Access to State Registries: What We Managed to Open and What We Didn't
Contents
This is a story about a legal provision that did not work for four years, and what it took to finally make it work.
Part 11 of Article 31 of the Law of Ukraine “On the High Council of Justice” is formulated as clearly as possible: a member of the HCJ, a disciplinary inspector, and an authorized person of the secretariat have direct access to automated information and reference systems, registries, and databases maintained by state bodies or local government bodies. Without a request. Without a court order. Without an authorization procedure.
This provision is not a privilege. It exists because the HCJ decides who will be appointed as a judge and who will be dismissed. Checking the integrity of a candidate without being able to look at what they declared, what they own, where they traveled, and what cases they participated in is an imitation of a check.
In September 2022, HCJ member Roman Maselko requested the secretariat to facilitate obtaining such access. What followed took years.
What We Managed to Open
As of today, members of the High Council of Justice, disciplinary inspectors, staff of the analytical department, and the secretariat can work with the following resources:
| Resource | What it provides |
|---|---|
| USRJD — Unified State Register of Judicial Decisions (full access) | Full, non-anonymized texts of judicial decisions |
| ”Arkan” — interagency system for tracking state border crossings | Travel history (crossings and returns), vehicles used to cross the border |
| SRRPR — State Register of Real Property Rights | Real estate ownership, history of rights transfer, mortgages, and encumbrances |
| SLC — State Land Cadastre | Land plots |
| USDR — Unified State Demographic Register (SMS) | Personal information and registered place of residence (limited) |
| SRIT — State Register of Individual Taxpayers | Identification data, income records |
| URPA — Unified Register of Powers of Attorney | Powers of attorney issued by or to a person |
| USR — Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Organizations | Corporate connections and business holdings |
| USRV — Unified State Register of Vehicles | Vehicle data, history of ownership |
| SREMP — State Register of Encumbrances on Movable Property | Encumbrances on movable assets |
Several of these resources are the very registries to which access was initially deemed impossible even by the secretariat of the High Council of Justice. The fact that they are on the list of accessible systems today is the result of several years of correspondence, not a one-time request.
Access to many registries was successfully established in two formats simultaneously: via the Electronic Cabinet and through direct access to the systems of the holding state authority. This opens up incredible opportunities for further automation of information retrieval from these databases.
What We Failed to Open
A list where every entry shares the same structure of refusal.
Registry of Insured Persons (Pension Fund of Ukraine). Refused. The Pension Fund replied in detail — and their answer is worth noting because it is honest. Having analyzed both laws, the PFU concluded that the regulations it is bound by contain an exhaustive list of users, and HCJ members are not among them; that the special Law “On the High Council of Justice” does grant such a right; and that there is indeed a conflict between these acts, which requires legislative changes to resolve. In other words, the data controller recognized the legal collision and stopped there.
Hereditary Register (Ministry of Justice). Refused: the regulation does not list the HCJ even among those who can obtain a full extract upon request.
Unified State Register of Lustrated Persons (persons subject to the Law “On Lustration”). Refused: only Ministry of Justice employees have access; the HCJ can only obtain information “upon request.”
Unified Register of Convicts and Persons in Custody. Refused: the registry is in pilot operation, and the scope of information available to users is not legally defined.
Automated System of Enforcement Proceedings. Only the public interface is available.
NACP Registries — asset declarations and the registry of persons who committed corruption offenses. Access is restricted during martial law; practically only the public access level remains.
IAS “Record of criminal records and convictions” (Ministry of Internal Affairs). No direct access; written requests only. For checking a candidate who declares no criminal record, this means weeks of waiting instead of a minute.
Unified Portal of the National Police, State Financial Monitoring Service — areas that remained at the stage of clarification.
The Mechanics of Refusal
If you read all the replies in a row, it becomes clear they were written using a single template:
Yes, the law grants you this right. However, the regulation governing our registry, approved by ministerial order, contains an exhaustive list of users. You are not in it. Therefore, no access is granted.
This is the core of the problem, and it is not technical. An act of lower legal hierarchy is used as a reason not to apply the law. Notably, none of the controllers claimed the law was invalid — they simply could not go beyond their own internal regulations, and they were in no hurry to change them.
There was also an almost comical episode. In response to two registries, the administrator explained in detail how automated access works via an Application Programming Interface (API): in real time, using shared protocols between the Ministry of Justice and the respective state body. That is, they described the technical procedure for obtaining the very access they had just refused.
The reason for this behavior is entirely rational, which is why it is so difficult to overcome. The data controller is held responsible for any data leaks from their registry. They are not held responsible if another state body cannot perform its functions. The incentives are aligned so that refusing is always safer than granting access. Until this changes, every new authority will have to travel the same path from scratch.
Internal Resistance
The most unexpected part of this story is that part of the path had to be fought inside the HCJ itself.
The most telling example is the Unified State Register of Judicial Decisions. This is a basic, daily, and most obvious tool for anyone investigating a disciplinary complaint or a candidate for a judicial position. As it turned out, secretariat employees performing the duties of disciplinary inspectors did not have full access to it.
This is not a formality. In the anonymized public version of a decision, it is impossible to identify the parties or see who exactly took the procedural actions described. This meant that the person checking a complaint against a judge had to read a document from which the key details they needed had been removed.
The regulations of the USRJD, by the way, explicitly allowed granting such access to authorized secretariat staff by a decision of the HCJ Chairman. The mechanism existed. Nobody had used it. It took a formal memo requesting review “in the near future” because the active analysis of judicial candidates was underway.
A similar pattern occurred with other resources. Every single access had to be justified separately, not only to external controllers. For a long time, the initiative was perceived not as an institutional need of the Council, but as a personal project of one member, with the corresponding level of priority.
How It Ended
Today, the HCJ has an analytical department capable of providing information support for the judicial recruitment process.
No candidate evaluation is conducted without an analytical memo. The memo compiles data from all available registries into a single document, cross-references them, and highlights discrepancies between what the candidate declared and what is recorded in state databases.
The best indicator of success is how routine it has become. The analytical report is now perceived as a normal part of the process, as if it had always been there. People joining the Council today do not know that four years ago this did not exist at all, and the attempt to change it caused surprise on both sides.
This is what a successful change looks like: it becomes invisible.
Peromat: When Access Exists, But Time Does Not
The newly gained access created a new problem of a kind that is easy to overlook.
Data from ten registries arrives in ten different formats: PDF extracts, web pages, tables, scanned copies. The analyst had to open them one by one and transfer the data into the report manually. Time tracking showed a distribution of time that was hard to look at calmly:
| Stage of work | Share of time |
|---|---|
| Data collection from registries | 5–10% |
| Processing and formatting | up to 5% |
| Transferring data from extracts to the report | 60–70% |
| Analytical work and risk assessment | less than 10% |
| Error checking | 5% |
This meant that less than a tenth of the time was spent on the actual analytical work for which the department was created. The rest was copying.
The solution was a personal initiative by Ihor Bilyk — the Peromat system: a local software application that processes registry extracts on the user’s computer and automatically generates the analytical report.
The key word here is local. The data is not sent anywhere, does not go to the cloud, and never leaves the workstation. For handling the personal data of judicial candidates, this is not an implementation detail, but a fundamental requirement for the system’s existence.
What it does:
- parses extracts from registries and retrieves structured data;
- cross-references entities across sources — identifying the same vehicle by VIN code in different extracts, tracing ownership history, and mapping close relatives;
- calculates income and assets;
- generates a draft report that only needs to be verified, not typed from scratch;
- builds an interactive view: a compact summary with the option to expand details for any specific object — real estate, vehicles, or border crossings.
Three registries are already fully automated: the Taxpayer Register, “Arkan,” and the Vehicle Register. Automation for the remaining ones is underway: for the real property register, it involves receiving structured JSON data instead of PDFs — a small change that saves two hours of manual work.
Impact: the system eliminates 70–80% of the time spent on purely technical tasks. The report is generated up to 90% automatically. The saved time is redirected where it belongs: to deep analysis, risk assessment, and reading between the lines.
A secondary but vital benefit is the reduction of typographical, arithmetic, and logical errors. A human transferring numbers between files for seven hours straight will eventually make mistakes. A program will not.
Key Takeaways
The right of access and the ability to use it are two different things. The law had existed since 2016. Practical access appeared after four years of correspondence. Analytical capacity followed the creation of the department. Speed followed the introduction of a tool that handles the technical work. Remove any of these links, and the others lose their value.
A sub-legal act cannot override a law, but it does so very successfully in practice. The most effective systemic change here is not another appeal, but aligning registry regulations with laws. This is tedious, invisible work with zero PR value, which is why it is so often ignored.
Internal resistance can be stronger than external. You can always write another letter to an external body. Internally, you have to prove that the tool is needed by the institution, not just by you.
And success looks boring. Today, the analytical report is just a routine step in the process. Nobody remembers that it used to be non-existent.