Ukraine’s ambitious digital notary reform has been thrown into controversy after reports of a possible data leak from state registries – reports the government denies, but which have sparked questions about security, politics, and vested interests.
Media outlets reported that citizens’ information from the Unified Registers had been leaked online. Authorities said the breach occurred during a training program for notaries, who have access to non-public registries.
But what exactly unfolded, and what factors may have influenced it?
Ukraine’s notary system
In Ukraine, notaries are state-authorized officials who certify documents, verify identities, register legally significant facts, handle real estate transactions, and draft wills.
Unlike notaries in Common Law countries, who mainly witness signatures, Ukrainian notaries play a more active role in ensuring the legality of documents and officially register transactions, meaning each legal transaction typically produces a set of notarized documents to be legally valid.
The e-Notary system, part of Ukraine’s digitalization drive, aims to simplify this process by allowing users to access and process notarized documents digitally through a single platform.
Reports of the leak
The authorities immediately denied the leak.
The Ministry of Digital Transformation, the Ministry of Justice, and the State Special Communications Service immediately assured that no documents had been leaked to the internet. The parliament responded by appealing to law enforcement agencies to verify the information that had been disseminated.
The information about the data leak was disseminated by the Notary Chamber of Ukraine (NPU), a non-governmental professional organization that, in accordance with the Law “On Notaries,” exercises professional self-government and unites state notaries.
“The Chamber wrote a letter about the data leak, which was immediately picked up by many different ‘experts,’ but for some reason, none of them asked the Chamber itself: ‘Where is the leak? Show me at least some fragment,” Alexander Fedienko, chairman of the Subcommittee on Cybersecurity, Government Communications, and Cryptographic Information Protection of the Verkhovna Rada Committee on National Security, Defense, and Intelligence, told Kyiv Post.
“I immediately wrote a letter to the Security Service of Ukraine (SBU) and the State Special Communications Service asking them to verify this information and report back to me whether there was a leak or not,” he added.
What happened before the ‘data leak’ story?
To understand the scandal, it helps to look at what led up to it.
On Sept. 2, the Ministry of Justice presented the e-Notary system, a project implemented jointly with the State Enterprise “NAIS” and Ukraine’s Ministry of Digital Transformation.
The main idea is to simplify the provision of public services by integrating several state registries into a single system, in which a notary, using the “single window” principle, will be able to transfer information from a multi-form to various registries with just one click.
This involves the ability to simultaneously work with the electronic notarial archive, the register of notarial actions, the Unified Register of Powers of Attorney, the Unified Register of Notaries, the Unified Register of Special Forms of Notarial Documents, and the Inheritance Register.
The next day, notaries began voluntary testing of the system, which would run for the rest of the month.
Participants were informed that the test version was intended to identify errors to ensure the system functions properly at its official launch.
But according to the NPU’s official statement, even in “training mode,” working with the system poses a risk of violating notarial secrecy.
“The transfer (copying) of information from the Inheritance Register and the Unified Register of Powers of Attorney to the test environment of the e-Notary system, a software product that has not been put into commercial operation, contains signs of a violation of notarial secrecy and unauthorized dissemination of information from electronic registers,” the NPU wrote.
“It is necessary to stop any experiments in reforming the activities of the notary,” it added.
In turn, the State Special Communications Service explained that there can be no dissemination of data, since only a notary with their own separate qualified electronic signature (QES) on a secure device can access the system.
According to Kyiv Post’s industry sources, apart from a notary with his flash drive and key, no one has access to the system. This means that viewing e-Notary data is closed even to representatives of the Ministry of Digital Transformation and the Ministry of Justice.
Sources reported that the NPU was unhappy with the electronic notary system from the outset, and notaries were warned that any actions in the test version were invalid.
“Despite the fact that this is only a training version, it cannot be said that there was no real data there. But it is still impossible to log in and see what is happening in the system if you are not a notary! Only with your own flash drive and key!” the source told Kyiv Post.
“And, of course, notaries must comply with the law: As soon as a document comes into their hands, it becomes a notarial secret, even if that document belongs to another notary,” the person added.
Opposition to the reform?
Oleksandr Fedienko, a lawmaker and member of the Parliamentary Committee on National Security and Defense, believes the story about the data leak was publicized to disrupt the digitalization reform.
“In my opinion, all this is being done precisely in order to disrupt the digitalization of notarial services, which should be enshrined in law. Let me remind you that there are currently several legislative initiatives in parliament aimed at digitizing notary services,” he said.
“Some people do not want this to happen, as was recently the case with the adoption of Law No. 11377 [Law on the Unified Information System for the Social Sphere], when some lawmakers were against it and tried to block it. But parliament had a different opinion,” he added.
Alain Bobrov, the former head of the Ministry of Justice’s strategic communications department, believes the lawmakers’ suspicions are entirely justified.
He said the information about the data leak from the registry appeared on Sept. 18. He said that, on that day, 229 lawmakers voted in favor of the government’s bill to create a Unified Information System for the Social Sphere (UISS), which will be able to combine more than 30 existing registers and databases in the social sphere.
“You can look at the timing. Just when lawmakers are considering bills on digitalization, such a resonant statement suddenly appears. At the same time, it may be a coincidence. After all, this communication and the gradual launch of e-Notary into the world and its testing were planned long before these events,” Bobrov said.
Bobrov pointed to signs of a targeted information campaign, noting that in early 2025, Ukraine faced Russia’s most severe cyberattack on the Ministry of Justice’s Unified Registers.
Data leaks remain a sensitive topic for Ukrainians, who recall the problems caused by the malfunctioning registries of legal entities, individual entrepreneurs, public organizations, and the State Registration Service.
“Was this campaign an attempt to influence the image of ‘Yenot,’ as the e-Notary is called? An important nuance is the way this information is presented. The Notary Chamber is doing this as publicly as possible, although this could have been avoided,” he said.
“They knew about the testing of e-Notary long before this issue arose. And they are doing this with dramatic statements about ‘unprecedented violations.’ The NPU immediately appealed to Minister Fedorov and the Minister of Justice, including through the media,” he added.
Bobrov said the move resembles a “well-constructed PR strategy.”
“Therefore, it all looks like a classic lobbying campaign and a well-constructed PR strategy: They chose a perfect and very painful topic in the context of the recent large-scale cyberattack on the Ministry of Justice’s registries. Data leaks are the worst thing for people, especially when it comes to wills or powers of attorney,” Bobrov said.
Lawmakers also took note of reports on data leaks, having felt the impact of state registry issues in January 2025, according to Bobrov.
For instance, the times when the National Agency for Corruption Prevention (NACP) temporarily halted the “Data for Declaration” function, as users could not receive complete certificates without access to the Ministry of Justice registries.
“Secondly, the representatives of the Chamber are not just criticizing, but are allegedly proposing a constructive dialogue. It looks solid and responsible. But will this story work on deputies? Partially, yes. Deputies are also people who see headlines about data leaks from e-Notary: Some may doubt whether it is worth implementing it so quickly,” Bobrov said.
“The government is pushing very hard for digitalization; it is the number one priority. And this is such an avant-garde project of the Ministry of Justice that it is unlikely to be completely stopped,“ Bobrov added.
But the truth might lie “somewhere in the middle,” Bobrov said – possibly attributed to insufficient communication with stakeholders.
“Notaries have always been cautious about digitization. And here you can understand them – it’s their bread and butter. If everything goes online, why would you need so many physical notary offices?” he said.
“But these fears are unfounded, because even after the launch of electronic notary services, you still can’t do without people. So, since this is an economic issue, it’s not just about data security,“ Bobrov added.
Lawmaker Fedienko agrees with him, however.
“Of course, not all notaries are comfortable with these electronic registries. With e-Notary, they will lose money and lose procedures where you have to come in, sign something, and have that document printed out on paper,” Fedienko said.
According to Fedienko, electronic transactions are not only entirely “unfavorable” to state and private notaries but also deliver a major blow to “black notaries” – those who operate illegally, often assisting clients in seizing property rights or reselling them unlawfully.
“If a person comes to a notary, for example, to check some property rights, it is normal for the notary to go to the unified notary register to look at it,” Fedienko said.
“If it is clearly visible which notary asked what, this will, on the contrary, be the right situation, which will help minimize the actions of so-called black notaries. These are notaries who take money for actions on the basis of which the purchase, sale, alienation, or raider seizure of some property then takes place,” he added.
“And then an honest person starts to sue these raiders. At this time, they manage to sell everything two or three times. And therefore, the adoption of the law on e-Notary will be able to prevent such a phenomenon,” he added.
When will e-Notary start operating in Ukraine?
The final step in launching this system is the adoption of the law itself. According to Kyiv Post sources, the document is still in the drafting stage.
“Work is underway to develop a draft law that would regulate the issue of e-Notary. Consultations are currently being held with interested parties and international experience is being analyzed,“ the source said.
”The draft law on e-Notary services is still being developed. We are currently holding consultations, talking to the public and other parties: This is the standard procedure for drafting a law,” the source added.
There is currently no precise information on when the initiative will be submitted to the parliament. Optimistically, the law could be passed by the end of 2025.
The Ministry of Justice also expects Ukrainians to be able to use online notary services as early as January 2026.
“The e-Notary system will be operational by the end of this year. We will link the e-Notary system to the Demographic Register database, which will allow notaries to verify the validity of passports,” said Minister of Justice Herman Halushchenko.
According to Halushchenko, the digitization of services, such as issuing a power of attorney for property and the state registration of real estate or businesses in electronic format, will reduce corruption risks, prevent fraud, and generally increase the security of notarial actions.
Incidentally, the Cabinet of Ministers has already adopted a resolution on standardizing the procedure to maintain the electronic and paper registers. So far, this is part of an ongoing experiment.
According to the State Enterprise “National Information Systems,” as of Sept. 16, about 2,000 notaries have already joined the e-Notary’s testing.
In just two weeks of testing the system, users submitted over 250 suggestions for its improvement.
The Ministry of Justice said the suggestions will help improve the system and have already been “taken into consideration.”
“We are taking the time to carefully review all the suggestions provided during the first part of the training and testing period. The Ministry of Justice is beginning the stage of refining the system in accordance with the suggestions received from notaries,” the Ministry of Justice’s press service wrote.
“After the relevant changes are made to the system, notaries will regain access to the training and testing period,” it added.
As of Sept. 25, scheduled technical work on the system was continuing, and training for notaries had not yet resumed.