Expanding Freedom and Democracy
Freedom on the Net 2022

Ukraine

Partly Free
59
100
A Obstacles to Access 18 25
B Limits on Content 21 35
C Violations of User Rights 20 40
Last Year's Score & Status
62 100 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 Russian military's full-scale invasion of Ukraine in February 2022 undermined internet freedom in the country. Ukraine’s internet infrastructure sustained severe damage during the invasion, though the government, telecoms operators, and internet service providers invested significant resources to keep users online, often working cooperatively. However, in some occupied cities, the Russian military rerouted online connections through Russian networks, subjecting users to content restrictions in place in Russia. Though independent media outlets became increasingly popular during the war, journalists covering the war faced serious danger when reporting. Meanwhile, aggressive disinformation campaigns, primarily originating from Russia or linked to Russian actors, sought to mislead users, including campaigns intended to falsely portray Ukrainian officials as supporting the full-scale invasion. In response to the invasion, the Ukrainian government instituted martial law, which places limits on freedom of expression. Government websites and media outlets were the frequent target of cyberattacks, often from Kremlin-linked actors, that started in the days before the invasion and persisted through the end of the coverage period. The Ukrainian government, however, has managed to defend itself against a number of significant cyberattacks.

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, attacks against journalists, activists, and members of minority groups. However, government initiatives to solve these problems sometimes suffer from a lack of political will and have experienced setbacks. 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 index, 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 has also 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, 2021 - May 31, 2022

  • During the full-scale Russian invasion, which was launched in February 2022, the Russian military significantly damaged telecommunications infrastructure in areas across Ukraine (see A1).
  • Starting in April 2022, the Russian military disrupted internet access as it rerouted internet connections in Kherson, an occupied southern city, through Russian networks. This prevented users there from accessing websites that are blocked in Russia, including Ukrainian news sites, Instagram, and Facebook (see A3).
  • Since the lead-up to invasion, Russian and Belarusian government-linked actors have targeted Ukraine with disinformation campaigns and covert influence operations (see B5).
  • In response to the invasion, the Ukrainian government implemented martial law, which places limits on free expression (see B4 and C1).
  • Independent Ukrainian online media outlets have witnessed an increase in their popularity since the Russian invasion, both in government-controlled territories and in areas under Russian occupation or siege (see B7).
  • Ukrainian journalists have faced severe physical danger when conducting their work since the start of the Russian military invasion (see C7).
  • The number and gravity of cyberattacks on Ukrainian government websites and media outlets significantly increased during the coverage period. However, the Ukrainian government has managed to thwart some large-scale attacks (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

Score Change: The score declined from 5 to 4 because of extensive damage that the Russian military inflicted on internet infrastructure.

Fourth-generation (4G) technology for mobile networks continued to expand to new areas during the coverage period, but the Russian military damaged internet infrastructure during the invasion, interrupting internet access for many.

According to the latest data from the International Telecommunication Union (ITU), as of 2020, Ukraine’s internet penetration rate was 75 percent, and in 2021, the fixed broadband penetration rate reached 18.3 percent and the mobile broadband penetration rate 80.1 percent.1 In 2021, the number of mobile internet users in Ukraine amounted to an estimated 26.4 million.2 Internet availability and ease of access vary by region.

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 has become selectively available on public transport, including high-speed trains and, most recently, airplanes.3

According to estimates from the market and consumer data company Statista, smartphone ownership reached 61 percent in 2021.4 In its 2021 mobile connectivity index, the Global System for Mobile Communications Association (GSMA) assigned Ukraine 72.6 points out of 100 for overall mobile internet adoption, and 65.6 for infrastructure, with Ukraine’s overall scores placing it in the same range as Mexico, Malaysia, and Kazakhstan.5 But, mobile internet speeds remain poor. The median mobile download speed in May 2022 was 22.3 megabits per second (Mbps), compared to a global average of 30.4 Mbps, according to the network intelligence company Ookla.6 The median fixed broadband speed was much faster, per Ookla, clocking in at 50.2 Mbps for Ukraine, though that was slower than the global average of 64.7.

The Ukrainian cities and towns that faced Russian attacks in 2022 sustained damage to internet infrastructure and internet outages,7 depriving many people, and particularly those in occupied cities, of reliable internet access and the ability to communicate with the outside world. A number of service providers across the country experienced disruptions during the early days of the invasion,8 and internet blackouts have persisted since then. In March, the Chernobyl and Zaporizhzhia nuclear plants experienced power outages after they were taken by Russian forces, which disconnected them from the internet.9 The Russian military damaged fiber-optic infrastructure when it rerouted internet connection in Kherson through Russian networks in April and May 2022,10 leaving many disconnected (see A3).

According to the State Services for Special Communication and Information Protection (SSSCIP), 20 percent of telecommunications infrastructure in the country was “damaged or destroyed” in the invasion, leaving “tens of thousands of kilometers of fiber networks” out of use.11 UkrTelecom, the country’s largest mobile operator and ISP, reported that more than 30 of its buildings have been destroyed and one hundred other facilities are “badly damaged” due to Russian attacks.12 When Ukrainian forces have retaken territories, reestablishing internet connection has been one of their priorities.13

The Ukrainian government provided alternative connections to regions where infrastructure was damaged in cooperation with the US-based company SpaceX and foreign donors to install over 11,000 emergency satellite Starlink receivers.14 Ukrainian soldiers have reportedly used the SpaceX-operated systems to coordinate military action and stay in touch with their families. President Zelenskyy has also used the Starlink receivers to communicate with the Ukrainian people.15

The government 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.16 Since March 2022, ISPs connected hundreds of bomb shelters to fixed-internet or Wi-Fi facilities and continued to expand their networks daily.17 As of April 2022, Ukrainian mobile service providers have been successfully rebuilding base stations and restoring connection in liberated territories across Ukraine.18 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.19

At the end of March 2022, the ITU agreed to aid Ukraine in rebuilding its telecommunication sphere.20 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.21

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.22 In October 2021, the national regulator established minimum technical requirements to the quality of mobile internet connection to improve 4G nationwide coverage.23

At the end of June 2020, three major mobile operators—Kyivstar, Vodafone, and Lifecell—started 4G long-term evolution (LTE)–900 technology network expansion as a part of a nationwide program to provide 4G technology to 90 percent of the population by 2024.24 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.25 According to the ITU, as of 2020 at least 87 percent of the population were covered by 4G mobile network and 79 percent of households had internet access at home.26

In 2021, ahead of schedule, Kyivstar and Vodafone covered four international highways with high-quality 4G connection.27 In mid-February 2022, the parliament approved a bill that simplifies procedure for deployment of 4G base stations by mobile operators, and halves the time required to obtain the necessary permit.28

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 202229 and then put on hold following the Russian 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. In 2020, the Ministry of Digital Transformation of Ukraine conducted the first-ever nationwide study on fixed-broadband internet penetration. According to the data, 5.75 million people had no access to the internet, and of those, 4.2 million resided in settlements with no fiber-optic internet provider and 1.55 million in villages where access costs were too expensive. Moreover, 17,000 out of 28,000 settlements did not have access to high-speed internet. Sixty-five percent of villages lacked connectivity as of 2020, though the government has launched a plan to provide internet coverage with speeds above 100 Mbps to 95 percent of the rural population (see A1).1

With an average monthly wage of 14,577 hryvnia ($504) as of January 2022,2 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 the National Bank of Ukraine.3 According to 2021 data from the ITU, the average cost of a 5 gigabyte (GB) monthly fixed-broadband subscription was 1.8 percent of gross national income (GNI) per capita, while that of a 2 GB mobile subscription was 1.5 percent of GNI per capita.4 High competition among operators generally keeps internet subscription prices affordable.

Studies have shown that prices for both fixed-broadband5 and mobile-broadband6 subscriptions in Ukraine are among the world’s least expensive. The 2020 Ministry of Digital Transformation of Ukraine study demonstrated that the price of connection to fiber-optic internet varies from 1,200 hryvnias ($41.75) per household in urban areas to 1,300 hryvnias ($45.23) in rural areas. At the same time, 18 percent of the rural population, usually those in remote villages, cannot purchase internet access for less than 2,500 hryvnias ($87), which is 150 percent higher than the average market price.7

Rates of access are low among members of Ukraine’s Roma minority.8

There is a slight gender gap in internet access, with more men (78 percent) than women (73 percent) using the internet, according to 2020 ITU data.9

In September 2021, the Interdepartmental Commission on International Trade introduced a 23.5 percent customs duty on cable imports. This move was heavily criticized, including by the Ministry of Digital Transformation, with detractors claiming it will impede plans for nationwide internet coverage by increasing procurement prices, and ultimately lead to higher internet tariffs shouldered by end users. The commission later waived this decision. However, two major domestic producers of cable challenged the customs duty waiver in the court. The court restored the customs duty at the end of October 2021, but the Ministry of Economy submitted an appeal, which was still pending at the end of this report’s coverage period.10

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

Score Change: The score declined from 5 to 4 to reflect disruptions caused by the Russian military’s efforts to reroute internet traffic in Kherson through Russian networks.

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 15 internet exchange points (IXPs),2 10 of which were operational as of August 2022.3 Ukraine’s largest IXP, UA-IX, allows Ukrainian ISPs to exchange traffic and connect to the global network.

However, during the coverage period 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), were forced by the Russian military to reroute Ukrainian internet traffic through Russian networks in April and May. Russian military attacks have also damaged the internet infrastructure across the country, limiting access to the internet in affected areas (see A1).4 The Russian military had previously taken similar actions in Crimea, which is outside of this report’s scope.5

Cloudflare reported a substantial decrease in traffic in the region between April 30 and May 4, as Russian occupying forces in Kherson attempted to force ISPs to route traffic through the Russian network,6 at times threatening ISP employees at gunpoint.7 A number of users lost access during the period, although some were able to connect to the internet through Russian networks.8 On May 4, internet traffic in Kherson was rerouted through Ukrainian networks and access was restored.9 Then, on May 30, Kherson Telecom users could not access the internet for about an hour, and internet traffic was subsequently rerouted through Miranda Media, a company in Crimea linked to Russian national provider RosTelecom. Additionally, the Russian military restricted access to Ukrainian mobile networks and forced Kherson residents to use Russian SIM cards.10

In June, after this report’s coverage period, users in Kherson were subject to frequent disruptions as other ISPs in the region also began to reroute their connection through Miranda Media. Russian occupying forces seized ISPs’ equipment and then ordered employees of the ISPs to reconfigure the connection, and have also done so by themselves.11 Users in Kherson 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 websites and messaging applications that are not blocked in Russia, including Google, YouTube, and the messaging application Viber.12

UkrTelecom, the largest telecommunications company and ISP in Ukraine, restricted access to parts of its network in response to the Russian invasion. At the end of March, UkrTelecom shut down a swath of its network for 15 hours in response to a hack from a group believed to be backed by the Russian government (see C8). During the invasion, employees of Ukrtelecom also sabotaged their own equipment instead of handing it over to Russian occupying forces, leading to blackouts in the affected areas.13

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,14 when the government may introduce “special rules” concerning “the connection and transmission of information through computer networks.”15 Under martial law, the military is empowered to prohibit “the transmission of information through computer networks.”16 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.17

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 and undergoing gradual development. According to the National Commission for State Regulation of Electronic Communications, Radio Frequency Spectrum and Provision of Postal Services (NCEC), there were 4,218 ISPs in the country in 2021.1 Ukraine reportedly boasts the world’s fourth-least-concentrated internet market. 2

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,3 other telecommunications providers are dependent on leased lines. However, UkrTelecom does not exert pressure or regulatory control over other ISPs. As of July 2021, Kyivstar maintained its leadership in the fixed-broadband market with 15.5 percent of the market share, followed by UkrTelekom (12.1 percent) and Volia (8.5 percent). Other major ISPs in Ukraine include Freenet, Datagroup, Megalink, and Farlep-Invest.4

As of June 2021, Datagroup, Ukraine’s leading national fiber-optic infrastructure and digital services provider, completed purchase of Volia, the country’s leading paid-television and broadband service provider.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, Lifecell (owned by Turkey’s Turkcell), and Vodafone Ukraine, owned by Azerbaijan’s BakCell.6 Though Intertelecom, the country’s fourth mobile operator, was allowed to start deployment of 4G networks in April 2020, three months ahead of its competitors, it failed to pay for the license and subsequently ceased its services altogether in nine regions of Ukraine. By the end of 2021, the company had only 0.2 percent of market share.7

There are no direct barriers to entering the ICT market, but any new business venture faces bureaucratic, legal, and tax hurdles, and may need to navigate pervasive corruption in the business and political spheres. In September 2020, the Global System for Mobile Communications Association (GSMA) and financial services consultant Ernst & Young released a report on mobile taxation in Ukraine revealing that the Ukrainian mobile sector is more heavily taxed than other European markets as a result of multiple regulatory fees and a special pension-fund fee.8 Regional ISPs are usually smaller businesses whose success depends on local political connections, making the market prone to corruption.

In September 2019, the government removed a licensing requirement for telecommunications operators, introducing a simplified notification procedure in its stead.9 However, mobile operators must still license the radio frequencies they use to provide cellular services.

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

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. 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). Unlike its predecessor, the NCEC is a central executive body with a special status. The law that established the new body outlines a more transparent procedure for selecting regulator’s 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 will continue to perform their duties until the end of the term.1

Previously, the president appointed a chair and six NCCIR members for six-year terms by decree and appointees could not serve on the commission more than two terms in a row. In June 2021, with considerable delay, the president appointed five new members, while the sixth one has one more year in office until his term expires.2

A lack of transparency regarding NCCIR appointments has continuously raised concerns in light of widespread corruption in Ukraine’s political system and the lucrative nature of the ICT sector.3 Former president Petro Poroshenko was criticized for reappointing current NCCIR chair Oleksandr Zhyvotovskyy before Poroshenko left office 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 building digital skills among Ukrainians.4 Zelenskyy’s administration has also created digital transformation leadership positions in each ministry, regional administration, state company, and state agency.5 Moreover, when the Law on Electronic Communications entered into force in January 2022, the Ministry of Digital Transformation assumed powers from the State Service of Special Communication and Information Protection (SSSCIP) related to shaping policy in the field of electronic communications and radio frequency spectrum. The transition period will last through June 2022.6

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. This practice expanded during the coverage period, particularly after the Russian regime launched a full-scale invasion of Ukraine in February 2022. Sanctions implemented in 2017 against several Russian-owned web platforms—including VKontakte (VK), Odnoklassniki (OK), and Mail.ru—and websites deemed to contain Russian propaganda were extended by President Volodymyr Zelenskyy in May 2020 for another three years, while sanctions against the Russia-affiliated companies Dr. Web, Kaspersky, and Yandex were extended for one year.1 Several Russian media outlets linked with the Russian government were also sanctioned that month, meaning that their websites were to be blocked in Ukraine.

In March 2021, the Ukrainian government imposed sanctions on other popular Russian online media outlets,2 and in May 2021 additional sanctions were leveled against Russian and pro-Russian Crimean media, payment systems (WebMoney, PayMaster, WM Transfer), and information technology companies (Megasoft, Yandex, Kaspersky, Dr. Web, 1C).3

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 disinformation4 or facilitated cyberattacks.5 In total, the NCEC ordered the blocking of more than 48 million 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 during the coverage period.6

The actual implementation of website blocking mandated by the sanctions has been inconsistent,7 disputed in the court,8 and never properly monitored.9 In September 2020, VK informed users about improvements in the mobile app’s proxy, which made it accessible in Ukraine without a virtual private network (VPN).10 As of May 2022, only 6.83 percent of Ukrainians were using Yandex11 and 2.63 percent were using VK.12

The Ukrainian government has also issued sanctions against 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 years in mid-February 2022.15

The authorities occasionally direct ISPs to block websites involved in cybercrime, fraud, illegal gambling, the drug trade, and money laundering. In January 2020, the NCCIR, acting on a court order, directed ISPs to block 59 websites, 8 of which were news aggregators, allegedly involved in criminal activities.16

In the past, courts have also blocked websites as on grounds that hosting particular content allegedly violates intellectual property rights. In February 2021, a court obliged ISPs to restrict access to four Telegram channels on these grounds; however, providers were unable to exercise selective blocking technically.17 In March 2021, another district court in Kyiv ruled similarly against 12 online media outlets, including well-known outlets Glavcom and Apostrophe, citing intellectual property concerns (see B3), after businessman Pavel Babul filed a complaint for their coverage of his Spets Techno Export venture.18 The providers complied with the blocking order, but the court decision was revoked two months later.19 20

In February 2021, a court also ordered the blocking of 426 websites after an individual complaint regarding fraud allegedly committed by these websites.21

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. However, the Ministry of Culture and Information Policy cooperates with the National Security and Defense Council (NSDC) concerning websites that threaten Ukraine’s security.22

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 2021, Facebook took down content in response to four private reports of defamation originating from Ukraine.1 In 2021, Google received 73 requests from the government regarding 309 items. The majority of the requests related to defamation, with a smaller number concerning threats to national security, copyright, or trademark. Google removed 70 (22.7 percent) of the requested items based on legal grounds.2 Between January and December 2021, Twitter received five content-removal requests from the Ukrainian government, but the company did not act on them.3

Social media platforms also removed content in response to the Russian invasion of Ukraine. In May 2022, YouTube announced that it had removed 9,000 channels, including content linked to Russia’s Ministry of Defense and Foreign Affairs. The content violated YouTube’s guidelines, including its “major violent events” policy, which prevents referring to the invasion as a “liberation mission.”4 In February 2022, YouTube restricted access to RT, a Russian-state-controlled television network, and other state-linked channels in Ukraine,5 and other online platforms followed suit. As of April 2022, TikTok had removed 41,191 videos focused on the war, 81 percent of which violated the company’s policy on misinformation.6 In February 2022, Meta announced that it had removed a network of 27 Facebook accounts, two pages, three groups, and four Instagram accounts, for violating the company’s policy against coordinated inauthentic behavior that in this case, operated from Russia and primarily targeted users in Ukraine (see B5).7

Prior to Google and Apple’s decision to remove the RT and Sputnik apps from app stores in the EU, Google had blocked users from downloading RT in Ukraine.8

After evidence of atrocities committed by the Russian military in Bucha emerged in March and April 2022, Meta, the parent company of Instagram and Facebook, inadvertently placed a restriction on the hashtags #bucha and #buchamassacre on both platforms. The move was the result of a filter that automatically blocked the graphic pictures accompanying these hashtags, and the policy was reversed upon discovery.9 In early March, Google temporarily prevented users from writing reviews on Google Maps in Ukraine and removed all reviews written since the war started, amid reports they were being used to provide information about Russian military movements.10

At the end of August 2021, the Ministry of Digital Transformation asked Google to stop recommending Russian pages on the default pages of Ukrainian YouTube and YouTube Music.11

In 2020, the SSU requested that Apple and Google delete the apps of Russian-based legal entities from their app stores.12 While VK and OK remained available for download, a few Russian television channels’ apps (Rossiya-1, Rossiya Television and Radio, Vesti FM, Vesti.ru) were removed from the Ukrainian app store upon SSU request.13

In February 2021, the Embassy of Ukraine to the United States officially requested that Twitter remove the verified account of the Russian Foreign Ministry's office in occupied Crimea, arguing that it is an illegitimate entity, but the company did not comply.14

The SSU periodically forces the removal of content from social media platforms deemed to endanger national security. In several cases, courts have held individuals liable for their online activity, including those who were found guilty of calling for violent change of the state border of Ukraine, violation of territorial integrity of Ukraine, and overthrow of constitutional order, as well as glorification of illegal military units (see C3).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

The criminal code currently mandates the blocking of child sexual abuse imagery,1 but the government’s authority to block other types of 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 When authorities extended the sanctions in May 2020, these inconsistencies were not addressed.

At the end of January 2021, lawmakers introduced to Parliament the first draft of the Law on the Security Service of Ukraine (bill 3196-d) (see C5), which would significantly strengthen the SSU’s powers while simultaneously limiting its oversight. The draft law lists a broad set of justifications for blocking online resources—for example, to prevent an act of terrorism or subversive activity against Ukraine; to counteract special information operations against Ukraine aimed to undermine constitutional order, sovereignty, or territorial integrity; or to aggravate the sociopolitical and socioeconomic situation in the country. However, according to the revised text submitted for the second reading, such blocking can only be introduced temporarily upon court decision. The provision on extrajudicial preventive blocking, which could last up to seven days before a court order is issued, was removed. The proposed bill still provides the SSU the authority to engage ISPs in counterintelligence activities. At the end of the coverage period, the revised draft law was pending second reading in the parliament.3

Despite some improvements to the draft law, civil society groups still objected to its adoption because of insufficient human rights guarantees, the ambiguous website-blocking procedure, and the SSU’s expanded ability to access electronic communications.4 Parliamentarians agreed that the final text requires additional consultations with human rights advocates.5

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.6

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, collaboration, terrorism, and Russia. The 2021 Vibrant Information Barometer by the International Research and Exchanges Board (IREX) claimed that 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, and journalists who disclose sensitive information or conduct investigations may threaten relationships with their neighbors.1

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.2 Such disclosures may also have been prohibited by the implementation of martial law (see C1), which limits the topics journalists can cover.

A January 2020 study focused on television journalists showed that formal and informal directives from editors and employers—who may have political agendas—lead to self-censorship (see B5).3 According to a 2019 study of 127 journalists, 48 percent practiced self-censorship, while 65 percent agreed that the war in eastern Ukraine had increased self-censorship.4

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 invasion.

Paid commenters and trolls have proliferated in Ukraine’s online public sphere. Some investigative reports suggest 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.

Social media platforms (primarily Facebook) have become the main source of news for many Ukrainians, which has driven the increased use of paid commenters and trolls on these platforms for political purposes. At the end of 2020, an advisor to the presidential office disclosed plans to cooperate with bloggers, potentially on a paid basis, to promote government policies and create a positive image of the state.2

Beyond social media manipulation, Ukraine’s online media landscape is highly polarized and frequently distorted. Media outlets tend to promote the political sympathies of their owners.3

Ukraine’s online information landscape is also subject to manipulation by Russian interests, and this significantly intensified due to Kremlin propaganda after Russia launched a large-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.4 For example, the Kremlin made efforts to justify the invasion by claiming that it began after an attack by the Ukrainian military, though open-source research investigators used heat-sensing satellite data to debunk the allegations.5 Russian officials and state affiliated outlets also took to social media to spread the theory that the US government had been developing a bioweapon in “biolabs” across Ukraine. The story was promoted online by Chinese officials6 and some actors on the American far right.7 The SSU has also accused Russian actors of creating Telegram channels that mimic Ukraine government officials’ channels and using them to spread disinformation.8

Fabricated or intentionally misleading information disseminated by actors linked to the Russian government and presenting Kremlin-friendly narratives is regularly circulated in online articles that mainly target Ukrainians in cities occupied by the Russian military.9 After journalists and rights groups publicized evidence of a massacre committed by Russian military forces in Bucha in March 2022, Russian-state affiliated media outlets and accounts on Facebook and Telegram spread disinformation that the Ukrainian Army had perpetrated the attack.10

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.11

According to Meta’s Adversarial Threat Report, published in April 2022 and covering the first quarter of the year, Ukraine was a target of cyberespionage and covert influence operations online by government-linked actors from Russia and Belarus. These activities intensified shortly before the Russian military invasion in February 2022. Meta also reported removal of a network of 31 Facebook and Instagram accounts, two pages, and three groups for violating the company’s policy against coordinated inauthentic behavior; these operated from Belarus and Russia, and primarily targeted users in Ukraine (see B2).12 The report also noted that the Russia-aligned hacking group Ghostwriter, which has also been linked to the Belarusian government,13 had attempted to hack Ukrainian soldiers’ Facebook accounts and post videos of Ukrainian soldiers surrendering, but Meta thwarted the operation (see C8).14

In May 2022, Twitter began placing a “warning” notice on tweets from government officials that spread dis- and misinformation. The company also limited content of over 30 accounts affiliated with the Russian government, disabling options to like or share their posts.15

Several Ukrainian groups work to identify content manipulation, such as TrollessUA, which identifies and flags suspicious accounts on Facebook,16 and the Feykogryz project, which is designed to identify disinformation, misinformation, and propaganda.17 Following Russia’s invasion of Ukraine, the independent analytical platform VoxUkraine launched a “Propaganda Diary” database of Russian propaganda in Italian and German media, identifying those countries as among those intensively targeted by Russian disinformation.18 Ukrainian Radio has also launched an “anti-fake program” to debunk Russian disinformation.19 #DisinfoChronicle, started by online portal Detector Media, collects and documents disinformation about the Russian invasion in real time.20 Many Ukrainian media outlets also focus efforts on uncovering Russian mis- and disinformation related to the war.

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.21 The National Security and Defense Council (NSDC) also has its own Center for Countering Disinformation.22

In 2021, the Security Service of Ukraine (SSU) reported that it shut down 21 bot farms—which together operated over 150,000 bots—for spreading destructive content. Additionally, the SSU banned 137 foreign citizens from entering Ukraine for disseminating “separatist” propaganda online, and blocked 15 networks of internet agitators for disseminating fake news about COVID-19.23

Unverified claims about Russian actions, as well as false information about successes of Ukraine’s armed forces, have been shared by Ukrainian politicians. For example, false information about the “Ghost of Kyiv,” which refers to a Ukrainian fighter pilot who allegedly shot down six Russian airplanes, was referenced by Ukraine’s official government Twitter account,24 former Ukrainian president Petro Poroshenko, and other Ukrainian government officials on Twitter.25 Although there are reports of Russian planes destroyed during combat, there is no evidence to support the notion that these actions can be linked to a single Ukrainian pilot. Fact-checkers found that one of the first viral ”Ghost of Kyiv” videos shared by Ukraine’s official Twitter account was actually a computer rendering of a combat flight simulator posted by a YouTube account with a small following.26

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 registration requirements for online media, and the government does not limit the ability of such outlets to accept advertising or investment.1 During 2021, the internet advertising market in Ukraine increased by 48 percent. Another 34 percent increase was predicted for 2022,2 but all major online media have reported a huge drop in online advertising since the beginning of war.3

Even despite the earlier growth, many online media outlets have 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 According to September 2020 monitoring by the Institute of Mass Information (IMI), a nongovernmental organization (NGO), 18 percent of interviewed journalists reported that they had been forced to publish jeansa, 8 percent reported they did so on their own, and 33 percent stated the outlets they work for would not be financially viable without such material.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 November 2021, Zelenskyy signed into law the so-called Oligarchs’ Bill, aimed to prevent threats to national security related to excessive influence of oligarchs. Significant influence on media is listed among criteria defining a person as oligarch. According to the bill, oligarchs are banned from funding political parties and campaigns and must submit an income e-declaration. There are concerns that such requirements might lead to oligarchs transferring media ownership rights to third parties while still preserving actual influence on editorial policies. The law also defines internet media for the first time.8

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 ($34,566). Companies that fail to pay could be fined 195,000 hryvnia ($6,740).9 Companies, like eBay, Amazon, Facebook, Google, and Netflix, announced they would effectively add the tax to customers’ fees.10

Net neutrality is not enshrined in national legislation. Mobile service providers violate net neutrality by offering plans in which users do not pay, or pay reduced rates, for access to social media platforms,11 although the existence of these plans “does not have a substantial effect on digital participation,” according to a report from Digitak.12 Following the Russian military’s 2022 invasion of Ukraine, and to support distance learning, Vodafone Ukraine has offered free broadband services for usage of certain communication services and resources, including video-conferencing services Microsoft Teams, Zoom, Skype, Hangouts, and Google Meet, as well as messengers Viber, Telegram, and WhatsApp, and Google Classroom.13 Similarly, mobile operators and Ukrtelecom continued providing services to subscribers. In addition, Lifecell provided an extra service package free of charge.14

B7 1.00-4.00 pts0-4 pts
Does the online information landscape lack diversity and reliability? 2.002 4.004

The online media landscape in Ukraine is generally pluralistic and diverse. 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

After Russia began its invasion, a number of 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.2

While independent media outlets have recently grown in Ukraine, most Ukrainians did not receive their news from these sources in 2021. Alarmingly, in November 2021, Adnan Kivan, the owner of the Kyiv Post, fired all the staff after they opposed his editorial policies, including installing a new editor in chief.3 The Post briefly shut down and then reopened, while the former journalists of the Kyiv Post launched a new publication, the Kyiv Independent.4 Prior to the firing of the staff, there were reports that the presidential administration had signaled to Kivan that they would prefer less critical coverage. The administration denied these allegations.5

Following the Russian military’s invasion of Ukraine, 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.6 Some channels sharing Russian propaganda narratives have been losing Ukrainian subscribers, while some independent Ukrainian media channels have experienced a significant increase in readers and followers.7

The Russian military’s invasion of Ukraine created difficulties for independent media, with outlets facing financial struggles, and journalists 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. At the same time, local media play a critical role in documenting the Russian military’s war crimes8 and delivering news to people living in cities under Russian occupation. However, disrupted internet connectivity has made this coverage increasingly difficult.9 To avoid broadcasting Russian propaganda, some local media outlets in cities under Russian siege have closed their operations.

Many online media outlets struggled to stay afloat after the invasion. Even major outlets had to reduce salaries, shift to remote modes of work, ask for donations, and launch crowdfunding campaigns. In 2022, Ukrainian journalists received a special citation from the Pulitzer Board “for their courage, endurance, and commitment to truthful reporting” during the war.10

There has also been online misinformation and disinformation concerning Russian military actions (see B5). Many such narratives rely on decontextualized images and video footage. For example, fact-checkers using reverse Google image searching revealed that a few photos claiming to show explosions in Ukraine were in fact old photos of Israeli military air strikes in Gaza.11 On TikTok, a viral video of a parachuting soldier gained millions of views on first day of the war, with the top comment claiming it was part of the Russian invasion. However, fact-checkers found that the video was from 2016.12 TikTok removed 41,191 videos spreading misinformation about the war in March 2022 (see B2).

Journalists, politicians, and activists use social networks, particularly Facebook, ubiquitously, which facilitates pluralism online. Russian social media platforms are used by a very limited number of Ukrainians, though they remain available through VPN and via some ISPs that did not comply with sanctions orders. In 2021, VK was visited only by 1.98 percent of Ukrainian social media users.13

During the coverage period, an average of 56,103 Ukrainian users accessed Tor daily through relays, comprising the tenth-largest national segment of Tor’s user base.14 Apple's new “private relay” encryption feature available on iOS 15 reportedly allows users to access to Russian websites blocked in Ukraine.15

In April 2019, the parliament passed the Law on Ensuring the Functioning of Ukrainian as the State Language. The law stipulates that, among other things, most public institutions’ websites have a Ukrainian-language version, and that this version be displayed by default; that media outlets’ websites and preelection campaign materials must be in Ukrainian by default; and that video-on-demand play Ukrainian as the default language. The provisions outline exceptions for religious ceremonies and private communication or media in English and other European Union (EU) languages, as well as Indigenous languages like Crimean Tatar.16 The law entered into force in January 2022 and the provisions compelling websites to change their default language were set to take effect in July 2022, after the coverage period17

Since the beginning of war, President Zelenskyy and his team have actively used social media for public diplomacy to gain support for Ukraine and expose the abuses that characterize Russia's invasion. Ukraine's official social media channels have experienced an enormous increase in followers since February 24, 2022.18

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, which expanded dramatically following the 2014 revolution, has become 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 and Skype.1 Telegram channels continue to grow rapidly and are largely focused on political issues.2

Ukrainians and Ukrainian government officials actively use e-petitions and online resources to publicize their activities and advocate for socially and politically important issues. Officials regularly engage with users. An online platform called LetMyPeopleGo3 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.4

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.5 Another team of volunteers created a dedicated website, called Post to Stop War, which showcases key messages about the Russian war in Ukraine in over 30 languages to audiences abroad.6 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.7 Ukrainian media and sectoral ministries have also conducted fundraising telethons.8 The Ministry of Culture and Information Policy of Ukraine, in cooperation with partners, presented “Ukraine Now and Forever,” a campaign celebrating Ukrainian cultural history and encouraging sanctions targeting Russia.9 Multiple online fundraising campaigns run by volunteers across the country have helped to collect funds to provide ammunition and equipment to Ukrainian soldiers.10

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.11 A flash mob using the hashtag #ятобінедорогенька (“I am not Darling to you”) was launched by two women journalists who wanted to draw attention to the sexist attitudes and actions of politicians as experienced by women in journalism. The hashtag drew popular support, but the women were also harassed online.12 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.13

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 may 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 However, Ukrainian courts are still hampered by corruption and political interference. Judicial reforms are ongoing, but at a slower pace than expected.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 In mid-April 2022, the parliament of Ukraine issued a statement on the importance of freedom of speech, urging state authorities to undertake necessary actions to protect the rights of journalists and media during martial law.5

Serious crimes against journalists often go unsolved (see C7). At the end of the reporting period, draft law 3633, which amended the criminal code by increasing fines for criminal offenses against journalists, was still awaiting the president’s signature.6 In July 2022, after the coverage period, the parliament passed draft law 2279, which requires media outlets to provide journalists with insurance, and to provide journalists covering combat with sufficient protective and medical equipment.7

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

No law mandates criminal penalties or civil liability specifically for online activities. However, 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 for those found guilty.1

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.2 Since January 2019, the code of administrative offenses penalizes any form of bullying, including via electronic communication (under Article 173-4). Individuals found guilty of bullying may be fined or given community service obligations. Individuals who fail to report bullying may also be subject to fines. In February 2019, a judge gave the first indictment for bullying on social media.3

Neither defamation nor insult are criminally penalized in Ukraine.4

In March 2022, following the Russian military’s full-scale invasion of Ukraine, the parliament adopted draft laws 5101 and 5102, which had been pending since early 2021. Amendments introduced by draft law 5101 prohibit the justification, legitimization, and “denial of the 2014 armed aggression of the Russian Federation against Ukraine”—including by calling it an internal conflict or civil war. Additionally, judges are enabled to shut down and ban religious organizations, NGOs, and political parties for violating the above terms, or for promoting war propaganda, communist regimes, and calls for changes in the constitutional order. Draft law 5102 specifies punishment for any violations of these bans.5

In the same month, the parliament criminalized collaboration with the Russian government 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 ten to fifteen years.6

In early June 2022, after the coverage period, 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 spread about aggression, publications condemning the Russian regime, museum exhibitions, research activities, and school textbooks.7

  • 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“Code of Ukraine on Administrative Offense,” Official Website of the Verkhovna Rada of Ukraine, https://zakon.rada.gov.ua/laws/show/80731-10#Text
  • 3“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…
  • 4“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
  • 5“Проект Закону про внесення змін до деяких законодавчих актів України (щодо заборони виготовлення та поширення інформаційної продукції, спрямованої на пропагування дій держави-агресора) [Draft 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, http://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=71149; “Проект Закону про внесення змін до деяких законодавчих актів України (щодо посилення кримінальної відповідальності за виготовлення та поширення забороненої інформаційної продукції) [Draft 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, http://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=71150
  • 6Закон 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, https://zakon.rada.gov.ua/laws/show/2108-IX#top
  • 7“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, http://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=73937
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

Multiple internet users in Ukraine have been arrested, fined, or sentenced to prison in recent years for activities that may be protected under international human rights standards; however, severe sentences have become less common.

In late 2020, the SSU opened criminal proceedings against politician and pro-Kremlin blogger Anatoliy Shariy for posting a map of Ukraine that excluded the occupied territories of Crimea and Donbas on his YouTube channel. He was charged under Article 111 of the criminal code with high treason, and under Article 161 on infringing citizens’ equality. The SSU put Shariy—who lives in Spain, where he had received asylum—on its wanted list.1 In early May 2022, Spanish authorities detained Shariy.2 He was later released under house arrest pending extradition, which can take up to one year.3

In March 2022, the Halytskyi District Court ordered the detention of another pro-Russian blogger, Glib Lyashenko.4 He was charged with treason in relation to appearances in pro-Russian media, and faces a possible 10 to 15 years in prison.5

In August 2021, regional courts ordered three years of imprisonment for a Russian citizen residing in Ukraine found guilty of disseminating anti-Ukrainian propaganda on Odnoklassniki, a Russian social media platform.6

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.7

The SSU regularly reports on the unmasking of alleged Russian agents involved in disseminating online content in violation of Articles 109 and 110 of the criminal code.8 In 2021, this resulted in the opening of 44 criminal proceedings and the criminal liability of 37 individuals for spreading anti-Ukrainian propaganda online (see C2).9 In November 2021, the SSU reported that 23 individuals who used social media to call on Russia to “violate the territorial integrity” of Ukraine had been convicted.10

Journalists who work online occasionally face civil defamation lawsuits from public and private actors who object to their reporting. For example, in July 2019, the ultranationalist group C14 successfully sued Hromadske TV, which had called it a “neo-Nazi” group in a post on Twitter. Hromadske TV was ordered to rescind the post and pay C14’s legal fees totaling 3,500 hryvnia ($130).11 In June 2020, Hromadske TV filed a complaint in connection with the case before the European Court of Human Rights (ECtHR),12 but there were no updates by the end of the coverage period.

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

There is currently no obligatory registration for either 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.

At present, there are no restrictions related to encryption tools, though the commercial provision of these tools is subject to licensing.1 VPNs are widely used in Ukraine.

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 SSU 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

A package of legislative amendments (draft laws 4002, 4003, 4004), which aims to improve the efficacy of operations combatting cybercrime and ensure compliance with government sanctions, has been pending in the parliament since September 2020. The bills would give authorities the right to access information on a smartphone or computer without a court order, while ISPs would be obliged to install, at their own expense, the technical means to intercept information from communication networks.4

Draft law 3196-d (see B3), which passed its first reading in January 2021 and was submitted in a revised version for the second reading in October 2021, would expand the SSU’s powers, giving it extrajudicial access to citizens’ personal data and information collected by telecommunications companies, based on SSU-specified conditions.5

In June 2021, the parliament registered draft law 5628 on personal data protection, in line with the European Union’s General Data Protection Regulation (GDPR). It stipulates, among other things, granting Ukrainian citizens the right to be forgotten, and obliges companies to delete personal data in question within 30 days after they receive such a request.6

  • 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, 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….
  • 4“Пакет законопроектів щодо протидії кіберзлочинності та посилення санкційного механізму від 1 вересня 2020 року містить загрози для цифрових прав – заява Коаліції “За вільний Інтернет” [Package of bills on combating cybercrime and strengthening sanctions mechanism as of September 1, 2020 contains threats to digital rights - the statement of the Coalition “For Free Internet”],” Digital Security Lab, September 8, 2020, https://dslua.org/publications/paket-zakonoproektiv-shchodo-protydii-ki…
  • 5Oleksandra Matviychuk “Кінець приватності, або Загрози закону про СБУ, які заперечують його автори [The end of privacy, or the threats of the SSU law, which its authors deny],” Zmina, October 6, 2021, https://zmina.info/columns/kinecz-pryvatnosti-abo-zagrozy-zakonu-pro-sb…
  • 6Viacheslav Masnyi, “Право на забуття. Рада може дозволити вимагати в інтернет-компаній видаляти персональні дані [The right to be forgotten. The parliament may allow Internet companies to delete personal data],” Suspilne, June 11, 2021, https://suspilne.media/209136-fahivci-poperedili-pro-mozlivi-kiberataki….
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

Score Change: The score declined from 2 to 1 to reflect the Russian military’s attacks on journalists and civilians since the beginning of the invasion.

Users and, in particular, journalists who work online are frequently subject to extralegal retaliation for their online activities.

Following the 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” from cities and regions under Russian siege. At least eight journalists, including online journalists, were killed by Russian forces during the coverage period. For example, Maks Levin, a Ukrainian photojournalist who contributed to LB.ua, among other more well-known publications, was reportedly executed by Russian soldiers outside of Kyiv, according to Reporters Without Borders (RSF).1 The Institute of Mass Information (IMI), by the end of May 2022, had recorded 280 crimes against journalists and media in Ukraine committed by Russian forces.2

Additionally, human rights groups have reported that Russian soldiers have compelled Ukrainians in occupied cities and towns to turn over their cell phones, and have killed people who refused to comply.3

Prior to the invasion, the IMI recorded 197 “violations of freedom of speech” in 2021, demonstrating a continued decrease from previous years. The majority of the recorded violations (145) involved physical aggression against journalists, both those who work in offline and online media.4 Additionally, in 2021, the national police documented 57 cases of threats or violence against journalists and one case of assault on journalist’s life. Overall, the number of investigations of crime against journalists rose by 69 percent in 2021 compared to 2020.5 Last year, the courts rendered decisions in 11 cases involving violations of journalists’ rights.6

In July 2020, the prosecutor general filed charges against Vladislav Manger and Oleksiy Levin, two officials from Kherson, for 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 attack7 was complete.8 However, human rights advocates questioned the timing of the decision, claiming that the authorities had sent the case to court prematurely. 9 At the end of the coverage period, the case against Manger and Levin was still in court.10

In 2016, Pavel Sheremet, a journalist working for the online newspaper Ukrayinska Pravda, was killed in a car bombing in Kyiv.11 In December 2019, the prosecutor general, the Ministry of Internal Affairs, and the police announced that the case was almost closed, with five suspects in detention. However, a month later, the prosecutor general admitted that it lacked enough evidence to find the suspects guilty.12 In May 2020, new prosecutors were assigned to the case,13 and subsequently, three suspects were sent to trial,14 while an investigation into unidentified people involved in organizing the killing remained ongoing.15 In September 2020, the court began hearing the case and appointed a jury panel.16 A year later, in September 2021, the judge leading Sheremet’s case was found dead.17 That same month, during a court hearing, the prosecutor revealed conclusions of the explosive examination from Sheremet’s car. However, suspects questioned the transparency and comprehensiveness of the examination.18 By the end of the coverage period, the court continued examining evidence and questioning witnesses.19 Two suspects remained under night house arrest and one under personal commitments.20

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.21

Nonphysical acts of harassment and doxing remain a problem.22

An online group of Ukrainian activists calling themselves Myrotvorets (Peacemaker) continued to harass and dox journalists and others they perceive as anti-Ukrainian.23 In February 2021, the European Parliament called upon Ukrainian authorities to ban Myrotvorets,24 though President Zelenskyy said in October 2019 that shutting down any website, including Myrotvorets’s, was beyond his mandate.25 In December 2021, the police started a pretrial investigation into Myrotvorets for publishing a minor’s personal data.26

The intimidation of marginalized groups online is common. LGBT+ individuals frequently face online harassment.27

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 ahead of the Kremlin’s invasion of Ukraine and throughout the war. 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.

During the first quarter of 2022, the Computer Emergency Response Team of Ukraine (CERT-UA) reported 802 cyberattacks against targets based in the country, which is more than double the amount recorded in the same period in 2021.1 According to an April 2022 report from Microsoft, at least 6 separate Russian-aligned actors launched over 237 cyberattacks against Ukrainian targets, many of which coincided with Russian military operations targeting services and institutions crucial for civilians, between the lead-up to the invasion and April 2022.2 Russian-aligned actors have also hacked local authorities’ websites to display false notices that local officials support the Russian invasion.3

In early February 2022, the GRU, the Russian military intelligence agency, reportedly launched a series of distributed–denial of service (DDoS) cyberattacks against Ukrainian banking, finance, and defense websites. 4

On February 22, 2022, two days prior to the invasion, several Ukrainian banking and government websites, including the Ministry of Foreign Affairs, Ministry of Defense, Ministry of Internal Affairs, Security Service (SBU), and the website for the cabinet were inaccessible after a DDoS attack. While access to several websites was restored within a few hours of the attack, latency and outages continued into the next day for others.5 The following day, the Kyiv Post, an independent news outlet (see B7), reportedly suffered constant cyberattacks, including DDoS attacks. However, the outlet found alternative means to publish via Facebook, Twitter, and LinkedIn.6 Hours prior to the invasion, a targeted cyberattack disrupted the Viasat satellite internet network, which serves Ukraine and much of Europe.7

In mid-March 2022, hackers briefly disrupted access to several well-known Ukrainian media websites, including Hromadske.radio and the Kherson-based MOST. During the hack, the sites displayed pro-Russian symbols of the invasion, such as the Russian flag, St. George Ribbon, and the letters Z and V.8

In late March 2022, Ukrtelecom, the largest provider of fixed-telephone service and one of the major internet providers in Ukraine, suffered a cyberattack, which was allegedly committed by the Russian government, that forced it to shut down service for a few hours (see A3 and A4).9

According to an April 2022 report from Meta, hacking group Ghostwriter, which has been linked to the Russian state and the Belarusian state,10 attempted to gain access to Ukrainian soldiers’ Facebook accounts and post demoralizing videos. Meta managed to stop the operation (see B5).11

In early April 2022, CERT-UA prevented an attempt by the Sandworm hacker group, which is a part of Russia’s GRU, to disable high-voltage electrical substations in Ukraine. Reportedly, the hackers planted malware on the systems of a Ukrainian energy company, but CERT-UA identified the malware and thwarted the attack.12

In June 2022, after the coverage period, 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.13

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 DDoS attacks on Russian websites, but actually installed malware on users’ devices.14

In 2021, the national regulator registered 147 cyber incidents, out of which 28 percent involved malicious code dissemination, 18 percent involved collection of information, and 6 percent involved fraud.15 The hacking and DDoS attacks were directed, among others, against the websites of the president of Ukraine, the SSU,16 the Ministry of Foreign Affairs, the Ministry of Education,17 large state banks,18 and Ukraine’s official website, Ukraine.ua.19

In 2021, the SSU reported that it had neutralized over 2,000 potential cyberattacks on public authorities’ websites and objects of critical infrastructure. Additionally, the SSU blocked a large-scale cyberattack on Ukrainian governmental resources initiated by the Russian hacker group Armageddon, controlled by Russian intelligence services.20 The IMI also identified 16 cyberattacks against journalists in 2021.21

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

    Yes

  • Users Arrested

    Yes