classic citizens’ appeals model that’s existed since the early 1990s. In the near term, people should closely follow official notifications and new forms/procedures for appeals offered after passage.

Major challenges will include:

• Adapting citizens, especially seniors, to new electronic processes.
• Possible narrowing or restriction of certain rights without an effective public control mechanism.
• Need for systematic public outreach, simple services, and clear instructions nationwide.

Nonetheless, steps toward deregulation and digitalization may modernize state–society communication, making it inclusive, transparent, and accountable. Only if the balance between simplification and the preservation of fundamental appeal rights is retained can Ukraine show its commitment to true European democratic standards.

Author: Igor Yasko, Managing Partner of the Law Firm “WINNER”, PhD in Law.
If you have any questions or issues related to the procedure for citizens’ appeals, you can seek consultation from our specialists. Our team will help you understand the new rules, prepare the necessary documents, and support your case at any stage. Contact us if you need professional advice or protection of your rights!