Expanding Freedom and Democracy
Freedom on the Net 2023

Ukraine

Partly Free
59
100
A Obstacles to Access 18 25
B Limits on Content 22 35
C Violations of User Rights 19 40
Last Year's Score & Status
59 100 Partly Free
Scores are based on a scale of 0 (least free) to 100 (most free). See the research methodology and report acknowledgements.

header1 Overview

The February 2022 full-scale invasion of Ukraine by the Russian military continues to undermine internet freedom in the country. Russian military attacks have severely damaged Ukraine’s internet infrastructure, but collaborative efforts between the government, internet and mobile service providers, and international partners helped individuals maintain access during the coverage period. The eastern regions of Ukraine have been particularly affected by the conflict. Occupying Russian authorities in some of those areas rerouted the internet through Russian networks, with the result that social media platforms, messengers, VPN services, and media websites that are blocked in Russia also became unavailable in parts of Ukraine. Restoring connectivity in places where the internet became inaccessible due to war damage has been a priority for Ukrainian forces upon retaking territories. According to Meta, Ukraine was the second-most targeted country in the world for coordinated inauthentic behavior networks in 2022, with most of these networks originating from Russia. Similarly, cyberattacks by Russian-affiliated actors against critical sectors, state institutions, and media remained regular, but Ukrainian government agencies mitigated the most severe threats.

Since the 2014 protest-driven ouster of former president Viktor Yanukovych, Ukraine has enacted a series of reforms to address the country’s ongoing endemic issues including widespread corruption, and attacks against journalists, activists, and members of ethnic and other minority groups. However, government initiatives to solve these problems sometimes suffer from a lack of political will, and have experienced setbacks. While the 2022 invasion forced the government to shift its primary focus from reform programs to more pressing wartime needs, authorities have continued work toward aligning legislation with European Union (EU) law. Since the Russian invasion of Crimea in 2014, the government has prosecuted individuals or groups perceived as threatening to Ukrainian sovereignty.

Note: To align this survey with Freedom House’s Freedom in the World survey, Freedom on the Net has excluded Russian-occupied eastern Donbas, based on boundaries established prior to the Kremlin’s full-scale invasion of Ukraine in February 2022, and Crimea from its analysis of Ukraine in recent years. Disputed or occupied territories are sometimes assessed separately by Freedom in the World if they meet certain criteria, including boundaries that are sufficiently stable to allow year-on-year comparisons. Readers can access Freedom House’s criteria for evaluating territories separately here.

Freedom House released an explainer detailing how Russian military actions elsewhere in Ukraine, including in areas the Russian military occupied during the coverage period, are factored into the country's Freedom on the Net scoring.

header2 Key Developments, June 1, 2022 - May 31, 2023

  • Due to blackouts caused by Russian military airstrikes on critical energy and telecommunications infrastructure, Ukrainians experienced periodic disconnections from broadband internet services. To mitigate these disruptions, the government established nationwide “invincibility” points where Ukrainians can freely access the internet and other basic services (see A1).
  • In some areas of Ukraine that were occupied by the Russian military during the coverage period, the internet was rerouted through Russian networks. As a result, users in those areas were reportedly unable to access websites, social media platforms, and VPN services banned in Russia. In the rest of the country, the absence of strict governmental control over the networks and the diversity of internet-service providers (ISPs) has helped Ukraine avert a nationwide internet shutdown (see A3, A4, C4, and C8).
  • In March 2023, a new media law, which outlines the process for voluntary registration, defines online media, lists categories of prohibited content, and enables the government to fine or ban outlets that fail to remove prohibited content, came into force (see B3 and B6).
  • Ukraine continues to be targeted with war-related disinformation propagated by Russia-based actors. During the coverage period, Meta observed that these operations have changed tactics: perpetrators are now more likely to be covert, and to attempt to flood the online space with low-quality content. Previously, overt activity by Russian state-controlled media was more common (see B5).
  • Throughout the course of the war, trust in media has increased and social media platforms and messengers, notably Viber, Telegram, and YouTube, have emerged as the primary news platforms for many Ukrainians (see B7).
  • Ukrainian courts have charged individuals for their online activities, particularly when these actions fall under the purview of criminal code articles 109 (actions aimed at violent change or overthrow of the constitutional order), 111-1 (collaborationism), or 436-2 (glorification of the armed aggression of the Russian Federation against Ukraine) (see C3).
  • In tandem with military operations, Russia has actively engaged in cyberattacks targeting critical sectors in Ukraine, including government, energy, transport, and financial infrastructure (see C8).

A Obstacles to Access

A1 1.00-6.00 pts0-6 pts
Do infrastructural limitations restrict access to the internet or the speed and quality of internet connections? 4.004 6.006

During the reporting period, damage caused by the Russian military’s full-scale invasion continued to interrupt internet access for many, though the government has taken action to restore access in liberated areas.1

According to the latest data from the International Telecommunication Union (ITU), as of 2021, Ukraine’s internet penetration rate was 79.2 percent, with the fixed- and mobile-broadband penetration rates reaching 18.3 percent and 80.1 percent respectively.2 According to DataReportal, as of February 2023, some 20.8 percent of Ukrainians remained offline, while the number of internet users declined by 5.8 million (16.8 percent) between 2022 and 2023, in large part a reflection of the fact that many people fled the country due to the war.3 Internet availability and ease of access vary by region, and have been significantly affected by war during the coverage period.

Most people access the internet on their mobile phones, though many cafés and restaurants provide free Wi-Fi connections. Wi-Fi is also common in public libraries, schools, malls, and airports. It is sometimes available on public transport, including high-speed trains and airplanes.4

Mobile internet speeds remain poor. The median mobile download speed in May 2023 was 24.74 megabits per second (Mbps), compared to a global average of 42.30 Mbps, according to the network intelligence company Ookla.5 The median fixed-broadband speed was much faster, per Ookla, clocking in at 66.88 Mbps.

Due to emergency blackouts resulting from Russian military air strikes on energy and telecommunications infrastructure, Ukrainians have been periodically disconnected from broadband internet. In such cases, significant additional consumption of mobile internet has also overloaded mobile operators’ networks, resulting in poor quality or the total loss of mobile internet service. Ukrainian internet providers use electricity generators to keep Ukrainians connected, with one generator typically able to function from 8 to 40 hours without refueling.6

In July 2022, the World Bank and the Ministry of Digital Transformation of Ukraine estimated that the Russian military’s destruction of infrastructure has led to a 19 percent decline in the quality of mobile connection compared to the prewar level. The quality of fixed-broadband internet dropped by 13 percent after the outset of war, but returned to prewar levels in government-controlled areas by mid-summer 2022. Over 15 percent of settlements across Ukraine either fully or partially lost mobile connection, while 11 percent of mobile operators’ base stations were disabled. The full-scale invasion has resulted in losses for over 720 internet providers, and rough estimates of the cost of restoring the telecom sector amount to $1.79 billion. Eastern regions of the country suffered the most severe damage.7 In October 2022, Cloudflare reported a 33 percent decrease in traffic across Ukraine in the first weeks of invasion, followed by gradual growth that reached its peak in the fall of 2022, when many Ukrainian refugees returned. Internet traffic was redistributed between the eastern and western regions of the country, as the former faced constant Russian attacks, and the latter received a multitude of internally displaced persons.8

In November 2022, the State Service of Special Communications and Information Protection of Ukraine (SSSCIP) reported the destruction or seizure of over 4,000 mobile operators’ base stations and upwards of 60,000 kilometers of fiber-optic lines since the start of the full-scale invasion.9 By January 2023, telecommunications companies had restored access to 1,200 mobile base stations and installed 1,500 new stations. Additionally, operators modernized 8,000 base stations, enabling them to use less electricity, and restored over 3,200 kilometers of fiber-optic lines. According to a statement from Brigadier General Yurii Shchyhol, the head of the SSSCIP, in January 2023, mobile connection was available across 77 percent of Ukrainian territory, including areas with active military actions. This marked a significant improvement compared to early 2022, when mobile coverage dropped to 40 percent after the Russian military’s initial air strikes.10

According to the Ministry of Digital Transformation, by the end of 2022, 90 percent of schools and hospitals were connected to high-speed internet and internet has been partially restored on 80 percent of liberated territories.11 In May 2023, the Ministry of Digital Transformation and Nokia signed an agreement to launch a pilot project modernizing networks in frontline settlements and settlements that were occupied by the Russian military, making them energy independent. The initial pilot will launch in Kherson.12

When Ukrainian forces have retaken territories, reestablishing internet connection has been one of their priorities.13 However, restoring infrastructure has been challenging due to mines, constant shelling, and power outages. While repairs are ongoing in liberated territories, Ukrainian providers have established makeshift Wi-Fi spots where residents are sometimes queueing for hours to connect to the internet for some 15 minutes.14

During the first year of war, Ukraine became one of the countries with the highest rate of SpaceX’s Starlink usage (see A4). By March 2023, Ukraine received at least 42,000 Starlink receivers,15 which have been operationalized to provide internet access to individual users and critical infrastructure facilities even during the blackouts and in the areas most heavily affected by the war.16 Ukrainian soldiers have reportedly used the SpaceX-operated systems to coordinate military action and stay in touch with their families.17 By the end of 2023, the Ministry of Digital Transformation and Ukrainian Railways plan to equip all high-speed intercity trains with Starlink receivers.18 In August 2023, after the coverage period, it was revealed that Elon Musk, the chief executive of SpaceX, had refused to activate Starlink satellites in Sevastopol when the Ukrainian government asked him to activate them so the Ukrainian army could attack a Russian fleet.19

In late November 2022, the government launched a nationwide “invincibility points initiative” by setting up specially equipped places where Ukrainians can charge their devices, warm up, and get free access to the internet and mobile networks in case of power outages.20

The government has also worked with mobile operators to help them launch a national roaming service allowing subscribers to switch between networks in cases where a signal is jammed.21 Since March 2022, ISPs connected hundreds of bomb shelters to fixed-internet or Wi-Fi facilities and have continued to expand their networks.22 In April 2022, 27 mobile operators in the European Union (EU) and Ukraine reached an agreement to provide roaming calls to Ukraine at a free or reduced price.23 The preferential roaming regime was prolonged until the beginning of July 2023, and extended to cover calls to fixed-line numbers in Ukraine. Another one-year extension was approved after the coverage period and will be effective until July 2024.24 Because of the reduced charges, Ukrainians abroad were able to get better access to mobile internet, with average data traffic consumption per subscriber increasing from 474 MB to 3.6 GB.25 Moreover, in mid-February 2023, the European Commission adopted a proposal to incorporate roaming into the EU-Ukraine Association Agreement.26

At the end of March 2022, the ITU agreed to aid Ukraine in rebuilding its telecommunication sphere.27 In April 2022, the Global NOG Alliance, a nonprofit organization supporting network operating groups, launched the “Keep Ukraine Connected” project to help mobile operators purchase equipment necessary for the restoration of telecom infrastructure.28

Earlier, in September 2021, the government approved a plan for 2021–22 aimed at providing 95 percent of the population of Ukraine with access to high-speed mobile and broadband internet, though the invasion has disrupted the initiative.29

At the end of June 2020, three major mobile operators—Kyivstar, Vodafone, and Lifecell—started a 4G long-term evolution (LTE)–900 technology network expansion as a part of a nationwide program to provide fourth-generation (4G) technology for mobile networks to 90 percent of the population by 2024.30 By the end of 2021, Kyivstar’s 4G network reached 90 percent of Ukraine’s population, closely followed by Vodafone Ukraine with 83 percent coverage.31 Further growth of the 4G network was put on hold with the operators’ attention being shifted to emergency restoration of base stations destroyed by Russian military. According to the ITU, as of 2021 at least 92 percent of the population were covered by 4G mobile network and 83 percent of households had internet access at home.32

In 2021, ahead of schedule, Kyivstar and Vodafone covered four international highways with high-quality 4G connection.33 In mid-February 2022, the parliament approved a bill that simplifies the procedure for deployment of 4G base stations by mobile operators, and halves the time required to obtain the necessary permit.34

In November 2020, the government adopted a 5G-technology implementation plan. The first government tender to install the network was to be announced in October 2021, but was postponed until February 202235 and then put on hold following the Russian military’s invasion.

A2 1.00-3.00 pts0-3 pts
Is access to the internet prohibitively expensive or beyond the reach of certain segments of the population for geographical, social, or other reasons? 2.002 3.003

Infrastructure for information and communications technology (ICT) companies is more developed in urban areas, though inequality along an urban-rural divide has continued to narrow.

With an average monthly wage of 13,376 hryvnia ($364) in 2022,1 monthly internet subscription rates are fairly affordable for most of the population; however, since the invasion, private-sector wages had decreased by an average of 25 to 50 percent, depending on the sector of work, according to June 2022 data from the National Bank of Ukraine.2 According to 2022 data from the ITU, the average cost of a 5 gigabyte (GB) monthly fixed-broadband subscription was 1.9 percent of gross national income (GNI) per capita, while that of a 2 GB mobile subscription was 1.3 percent of GNI per capita.3 High competition among operators generally keeps internet subscription prices affordable. As reported by the Ministry of Digital Transformation, during 2022, internet subsidies helped provide 367 villages with fiber-optic connections for the first time.4

Studies prior to the war showed that prices for both fixed-broadband5 and mobile-broadband6 subscriptions in Ukraine were among the world’s least expensive.7

In February 2023, Ukrtelecom announced the launch of free public Wi-Fi zones in the largest Ukrainian cities—Kyiv, Dnipro, Lviv, Odesa, and Kharkiv—that have a capacity to remain functional for two to four hours during electricity blackouts.8 The Ministry of Digital Transformation plans to expand the number of such free public Wi-Fi zones by installing Starlink receivers, including in recaptured territories.9

Rates of access are low among members of Ukraine’s Romany minority, as many Roma lack access to computers or smartphones or live in communities with limited services.10

There is a slight gender gap in internet access, with more men (82 percent) than women (77 percent) using the internet, according to 2021 ITU data.11

A3 1.00-6.00 pts0-6 pts
Does the government exercise technical or legal control over internet infrastructure for the purposes of restricting connectivity? 4.004 6.006

Ukraine’s diverse and open internet infrastructure hinders Ukrainian authorities from blocking connectivity on large scales. The backbone connection to the global internet is not centralized, and major ISPs manage their own channels independently.1 The country has at least 23 internet exchange points (IXPs),2 12 of which were operational as of March 2023.3 Ukraine’s largest IXP, UA-IX, allows Ukrainian ISPs to exchange traffic and connect to the global network. Ukraine’s internet proved to be resilient even during the full-scale war due to availability of numerous exit points with neighboring countries, a well-provisioned network of international connectivity providers, a strong local peering fabric, and well-secured networks to mitigate security issues. 4

As reported by Access Now, during the first year of war, the Russian military restricted internet access at least 22 times through the intentional destruction of infrastructure. Moreover, the report noted Russia’s air strikes resulted in at least 14 network disruptions in Ukraine in 2022.5

Users in the Russian-occupied Kherson region, which was home to 280,000 people as of May 2022, experienced internet blackouts, as local ISPs including Kherson Telecom (Skynet) rerouted Ukrainian internet traffic through Russian networks, imposing restrictions on content.6 During the summer of 2022, the Kremlin blocked access to Instagram, Facebook, and YouTube in the city of Kherson and the Zaporizhzhia Region.7 Even after the traffic ceased to reroute through Russia in October 2022, Ukrainian networks in Kherson Region suffered major outages through at least the end of 2022, with two networks remaining offline.8 The Russian military had previously taken similar actions in Crimea, which is outside of this report’s scope.9

Beginning in late April and May 2022, Russian occupying forces in Kherson attempted to force ISPs to route traffic through the Russian network,10 at times threatening ISP employees at gunpoint, and a number of users temporarily lost access.11 Additionally, the Russian military restricted access to Ukrainian mobile networks and forced Kherson residents to use Russian SIM cards.12 Russian occupying forces seized ISPs’ equipment and ordered ISP employees to reconfigure the connection to go through a Crimea-based ISP linked to the Russian national provider,13 but the majority of service providers deliberately destroyed or disconnected their equipment to prevent its seizure by Russian military. Others, primarily smaller, local ISPs, continued operations on Russia’s conditions to continue their business and provide residents at least some connection.14 Users connected to ISPs routed through Russian networks are unable to access websites that are blocked in Russia, including Instagram and Facebook. Additionally, in July 2022, Russian-backed authorities in Kherson reportedly restricted access to VPNs (see C4), websites and messaging applications that are not blocked in Russia, including Google, YouTube, and the messaging application Viber.15

The Russian occupying authorities took a similar approach with mobile operators. The authorities forced people to switch to SIM cards of Kremlin-run mobile operators. For example, 7Telecom and MirTelecom started operating in Kherson and Zaporizhzhia regions. Calls to Ukraine are blocked by the above mobile operators preventing local residents from connecting with their loved ones.16 In October 2022, following the Ukrainian army’s Kherson counteroffensive, networks in Kherson were no longer routed through Russia, but residents continued to experience several internet outages throughout the end of the year.

Ukrainian legislation on states of emergency and martial law could potentially be used to restrict connectivity. In December 2020, Parliament passed the Law on Electronic Communications (see C6), which amended the Law on Combatting Terrorism to enable the government to temporarily restrict access to the internet for the sake of antiterrorist operations. The law also allows the restriction of internet access during states of emergencies or martial law,17 when the government may introduce “special rules” concerning “the connection and transmission of information through computer networks.”18 Under martial law, the military is empowered to prohibit “the transmission of information through computer networks.”19 As of the end of the coverage period the government had refrained from implementing these provisions, even after martial law was declared in response to the Russian invasion.20

A4 1.00-6.00 pts0-6 pts
Are there legal, regulatory, or economic obstacles that restrict the diversity of service providers? 5.005 6.006

The Ukrainian ICT market is fairly liberal. According to the National Commission for State Regulation of Electronic Communications, Radio Frequency Spectrum and Provision of Postal Services (NCEC), there were 3,543 ISPs in the country at the end of the coverage period.1 The diversity of ISPs and absence of strict state control over the networks were key factors that enabled Ukraine to avoid a nationwide internet shutdown during the massive and continuous attempts by Russia to destroy telecom infrastructure since the beginning of full-scale invasion (see A1).

Because Ukrtelecom, which was 93 percent state-owned prior to its privatization in 2011, owns much of the ICT infrastructure, and some providers lack the resources to build their own networks,2 there is some dependency on leased lines. However, Ukrtelecom does not exert pressure or regulatory control over other ISPs. At the end of 2021, Kyivstar maintained its leadership in the fixed-broadband market with 18 percent of the market share, followed by Ukrtelecom (15 percent) and Volia (13 percent).3 Other major ISPs in Ukraine include Freenet, Datagroup, Megalink, and Farlep-Invest.4 In 2022, subscribers regularly shifted between ISPs, with experts attributing the shifts to customers’ need to look for stable internet connection during electricity blackouts, and to give preference to passive optical networks (PON), which require reduced electricity.5

The fixed-broadband market is highly saturated, with hundreds of ISPs operating at national, regional, and local levels. At the same time, the mobile-broadband market is dominated by three main competitors: Kyivstar (VEON), Lifecell (owned by Turkey’s Turkcell), and Vodafone Ukraine (owned by Azerbaijan’s BakCell) covering 97 percent of population.6 However, by mid-2022 the three mobile operators altogether lost 4.5 million of subscribers.7

An April 2021 decision by the Antimonopoly Committee of Ukraine concluded that there are no significant administrative barriers to entering the ICT market and financial expenses at the startup phase are relatively low. Moreover, major players often allow new providers to access existing infrastructure for nominal fees when they are establishing their operations. Easy entry to the market and the ability of users to change the provider of their choice keep the competition among ISPs high.8

In September 2019, the government removed a licensing requirement for telecommunications operators, introducing a simplified notification procedure in its stead.9 Additionally, Diia Business, a digital platform launched by the Ministry of Digital Transformation, offers guidelines for those looking to launch an ISP.10 However, mobile operators must still license the radio frequencies they use to provide cellular services. At the same time, during the reporting period mobile operators received additional frequencies to enhance network capacity during wartime.11

A5 1.00-4.00 pts0-4 pts
Do national regulatory bodies that oversee service providers and digital technology fail to operate in a free, fair, and independent manner? 3.003 4.004

Recent changes to the regulatory framework for the ICT sector are meant to introduce greater transparency and reduce the potential for corruption in oversight of this lucrative part of the economy.

Until recently, the ICT sector in Ukraine was regulated by the National Commission for the State Regulation of Communications and Informatization (NCCIR), which was subordinate to the president and accountable to the parliament. Under this system, there were persistent concerns about a lack of transparency regarding NCCIR appointments in light of corruption in Ukraine’s political system and the growing economic performance of the sector.1 In February 2022, the NCCIR was transformed into the National Commission for State Regulation of Electronic Communications, Radio Frequency Spectrum, and Provision of Postal Services (NCEC). The new body features a more transparent procedure for selection of its seven members, involving an independent selection commission and final approval by the government. The NCEC chair is to be selected by members from among themselves for a three-year term.

The current members and chair, who were appointed under the previous presidential decree system, will perform their duties until the end of their terms.2 (The current NCCIR chair, Oleksandr Zhyvotovskyy, was controversially reappointed by former president Petro Poroshenko just before Poroshenko left office in May 2019. This move ensured that Zhyvotovskyy would serve for six years instead of the one year remaining on his original term.)

President Zelenskyy has prioritized digitalization, and in 2019 created a Ministry of Digital Transformation by restructuring the State E-Governance Agency. This body is responsible for articulating and implementing state policy in the areas such as e-government and is in charge of efforts to build digital skills among Ukrainians.3 Zelenskyy’s administration has also created digital transformation leadership positions in each ministry, regional administration, state company, and state agency.4 Moreover, when the Law on Electronic Communications entered into force in January 2022, the Ministry of Digital Transformation assumed powers from the SSSCIP related to shaping policy in the field of electronic communications and radio frequency spectrum. The transition period lasted through June 2022.5

Several civil society groups actively influence ICT and media regulation in Ukraine, including the Internet Association of Ukraine and the National Union of Journalists of Ukraine.

B Limits on Content

B1 1.00-6.00 pts0-6 pts
Does the state block or filter, or compel service providers to block or filter, internet content, particularly material that is protected by international human rights standards? 3.003 6.006

The Ukrainian government blocks numerous Russian and pro-Russian websites, including those that spread disinformation. Russian-owned web platforms, including VKontakte (VK), Odnoklassniki (OK), and Mail.ru; a wide variety of websites deemed to contain Russian propaganda; and Russia-affiliated companies like Dr. Web, Kaspersky, and Yandex have been blocked via “sanctions,” which have been repeatedly renewed, since 2017.1 In May 2021 additional sanctions were levelled against Russian and pro-Russian Crimean media, payment systems, and information technology companies.2 At the end of this report’s coverage period, blocking orders also included the online resources of the self-proclaimed governance bodies of the Kremlin-controlled Luhansk People’s Republic, as well as those of Rostelecom, Russia Today, National Media Group, All-Russia State Television and Radio Broadcasting Company, Channel One, Information Agency ITAR-TASS, and others.3 The actual implementation of website blocking has been inconsistent,4 disputed in the court,5 and never properly monitored.6

After instituting martial law (see C1) in response to the February 2022 invasion, the NCEC asked ISPs to block a massive number of Russian websites that allegedly spread disinformation7 or facilitated cyberattacks.8 In total, the NCEC ordered the blocking of more than 48 million Russian IP addresses. The penalty for noncompliance is exclusion from the register of telecom operators and providers, and the regulator is empowered to apply more severe measures. At least one such case has been reported so far.9

In March 2023, the National Center for Operational and Technical Management of Telecommunications Networks began deploying a filtration system for phishing domains to combat malware spread by Russian hackers. The decision met some resistance from the industry, including from the Ukrainian Internet Association, partially because the measure could lay the ground for future indiscriminate blocking of online resources.10 Similar measures had previously been applied to fraudulent online casinos.11 The policy obliges DNS providers to filter phishing domains, based on a list produced by the Cybersecurity Incidents Response Team of the National Bank of Ukraine, that are used for fraudulent purposes in banking and financial sector. The agency will also create a “whitelist” to specify domains that cannot be subject to filtration. The policy states that the filtration system will not be used to restrict access to sanctioned internet resources or those that are used for dissemination of harmful software, propaganda, disinformation, amongst other issues.12

The Ukrainian government has also issued sanctions against non-Russian media outlets that adopt a pro-Russian stance. For example, in August 2021, Zelenskyy banned the news outlet Strana.ua and sanctioned its editor in chief, Ihor Huzhva, and blogger Anatoliy Shariy (see C3).13 Blocking also was ordered for related channels and pages on YouTube, Facebook, Twitter, and Telegram, and affiliated individuals and businesses were also affected.14 The sanctions against online resources related to Huzhva and Shariy were extended for three and ten years respectively in February 202215 and January 2023.16

The authorities occasionally direct ISPs to block websites involved in cybercrime, fraud, illegal gambling, the drug trade, and money laundering.17 In the past, courts have also blocked websites on grounds that hosting particular content allegedly violated intellectual property rights.18

The Ministry of Culture and Information Policy, previously known as the Ministry of Culture, Youth, and Sports, does not maintain a list of websites to be blocked, as the Ministry of Culture, which preceded both ministries, did. The Ministry of Culture and Information Policy cooperates with the National Security and Defense Council (NSDC) concerning websites that threaten Ukraine’s security.19

  • 1“Decree of the President of Ukraine No. 184/2020 on Approval of the National Security and Defense Council as of 14 May 2020 on Application, Elimination and Amendment of Personal Special Economic and Other Restrictive Measures (Sanctions)” [in Ukrainian], Presidential Office of Ukraine, https://www.president.gov.ua/documents/1842020-33629.
  • 2Dmytro Gubenko, “Зеленський увів у дію санкції проти кримінальних авторитетів і злодіїв у законі [Zelensky imposed sanctions against criminal authorities and thieves in law],” Deutsche Welle, May 21, 2021, https://p.dw.com/p/3tnQs.
  • 3“Указ Президента України №726/2022 Про рішення Ради національної безпеки і оборони України від 19 жовтня 2022 року “Про застосування та внесення змін до персональних спеціальних економічних та інших обмежувальних заходів (санкцій)” [Decree of the President of Ukraine No. 726/2022 On the decision of the National Security and Defense Council of Ukraine as of October 19, 2022 "On the application and introduction of changes to personal special economic and other restrictive measures (sanctions)"],” Official Website of the President of Ukraine, https://www.president.gov.ua/documents/7262022-44481.
  • 4“Укртелеком, Ланет, Паутина.Net. Провайдери починають блокувати сайти Шарія та strana.ua [Ukrtelecom, Lanet, Pautyna.Net. Providers start blocking Shariy and strana.ua websites],” Dev.ua, August 23, 2021, https://dev.ua/news/blokirovka;“Кіберполіція викрила одеського провайдера у наданні доступу абонентам до російського контенту [Cyber police exposed Odesa provider in providing subscribers with access to Russian content],” Official Website of the Ministry of Internal Affairs, December 15, 2022, https://mvs.gov.ua/uk/news/kiberpoliciia-vikrila-odeskogo-provaidera-u-….
  • 5“Київський провайдер НетАссіст відмовився блокувати вконтакті та подав до суду” [Kyiv Based ISP NetAssist Refused to Block Vkontakte and Filed a Lawsuit], Detector Media, September 6, 2019, https://ms.detector.media/videoteka/post/23466/2019-09-06-kiivskii-prov…; Decision by Kyiv District Administrative Court in Case No. 640/17037/19, Unified State Registry of Court Decisions, May 18, 2020, http://reyestr.court.gov.ua/Review/89350804.
  • 6Ksenia Savoskina, “Три года без “ВКонтакте”: сколько украинцев все еще пользуются соцсетями РФ [Three years without VKontakte: How many Ukrainians still use social networks in the Russian Federation],” Hromadske TV, 22 May 2020, https://hromadske.ua/ru/posts/tri-goda-bez-vkontakte-skolko-ukrainskij-…
  • 7“НКЕК просить постачальників електронних комунікаційних мереж та/або послуг негайно заблокувати веб-ресурси відповідно до розпорядження НЦУ від 01.04.2022 [‎NCEC asks providers of electronic communication networks and/or services to immediately block web resources in accordance with the order of the NSU as of 01.04.2022‎],” National Commission for State Regulation of Electronic Communications, Radio Frequency Spectrum and Provision of Postal Services, accessed September 2023, https://nkrzi.gov.ua/index.php?r=site/index&pg=99&id=2294&language=uk.
  • 8“НКЕК просить постачальників електронних комунікаційних мереж/послуг посприяти знищенню інформаційної навали з боку РФ [NCEC asks suppliers of electronic communication networks / services to contribute to the destruction of the information invasion by the Russian Federation],” National Commission for State Regulation of Electronic Communications, Radio Frequency Spectrum and Provision of Postal Services, accessed September 2023, https://nkrzi.gov.ua/index.php?r=site/index&pg=99&id=2252&language=uk.
  • 9“За відмову блокувати роспропаганду інтернет-провайдерів почали виключати з реєстру [For refusing to block Russian propaganda Internet providers are excluded from the register],” Ukrinform, March 31, 2022, https://www.ukrinform.ua/rubric-technology/3444548-internetprovajderiv-….
  • 10“В Україні створюється “троянський кінь” - централізована система автоматичного блокування інтернет-ресурсів ["Trojan horse" - centralised system of automatic blocking of Internet resources is being created in Ukraine],” Internet Association of Ukraine, February 28, 2023, https://inau.ua/news/novyny-inau/v-ukrayini-stvoryuyetsya-troyanskyy-ki….
  • 11“В Україні розпочала роботу система блокування сайтів та збору даних користувачів [Ukraine deployed system of blocking sites and collecting user data],” Novyny N, March 5, 2023, https://novosti-n.org/ua/news/V-Ukrayini-rozpochala-robotu-systema-blok….
  • 12Order of the National Centre for Operations and Technology Management of Telecommunications Networks (NTNOC) [acting under the State Service of Special Communication and Information Protection of Ukraine] “On Deployment of Filtration System of Phishing Domains” No. 67/850, accessed January 30, 2023, https://nkrzi.gov.ua/images/news/11/2580/67_30012023.pdf.
  • 13“Ukraine: President bans opposition media Strana.ua and sanctions editor-in-chief,” European Federation of Journalists, August 26, 2021, https://europeanjournalists.org/blog/2021/08/26/ukraine-president-bans-… .
  • 14“Decrees of the President of Ukraine No. 375/2021 and No. 376/2021 on Approval of Decisions of the National Security and Defense Council as of 20 August 2021 on Application of Personal Special Economic and Other Restrictive Measures (Sanctions)” [in Ukrainian], Presidential Office of Ukraine, https://www.president.gov.ua/documents/3752021-39741, https://www.president.gov.ua/documents/3762021-39745.
  • 15“Зеленський розширив санкції проти Шарія та Гужви [Zelenskyy expanded sanctions against Shariy and Huzhva],” Ukrainska Pravda, February 16, 2022, https://www.pravda.com.ua/news/2022/02/16/7324274/.
  • 16“Указ Президента України №23/2023 Про рішення Ради національної безпеки і оборони України від 15 січня 2023 року "Про застосування та внесення змін до персональних спеціальних економічних та інших обмежувальних заходів (санкцій)" [Decree of the President of Ukraine No. 23/2023 On the decision of the National Security and Defense Council of Ukraine dated January 15, 2023 "On the application and introduction of changes to personal special economic and other restrictive measures (sanctions)"],” Official Website of the President of Ukraine, https://www.president.gov.ua/documents/232023-45589
  • 17“В Україні заблокують 59 сайтів, з них вісім новинних (СПИСОК) [Ukraine will block 59 websites, including eight news aggregators (LIST)],” Detector media, February 2, 2020, https://detector.media/rinok/article/174680/2020-02-12-v-ukraini-zablok…
  • 18“До уваги операторів, провайдерів телекомунікацій [To the attention of operators, telecommunications providers],” National Commission for the State Regulation of Communications and Informatization, February 24, 2021, https://nkrzi.gov.ua/index.php?r=site/index&pg=99&id=2055&language=uk; “Печерський суд заблокував “Главком” [Pechersk court blocked Glavcom],” Glavcom, March 25, 2021, https://glavcom.ua/country/incidents/pecherskiy-sud-zablokuvav-glavkom-…; Olena Tokmach, “Свобода слова перемогла: суд скасував блокування українських сайтів [Freedom of speech won: court lifted blocking of Ukrainian websites],” Glavcom, April 28, 2021, https://glavcom.ua/columns/oksana_tokmach/svoboda-slova-peremogla-sud-s…; Olena Tokmach, “Свобода слова перемогла: суд скасував блокування українських сайтів [Freedom of speech won: court lifted blocking of Ukrainian websites],” Glavcom, April 28, 2021, https://glavcom.ua/columns/oksana_tokmach/svoboda-slova-peremogla-sud-s….
  • 19“Culture Ministry ceases to compile list of websites recommended for ban in Ukraine,” Interfax, January 5, 2021, https://en.interfax.com.ua/news/general/714287.html.
B2 1.00-4.00 pts0-4 pts
Do state or nonstate actors employ legal, administrative, or other means to force publishers, content hosts, or digital platforms to delete content, particularly material that is protected by international human rights standards? 2.002 4.004

The government sometimes refers content to third parties, seeking its removal. During the coverage period, social media platforms and search engines also removed content in response to the Russian military’s invasion of Ukraine.

In the first six months of 2022, Facebook restricted access in Ukraine to 7,725 items of content related to the war, which were reported by both the Ukrainian government and civil society for “allegedly violating local laws on hate speech, incitement to violence, extremism law, spreading misinformation and propaganda, impersonation of high-profile officials, and war crimes,” among other issues. Additionally, the platform removed content that was linked to Russian state-controlled media outlets. Meta also reported it took “further action” on another 839 items based on a separate review.1 In the first half of 2022, Google received 24 requests from the government regarding 125 items, removing 28.8 percent of them on legal and policy ground, In the second half of the year, Google received 64 requests from the government concerning 559 items, removing 26.9 percent of them. Most of the requests related to defamation and national security.2 X, formerly known as Twitter, did not produce a transparency report covering the reporting period.

Several Ukrainian social media pages that have shared information about the war or tried to organize support for the Ukrainian army have also had their pages removed, or otherwise limited since the start of the full-scale invasion. For example, popular online media outlet Ukrainska Pravda and DOU had their Facebook pages placed on “red status,” which prevents them from monetizing content and reduces their organic reach.3 The English version of the “Kyiv Not Kiev” Facebook page was deleted after publishing pictures of atrocities committed by the Russian military in Bucha. Previously, in April 2022, Meta inadvertently placed a restriction on the hashtags #bucha and #buchamassacre on both platforms because of a filter that automatically blocked the graphic pictures accompanying these hashtags. The policy was reversed upon discovery.4

In June 2023, after the coverage period, Twitter allegedly shadow banned Ukrainian users who published posts about the Russian military blowing up the Kakhovka hydroelectric power plant.5 In January 2023, the NSDC Center for Countering Disinformation, in cooperation with Lithuanian initiative Debunk.org, started collecting evidence of pro-Ukrainian users’ who had their accounts removed for war-related publications on social networks.6 Additionally, the Ministry of Digital Transformation asked Meta in 2022 to review its moderation policy of content shared by Ukrainian users, and to publicize a list of prohibited words that the company defines as hate speech.7

In January 2023, Meta accepted the ministry’s request to exclude the Azov Regiment—a unit of the National Guard of Ukraine whose members and founder have a history of having espoused far-right nationalist ideology,8 —from its blocking policy as dangerous organization and to allow the regiment to have accounts on its platforms.9

In 2022, the SBU submitted blocking requests for over 1,500 Telegram channels, and the same number of accounts on Instagram, Facebook, and TikTok, largely concerning the spread of disinformation. Companies acted only upon some of these requests.10

In 2022, Google disrupted over 1,950 instances of Russian information operations on its platforms (see B5).11 Shortly after the war started, the company its updated Sensitive Events Policy and paused ads on pages containing content that is exploitative, dismissive, or condones the invasion, and stopped ads from and on Russia’s state-funded media.12

As revealed by Meta, in 2022 Ukraine was the second-most targeted country in the world by coordinated inauthentic behavior networks with majority of them originating from Russia (see B5).13 In the second half of 2022, the company removed two distinct networks in Russia, including 2,744 accounts, 703 pages, and one group on both Facebook and Instagram targeting Ukrainian and global public discourse about the war.14

To counter Russian propaganda online, the Cyber Police collaborated with volunteers to develop the Mriya project, which allows Ukrainians to send social media posts containing Kremlin propaganda to the Telegram bot “StopRussia | MRIYA” for further investigation. If an assessment conducted by the Cyber Polices establishes that the content contains misinformation or pro-Kremlin propaganda, the Telegram channel provides subscribers with a template to report this information for removal on the relevant social media platform. As of January 2023, over 3.95 million complaints had been submitted, resulting in the blocking or removal of more than 20,800 items.15

B3 1.00-4.00 pts0-4 pts
Do restrictions on the internet and digital content lack transparency, proportionality to the stated aims, or an independent appeals process? 2.002 4.004

With the exception of provisions that mandate the blocking of child sexual abuse imagery,1 the government’s authority to block content is largely ungrounded in legislation.

The sanctions against Russian web platforms and websites prohibit “internet providers” from allowing access to the sanctioned resources, even though this term has not been defined in domestic law. (The Law on Telecommunications, for instance, regulates “operators and providers of telecommunications.”) Further, the Law on the National Security and Defense Council implies that sanctions are only binding upon state bodies—and not upon “internet providers” or “operators or providers of telecommunications.” However, the NCCIR has acted as if ISPs must abide by the sanctions, a position the courts have supported (see B1).2 These inconsistencies have gone unaddressed when authorities have extended the sanctions.

The new law “On Media” (see B6), which was passed in December 2022 and came into force in March 2023, enables the National Council on Television and Radio Broadcasting to issue fines, order the removal of content in violation of the law, and block websites in cases of noncompliance. The law classifies the dissemination of information that denies or justifies criminal nature of the 1917–91 communist totalitarian regime and Nazi totalitarian regime, or creates positive image of their leaders; contains any symbols of these regimes, or humiliates or insults Ukrainian language as significant offenses. Additionally, the law prohibits incitement to discrimination based on sexual or gender identity.3

In the conditions of a full-scale war, there are further regulations that apply from the moment a state is recognized by the Ukrainian parliament as an aggressor state and until five years after this status is canceled, subject to annual revision of the necessity to sustain limitations. Among them, media, including online outlets, are prohibited from disseminating information that presents armed aggression against Ukraine as an internal conflict or civil war; or inaccurate information about armed aggression and actions of an aggressor state with the aim to fuel hatred, forcefully change the constitutional order, or violate the territorial inviolability—all of which constitute “severe” offenses. They are also prohibited from disseminating materials, except for informational and analytical ones, from participants who have been included in the list of persons that present a danger to national security; that violation constitutes a “significant” offense.4

Online media outlets found guilty of violations are subject to fines, and repeated violations can lead to suspensions by the National Council on Television and Radio Broadcasting or bans by the courts.5 ISPs will have three days to restrict access to websites of fully or temporarily banned online media. National groups, including the Independent Media Trade Union of Ukraine, and international organizations, including the Committee to Protect Journalists (CPJ) have criticized the law for giving the National Council too much power to ban outlets and block websites.6

The media law also allows the National Council to request providers of information-sharing platforms and representatives of search engines to restrict and exclude from search results material that is in violation of the law.7

In March 2023, following the ratification of the Additional Protocol to the Council of Europe Convention on the Prevention of Terrorism, the Ukrainian parliament adopted a law that amends the Law on Sanctions to allow for the blocking of online resources thar promote terrorist groups.8

The 2017 Law on State Support of Cinematography in Ukraine requires website hosts to limit access to pages containing unauthorized reproductions of certain categories of copyrighted materials upon a request from a copyright owner, if the owners of the pages fail to remove said materials. The website host can hide pages without a court order for up to 10 days. Hosting providers risk liability for noncompliance.9

B4 1.00-4.00 pts0-4 pts
Do online journalists, commentators, and ordinary users practice self-censorship? 3.003 4.004

Online journalists and ordinary internet users have faced pressure to self-censor, especially on topics related to separatism, collaborationism, terrorism, and Russia. Self-censorship in Ukrainian media also results from outlets’ financial dependence on their owners, pressure on journalists, and impunity for perpetrators. Reportedly, self-censorship can be even stronger in towns where communities are smaller, as journalists who disclose sensitive information or conduct investigations may endanger personal or other relationships with their neighbors.1 According to a May 2023 survey conducted by the lko Kucheriv Democratic Initiatives Foundation and Human Rights Centre ZMINA, which covers the challenges journalists have faced since the beginning of the full-scale invasion, 78 percent of respondents said the Russian invasion has led to more self-censorship cases.2

Following the Russian military’s invasion in February 2022, journalists avoided disclosing information about the location of Ukrainian military units, losses among Ukrainian soldiers, and specific places hit by Russian airstrikes, as doing so could have provided the Russian military with details about Ukrainian defenses.3 Such disclosures may also have been prohibited by the implementation of martial law (see C1), which limits the topics journalists can cover.

B5 1.00-4.00 pts0-4 pts
Are online sources of information controlled or manipulated by the government or other powerful actors to advance a particular political interest? 2.002 4.004

Domestic and foreign dis- and misinformation, particularly from Russia,1 is present within Ukraine’s online media landscape, and increased significantly following the 2022 full-scale invasion. Beyond social media manipulation, the online media landscape is highly polarized and frequently distorted. Media outlets tend to promote the political sympathies of their owners.2

Ukraine’s online information landscape is also subject to manipulation by Russian interests, and this significantly intensified due to Kremlin propaganda after Moscow launched its full-scale war in Ukraine in February 2022. Online news outlets and social media accounts affiliated with the Russian state have created fabricated content, including doctored videos and images, to intentionally mislead online audiences.3 For example, the Kremlin routinely bombed Ukrainian hospitals, maternity wards, railway stations, and residential buildings, but denied accusations of these large-scale indiscriminate attacks on its accounts. Likewise, Russian media outlets regularly spread propaganda accusing the Ukrainian government of using nuclear power plants for storing military equipment, even after the Russian military seized the Zaporizhzhia nuclear power plant at the beginning of the invasion. Russian authorities also attempted to manipulate public perception of the war by claiming local residents’ support for “liberation operation” in the east of Ukraine.4 The SBU has also accused Russian actors of creating Telegram channels that mimic Ukraine government officials’ channels and using them to spread disinformation.5 In same way, Russian actors have mimicked fact-checking resources to spread false information about the war.6

Fabricated or intentionally misleading information disseminated by actors linked to the Russian government and presenting Kremlin-friendly narratives are regularly circulated in online articles that mainly target Ukrainians in areas occupied by the Russian military.7 Ukrainian journalists in occupied territories have been forced to cooperate with occupying authorities and obtain approval from the Russian military before publishing. In occupied territories, people who have shared information that challenges the Russian military’s narrative have been arrested, tortured, and killed on the spot.8

The Russian government has also attempted to justify its war in Ukraine by disseminating false narratives about the “denazification” of the country. Russian government officials, including President Vladimir Putin, and state-affiliated media have attempted to paint the Ukrainian government as “neo-Nazis." The Kremlin has specifically targeted President Zelenskyy, who is Jewish, by disseminating false narratives about his heritage and supposed Jewish ties to Nazism.9 According to February 2023 monitoring data published by the National Council on Television and Radio Broadcasting of Ukraine, Russian media designed thousands of pieces of fake news about Ukraine which it placed in 16 categories; these include false information about the Ukrainian government, false information about NATO, false information about war crimes; anti-Russian sentiments (Russophobia), conspiracy theories, false claims of the current Ukrainian government’s links to Nazism, and false information about sanctions.10

To circumvent blocking in Ukraine, Russian actors spreading false information largely operate on social media platforms, such as Facebook and Instagram, and messenger apps, including Telegram and Viber, with Facebook and Telegram becoming the most popular channels of Kremlin supporters.11

Throughout the coverage period, social media platforms routinely removed networks spreading disinformation from their platforms. For example, according to Meta, in 2022 Ukraine was the second-most targeted country in the world by coordinated inauthentic behavior networks, with majority of them originating from Russia.12 In the second half of 2022, the company removed two distinct networks in Russia, which included 2,744 accounts, 703 pages, and one group, on both Facebook and Instagram targeting global public discourse about the war in Ukraine, primarily targeting the European Union.13 According to Meta’s Adversarial Threat Report covering the final quarter of 2022 there has been a shift in the method of dissemination of Russian-originated disinformation. Most notably, overt activity by Russian state-controlled media decreased by the end of 2022, opening more space for covert operations. Reportedly, state-controlled media moved to other platforms, while covert influence campaigns on Meta’s platforms were widespread, but “low quality.”14 Meta revealed that this operation, which it has called Doppelganger, was linked to the Russia-based companies Structura National Technology and Social Design Agency, which were also sanctioned by the European Union (EU).15

In 2022, Google disrupted over 1,950 instances of Russian information operations on its platforms, including on YouTube, where it terminated accounts and pages that participated in these operations (see B2).16 A February 2023 report by Newsguard, an NGO that analyzes information operations, found that over 100 YouTube channels had uploaded 50 different videos propagating false information about Ukraine created by RT, even though the outlet is banned from the platform.17

Between July and September 2022, TikTok removed two distinct covert influence operations’ networks composed of 1,704 accounts, which aimed to influence public opinion about the war, primarily in the EU. The company also removed 2,319 videos for violation of misinformation policy when reporting on the invasion of Ukraine, and removed livestream videos originating in Russia and Ukraine from the For You feed of users located in the EU to minimize risk of harmful content.18

Since the start of the full-scale invasion, Twitter removed most influential pro-Kremlin accounts, while many others had their content deamplified, thus reducing the amount of anti-Ukrainian propaganda disseminated on the platform. As of December 2022, Twitter had removed upwards of 75,000 accounts discussing the conflict, but this removal primarily concerned accounts attempting to financially scam other Twitter users.19

In 2022, the SBU reported that it shut down 45 bot farms, including over two million fake accounts, for spreading false information, as well as around 500 pro-Russian YouTube channels with a total audience exceeding 15 million subscribers.20 Additionally, the SBU identified over 1,200 individuals who disseminated false information.21

Unverified claims about Russian military actions, as well as false information about successes of Ukraine’s armed forces, have been occasionally shared by Ukrainian politicians.

Prior to the full-scale invasion, some investigative reports suggested that many Ukrainian political actors hire public relations companies and trolling groups to burnish their reputations or assail their opponents online. These activities are usually conducted through networks of automated social media accounts, or bots. Little is known about the operation of these firms and their actual impact on public discussion and opinion.

Several Ukrainian groups work to identify content manipulation (see B7).

In 2021, the Ukrainian authorities institutionalized efforts to combat disinformation originating from Russia. The Ministry of Culture and Information Policy established a Center for Strategic Communications and Information Security, with a mandate of countering disinformation.22 The National Security and Defense Council (NSDC) also has its own Center for Countering Disinformation.23

B6 1.00-3.00 pts0-3 pts
Are there economic or regulatory constraints that negatively affect users’ ability to publish content online? 2.002 3.003

Online media in Ukraine are generally less constrained by economic pressures and owner interests than print and broadcast media. Lower production costs and generally liberal regulations have also contributed to the development of a vibrant online media landscape. There are no obligatory registration requirements for online media, though the March 2023 media law establishes a system of voluntary registration, which affords registered outlets more protections. During 2022, the internet advertising market in Ukraine decreased by 42 percent:1 All major online media outlets have reported a huge drop in online advertising since the beginning of war.2

In 2022, at least 217 Ukrainian media outlets shuttered their operations due to loss of subscribers and advertisers, problems acquiring electronic and other supplies, lack of staff, and financial losses resulting from destruction, according to a February 2023 report from the Institute of Mass Information (IMI) and Reporters Without Borders (RSF). The report also noted that approximately 15 percent of media workers were suspended from work without pay.3

Prior to the war, many online media outlets already struggled to remain financially viable in a market deeply distorted by consolidated media conglomerates whose backers are willing to lose money in order to maintain the political influence afforded to them through media ownership. Independent online outlets rely mainly on advertising for funding, though some generate revenue by publishing jeansa—paid commercial or political materials disguised as journalistic content.4 The amount of jeansa in Ukrainian online media sharply decreased at the beginning of the war, but was on the rise in March 2023, according to a report from the IMI. The report noted that jeansa since the war focuses more on the contributions of high-profile individuals and companies to the war effort.5

Since his election, President Zelenskyy has repeatedly stressed that media owners must be apolitical and should not influence editorial policy.6 He has also mused aloud that media can only be independent if they belong to Ukrainians.7 In May 2022, the so-called Oligarchs’ Law, aimed to prevent threats to national security related to excessive influence of oligarchs, entered into force. Significant influence on media is listed among criteria defining a person as oligarch. According to the law, oligarchs are banned from funding political parties and campaigns and must submit an income e-declaration. In June 2022, the president approved the NSDC decision to create the oligarchs’ register, but it had not been launched by the end of this report’s coverage period.8 According to initial NSDC estimates 86 individuals might qualify as oligarchs.9 Rinat Akhmetov was the first oligarch to announce he would be turning over his group’s media licenses and respective online media, in compliance with the requirement that oligarchs must sell their media assets within six months.10

In mid-December 2022 the parliament adopted the law “On Media,” which entered into force in March 2023 (see B3). The Law defines online media as “media that regularly disseminates digital information in textual, audio, audiovisual, or any other form via internet on its own website, except for media that are classified as audiovisual media.” Bloggers are not considered online media unless they register under the law. The law also covers providers of video sharing platforms, but only includes those that are not registered in EU member states and have either parent or subsidiary companies registered in Ukraine.11 In mid-May 2023, the regulator adopted procedure for registration of online media and publication application templates.12 The measure includes transparency requirements and forbids ownership and funding of media in Ukraine by individuals and legal entities based in Russia.13 Additionally, the law outlines different types of banned content, primarily concerning content that promotes Russian government narratives; outlets can be fined for posting such content, ordered to remove it, and banned if they do not comply.

Press freedom organizations, including the Committee to Protect Journalists, have also criticized the SBU’s efforts to influence journalists covering the Ukrainian military, prevent them from covering certain operations, or withhold accreditation for journalists.14

Since January 2022, foreign technology companies providing services to users in Ukraine, are obliged to pay a 20 percent value added tax if the cost of the services they provide exceeds 1 million hryvnia ($34,600). Companies that fail to pay could be fined 195,000 hryvnia ($6,700).15 Companies, like eBay, Amazon, Facebook, Google, and Netflix announced that they would effectively add the tax to customers’ fees.16 During the first five months of 2023, the state budget of Ukraine received 3.2 billion hryvnia ($87 million) from the tax.17 In 2023, the tax authorities began monitoring to identify the companies that still have not registered as taxpayers, which will be fined.18

Following the Russian military’s 2022 invasion of Ukraine, and to support distance learning, Vodafone Ukraine has offered free broadband services for some communication resources, including video-conferencing services Microsoft Teams, Zoom, Skype, Hangouts, and Google Meet, as well as messengers Viber, Telegram, and WhatsApp, and Google Classroom.19 Similarly, mobile operators and Ukrtelecom continued providing services to subscribers. In addition, Lifecell provided an extra service package free of charge.20

B7 1.00-4.00 pts0-4 pts
Does the online information landscape lack diversity and reliability? 3.003 4.004

Score Change: The score increased from 2 to 3 to reflect increased trust in the media as well as efforts to combat dis- and misinformation.

The online media landscape in Ukraine is generally pluralistic and diverse. However, despite the existence of high-quality journalism published by some Ukrainian online media outlets, the general quality of online publications remains low, due in large part to politicization of the media sector (see B5 and B6). Although many television news channels have online presences, most are owned by oligarchs. And, while social media has been beneficial to the growth of independent media outlets, it has also facilitated the spread of Russian disinformation.1 However, a December 2022 survey conducted by the Kyiv International Institute of Sociology found that trust in the Ukrainian media increased from 32 percent to 57 percent over the past year.2

After Russia began its invasion, several companies owned by oligarchs quickly mobilized to communicate support for Ukraine. Additionally, the four largest Ukrainian media groups, which are oligarch-owned, issued a joint statement on how they planned to provide open access to news and other content while the country was under martial law.3

Following the invasion, online media took a pro-Ukrainian position, including some outlets that had been heavily criticized before over their pro-Russian editorial stance. Telegram channels remain one of the main sources of updates on the war across the country (see B5).4 Some channels sharing Russian propaganda narratives have lost Ukrainian subscribers, while some independent Ukrainian media channels experienced a significant increase in readers.5

The invasion created difficulties for independent media. Many outlets face financial struggles, and even major outlets have had to reduce salaries, shift to remote modes of work, ask for donations, and launch crowdfunding campaigns. Journalists must also contend with threats to their physical security (see C7) and psychological distress. In some cases, news outlets were unable to continue operations under occupation and journalists evacuated. Nevertheless, local media play a critical role in documenting the Russian military’s war crimes6 and delivering news to people living in cities under Russian occupation, even as disrupted internet connectivity has made this coverage difficult.7 To avoid broadcasting Russian propaganda, some local media outlets in cities under Russian siege closed their operations.

In 2022, Ukrainian journalists received a special citation from the Pulitzer Board “for their courage, endurance, and commitment to truthful reporting” during the war.8

Journalists, politicians, and activists use social media, particularly Facebook and Telegram, ubiquitously, which facilitates pluralism online. Russian social media platforms remain available through VPN and via some ISPs that did not comply with sanctions orders, but their use among Ukrainians is low. As of March 2023, only 8.42 percent of Ukrainians were using Yandex9 and 2.05 percent were using VK, both of which are blocked in the country (see B1), according to Statcounter.10

According to a February 2023 study by the independent research organization Rating Group, social media platforms have become the main source of news for many Ukrainians, with messengers gaining momentum during the war. Thus, reliance on news in Viber groups and Telegram channels increased from 11 to 41 percent in 2022. Similarly, YouTube became a source of news for 29 percent of Ukrainians, demonstrating 8 percent growth from the previous year. News consumption on Facebook, Twitter, and Instagram remained at the same level of 35 percent.11

Several Ukrainian groups work to identify content manipulation (see B5), such as TrollessUA, which identifies and flags suspicious accounts on Facebook,12 and the Feykogryz project, which is designed to identify disinformation, misinformation, and propaganda.13 Following the full-scale Russian invasion, the independent analytical platform VoxUkraine launched a “Propaganda Diary,” which logs Russian propaganda in Italian and German media, identifying those countries as among those intensively targeted by Russian disinformation.14 Ukrainian Radio has also launched an “anti-fake program” to debunk Russian disinformation.15 #DisinfoChronicle, started by the online portal Detector Media, collects and documents disinformation about the Russian invasion in real time.16 Many Ukrainian media outlets also focus efforts on uncovering Russian mis- and disinformation related to the war. In 2022, Meta provided Ukrainian fact-checking partners StopFake and Vox with emergency funding to support their teams’ safety and sustain their work during war time.17

During the coverage period, for the first time since 2016, Ukraine dropped out of the top 10 list of countries in which users access Tor daily through relays.18 Apple's new “private relay” encryption feature available on iOS 15 reportedly allows users to access to Russian websites blocked in Ukraine.19

In 2022, the Law on Ensuring the Functioning of Ukrainian as the State Language took effect.20 It stipulates that a variety of online media use Ukrainian as the default language, with some exceptions for religious material, private communications, and media in Indigenous languages.21 In September 2022, the language ombudsman reported that 7 of 50 monitored online media outlets had violated the law, meaning that they could face fines.22

B8 1.00-6.00 pts0-6 pts
Do conditions impede users’ ability to mobilize, form communities, and campaign, particularly on political and social issues? 5.005 6.006

The Ukrainian social media sphere is an important space for debate about politics, reforms, and civil society. Online messengers continue to gain momentum, with Viber, Facebook Messenger, and Telegram among the most popular, followed by WhatsApp.1 Telegram channels continue to grow rapidly and are largely focused on political issues.2 However, in territories occupied by the Russian military, authorities prohibit public officials from using Viber, WhatsApp, and Telegram connected to Ukrainian mobile numbers, while forcing them to register email addresses in the .ru domain.3

Ukrainians and Ukrainian government officials actively use e-petitions and online resources to publicize their activities and advocate for social and political issues. Officials regularly engage with users. An online platform called LetMyPeopleGo4 offers regular information about Ukrainian citizens held captive or being prosecuted by Russian-backed forces, and campaigns for their release. Since 2014, investigative journalists and activists have worked to maintain a digital database of officials’ tax declarations.5

During the coverage period, Ukrainian, Georgian, and American volunteers launched a global initiative titled #SuspendKremlin urging major social media platforms to ban Russian government officials from their platforms, in an effort to combat the spread of Russian state-sponsored disinformation.6 Another team of volunteers created a dedicated website called Post to Stop War, which showcases key messages about the invasion in over 30 languages to audiences abroad. (For example, messages may explain the invasion’s illegality, or draw parallels with local injustices or crimes, to shore up international support for Ukraine).7 Moreover, Ukrainians used buy-and-sell groups on the sanctioned VKontakte platform to inform Russian users about the Russian military’s looting in Ukrainian towns.8 Ukrainian media and sectoral ministries have also conducted fundraising telethons.9 The Ministry of Culture and Information Policy, in cooperation with partners, presented “Ukraine Now and Forever,” a campaign celebrating Ukrainian cultural history and encouraging sanctions targeting Russia.10 Multiple online fundraising campaigns run by volunteers across the country have helped to collect funds to provide ammunition and equipment to Ukrainian soldiers.11 Ukrainians have been actively used hashtags on social media to draw attention to the war and its consequences (e.g. #saveukraine, #stopwar, #peaceforukraine, and #russiaisaterroriststate).12 Dedicated online campaigns have been launched to collect evidence of Russian war crimes in Ukraine13 and to track the damage inflicted by the Russian military.14 In May 2022, President Zelenskyy launched UNITED24, billed as “the official fundraising platform” to help Ukraine,15 which had raised $325 million by May 2023.16

Marginalized and underrepresented groups actively use online platforms to advocate for their rights. Povaha, an online platform launched in 2016, seeks to combat sexism in the media through advocacy campaigns and the creation of a database of women experts.17 LGBT+ people in Ukraine regularly use social media tools to organize offline events, such as Kyiv Pride. However, they sometimes face resistance, also organized online, by far-right groups.18

C Violations of User Rights

C1 1.00-6.00 pts0-6 pts
Do the constitution or other laws fail to protect rights such as freedom of expression, access to information, and press freedom, including on the internet, and are they enforced by a judiciary that lacks independence? 3.003 6.006

The right to free speech is granted to all citizens of Ukraine under Article 34 of the constitution, but the state can restrict this right in the interests of national security or public order, and it is sometimes restricted in practice. Article 15 of the constitution prohibits censorship.1 Despite some reforms, Ukrainian courts still feature corruption and political interference, which at times undermines their ability to uphold fundamental rights.2

Following the Russian regime’s invasion of Ukraine in February 2022, the Ukrainian government imposed martial law, which, according to the constitution, enables the government to restrict some rights, including the right to freedom of expression.3 Specifically, martial law gives the government the right to “control the media,” prohibits “public demonstrations and other mass gatherings,” and transforms civilian authorities into military administrations.4

Serious crimes against journalists often go unsolved (see C7).

C2 1.00-4.00 pts0-4 pts
Are there laws that assign criminal penalties or civil liability for online activities, particularly those that are protected under international human rights standards? 2.002 4.004

Some laws criminalize online activities, while others do not explicitly criminalize them, but have been used to penalize individuals for their online activities. The criminal code penalizes extremism, separatism, and terrorism, including through online activities. Article 109(2) of the criminal code prescribes prison sentences of three to five years for public calls to violently overthrow the constitutional order. Article 110 criminalizes public calls for the infringement of Ukraine’s territorial integrity, including those made online, with a maximum penalty of five years in prison. Article 161 prohibits “inciting national, racial, or religious enmity and hatred” and assigns a maximum penalty of five years in prison.1 Neither defamation nor insult are criminally penalized.2

In March 2022, following the Russian military’s full-scale invasion of Ukraine, the parliament adopted amendments to the Law on Political Parties and the Law on Civic Associations. The amendments allowed courts to ban political parties, and prohibited the creation of civic associations that undertake actions or aim to liquidate the independence of Ukraine, make violent attempts to change constitutional order, undermine sovereignty and territorial integrity, disseminate war propaganda, propagate communist or Nazi totalitarian regimes and their symbols, or disseminate information containing justification, legitimization, or denial of the armed aggression of the Russian Federation against Ukraine. In the same month, the parliament adopted amendments to the criminal code specifying punishments for justification, legitimization, or denial of the armed aggression of the Russian Federation against Ukraine launched in 2014, including by calling it internal civil conflict, as well as of temporary occupation of some parts of Ukraine’s territory.3 Under Article 436-2, which criminalizes justification, recognition as legitimate, or denial of the armed aggression of the Russian Federation against Ukraine violators can face up to eight years in prison if the offenses are committed on mass media or by a public official.

In the same month, the parliament criminalized collaborationism with the Russian government under article 111 of the criminal code in the form of public denial of the armed aggression against Ukraine; supporting the occupation of Ukrainian territory; or public calls by a citizen of Ukraine for cooperation with the aggressor state, its armed formations, or occupation administrations. The law, which applies to online speech, also criminalized denying Ukrainian sovereignty over the occupied territories‎. Individuals found guilty can be deprived of the right to hold certain positions or engage in certain activities for a period of 10 to 15 years. Certain non-speech related offenses under the amendments carry heavier punishments.4

A December 2022 coalition of Ukrainian civil society organizations criticized the breadth and vagueness of some of the measures included in the amendments.5

In June 2022, the president signed a revised draft law prohibiting “propaganda of the Russian neo-Nazi totalitarian regime and the act of aggression against Ukraine.” Among other things, the law envisages a ban on the usage of symbols associated with the Russian military invasion in Ukraine, including in online advertising and social media publications. However, there are a few exemptions when such usage is considered legal, including media reporting on false narratives, publications condemning the Russian regime, museum exhibitions, research activities, and school textbooks.6

Article 173-1 of the code of administrative offenses prescribes fines for spreading false rumors that sow panic; the law was periodically invoked during the COVID-19 pandemic.7 Since January 2019, the code of administrative offenses penalizes bullying, including via electronic communication, punishable by fines or community service. Individuals who fail to report bullying can also be penalized.8

  • 1“Criminal Code of Ukraine (2001, Amended 2016),” Legislationline, Organization for Security and Co-operation in Europe, http://www.legislationline.org/documents/section/criminal-codes/country….
  • 2“Defamation and Insult Laws in the OSCE Region: A Comparative Study,” OSCE Representative on Freedom on the Media. March 2017, https://www.osce.org/fom/303181?download=true.
  • 3“Закон про внесення змін до деяких законодавчих актів України (щодо заборони виготовлення та поширення інформаційної продукції, спрямованої на пропагування дій держави-агресора) [Law on Amendments to Certain Legislative Acts of Ukraine (on Prohibition of Production and Distribution of Information Products Aimed at Promoting the Actions of the Aggressor State)],” Official Website of Verkhovna Rada of Ukraine, March 31, 2022, https://zakon.rada.gov.ua/laws/show/2109-IX#Text; “Закон про внесення змін до деяких законодавчих актів України (щодо посилення кримінальної відповідальності за виготовлення та поширення забороненої інформаційної продукції) [Law on Amendments to Certain Legislative Acts of Ukraine (Regarding Strengthening Criminal Liability for Production and Distribution of Prohibited Information Products)],” Official Website of Verkhovna Rada of Ukraine, March 3, 2022, https://zakon.rada.gov.ua/laws/show/2110-IX#Text.
  • 4Закон України “Про внесення змін до деяких законодавчих актів України щодо встановлення кримінальної відповідальності за колабораційну діяльність” [Law of Ukraine on Amendments to Certain Legislative Acts of Ukraine Concerning the Establishment of Criminal Liability for Collaborative Activities], Official Website of Verkhovna Rada of Ukraine, March 3, 2022 https://zakon.rada.gov.ua/laws/show/2108-IX#top.
  • 5Human Rights Centre ZMINA, Civil Holding, GROUP OF INFLUENCE, NGO, Donbas SOS, Crimea SOS, VostokSOS, Stabilization Support Services, and Crimean Human Rights Group ”CRIMINAL LIABILITY FOR COLLABORATIONISM: analysis of current legislation, practice of its application, and proposals for amendments,” December 2022, https://zmina.ua/en/publication-en/criminal-liability-for-collaboration….
  • 6“Пропозиції Президента до Закону "Про заборону пропаганди російського нацистського тоталітарного режиму, збройної агресії Російської Федерації як держави-терориста проти України, символіки воєнного вторгнення російського нацистського тоталітарного режиму в Україну" [Proposals of the President to the Law "On Prohibition of Propaganda of the Russian Nazi Totalitarian Regime, Armed Aggression of the Russian Federation as a Terrorist State Against Ukraine, Symbols of the Military Invasion of the Russian Nazi Totalitarian Regime in Ukraine"],” Official Website of Verkhovna Rada of Ukraine, May 22, 2022, http://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=73937.
  • 7“Code of Ukraine on Administrative Offense,” Official Website of the Verkhovna Rada of Ukraine, March 20, 2023, https://web.archive.org/web/20230318104402/https://zakon.rada.gov.ua/la….
  • 8“На Хмельниччині школяра засудили за булінг учителя [In Khmelnytskyy region pupil was charged for bullying teacher],” Zmina, March 5, 2019, https://zmina.info/news/na_khmelnichchini_shkoljiara_zasudili_za_buling… .
C3 1.00-6.00 pts0-6 pts
Are individuals penalized for online activities, particularly those that are protected under international human rights standards? 3.003 6.006

Since the start of the Russian military’s full-scale invasion of Ukraine, several individuals have been charged under criminal code articles 109, which criminalizes actions aimed at the violent change or overthrow of the constitutional order or at the seizure of state power; 110, which prohibits public calls for the infringement of Ukraine’s territorial integrity; 111-1, which criminalizes collaborationism or high treason; and 436-2, which criminalizes justification, recognition as legitimate, or denial of the armed aggression of the Russian Federation against Ukraine. As of March 20, 2023, 1,609 criminal proceedings were opened; 745 individuals were prosecuted; and 663 criminal proceedings were sent to court, including 7 proceedings in absentia, under Article 436-2 of the Criminal Code, which came into effect in March 2022 (see C2).1 In some cases, courts have found that guilty individuals received material support from Russian agents.

The SBU has frequently invoked criminal code Articles 109 and 110 against alleged Russian agents for various forms of speech online.2 In 2022, 1,200 such criminal proceedings were opened, and various imprisonment terms were handed down to 230 individuals for spreading anti-Ukrainian propaganda (see C2).3

In May 2023, two men in Cherkasy and Vinnytsia were sentenced to five-and-a-half years and five years in prison, respectively, under Article 436-2 for social media posts supporting the Russian military.4 In the same month, the Krasnograd District Court in Kharkiv sentenced a man, who was paid by a Russian agent to create a website spreading propaganda, to five years in prison under articles 436-2 and 110 of the criminal code.5

In March 2023, the SBU arrested a blogger who was accused of spreading pro-Kremlin disinformation and had allegedly organized protests in support of the Kremlin in Kyiv-Pechersk Lavra. On his YouTube channel, which had 23,000 subscribers, he routinely gave speeches blaming the Ukrainian government for the war. He faces a maximum of eight years in prison under Article 436-2.6

In April 2023, the SBU charged three individuals in Bucha, Kyiv, and Odesa, who had supported the Wagner Group and called for the overthrow of the Ukrainian government, under articles 109 and 436-2 of the criminal code. The woman who was detained in Kyiv allegedly ran a network of bots that propagated Russian propaganda, mainly targeting the European Union.7

In April 2023, the SBU charged a man allegedly working for oligarch Viktor Medvedchuk, who was sent to Russia in a September 2022 prisoner exchange, with treason under Article 111 of the Criminal Code. The SBU claimed he worked for the Russian outlet Newsfront to spread false information about the Ukrainian government and the war.8

In March 2023, a court in Kovel sentenced Yury Yefimets to four months in prison because he “liked” videos of Russian military attacks against the Ukrainian army.9

In March 2023, a court in Ivano-Frankivsk sentenced the administrator of the “Kherson Republic” Telegram channel, which echoed Russian propaganda calling for the overthrow of the Ukrainian government and support for occupying authorities, to six years in prison under the same charges.10

In June 2022, a court in the city of Cherkasy convicted a woman guilty of insulting the honor and dignity of a military officer in Facebook comments, and sentenced her to three years’ imprisonment, though she was subsequently exempted from serving the sentence and instead given two years probation.11

In the same month, another Cherkasy resident was sentenced to four years’ imprisonment with a three-year probation period for publicly calling for the violent overthrow the Ukrainian government and justifying Russian armed aggression in a TikTok video.12 In other cases, individuals were arrested for social media posts allegedly discrediting the Ukrainian Armed Forces, praising the Kremlin, justifying air strikes on Ukrainian cities, and calling for the overthrow of the Ukrainian government.13

In March 2022, the Halytskyi District Court ordered the detention of another pro-Russian blogger, Glib Lyashenko.14 He was charged with treason in relation to appearances in pro-Russian media, and faces a possible 10 to 15 years in prison.15 As of March 2023, the investigation was still ongoing.16

In late 2020, the SBU charged politician and pro-Kremlin blogger Anatoliy Shariy under Articles 111 and 161 (infringing upon citizens’ equality) of the criminal code for posting a map of Ukraine on his YouTube channel that excluded the occupied territories of Crimea and Donbas. The SBU put Shariy—who lives in Spain, where he had received asylum—on its wanted list.17 In May 2022, Spanish authorities detained Shariy,18 and later released him to house arrest pending extradition.19 Reportedly, in October 2022, the Spanish court closed the case after Ukrainian official failed for a second time to file extradition paperwork.20 In July 2023, after the coverage period, the SBU charged him with high treason once again, claiming he had instructed Russia’s FSB on media production.21

In May 2020, blogger Serhiy Poyarkov was indicted under Article 346 of the criminal code (penalizing among other things “threats of murder, impairment of health, destruction, or impairment of property, kidnapping, or confinement made in respect of the president of Ukraine”) for allegedly threatening President Zelenskyy in a YouTube video uploaded in October 2019. Poyarkov claims the video was a parody. The charge carries a maximum sentence of five years in prison, and the case was still pending at the end of the coverage period.22

In the occupied city of Berdyansk in the Zaporizhzhia region, the Russian occupying authorities announced random checks of Ukrainian citizens’ mobile phones with the aim to identify whether they follow “propagandistic resources” of the Kyiv regime.” If “found guilty,” a person first gets a warning, which then can be followed by fine and criminal liability according to Russian laws.23

C4 1.00-4.00 pts0-4 pts
Does the government place restrictions on anonymous communication or encryption? 3.003 4.004

Score Change: The score declined from 4 to 3 because Russian occupying authorities restricted access to VPN services on temporarily occupied territories of Ukraine and compelled public officials in Kherson to register emails in the .ru domain.

There is no obligatory registration for internet users or prepaid mobile device subscribers. Users can purchase prepaid SIM cards anonymously and may comment anonymously on many websites. The Law on Electronic Communications (see A3 and C6), which came into force in January 2022, preserves the right to use communication services anonymously.

There are no restrictions related to encryption tools in government-controlled territory, though the commercial provision of these tools is subject to licensing.1 VPNs are widely used in Ukraine.

However, in Kherson, one of the territories temporarily occupied by the Russian military during the coverage period, which had its internet rerouted through Russian providers (see A3), users reportedly experienced issues accessing several VPNs.2 The occupying authorities also prohibited residents from using Ukrainian mobile numbers and forced employees of public institutions to register email addresses in .ru domain.3

C5 1.00-6.00 pts0-6 pts
Does state surveillance of internet activities infringe on users’ right to privacy? 3.003 6.006

Little information about surveillance or communications interception in Ukraine is publicly available. There is a lack of comprehensive legislation to protect privacy and prevent abuse of surveillance powers. The SBU and police can initiate criminal investigations and use wiretapping devices on communication technologies, but existing legislation, such as the Law on Operative Investigative Activity,1 does not specify the circumstances that justify these measures or set limits on the time frame or scope of their implementation.

Previous governments had purchased equipment compliant with the Russian-designed System for Operational Investigative Measures (SORM) surveillance architecture.2 Some analysts believe that Ukrainian law enforcement and intelligence services currently make use of an analogous architecture, requiring operators to install equipment that facilitates the lawful interception of user data.3

Deep packet inspection (DPI) technology can be used to filter internet traffic and surveil users. Authorities have repeatedly tried to oblige providers to install DPI for these purposes, but their efforts have been unsuccessful. Mobile operators Kyivstar and Vodafone use DPI systems, ostensibly to allocate resources more effectively, analyze subscribers’ preferences, and enhance targeted advertisements. Kyivstar claims its system handles depersonalized data. The operator Lifecell has not disclosed whether it has a DPI system.4

C6 1.00-6.00 pts0-6 pts
Does monitoring and collection of user data by service providers and other technology companies infringe on users’ right to privacy? 3.003 6.006

Previously, ISPs were not legally required to aid the government in monitoring the communications of their users in the absence of a court order, but recent laws on Electronic Communications and Intelligence have provided the government with ways to circumvent a court order.

The Law on Electronic Communications, which entered into force in January 2022, obliges providers of electronic communication services to retain users’ personal data, location data, and data-transfer routes. This data can be shared with the government only when the law is violated and when an investigating judge or court has issued a request. The law stipulates that electronic communications services must give the state the technical ability to access communications; the state may do so autonomously. The law also envisages that operators must ensure the integrity of their subscribers’ data, which can only be disclosed after subscribers have given explicit consent or if they have violated the law.1 In March 2022, the parliament amended the law to allow prosecutors, along with courts and investigative judges, to gain access to subscribers’ information and metadata.2

In October 2020, the Law on Intelligence came into effect, which enables the intelligence authorities to autonomously intercept information from telecommunications networks. According to the law, interception can begin up to 72 hours before a court order is issued. Moreover, court orders (both approving and denying interception) are not subject to being recorded in a unified register. Civil society claims that the law was adopted without proper public consultation and contains significant contradictions to the country’s constitution and the European Convention on Human Rights.3

  • 1Закон України “Про електронні комунікації” [Law on Electronic Communications],” Official Website of the Verkhovna Rada of Ukraine, https://zakon.rada.gov.ua/laws/show/1089-20#top.
  • 2“Закон України “Про внесення змін до Кримінального процесуального кодексу України та Закону України "Про електронні комунікації" щодо підвищення ефективності досудового розслідування "за гарячими слідами" та протидії кібератакам [Law of Ukraine “On Amendments to the Criminal Procedure Code of Ukraine and the Law of Ukraine "On Electronic Communications" to increase the efficiency of pre-trial investigation "in hot pursuit" and counter cyberattacks],” Official Website of Verkhovna Rada of Ukraine, March 15, 20222, https://zakon.rada.gov.ua/laws/show/2137-%D0%86%D0%A5#top.
  • 3“Громадянське суспільство вимагає накласти право вето та повернути на повторний розгляд до Верховної Ради України Закон “Про розвідку” [Civil society demands to veto and return Law on Intelligence to Verkhovna Rada of Ukraine for reconsideration],” Anti-CorruptionResearch and Education Centre, https://acrec.org.ua/news/hromadians-ke-suspil-stvo-vymahaie-naklasty-p….
C7 1.00-5.00 pts0-5 pts
Are individuals subject to extralegal intimidation or physical violence by state authorities or any other actor in relation to their online activities? 1.001 5.005

Following the full-scale Russian invasion, journalists in Ukraine have faced extreme danger due to Russian attacks while conducting their work. According to rights experts at the United Nations, journalists have been “targeted, tortured, kidnapped, attacked, and killed, or refused safe passage”1 from cities and regions under Russian siege. As of July 2023, at least 14 journalists had been killed by Russian forces while covering the war or because of their status, and at least 26 had been injured, according to the Council of Europe’s Safety of Journalists platform.2 Reporters Without Borders (RSF) filed eight war crimes complaints with the International Criminal Court and Ukraine’s prosecutor general covering 53 total acts of violence and abuse involving 121 journalists by May 2023.3 From February 2022 until end of May 2023, the Institute of Mass Information (IMI) had recorded 514 crimes against journalists and media in Ukraine committed by Russian forces.4

In 2022, the IMI recorded 567 “violations of freedom of speech,” out of which 470 were attributed to Russia. The number of violations committed by Ukrainian private and public actors dropped more than twofold compared to 2020 and 2021, with majority of the recorded violations (74 out of 97) involving obstruction of legitimate journalistic activity, restriction of access to public information and cybercrimes including journalists who work both in offline and online media.5 Additionally, in 2022, the national police documented 23 cases of threats or violence against journalists and one case of assault on journalist’s life.6 In 2022, the courts rendered decisions in five cases involving violations of journalists’ rights, twice lower number than in previous year. All decisions were related to violations that occurred prior to Russian invasion.7

Human rights groups have reported that Russian soldiers have forced Ukrainians in occupied cities and towns to turn over their cell phones, and have killed people who refused to comply.8

In July 2020, the prosecutor general filed charges against Vladislav Manger and Oleksiy Levin, two officials from Kherson, of ordering the 2019 murder of journalist Katernya Handziuk. Handziuk, who used social media platforms and the local citizen journalism website MOST to expose corruption, died of injuries she sustained in an acid attack in 2018. In April 2020, the prosecutor general and the SSU announced that the much-delayed investigation into her murder, which had seen five people jailed for carrying out the acid attack9 was complete.10 However, human rights advocates questioned the timing of the decision, claiming that the authorities had sent the case to court prematurely. 11 At the end of the coverage period, the case against Manger and Levin was still in court.12

Fair and timely investigations of attacks against journalists working online and other internet users are exceptions rather than the rule. In September 2020, the prosecutor general created an interdepartmental working group to coordinate law enforcement agencies’ investigative efforts in criminal proceedings of these cases.13

Investigations and prosecutions for the 2016 murder of Pavel Sheremet, a journalist with the online newspaper Ukrainska Pravda, have been characterized by delays and mismanagement.14 In September 2021, the judge leading Sheremet’s case was found dead.15 Court hearings were suspended amid the full-scale Russian invasion.16

Nonphysical acts of harassment and doxing remain a problem.17

The intimidation of marginalized groups online is common. LGBT+ individuals frequently face online harassment.18

C8 1.00-3.00 pts0-3 pts
Are websites, governmental and private entities, service providers, or individual users subject to widespread hacking and other forms of cyberattack? 1.001 3.003

Cyberattacks, including distributed denial of service (DDoS) attacks, from Russian-aligned actors intensified significantly during Kremlin’s full-scale invasion of Ukraine, though Ukrainian government agencies have worked to mitigate the impact of these attacks. While online media outlets, journalists, and human rights defenders, are frequently subject to cyberattacks, there is no indication that the Ukrainian state is involved in these attacks. Detailed monthly analysis of cyberattacks against Ukrainian media, state institutions, and organizations has been jointly compiled by the SSSCIP and the Economic Security Council of Ukraine.1

In 2022, the SBU reported that it had neutralized over 4,500 cyberattacks on public authorities’ databases and informational resources, military facilities, and objects of critical infrastructure. Cyberattacks originating from Russia increased more than twofold compared to the previous year with an average of 10 cyberattacks per day.2 The IMI and RSF also identified 42 cyberattacks against media in 2022.3 In 2022, the Computer Emergency Response Team of Ukraine (CERT-UA) registered 2,194 cyber incidents and mitigated 1,148 “critical high-level incidents.”4 During the second half of 2022, Russian hackers shifted their focus from the media and telecom sectors to the energy sector, which was also more heavily targeted by missile strikes beginning in October 2022, according to the SSSCIP. In the energy sector, CERT-UA processed 84 critical cyber incidents from the beginning of the full-scale invasion up until mid-December 2022.5

In 2022, Ukraine became the leader in “wiper attacks,” experiencing at least 30 attacks intended to delete or destroy data on the targeted systems, though most of them were neutralized, according to Microsoft. Around 55 percent of these attacks targeted critical infrastructure: organizations providing energy, transportation, or water supply; law enforcement; emergency services; and health care services.6 An ESET Research report noted Ukraine experienced more types of wiper attacks in a yearlong period than it had ever observed in any other country. The wiper attacks are primarily attributed to advanced threat group Sandworm, which is affiliated with Russian intelligence services.7 In September 2022, CERT-UA identified a Sandworm domain mimicking Ukrainian telecom providers, which reportedly aimed to target these providers.8 In October, Microsoft detected the CaddyWiper malware in the critical infrastructure of the Mykolaiv and Kyiv regions, while Prestige ransomware was identified in the information system of Ukrainian and Polish logistics and transport companies.9 In January 2023, CERT-UA reported a wiper attack on Ukrinform, the national news agency .10

The SSSCIP report for 2022 noted that 3 in 10 operations were focused on destroying online resources, while the majority of the remaining attacks concern sophisticated spear-phishing campaigns aiming to extract data or conduct cyber espionage, particularly against the energy, defense, telecom, and financial sectors, as well as government institutions that oversee these sectors.11 Google estimated in 2023 that Russian hackers attacked users in Ukraine more than in any other country, with a 250 percent increase in phishing campaigns compared to 2020.12 In February 2023, CERT-UA reported a new phishing campaign addressed to Ukrainian government officials, which tried to dupe them into downloading “antivirus software,” which would actually compromise their devices.13

According to another report from Trellix, the number of phishing attacks increased twentyfold in November and December 2022, with most attacks targeting email addresses used by government and military agencies. The Russian state sponsored Gamaredon hacking group is reportedly behind the “large majority of” these attacks. In September 2022, Google's incident response group Mandiant detected a new wave of attacks against Ukrainian users, with hackers, allegedly linked to the Russian hacking group Turla, using a 2013-version of Andromeda malware.14 Another wave of phishing attacks was directed toward individuals and civil servants who received compromised emails allegedly on behalf of various institutions, including the NSDC15 , the State Emergency Service,16 CERT-UA,17 the State Service of Special Communications and Information Protection,18 Ukrtelecom,19 courts,20 and other institutions. In December 2022, a similar attack targeted users of the Delta military system.21

Russian-aligned actors have also hacked state and local authorities’ websites to modify their content22 or mimic the legitimate official resources, such as those of the Ministry of Foreign Affairs and the Security Service of Ukraine.23

In July 2022, Google released a report that demonstrated how Russian-government affiliated hackers had released an application targeted to Ukrainian audiences, CyberAzov, that advertised itself as a tool to launch distributed denial-of-service (DDoS) attacks on Russian websites, but actually installed malware on users’ devices.24

In June 2022, Victor Zhora, the head of Ukraine's State Special Communications Service, reported that Ukrainian government officials’ phones had been targeted with malware since the beginning of the invasion.25

On Ukraine

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Country Facts

  • Global Freedom Score

    50 100 partly free

  • Internet Freedom Score

    59 100 partly free

  • Freedom in the World Status

    Partly Free

  • Networks Restricted

    No

  • Websites Blocked

    Yes

  • Pro-government Commentators

    No

  • Users Arrested

    Yes