Before launching a store ad, check whether the product may be advertised in the chosen channel, whether the advertised prices and terms match the actual sale, and whether buyers will understand that they are seeing an ad. For a promotion, define the products, stores, eligible customers, dates, and discount amount in advance, then check the final price at checkout.
Assign an employee to approve the final copy, images, and placement settings. It is useful to keep the promotion terms, evidence supporting advertising claims, price history, contracts, and published materials together. This will help you correct mistakes and provide an explanation if a customer or government authority asks questions.

Determine Whether a Message Is an Advertisement
Under Article 1 of the Law of Ukraine “On Advertising” No. 270/96-VR, advertising includes information about a person, idea, or product that is disseminated for monetary or other consideration, or as self-promotion, to build or maintain consumer awareness and interest. Therefore, the fact that a store did not pay to publish a message on its own page does not by itself exempt that message from advertising requirements.
At the same time, the law distinguishes advertising from product information. Part 7 of Article 8 does not treat as advertising information about a manufacturer or product at the point of sale, including on trade equipment, on the product itself, and on its packaging. A separate exception covers the display of such information while a purchase is being placed on an online store’s website. Article 15 of the Law of Ukraine “On Consumer Protection” No. 1023-XII also states that product information is not advertising.
| Situation | What the store should do |
|---|---|
| Price tag and product details by the shelf | Provide accurate information about the product, price, and purchase terms. Check for separate restrictions that apply to special product categories. |
| A post on the store’s own page: “Discount on selected models through Sunday” | Review it as self-promotion: check the product, price, dates, restrictions, and clear advertising purpose. |
| A blogger’s review in exchange for payment, a gifted product, or a discount | If the material promotes the store or product, ensure it is identified as advertising and approve its content. |
| An independent customer review without compensation | The mere mention of a store does not make a review an advertisement. If the store commissions its later promotional distribution, review that new use separately. |
| An advertising message sent to customers | Check that prior written consent, including electronic consent, has been obtained and that customers have a simple, free way to opt out. |
Practical recommendation: assess each message by its content, purpose, consideration, and method of distribution. Having your own website or account does not create a general exception for everything posted there.
When Ukrainian Law Applies
This guide covers advertising produced, distributed, and consumed in Ukraine. For online advertising, Article 2 takes into account both its availability in Ukraine and whether products are offered to people located in Ukraine. The oversight authority must establish at least three of the indicators specified by law, including whether the content targets a Ukrainian audience, uses the Ukrainian language, involves a seller present in Ukraine, or offers delivery or service in Ukraine.
Part 6 of Article 2 provides an exception to this territorial-targeting rule for advertising in official European Union languages distributed by a legal entity located in a member state. Articles 14-2 and 13 also contain relevant special exceptions. If you commission the broadcast or retransmission of advertising spots or teleshopping in audiovisual or audio media programs for Ukraine, also check the payment: Part 8 of Article 13 permits such distribution only if a Ukrainian legal entity has been paid for it.
This requirement does not apply to advertising in official European Union languages distributed by a legal entity located in a member state. For a Ukrainian store, using a foreign advertising platform does not by itself mean Ukrainian requirements no longer apply.
Label Ads and Approve Blogger Posts
Article 9 requires advertising to be clearly distinguishable from other information and prohibits covert advertising. In the media, advertising materials must be separated using the word “Реклама” (“Advertising” in Ukrainian). The same word is required for informational, authorial, or editorial material that, in exchange for monetary or other consideration, draws attention to a specific person or product and maintains interest in them.
Under Article 14-2, a user who distributes a program or user-generated video on a video-sharing platform must indicate the presence of advertising when uploading it. A user who distributes advertising content through an information-sharing platform must identify its advertising nature when creating or uploading it. Consideration may include free products, work, services, or discounts. Therefore, an agreement to provide a product in exchange for a review requires the same care as a cash payment.
Practical recommendation: put the visible word “Реклама” (“Advertising” in Ukrainian) at the beginning of a commissioned review and use the platform’s designated labeling tool. Labels such as “partnership,” “thanks to the brand,” or a label hidden among other hashtags do not replace the word “Реклама” where the law expressly requires it. Check that the label is readable on a phone screen.
In your contract with a blogger, specify the product, permitted claims, exact promotion terms, labeling format, publication dates, and process for correcting errors. Approve the spoken script of a video before publication as well: an incorrect promise in the voice-over is still part of the advertisement.
If the parties choose sponsorship or product placement in other content, the special rules in Articles 5 and 5-2 apply. Sponsored material must be identified accordingly; advertising information about the sponsor is limited to the name, business names, and trademark permitted by law. The sponsor may not influence the content of the sponsored material. Sponsorship of news and current affairs programs is prohibited. For product placement, the advertiser likewise may not influence the content of user-generated material; the material must not directly encourage a purchase or give undue prominence to the product.
In new user-generated video created by an individual, product placement must be clearly identified at the beginning, at the end, and after advertising breaks. Product placement is prohibited in news, current affairs, consumer protection, religious, and children’s programs. Calling a commissioned promotional review “sponsored” does not remove the requirements that apply to its content.
Prepare Ukrainian Copy and Check Trademarks
Under Article 6 of the Law “On Advertising,” the language of advertising is the state language. Write the headline, description, terms, call to action, captions, and advertising voice-over in Ukrainian. Intellectual property must be used in the language in which it is legally protected: for example, a registered trademark may be reproduced in its protected form. This rule does not extend the exception to arbitrary foreign-language text placed alongside it.
Website addresses, internet identifiers, and electronic communication addresses may be written in Latin characters. Product images must match the appearance in which the product is offered to consumers in Ukraine, in compliance with language and consumer-protection requirements.
Article 32 of the Law of Ukraine “On Ensuring the Functioning of Ukrainian as the State Language” provides separate language options for print media published in an official European Union language and for specified broadcasters. The use of languages of Indigenous peoples and national minorities is governed by a special law. Prepare an ordinary ad for a Ukrainian store in Ukrainian.
Match Advertising Claims to Documents and Store Operations
Articles 1, 7, and 10 of the Law “On Advertising” prohibit misleading advertising that deceives or may deceive through inaccuracy, unreliability, ambiguity, exaggeration, or omission. So check both the explicit claims and the overall impression created by the copy, images, and terms. If you use state symbols, check that they do not mislead buyers, including about the product’s origin, and do not show disrespect for those symbols: this is prohibited by item 6 of Part 1 of Article 8.
Official names of state authorities, local self-government bodies, and international organizations or associations may be used only in the cases listed in item 7 of that part. For an ordinary store ad, check whether the law requires such a reference or whether the relevant authority, organization, or association has permitted or commissioned it.
| Claim | What to check before publication |
|---|---|
| “In stock” | Availability of the exact model, size, color, and configuration, and the ability to fulfill the order within the stated period. |
| “Delivery tomorrow” | Eligible cities, order cut-off times, available products, and actual delivery capacity. State any conditions next to the promise. |
| “Free” | Whether there is a mandatory extra charge. For delivery above a certain order value or a gift with a purchase, show the threshold and other terms immediately. |
| “Only two left” | The actual quantity and how the message is updated. Do not use a scarcity counter that never changes. |
| “Certified” | The document, its validity period and scope, and whether it applies to the specific product. Do not imply that it confirms properties outside its scope. |
| “Warranty” | Who provides it, for how long, and under what terms. Align the ad with the warranty documents and information given to buyers. |
Advertised prices for goods sold and services provided in Ukraine must be stated exclusively in hryvnias. Under Article 15 of the Law “On Consumer Protection,” the consumer price includes all taxes and mandatory charges paid by the buyer at purchase. Explain any additional costs or restrictions that could affect a purchase decision before the order is placed.
Practical recommendation: create a list of claims with links to supporting evidence. Attach manufacturer documentation for product specifications, inventory records for availability, agreed terms for delivery, and the relevant document for warranties. Assign an employee to check that the claims remain accurate throughout the campaign.
How to Compare Yourself with Competitors Accurately
Article 11 permits comparative advertising if all prescribed conditions are met. You may compare like products intended for the same purpose and material, comparable, and representative characteristics, including price. The ad must not contain false information, discredit a competitor, create confusion, or depict a competitor’s product protected by a trademark or trade name through imitation; products with a designation of origin are subject to a separate requirement that the designation be analogous.
If you plan to compare prices, keep the date, source, exact model, configuration, and terms of the competitor’s offer. Comparing different package sizes, or a price that includes delivery with one that does not, can create a false impression. A broad claim such as “lowest price” requires evidence covering the full scope of that comparison.
Set Up a Discount, Sale, or Bundle Offer
Part 4 of Article 8 of the Law “On Advertising” requires ads for price reductions or sales to state the location, start and end dates, and the relationship of the new price to the previous selling price or the discount amount. A special rule applies to audio media: the ad must identify a source where customers can learn the terms of discounts or sales.
In addition, Article 15 of the Law “On Consumer Protection” permits an offer to be called a discount if the seller directly sells the product, the price reduction applies for a defined limited period, and the price is below the usual price. A sale must apply to all products at a specific location or a clearly defined group, be limited in time, and offer prices below the usual prices. After a public announcement, buyers must be told the price before the promotion and the price of the same product after it begins.
- Define the exact products and variants, stores or website, eligible customers, dates, and restrictions.
- Keep previous prices and records that substantiate the usual price. For comparisons, use the same product, unit of measurement, quantity, and configuration.
- Calculate the new price and check rounding. Do not use the manufacturer’s recommended price as your own previous selling price.
- Include the required details in the ad, and show buyers the previous and new prices.
- Check that the ad, price tag, product page, and amount due all match.
Hypothetical example. A store sold a specific backpack for 1,200 Ukrainian hryvnias (UAH) and offers a 20% discount. The discount is UAH 240, making the new price UAH 960. The ad could read: “20% off the black Model A backpack at the store at [address], from October 17 through October 20. Price before the promotion: UAH 1,200; promotional price: UAH 960.” If the offer is available only to cardholders, add that condition.
For bundles and offers such as “second item at a lower price,” Article 15 requires you to state the offer’s contents and price. If several products are sold for one price, you must also state the price of each component. Buyers must know the duration, quantity limits, and other restrictions.
Hypothetical example. A cup costs UAH 240 on its own and a plate costs UAH 360, for a total of UAH 600. A bundle priced at UAH 510 saves UAH 90, or 15% of the combined individual prices. State the bundle contents, each separate price, the total price, the location and dates, and any quantity limits.
For contests, prize draws, and promotional events, Part 3 of Article 8 requires the dates, location, and a source for the full terms; for audio media, identifying that source is sufficient. Changes to the terms, location, or dates must be communicated in the same way as the original information. In practice, keep one approved rules page and check every ad against it.
Check Rights to Photos and Obtain People’s Consent
As a general rule, item 9 of Part 1 of Article 8 prohibits using a person’s image or name in advertising without their written consent, including electronic consent, or the appropriate consent of other persons in the manner prescribed by law. Therefore, obtain consent for the specific advertising use before publishing a customer’s or employee’s photo.
The law provides exceptions for a person’s image when they posed or performed a role to create an ad in exchange for monetary or other consideration, and for using the image of a participant in an audiovisual work or program in advertising that work or program, where sufficient intellectual property rights are held. A separate exception applies to displaying banknotes or coins featuring images of people. Do not automatically extend the exception for images to every use of a person’s name.
Articles 307–308 of the Civil Code of Ukraine separately regulate photography and filming and the subsequent display and distribution of images. Consent to photography or filming carried out openly at a public event may be presumed, but that alone does not establish the store’s right to use a visitor’s portrait in an ad for a product. Under Part 2 of Article 308, a person who posed for a fee may demand that the public display, reproduction, or distribution of their image stop if they compensate the author or another person for the resulting losses.
After that person’s death, their children, widow or widower, parents, brothers, and sisters may make the same demand on the same condition. Therefore, paying for posing does not rule out a later demand to stop using the image. Part 3 of this article separately permits distributing a photograph without the depicted person’s consent if necessary to protect that person’s or others’ interests.
Check rights to advertising materials separately from the depicted person’s consent. Article 4 of the Law “On Advertising” requires compliance with intellectual property law, and item 10 of Part 1 of Article 8 prohibits unlawfully copying or imitating the text, images, music, or sound effects of ads for other products. In practice, include the approved uses, channels, duration, and right to make necessary changes in your contract with the photographer or designer.
Remove Discriminatory Claims and Unsafe Scenes Involving Children
Article 8 prohibits discriminatory claims and images, incitement to hatred, and degrading people’s dignity on the basis of sex. It prohibits using images of a person’s body or body parts solely as a sexual object to attract attention. References to sexual relationships unrelated to the advertised product or its use are also prohibited. Item 15 of Part 1 of Article 8 provides an exception for social advertising aimed at condemning these phenomena. It is also prohibited to discriminate against people who do not use the advertised product or to encourage disregard for safety.
Article 20 sets additional restrictions for advertising that features or targets children. Ads may not urge children to buy a product or to ask other people to buy it. They may not undermine the authority of parents and teachers, show children using products intended only for adults, or depict dangerous behavior. Ads must not make children feel inferior, promise an advantage over other children from owning a product, or create the impression that every family can afford it regardless of budget.
Practical recommendation: replace “Ask your parents to buy it” with information for adult buyers about the product’s purpose, suitable age, and features. Check whether a video shows behavior a child might imitate dangerously. For ordinary store advertising, also account for the ban on images showing the use of real or toy firearms and explosive devices; statutory exceptions apply to specified social advertising and audiovisual works.
Check Products with Special Restrictions Separately
Tobacco, E-Cigarettes, and Related Products
Part 1 of Article 22 prohibits any advertising and sales promotion of tobacco products, items associated with their use, herbal smoking products, electronic cigarettes, refill containers, liquids, devices for consuming tobacco without combustion, and tobacco-containing products for electrical heating. The ban covers associated trademarks, the internet, and social media. Restricting access by age does not make this advertising permissible.
Do not include these products in promotional prize draws, gifts, reimbursement offers, or other sales promotions. Part 6 of Article 22 also prohibits selling the listed tobacco and related products in bundles with other products unrelated to their use. For tobacco products, Article 16 of Law No. 2899-IV establishes a broader ban: they may not be sold in bundles with any other goods or services.
Do not use their images or depictions of their use to advertise other products. Article 16 of Law No. 2899-IV further restricts information about tobacco products at the point of sale: it provides for one poster no larger than 40 × 30 cm, with black text on a white background, listing available products and prices. Do not arbitrarily extend this specific rule for tobacco products to all other categories.
Alcohol: Check the Channel, Content, and Warning
Article 22 sets the following restrictions on advertising alcoholic beverages and the trademarks under which they are produced:
- Outdoor and indoor advertising, and advertising on the exterior or interior surfaces of public transport and the metro, are prohibited.
- Advertising is prohibited in any audiovisual media from 6:00 a.m. to 11:00 p.m. The nighttime window does not remove the other requirements.
- Advertising in print media is prohibited except in specialized publications; separate bans apply to front and back pages and material for children and young people.
- Promotional events are prohibited, except for special exhibitions of alcoholic beverages.
- Messages to an undefined group of people by post, email, or mobile communications are prohibited.
For ordinary advertising on a website or social network, Article 22 does not impose a blanket ban on all internet placements. However, check the status of the platform, the format, and the audience. Advertising is prohibited in material intended primarily for people under 18; minors may not be engaged as models, and ads may not show alcohol being consumed or feature popular figures or their endorsement of drinking.
Alcohol must not be associated with success, solving personal problems, treatment, or stimulating or calming effects; ads must not encourage its consumption or portray abstinence negatively. Images of doctors, other professional medical workers, or people imitating doctors’ appearance are prohibited, as are claims that most people drink and portraying high alcohol content as an advantage. Advertising is subject to a restriction within 300 meters in direct line of sight of the grounds of educational institutions.
Permitted direct advertising must include the warning: “Надмірне споживання алкоголю шкідливе для вашого здоров’я” (“Excessive alcohol consumption is harmful to your health”). The warning must take up at least 15% of the area or volume of the entire ad, with black text on a white background; in print media, it must run horizontally along the bottom of the image. The law also requires advertisers, in the manner established by law, to direct at least 7% of the funds spent on distributing alcohol advertising in Ukraine to social advertising about the harms of alcohol abuse.
Sponsorship and product placement involving alcohol are governed separately by Articles 5, 5-2, and 22. Part 4 of Article 22 expressly permits alcohol sponsorship of specified linear media programs and events. It also permits alcohol product placement in linear audiovisual media programs, provided that Part 3 of that article is complied with. Article 5 prohibits advertising information about a sponsor that manufactures alcohol, its business name, product, or trademark in the spoken narration or audio accompaniment of audiovisual media programs, online media materials, and content on video- and information-sharing platforms.
Exceptions to the warnings in Section III apply to materials that meet the requirements for sponsorship or product placement. Do not commission alcohol sponsorship of events intended primarily for people under 18. Part 6 of Article 22 also prohibits distributing and selling products bearing alcohol trademarks, except for the exceptions expressly listed there. For example, a store may not sell cups or T-shirts bearing such trademarks.
Before commissioning sponsored material or alcohol product placement in content, check its legal form, content, and channel. Direct promotional reviews must meet the requirements for direct advertising.
Medicines, Medical Devices, and Dietary Supplements
Article 21 permits advertising medicinal products, medical devices, and relevant methods approved for use in Ukraine. Medicinal products must also be available without a prescription and must not be on the list of products banned from advertising. Prescription medicines and medicines banned from advertising may not be advertised. Part 14 of Article 21 also prohibits teleshopping for medicinal products and methods of prevention, diagnosis, treatment, and rehabilitation, as well as medical equipment whose use requires special knowledge and training. Teleshopping means a direct public offer to enter into a contract for paid purchase of a product in audiovisual media advertising.
Advertising covered by Part 4 of Article 21 must provide objective information, clearly identify the advertised product or method, state that consultation with a doctor is required before using a medicinal product or medical device, and recommend reading the medicinal product’s instructions. The warning “Самолікування може бути шкідливим для вашого здоров’я” (“Self-medication may be harmful to your health”) must take up at least 15% of the area or duration of the entire ad. In audio media, it must be spoken at least once per spot and no less than once per minute, at the same volume as the rest of the audio.
In ads for these medical products and methods, do not promise a guaranteed therapeutic effect or imply that professional advice is unnecessary. It is prohibited to present them as the most effective, safest, or uniquely free of side effects; frighten people with deteriorating health if they do not use the product; or cite specific cases of successful use. Do not use images of bodily changes caused by illness or injury, claims that encourage self-diagnosis and treatment, or references to therapeutic effects for diseases that are incurable or difficult to treat.
Recommendations by medical workers, scientists, medical institutions, and organizations are prohibited, as is participation by doctors, other professional medical workers, and people imitating a doctor’s appearance. Testimonials about treatment, images and names of popular figures, and characters specified by law are also prohibited. Ads for medicines must not imply that they are food, cosmetics, or another consumer product, or that their safety or effectiveness is due to natural origin.
Dietary supplements, ordinary food products, cosmetics, and other products outside the defined medical categories may not be assigned therapeutic properties.
These requirements do not mean that a medical warning must be added to advertising for every personal care or food product. First determine the product category. Article 21 also provides an exception for specified specialist publications for medical institutions and doctors, and for advertising at medical seminars, conferences, and symposia. An ordinary store page does not become such a publication by mentioning health.
If your range includes veterinary medicines or infant formula, check the special provisions in Articles 21-1 and 25-2 before launching a campaign. If the store advertises weapons, a financial service such as a partner’s loan, or uses the brand of a gambling operator, it requires a separate review under Articles 23, 24–25, or 22-1, respectively. The general rules for ordinary goods are not sufficient here.
Distinguish a Sign from Outdoor Advertising and Obtain Required Approvals
Under Part 6 of Article 9, a sign or plaque is not advertising if it contains the details specified by law: registered business name, trade name, lawfully used trademark, type of business, and opening hours. It must be placed on the interior surface of premises owned or otherwise made available for use, or on the exterior of the building by the entrance, no higher than the ground floor or the floor where those premises are located.
Practical recommendation: before making a fixture, check both its content and placement against every condition of the exception. A banner with prices, discounts, or a call to buy should not automatically be treated as an ordinary sign. Keep the design, a photo of its location, and documents showing the right to use the premises.
Article 16 requires a permit for outdoor advertising: within a settlement, it is issued by the executive body of the relevant village, settlement, or city council; outside settlements, by the regional state administration; and in the territory of the Autonomous Republic of Crimea, by the Council of Ministers of the Autonomous Republic of Crimea. Consent is also required from the owner of the land, building, or structure, or an authorized person. Charging a fee for issuing a permit is prohibited; this provision concerns the permit’s issuance specifically.
For road right-of-way areas, monuments, their protected zones, and historic areas of settlements, the relevant authorities participate in the permitting process. Advertising must not obstruct road signs or visibility, reproduce road signs, dazzle road users, or illuminate apartments. The law prohibits structures on pedestrian paths and park walkways, and Article 8 prohibits them on components of overhead power lines for electric transport and on outdoor lighting equipment.
If an advertising surface in a settlement extends over the edge of the carriageway, it must not be placed less than 5 meters above the road surface. For advertising above the carriageway, the lower edge must also be at least 5 meters above it. Outside settlements, a structure must not be installed closer than 5 meters from the edge of the carriageway. Before producing a structure, check these distances and the other technical requirements in Part 2 of Article 16.
Under Article 17, indoor advertising requires approval only from the owner of the location or an authorized person. Indoor advertising is prohibited in the premises of state authorities and local self-government bodies, preschools, general secondary schools, and specialized general educational institutions. This prohibition does not apply to social advertising.
Under Article 18, advertising on transport requires approval from the owner of the relevant vehicle or transport facility, or an authorized person. If safety and traffic rules are observed, the vehicle owner may not be required to obtain additional advertising permits. However, advertising may not imitate the appearance of special-purpose vehicles or use reflective materials, sound signals, or light signals. On transparent surfaces, only materials that allow an unobstructed view from inside the vehicle are permitted. Do not commission commercial advertising announcements through passenger announcement sound systems on public transport, at metro stations, railway stations, ports, or airports: Part 5 of Article 18 permits only social advertising through such systems.
Send Advertising Messages with Consent
Article 14-3 prohibits advertising spam, including mass calls without prior written consent, including electronic consent. Advertising using a consumer’s phone number or other network identifier is permitted with such consent, provided that the consumer can opt out of the use of their data, including receiving advertising, at any time through a simple, clear, and free process.
Practical recommendation: keep the text and version of the consent, its date, and evidence of the customer’s action. Providing a phone number for delivery does not establish consent to receive advertising messages. Test the opt-out process: after opting out, the contact should stop receiving the relevant advertising. For products subject to special prohibitions, customer consent does not remove restrictions on sending messages.
Set Up a Promotional Discount in Torgsoft and Check the Price
In Torgsoft, the “Маркетинг → Акції” (“Marketing → Promotions”) mode lets you set a discount percentage or amount, product group, sales outlets, and customers. On the period tab, you can define the start and end dates, days of the week, and hours. Practical recommendation: enter the approved terms in the settings and check that the products, stores, and eligible customers match the ad. Choose the appropriate trade type: “Роздріб” (“Retail”), “Опт” (“Wholesale”), or “Опт і роздріб” (“Wholesale and Retail”).
On the “Результат” (“Result”) tab, the program displays a written interpretation of the terms. For the selected inventory center, you can view the products covered by the promotion. Compare the list with the ad and check the final price in a test sale, including a purchase by a customer with a customer discount: the result depends on discount priorities and the configured way discounts are combined. If the offer depends on quantity or purchase contents, also check what happens when the quantity changes or a product is removed. If control barcodes are configured, first scan such a code, then the customer card and the products to activate the promotion.
According to the official Torgsoft guide, for the “Роздріб” (“Retail”) and “Опт і роздріб” (“Wholesale and Retail”) trade types, the promotion applies to the retail price, but not to the “Ціни зі знижкою” (“Discounted Price”). After making changes, restart the program or click “Нова реалізація” (“New Sale”) in the “Реалізація” (“Sale”) form. Before publication, the responsible employee must separately check the legality of the advertising copy and confirm that the actual price matches the advertised price for all stated customer categories.
Assign Responsibilities and Account for Penalties
Article 27 allocates liability according to the specific acts involved. The advertiser is responsible, among other things, for inaccurate source data, commissioning prohibited advertising, and failing to meet content requirements; if the advertiser distributes the ad itself, it is also responsible for the distribution procedure. The ad producer is responsible for violations of third-party rights during production; the distributor is responsible for violations of placement and distribution procedures. An agency contract helps organize the work, but does not override this statutory allocation of liability.
For cases within the competence of the state authority overseeing compliance with consumer protection legislation, Part 4 of Article 27 provides for:
- for an advertiser, a fine of five times the cost of the distributed advertising for specified violations under the law;
- for a producer, five times the production cost for violations of third-party rights;
- for a distributor, five times the distribution cost for violating placement procedures.
Repeating the listed violations within a year doubles these fines. The cost of distributed advertising is determined under the contract, excluding taxes and fees established by the Tax Code of Ukraine. If it is impossible to determine the cost of advertising distributed in violation of the law, Part 7 provides for a fine of up to 300 non-taxable minimum incomes of citizens for advertisers and distributors.
A fine of 100 non-taxable minimum incomes of citizens applies for failure to provide information on cost or other necessary details, late provision, or knowingly false information. For violating the requirements of Part 2 of Article 14-3 on advertising electronic communications, a distributor is fined 3,000 such minimums. Documents showing costs and proof of customer consent therefore have practical value.
These penalties are not universal for all advertising violations. Article 27 excludes violations of Articles 24, 24-1, and 25 from its general regime; separate authority and procedures apply to media, financial services, competition, and gambling. Under Article 26, state authorities may request documents and explanations, issue binding orders, and suspend the distribution of the relevant advertising.
Separate Liability for Unfair Competition
If incomplete, inaccurate, or false information about a product, price, discount, or terms may affect a purchase decision, Article 15-1 of the Law of Ukraine “On Protection Against Unfair Competition” may also apply. This is a separate basis for review by the Antimonopoly Committee of Ukraine.
Article 21 of that law provides for a fine of up to 5% of revenue from product sales for the last reporting year before the year in which the fine is imposed, for the acts it specifies. If there was no revenue, or the respondent did not provide revenue information in response to a proper request, a fine of up to 10,000 non-taxable minimum incomes of citizens applies. These are the maximum limits under a separate liability regime; the specific penalty is determined in the relevant case.
Complete a Final Review and Monitor Advertising After Launch
For each campaign, it is useful to create one folder containing the final materials and supporting evidence. Before an ad is sent for publication, the responsible employee should check the following:
- Product and channel. Is this product permitted to be advertised in this channel? Are the required certificates, licenses, and permits in place for products and activities where they are mandatory? If a store as a Ukrainian resident commissions advertising for activities or products that require a license or permit, also check the licensing and permitting authorities’ registers for information confirming that one was issued to the relevant person. If that information is absent, Part 2 of Article 8 prohibits commissioning the distribution of the ad. For online placement, also check whether the website appears on the national list of websites of concern regarding intellectual property rights. Part 10 of Article 8 prohibits advertising on websites whose addresses have been included in this list on Ukraine’s behalf, as indicated by information from the World Intellectual Property Organization. The law requires the list to be published on the official website of the authority responsible for state policy on intellectual property.
- Content. Are the specifications, stock, delivery times, warranties, and other promises substantiated? Are there any discriminatory claims or unsafe scenes?
- Price and promotion. Are the prices correctly stated in hryvnias? Are the previous and new prices, discount amount, location, start and end dates, and restrictions correct? Have bundle offers been checked?
- Language and labeling. Is the advertising copy in Ukrainian? Is the advertising identification visible, and are all required warnings included?
- Rights. Are there documents allowing use of the materials and appropriate consents from people? Do they cover the planned channels?
- Placement. Have the required permits or approvals been obtained? Are time, age, and other special conditions met?
- Actual sale. Does the final price match the ad for an ordinary customer, a loyalty-program member, and every other stated customer category?
Keep approved rules, versions of copy and designs, contractor approvals, rights documents, evidence supporting prices and advertising claims, contracts, and cost records in the folder. After launch, add screenshots or records of the actual placement: the final publication may differ from the approved design.
Set a time for a repeat review and assign an employee who can stop the ad. If stock, delivery, or price changes, check every active ad, page, and scheduled message. After a promotion ends, remove or update materials that still promise a discount. If you find an error, save a copy of the version, stop distributing it, and record the correction; for changes to contests and prize draws, follow the statutory notification procedure.
Rules to Check When Reviewing an Advertising Campaign
- Law of Ukraine “On Advertising” No. 270/96-VR: Articles 1–2—definitions and scope; 4–6—rights, advertising forms, and language; 8–11—content, discounts, identification, and comparison; 14-2–14-3—platforms and electronic communications; 16–18—placement locations; 20–25-2—special restrictions; 26–28—oversight, liability, and retraction.
- Law of Ukraine “On Consumer Protection” No. 1023-XII, Article 15: product information, prices, discounts, sales, and bundle offers.
- Law of Ukraine “On Ensuring the Functioning of Ukrainian as the State Language” No. 2704-VIII, Article 32: advertising language and special language rules.
- Civil Code of Ukraine No. 435-IV, Articles 307–308: photographing or filming a person and using their image.
- Law of Ukraine “On Measures to Prevent and Reduce the Use of Tobacco Products and Their Harmful Effects on Public Health” No. 2899-IV, Article 16: bans on advertising, sales promotion, and sponsorship of tobacco products.
- Law of Ukraine “On Protection Against Unfair Competition” No. 236/96-VR, Articles 4, 7–8, 15-1, and 21: use of designations, comparison, discrediting, misleading information, and fines.









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