Ukraine’s Draft Law No. 9363: How Automated Debt Enforcement Could Reshape Justice
Ukraine has over six million enforcement proceedings on record.
Some are a decade old. Others involve minor fines that spiraled into problems because the debtor didn’t know how to challenge them. But many reflect another reality — one where debtors deliberately hide, change addresses, shift assets, and evade responsibility for years.
That era may be coming to an end.
Ukraine’s parliament is reviewing Draft Law No. 9363 — a legislative reboot of the country’s enforcement system. It’s not just about digitizing paperwork. It’s about changing the logic: from human-led to automated, from procedural to algorithmic.
An Enforcement System Without Friction
This isn’t a technical update — it’s a paradigm shift.
Under the new model, debt isn’t a matter of debate — it’s an automated action.
The draft law proposes four core mechanisms that fundamentally redefine how enforcement works in Ukraine.
1. Instant Freezing of Bank Accounts and Property
As soon as an enforcement officer generates an electronic order, banks must comply.
No court. No verification. No phone call.
What it means:
If you’re repaying a debt in installments, your salary account could still be frozen — instantly. You may find out when your card is declined at the pharmacy or the grocery store. No warning, no grace period.
2. A Nationwide Debtor Registry — More Than Just a List
All public and private registries will be required to integrate with a centralized debtors database. This means even small unpaid debts can automatically block property sales, vehicle registration, business transactions, or asset transfers.
Example:
A 3,000 UAH unpaid alimony debt could halt a planned apartment sale — not via court order, but through an automated “no” embedded in the system.
3. Deposits Are No Longer “Safe”
Once a fixed-term deposit matures, enforcement officers may seize it.
Currency accounts are not exempt. Debtors won’t need to prove intent — the system assumes liability.
In real terms:
A person who saved for three years “just in case” may learn that their emergency fund is now funding a creditor instead.
4. No More Voluntary Sales of Seized Property
Until now, a debtor could find a buyer for their car or apartment and pay off the debt directly. Draft Law No. 9363 ends that flexibility — all seized assets will go through state-run online auctions.
This reduces fraud risks — but also removes negotiation and human compromise.
Legal Community Response: Progress or Digital Overreach?
The legal community is divided. Some welcome the efficiency. Others see risks.
Pros:
- A systemic response to decades of enforcement paralysis.
- Reduced corruption due to less manual interference.
- A unified data ecosystem for enforcement transparency.
Concerns:
- No judicial oversight at the initiation stage.
- Debtors may discover enforcement only after their accounts are frozen.
- Vulnerable populations — retirees, small business owners, single parents — face disproportionate impact.
Revelant
What Do Key Organizations Say?
Ukrainian National Bar Association (UNBA):
“Digitalization is inevitable. But an electronic order must never replace the courts. Even speed has limits in a rule-of-law society.”
Association of Private Enforcement Officers of Ukraine (APEU):
“We need this tool. The system has been paralyzed for years. But we must clearly define protections for debtors in this new model.”
Where Things Stand: Status and Debate
- Draft Law No. 9363 has passed its first reading in parliament.
- It’s currently being revised for a second reading following multiple amendments.
- Heated debates continue between the Ministry of Justice, legal experts, banks, and civil society.
The real risk? That technical efficiency outpaces legal caution.
Algorithms don’t pause — but laws must, when rights are at stake.
Oversight Is Not the Enemy of Efficiency
Ukraine can no longer afford a system where court orders go unenforced.
But enforcement should not be built on a “speed above all” mentality.
A system with an instant freeze button must also have an appeal button — equally visible, equally fast.
Only then will automation become a tool for justice — not a digital weapon in a system that forgets people are not numbers.
About the Author
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