Until September 2015, pursuant to the Law “On Television and Radio Broadcasting”, only legal entities of Ukraine and citizens of Ukraine were entitled to establish television and radio broadcasting companies in Ukraine. Foreign investors were, nonetheless, allowed to acquire shares of existing broadcasting companies, with certain exceptions, such as foreign entities and individual entrepreneurs registered in offshore zones, who were forbidden from both setting up and being shareholders of broadcasting companies. Following the amendment, only foreign entities and individual entrepreneurs registered in offshore zones remained restricted from establishing and participating in the capital of television and radio broadcasting companies in Ukraine.
In 2019, an amendment to the law established that the ultimate beneficial owner (controller) of a provider of a multi-channel TV network program service in the DVB-T, DVB-T2 standard, another standard for transmitting a television image using a radio frequency resource for the purposes of digital terrestrial broadcasting could only be a citizen of Ukraine. 
As of 31 March 2023, pursuant to the new Law on Media No. 2849-IX of 13.12.2022, which repealed the previous Law on  “On Television and Radio Broadcasting”, the ultimate beneficial owner or key shareholder in a media entity provider of electronic communications services for broadcasting needs with the use of radio frequency resource must be citizen of Ukraine or Ukrainian state authority.
In addition, under the martial law, it is prohibited for natural persons and legal entities of aggressor countries (registered or located there) to establish media entities; the ultimate beneficial owner or key shareholder in a media entity cannot be from an aggressor country.
"Section II. SUBJECTS IN THE SPHERE OF MEDIA
Article 13. Entities in the field of media
1. For the purposes of this Law, subjects in the field of media are:
1) subjects in the field of audiovisual media; 2) entities in the field of print media; 3) entities in the field of online media; 4) providers of audiovisual services; 5) video sharing platform providers; 6) providers of electronic communication services for broadcasting needs using the radio frequency spectrum.
[...]
Article 19. Providers of electronic communication services for broadcasting needs using the radio frequency spectrum
1. A provider of electronic communication services for broadcasting needs using the radio frequency spectrum is a person who distributes packages of TV channels and radio channels in an on-air multi-channel electronic communication network in accordance with a license issued by the National Council
[...]
Article 21. Requirements for subjects in the field of audiovisual media
1. Subjects in the field of audiovisual media may be citizens of Ukraine, foreigners and stateless persons residing in Ukraine, legal entities of Ukraine registered in accordance with the procedure established by law.
A subject in the field of audiovisual media that uses the radio frequency spectrum of Ukraine to provide the appropriate service, a subject in the field of non-linear audiovisual media may be registered in accordance with the procedure established by the legislation of Ukraine, a legal entity or a natural person - an entrepreneur.{Part one of Article 21 as amended by Law No. 3136-IX dated May 30, 2023 }
2. A subject in the field of audiovisual media cannot be a person whose ownership structure includes state bodies, local self-government bodies, their associations, except for exceptions provided for by law, political parties, their structural subdivisions, as well as legal entities founded by such entities, except for scientific institutions, educational institutions and cultural institutions.
The specified restrictions do not apply to public audiovisual media and to the subject in the field of parliamentary broadcasting.
3. State bodies of foreign countries, religious organizations, international organizations, as well as legal entities founded by such entities cannot be included in the ownership structure of an entity in the field of audiovisual media that uses the radio frequency spectrum of Ukraine to provide the relevant service.
[...]
Article 22. Requirements for audiovisual service providers
1. A legal entity or an individual entrepreneur may be registered as a provider of audiovisual services in accordance with the procedure established by the legislation of Ukraine.{Part one of Article 22 as amended by Law No. 3136-IX dated May 30, 2023 }
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Article 24. Requirements for providers of electronic communication services for broadcasting needs using the radio frequency spectrum
1. A legal entity may be registered as a provider of electronic communication services for broadcasting needs using the radio frequency spectrum in accordance with the procedure established by the legislation of Ukraine.
The ultimate beneficial owner of a provider of electronic communication services for broadcasting needs using the radio frequency spectrum for the purposes of digital terrestrial broadcasting can only be a citizen of Ukraine. Key participants of such a supplier can only be citizens of Ukraine. Persons registered in offshore zones, the list of which is approved by the Cabinet of Ministers of Ukraine, cannot be the owners of significant participation at all levels of the chain of ownership of corporate rights of such a supplier.
The provisions of the second paragraph of this part do not apply to providers of electronic communication services that are legal entities of the state ownership form (100 percent of the shares of the authorized capital or shares of which belong to the state).{Part one of Article 24 as amended by Law No. 3136-IX dated May 30, 2023 }
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Article 25. Requirements for the ownership structure
1. The ownership structure of the subject in the media sphere must be transparent.
2. The ownership structure of a media entity is transparent if the following requirements are simultaneously met: [...]
3) there are no legal entities registered in offshore zones, the list of which is approved by the Cabinet of Ministers of Ukraine, among the owners of significant participation in the subject in the field of media at all levels of the ownership structure.
In the event that the Cabinet of Ministers of Ukraine includes a certain country (territory) in the list of offshore zones, a subject in the field of media, the owner of which is a legal entity registered in such a country (in such a territory), is obliged within six months from the date of recruitment to bring its ownership structure into compliance with the requirements of paragraph 3 of this part by the relevant resolution of the Cabinet of Ministers of Ukraine.
[...]
Section IX. FEATURES OF THE LEGAL REGULATION OF MEDIA ACTIVITIES IN THE CONDITIONS OF ARMED AGGRESSION
Article 118. Effect of the provisions of this section in time
1. The provisions of this section are effective from the moment the Verkhovna Rada of Ukraine recognizes a certain state as an aggressor state (occupier state) and within five years from the day the Verkhovna Rada of Ukraine adopts a decision to cancel such status. During such a five-year period, the Verkhovna Rada of Ukraine is obliged to annually review the necessity of applying the restrictions provided for in this section and adopt a resolution on the extension or cancellation of the provisions of this section.
2. In the event of succession to the aggressor state (occupier state), the provisions of this section shall apply to all entities recognized as legal successors of the aggressor state (occupier state).
[...]
Article 120. Restrictions on the structure of ownership and financing of the media during armed aggression
1. The subject in the field of media in Ukraine cannot be:
1) a natural person who is a citizen of the aggressor state (occupier state), with the exception of persons who have a temporary or permanent residence permit in Ukraine;
2) a legal entity registered in the aggressor state (occupier state) or located in such a state;
3) a legal entity, in which the ultimate beneficial owner, key participant or owner of a significant participation at any level of the chain of ownership of corporate rights is a natural person who is a citizen or resident of the aggressor state (occupier state), or a legal entity registered in to such a state or with a location in such a state;
4) a legal entity that receives financing (credits, loans, loans, investments, sponsor contributions, charitable contributions, other financial assistance) from natural persons who are citizens of the aggressor state (occupier state), legal entities registered in such a state or domiciled in such a state.
2. The National Council refuses to register and does not allow the entities specified in the first part of this article to participate in the competition for obtaining a license, in accordance with the procedure established by this Law.
[...]
Article 121. Restrictions on the activities of foreign linear media
1. The National Council refuses or cancels the registration of a foreign linear media in case of detection of one of the following circumstances:
1) such media is registered (including as a legal entity) in the aggressor state (occupier state);
2) the final beneficial owner, key participant or owner of a significant participation at any level of the chain of ownership of corporate rights of such media is the person specified in the first part of Article 120 of this Law;
3) signs are found that the editorial control of such media is carried out by the persons specified in the first part of Article 120 of this Law. [...]
3. In the event that the circumstances provided for in the first part of this article are established in relation to a foreign linear media sourced from a member state of the European Union, the National Council within seven working days from the day of receiving information indicating the existence of relevant circumstances shall limit the retransmission of such media on the territory of Ukraine for the period determined by the first part of Article 118 of this Law. In the case of introducing such a restriction, the National Council must immediately notify the reasons for such urgency to the regulator having jurisdiction over the relevant foreign linear media originating from a member state of the European Union. [...]" (Law on Media No. 2849-IX of 13.12.2022, in force as of 31.03.2023 [google translation] [google translation])
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"Chapter I - GENERAL PROVISIONS
Article 1. Definition of terms
1. For the purposes of this Law, the following terms are used: [...]
ultimate beneficial owner (controller) - a natural person who, regardless of formal ownership, has the ability to exert a decisive influence on the management or economic activity of the subject of information activity in the field of television and radio broadcasting directly or through other persons, which is carried out, in particular, by exercising the right of ownership or the use of all assets or a significant part of them, the right to have a decisive influence on the formation of the composition, the results of voting, as well as the execution of transactions that provide the opportunity to determine the conditions of economic activity, provide mandatory instructions or perform the functions of a management body, or which has the ability to perform influence through direct or indirect (through another natural or legal entity) ownership by one person alone or jointly with related natural and/or legal entities of a share in the subject of information activities in the field of television and radio broadcasting;
[...]
Article 12. Establishment of television and radio organizations and requirements for their founding and statutory documents
1. The right to establish television and radio organizations as business entities in Ukraine belongs to legal entities of Ukraine and citizens of Ukraine, who are not limited in civil capacity.
2. In Ukraine, it is prohibited to establish and participate in television and radio organizations or program service providers: [...]
legal entities and natural persons - entrepreneurs registered in offshore zones, the list of which is approved by the Cabinet of Ministers of Ukraine, as well as stateless persons;
natural and legal persons who are residents of a state recognized by the Verkhovna Rada of Ukraine as an aggressor state or an occupying state, as well as legal entities whose participants (shareholders) are such legal or natural persons, at all levels of the chain of ownership of corporate rights of a television and radio organization or program provider services and final beneficiaries; [...]
The ultimate beneficial owner (controller) of a provider of a multi-channel TV network program service in the DVB-T, DVB-T2 standard, another standard for transmitting a television image using a radio frequency resource for the purposes of digital terrestrial broadcasting can only be a citizen of Ukraine. Legal entities and natural persons - entrepreneurs registered in offshore zones, the list of which is approved by the Cabinet of Ministers of Ukraine, as well as stateless persons are prohibited from participating in the program service provider of a multi-channel television network in the DVB-T, DVB-T2 standard, another standard for transmitting a television image with using the radio frequency resource for the purposes of digital terrestrial broadcasting at all levels of the chain of ownership of corporate rights. [as amended by Law No. 2529-IX dated August 16, 2022]
3. The participation of foreign individuals and/or legal entities in the authorized capital of television and radio organizations and program service providers is regulated by law.
The activities of television and radio organizations, program service providers, specified in the second part of this article, are prohibited." (Television and Radio Broadcasting Law (№ 3759-XII of 21.12.1993), last amended on 01.01.2022, [repealed by Law on Media No. 2849-IX of 13.12.2022, in force as of 31.03.2023 [google translation])
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"Article 12.
1. The right to establish television and radio organizations as business entities in Ukraine belongs to legal entities of Ukraine and citizens of Ukraine, who are not limited in civil capacity.
2. In Ukraine, it is prohibited to establish and participate in television and radio organizations or program service providers: [...]
legal entities and natural persons - entrepreneurs registered in offshore zones, the list of which is approved by the Cabinet of Ministers of Ukraine, as well as stateless persons;
to individuals and legal entities who are residents of a country recognized by the Verkhovna Rada of Ukraine as an aggressor state or an occupying state, as well as to legal entities whose participants (shareholders) are such legal entities or individuals, at all levels of the chain of ownership of the corporate rights of the television and radio organization and to the ultimate beneficiaries; [...]
3. The participation of foreign individuals and/or legal entities in the authorized capital of television and radio organizations is regulated by the Economic Code of Ukraine.
The creation and operation of a television and radio organization whose founder (co-founders) and owner (co-owners) is a non-resident (non-residents) registered in one of the offshore zones, the list of which is determined by the Cabinet of Ministers of Ukraine, is prohibited." (Television and Radio Broadcasting Law (№ 3759-XII of 21.12.1993), last amended on 4.11.2018, Article 12 [google translation])
Law on Media No. 2849-IX of 13.12.2022, in force as of 31.03.2023 [google translation]
Television and Radio Broadcasting Law (№ 3759-XII of 21.12.1993), last amended on 01.01.2022, Article 12 [google translation]
Television and Radio Broadcasting Law (№ 3759-XII of 21.12.1993), last amended on 4.11.2018, Article 12 [google translation]
[<a href="https://zakon.rada.gov.ua/laws/show/2849-20#n2350">Law</a>],[<a href="https://zakon.rada.gov.ua/laws/show/3759-12/ed20220101#Text">Law</a>],[<a href="https://zakon.rada.gov.ua/laws/show/3759-12/ed20181104#Text">Law</a>],[<a href="https://cedem.org.ua/en/analytics/ukrainian-media-law-a-reform/">Other</a>]