Is It Mandatory to Update a Security License: Changes Effective from November 2025

In November 2025, amendments to the Licensing Conditions for Security Activities, approved by the Resolution of the Cabinet of Ministers of Ukraine No. 1087 dated September 3, 2025, will come into force. These changes strengthen the requirements for license holders and introduce new obligations for updating information in the license.

In other words, businesses operating in the security services sector must adapt to the new rules to maintain their right to operate. This article explains what exactly needs to be done and which documents must be prepared to stay compliant with the law and avoid business risks.

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Who Is Affected by the Changes in Security Licensing Conditions

The updates apply to all companies engaged in security activities that hold a license issued by the Ministry of Internal Affairs (MIA) before November 5, 2025. Such license holders are required, within two months, to:

• details on the availability of service dogs;
• details on the availability of technical information protection systems;
• information on the presence of centralized monitoring points;
• confirmation of no controlling influence over the license applicant or holder as defined by the Laws of Ukraine “On Protection of Economic Competition” and “On Defense of Ukraine,” including confirmation of no trade relations with residents of states engaged in armed aggression against Ukraine.

• a copy of the taxpayer identification number (TIN), or, if declined, a copy of the passport with the corresponding note;
• a copy of the military document showing service, reserve status, deferment, or exemption.

Please note that missing the deadline to submit updated information to the licensing authority may result in suspension or even revocation of the security license. More details on this are provided below.

Deadlines for Submitting Information to the Ministry of Internal Affairs

According to the Licensing Conditions, a security services entity must notify the licensing authority within one month after any changes occur. The notification may be submitted in writing or electronically and must include copies of documents confirming the changes.

An exception applies to the submission of information regarding:

• security personnel;
• special equipment;
• response vehicles.

Data on these categories must be submitted quarterly, by the 10th day of the following month.

Consequences of Failing to Update a Security License on Time

If a license holder fails to fulfill the obligation to update information, the licensing authority has the right to:

• suspend the license until the violations are corrected;
• impose a fine as provided by the Code of Ukraine on Administrative Offenses.

Failure to notify the licensing authority within the required time about changes to the information stated in the application or documents submitted when obtaining the security license results in a fine ranging from 4,250 UAH to 8,500 UAH.

• In case of a repeated violation, the authority may revoke the license.

If a company continues operating without a valid license or during a license suspension, it may face a fine ranging from 17,000 UAH to 34,000 UAH.

Please note! Once a license is suspended, the company is not allowed to sign new security contracts or hire new employees until a formal application for reinstatement is submitted.

What a Security Company Should Do Now

Given the short two-month period, all active security service providers must make sure to:

1. Bring their documentation and operations into full compliance with the new Licensing Conditions.
2. Prepare an updated set of documents in accordance with the revised Licensing Conditions.
3. Submit all required information and supporting documents about the changes no later than January 5, 2026.

Required Documents for Each Security Guard

Special attention should be paid to ensuring that all personnel meet the established requirements and possess the necessary documentation. Each security guard must have the following:

• employment contract;
• medical certificates, including results of narcological and psychiatric examinations;
• certificate of no criminal record
• Copy of the Ukrainian passport and taxpayer identification number (TIN);
• state-issued diploma and qualification certificate (for example, confirming status as a security guard or watchman);
• military registration document, including information on service, reserve status, deferment, or exemption.

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Legal Support for Security Companies

Our firm assists security businesses by providing comprehensive legal support, including throughout the process of updating licenses in accordance with the new requirements of the Ministry of Internal Affairs (MIA).

We handle the entire process so you can continue operating without interruptions:

• conduct a document audit to ensure compliance with the updated Licensing Conditions;
• prepare and submit all required notifications, information, and documents to the MIA;
• oversee the compliance confirmation process to minimize the risk of fines or license suspension.

If your security company already holds a license but you are unsure whether updated information must be submitted, contact us.

We will promptly review your case and advise on the exact changes needed to protect your license and your business.