State Special Communications Service's "blacklist": what risks do businesses that still work with 1C or BAS face?

State Service of Special Communications and Information Protection (Derzhspetszviazok) published The "blacklist" of accounting software. This is a list of software that is prohibited from being used in Ukraine.Among the 27 program titles on the list are 20 different products of the popular 1C and seven BAS, which for years businesses considered a safer alternative to the Russian accounting program. And also – UA-Budget. All of them are now banned.LIGA.netI was figuring out who this decision applies to, and how they will search for and punish offenders.Why do people continue to use 1C?In the fourth year of the war, the accounting, logistics, and HR departments of Ukrainian companies continue to work on Russian software. Specifically, on the accounting software product 1C. This popular Russian system was used by most Ukrainian companies before the full-scale war.1C is still widely used, as evidenced by the demand for employees who service the software. As of January 22, 2026, Work.ua There are about a hundred vacancies for operators, accountants, and 1C programmers.The 1C product is no longer available on the market in its pure form; about 75% of companies in Ukraine still use its disguised analogues, particularly BAS. The State Special Communications Service document indicates that the developer of all three banned products is 1C LLC. According to YouControl, the company's founders are Oleksandr Dutyi, who also had a sole proprietorship providing photo services, and Oleksandr Fomenko.The 1C development company has been under sanctions by the National Security and Defense Council since 2023, and 1C and BAS products since 2024.The document with the list of prohibited software was created primarily for state institutions, government bodies, and critical infrastructure facilities, explains Taras Dzyuba, head of the information communications department of the State Special Communications Service.This means that the ban on Russian software applies to all legal entities, but at the current stage, the responsibility primarily rests with state-owned enterprises and companies with the status of critical infrastructure facilities.Among the latter, there are many private firms. For example, pharmaceutical companies, chemical plants, telecom providers, and media can be considered critical.Read alsoThe government has introduced new criteria for reserving workers. What are they for and how do they work?How will the use of "enemy" software be punished?The use of software from the "blacklist" entails criminal or administrative liability. The Law "On the Basic Principles of Cybersecurity of Ukraine" enshrines the principle that any cybersecurity violations are punishable by other laws."Depending on the nature of the violation, on the one hand, administrative liability is possible: for non-compliance with the requirements of the State Special Communications Service (Article 188-31 of the Code of Administrative Offenses): UAH 850–1700 for officials, UAH 1700–2550 for a repeated violation within a year," explained the press service of the IT Ukraine Association.On the other hand, criminal liability is also possible. The use of 1C can be interpreted as a violation of the rules for operating IT systems. This is punishable by a fine of UAH 34,000 – 68,000 or restriction of liberty for up to three years, plus a possible ban on holding certain positions, the association notes.However, for now, the penalty for ignoring the 1C/BAS ban primarily concerns the heads of state-owned companies, who could potentially face disciplinary action.Private companies, especially those that are part of critical infrastructure, may also face problems until they abandon 1C, explains Vladyslav Martynchuk, a litigation lawyer at the De Yure law firm.Also, in the case of using 1C, companies in the defense sector or those in close relations with them are at risk of sanctions, he adds.How will offenders be sought?Those who continue to use 1C will be identified during inspections by the State Special Communications Service. These can be scheduled or unscheduled. The latter are carried out in case of appeals, incidents, non-compliance with requirements, or at the request of the agency itself. This was reported to LIGA.net by the State Special Communications Service."As part of the inspections, the issue of revoking the authorization of information systems will be raised. If the violations are not eliminated, administrative liability (fines, the amount of which is determined by the court) will be imposed," explains Taras Dzyuba, head of the information communications department of the State Special Communications Service.In the state and critical sectors, violations are easiest to detect, primarily through the public procurement system, IT Ukraine emphasizes. According to the association, since 2015, Ukrainian state institutions have spent UAH 2.25 billion on the purchase of Russian software through the system. ProzorroHalf of them were allocated during the full-scale invasion alone. In particular, UAH 304 million in 2024."After the rules are tightened, prohibited software will be automatically 'cut off' at the procurement stage, and the public sector will become an area of the fastest control," explains IT Ukraine."Hostile software" is easiest to track through sales and distribution procedures. A public digital "footprint" is left by commercial offers, websites, marketplaces, advertising, contracts, invoices, integration services, and tender documentation. Supply and distribution channels are the first and most obvious control points, according to the IT association.In private companies, detecting software usage is more difficult, but over time, this will be facilitated by compliance requirements and internal audits, cybersecurity checks, and participation in tenders and partnerships where compliance becomes mandatory. In other words, it will be harder to "remain unnoticed."It is especially important for Ukraine to move away from Russian software against the backdrop of increasing cybercrime, explains MP Oleksandr Fediienko. In 2025, the National Cyber Incident Response Team CERT-UA at the State Special Communications Service processed 5,927 cyber incidents where software products of Russian origin were used. This is 37.4% more than in 2024 (4,315 cases).For according to the data According to the State Special Communications Service, in 2025, 279 incidents were recorded in the energy sector alone, 1039 in the security and defense sector, and government organizations and local authorities were also under attack, with 3285 incidents.The number of attacks on IT companies increased to 75 incidents, and on the medical sector to 95. "The industrial sector remains particularly vulnerable due to the scale of enterprises, the complexity of production processes, the use of specialized software, and limited opportunities for rapid transition and timely system updates," says Fediyenko.Read alsoWhy the weakest links in cybersecurity are not servers, but peopleWhy businesses don't abandon 1CDespite the ban on 1C/BAS versions, Ukrainian businesses are not rushing to abandon Russian software. Thousands of companies use it.Support tools have been created in Ukraine to help people switch to other programs. In September 2025, Diia.Business, in cooperation with IT Ukraine, launched Digital Solutions Marketplace – an online platform with verified software. It currently offers almost 130 solutions.More details about 1C-like programs LIGA.net wrote earlier.However, businesses are not rushing to abandon 1C products en masse.The decision to switch to secure software is significantly influenced by habit and price, explains Anton Skokov, head of digital services for business at Vchasno.Vchasno has switched to Microsoft Business Central, a next-generation ERP. The process took two years: the company prepared its team, rebuilt internal processes, and migrated functions to the new platform."1C is mainly used out of habit by companies that have been around for a long time, and this applies not only to private businesses but also to state and municipal structures," explains IT Ukraine.The financial issue also plays a role. 1C is readily available on pirate torrents, while pirated versions of its counterparts are better protected. And a legal license is not cheap. "Switching to Western software products can cost tens or hundreds of thousands of hryvnias, depending on the size of the company," says Skokov. According to his forecast, the realistic scenario for the transition is a gradual "washing out" of hostile products from the market. And this process could take 10–15 years. However, the transition from free software to expensive alternatives will be painful.However, the most important thing that keeps Ukrainian companies on 1C is that there is still no full-fledged analogue of this accounting system in Ukraine, emphasizes Yulia Lazebna, founder and head of the "Biitkod" company. The company has the right to distribute, among other things, the BAS line.According to her, companies that decide to switch mainly consider SaaS solutions, such as "Dilovod", "Bookkeeper", and "MASTER:Accounting".However, these programs cannot always satisfy all the requirements that users place on them. If a full-fledged ERP-level program is needed, then Odoo is considered, the cost of implementation and maintenance of which is higher."For example, the 'Dilovod' software is convenient for simple operations. But it's suitable for those who don't have foreign economic activity. Plus, it doesn't account for excise and retail tax," Lazebna explains.Until an adequate Ukrainian equivalent appears on the market at an affordable price, there will be no mass transition, she predicts.For now, the "blacklist" will primarily operate within the state and municipal sectors, but it also gives private businesses food for thought, according to Anton Skokov from "Vchasno".According to MP Oleksandr Fediyenko, it is currently difficult to control the private sector. "But if a company wants to work with state-owned holdings or important critical facilities, or participate in tenders, it will be forced to abandon 'hostile software'," he is convinced.Read also"Russia is among the top 3 hackers in the world." How Estonia is building a strong cybersecurity systemThe project that will fix everything.The punishment for using 1C and its analogues is also provided for in draft law No. 13505, registered in the Verkhovna Rada. The document provides for a phased transition to secure software: the state and critical infrastructure must do this first. Businesses will follow suit by January 1, 2030.The draft law provides for the gradual phasing out of such products by January 1, 2030, explains Oleksandr Horobets, a partner in the business security practice at Juscutum. Their purchase and use by government agencies, critical infrastructure entities, defense sector enterprises, and payment system participants are also prohibited, except in certain cases provided for intelligence agencies.Violators will face a fine of 2% of their annual turnover, but not less than the revenue generated from such software. Sanctions will be applied by court order based on a lawsuit from the authorized body responsible for the cybersecurity of state information resources, critical infrastructure, and countering cyber aggression. That's when the liability is supposed to take effect."This is a regulatory incentive, not a punitive one," emphasizes MP Fediyenko. He is one of the authors of draft law No. 13505, which was prepared by a working group under the Verkhovna Rada Committee on National Security, Defense and Intelligence, coordinated by the IT Ukraine Association.The draft law is currently being prepared for its first reading.IT Ukraine is convinced that this approach will ensure a managed and predictable transition to secure software not only for state-owned companies but also for businesses, which will be given enough time for a secure migration without interrupting their operational activities.For businesses, it is advisable to take preventive measures today, including auditing their software for prohibited products, explains Oleksandr Horobets, a partner in the business security practice at Juscutum. This is especially true when participating in public procurement or operating in the critical infrastructure sector."The ban on software products of Russian origin is an integral part of a comprehensive state strategy aimed at strengthening cybersecurity, ensuring economic independence, and protecting Ukraine's national interests," emphasized Oleksandr Horobets.

State Special Communications Service's "blacklist": what risks do businesses that still work with 1C or BAS face?

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