Media Received New Rules for Operating During the War: Who Will Be Affected by the National Council's Changes

With the start of the full-scale invasion, the professional lives of media workers changed significantly: editorial offices began to adapt to new working conditions, some completely lost this opportunity due to occupation and shelling, and some editorial offices lost the technical capabilities to broadcast. They had to work under new special rules that are constantly changing according to new challenges.

It is precisely the changes to the subordinate regulatory acts that often determine whether a broadcaster can continue working during hostilities, obtain the necessary permit, or temporarily suspend broadcasting without risking losing their license. For this reason, the National Council for Television and Radio Broadcasting once again reviewed the licensing rules, adapting them to the realities of wartime.

We explain what has changed for broadcasters and what new opportunities Decision No. 1838 provides.

What the Regulation Governs and Why Its Update Matters

The Regulation on the Features of Licensing and Registration in the Media Sphere during martial law or a state of emergency was adopted by the National Council back in May 2023. The document defines a special procedure for the regulator’s work under martial law or a state of emergency.

It is on this basis that the National Council considers licensing issues for broadcasters, registration of new entities in the media sphere, approval of temporary suspension of broadcasting, and also establishes special conditions for companies that cannot comply with certain legal requirements due to hostilities.

In fact, this is one of the key documents that allows the media regulation system to operate even in regions under constant threat of shelling or that have temporarily lost stable infrastructure.

Media from Combat Zones Received Additional Opportunities

Decision No. 1838 was adopted on July 9, 2026, and published on July 10. The document introduces changes to the Regulation on the Features of Licensing and Registration in the Media Sphere that operates during wartime and clarifies the list of territories with a special broadcasting regime. The new rules primarily concern broadcasters operating in areas of active hostilities, temporarily occupied territories, or affected by wartime restrictions.

One of the key innovations concerns licensees whose transmitters are located in territories of active hostilities. Now such broadcasters can apply to the National Council with a petition to postpone the deadline for the start of broadcasting, temporarily suspend broadcasting, and determine the terms of such suspension. At the same time, they will need to provide explanations of the reasons and documentary evidence of the circumstances that make work impossible.

This provision applies both to TV and radio broadcasters using the radio frequency spectrum and to media entities broadcasting without using frequencies if their main stations are located in combat zones.

Thus, the state officially recognizes that under wartime conditions, some broadcasters physically cannot comply with peacetime requirements.

New Grounds for Revoking Temporary Broadcasting Permits

The document also clearly formulates the list of grounds on which temporary broadcasting permits may be revoked. From now on, one such ground will be the inclusion of a territory in the list of temporarily occupied territories according to the order of the Ministry of Community Development and Territories No. 376 dated February 28, 2025.

Another provision has been added – a temporary broadcasting permit may be suspended after the completion of frequency retuning or broadcasting channels if the corresponding radio frequency bands were previously released for defense and state security needs. It should be noted that during the war, part of the radio frequency resource was used by the military and law enforcement agencies, and media were temporarily transferred to other channels.

Regulation of Military Broadcasters

The procedure for applying special conditions to audiovisual media founded by the Ministry of Defense of Ukraine has also been clarified. This concerns broadcasters performing informational tasks in the interests of the security and defense sector. They retained the ability to operate under separate rules provided by the Law "On Media", which allows for faster organization of broadcasting during martial law and ensures continuous information dissemination to the population and servicemen. This approach takes into account the special role of state defense media during the war, when the speed of spreading official information is often critical.

What This Means for the Media Market

At first glance, the changes seem purely technical. In reality, they close gaps that broadcasters have been facing for more than a year. The situation during the war can change at any moment: a territory where a TV company operated yesterday may today be under shelling or temporary occupation. Because of this, it is often simply impossible to meet licensing requirements within the prescribed deadlines.

It is precisely such practical situations that became the basis for adjusting the Regulation. The document does not introduce fundamentally new rules but rather details the mechanisms that the National Council has already applied during martial law. This should make the regulator’s decisions more predictable for the broadcasters themselves.

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