Ukraine Can Fix Its Campaign Regulation

Călin Georgescu, a far-right politician with no party, no parliamentary faction, and almost no presence in the polls won the first round of Romania's presidential election In November 2024. A month earlier, pollsters had put him in the low single digits.

In his campaign financial report, he declared zero expenditures. Technically, he was telling the truth. He bought no airtime, printed no leaflets, rented no billboards. No party paid for these things on his behalf, because he had no party. Yet, within weeks, the whole country knew his name. No election law was broken. The regulations were measuring the wrong thing.

Declassified Romanian intelligence revealed that a network of roughly 25,000 TikTok accounts began promoting Georgescu in a coordinated way shortly before the vote. Prosecutors later charged businessman Bogdan Peschir, alleging he transferred around $381,000 to those account-holders over the course of a month. The Center for European Policy Analysis estimates the total moved through the platform at over €1 million.

The money travelled through three parallel channels: TikTok's built-in gifting function, Revolut transfers, and cryptocurrency. VSquare found that a separate set of creators had been hired by a marketing agency registered in South Africa at around $1,000 per video. This led to the Constitutional Court’s December 6, 2024 decision to annul the election. 

Ukraine’s Campaign Law

Ukraine's Electoral Code rests on a straightforward premise: Campaigning is the activity of candidates and the parties and persons acting on their behalf, and is financed through an official campaign fund—the account through which Ukrainian law requires all campaign spending to pass. Concealed campaigning is prohibited. 

If an influencer with a million followers were to post a video supporting a particular candidate, they would be within their rights as a citizen. The difficulty begins when an there is an undisclosed client and a payment that never touches a campaign fund behind that personal opinion. Or perhaps nothing is bought at all. Reach can be manufactured by manipulating the algorithm, for example when a network of accounts is activated at the same moment, and the platform reads the resulting spike as genuine interest. This is what the Romanian reports describe. The creators may be paid directly, paid through an intermediary abroad, or not paid at all, but in none of those cases is there a purchase of advertising or a payment from a campaign fund. The law, meanwhile, is looking for a transaction it can recognize as campaign spending, and there is none.

If a violation is proven, the person or entity committing the violation is fined an administrative fee of a few hundred to a few thousand hryvnias, or several hundred US dollars. This is barely a line item for a €1 million operation. There is a criminal provision on vote-buying, but such payments fit only awkwardly, and the process delivers a verdict years after the vote. There is no way to halt an operation or remove a candidate mid-campaign. The grounds for cancelling a candidate’s registration are set out exhaustively in Article 105 and Article 160, and campaign violations are not among them.

Annulment does not stop an operation; it cancels the result the operation helped produce. That is not protection of an election but an admission that the election was not protected as it occurred. 

Elections Are Won by Reach

Campaign finance regulation in Ukraine, as in most democracies, assumes that influence is roughly proportional to expenditure. That assumption stopped holding at least as far back as the rise of Cambridge Analytica, when audience-targeting precision proved to matter more than budget size. A single video can now gather millions of views with no payment at all if the algorithm picks it up, while a million euros could end up buying nothing, particularly on platforms such as TikTok and Telegram, where recommendation mechanics are opaque.

Money is no longer the measure of influence. It remains one of several ways to obtain it. The object of regulation should therefore be the operation that produces political reach, not the payment. Its markers are verifiable: publications coordinated in time, identical narratives surfacing across unconnected sources, anomalous activity spikes, or the structure of the distribution network.

One boundary must be drawn explicitly. What triggers a response from the government has to be demonstrated covert coordination, not the content of a position: an undisclosed client, synchronized network behavior, opaque payment, artificial amplification. Criticism of the government, unpopular opinions, and organic mobilization are not operations, and do not become operations by attracting large audiences. Without that line, protecting elections becomes another word for censorship.

Anonymity, With and Without AI

A synthetic avatar commenting on politics daily for hundreds of thousands of followers dissolves the chain of responsibility. Who is the campaigner, the scriptwriter, the client, the account operator, the model owner? What is the platform? Electoral law does not cover these questions.

The problem is not primarily technological. Ukrainian audiences have for years consumed news through anonymous Telegram channels whose beneficiaries are unknown. The largest, Trukha, changed hands in the summer of 2026, while its public face stayed the same. Reporting over several years has identified different people behind that front at different times, with visible effects on its editorial line. Ukrainian media law requires media outlets to have transparent ownership. A channel with a larger audience than most national broadcasters might not disclose anything, and in other cases a nominal owner satisfies everyone. There are hundreds of such networks.

Recommendations

The temptation after each such case is to ban the instrument used. In 2024 it was TikTok and crypto. Next time it will be something else, and by the time a prohibition is drafted the operation will have moved. No one can predict the vector of the next interference. The question is whether the state can see an anomaly while it is happening and has a response it can use without waiting for new legislation.

Change the question the regulation answers. Questions should not be about how something was financed, but about whose interest the operation served. An influencer need not promote Candidate A at all; systematically attacking Candidate B produces the same effect, with no payment from Candidate A's campaign fund and no mention of Candidate A anywhere. As long as the law asks who paid whom, such operations do not exist for it.

Make monitoring of the information space a standing function. Monitoring broadcast airtime was once routine electoral oversight. The terrain has moved, but the function has not followed. The equivalent today is systematic analysis of social platforms and messengers, requiring open-source intelligence and machine analysis. That requires different competencies and budgets, cooperation with civil society organizations already doing part of this work better than the state, and rules on what the state may do with the resulting data so that it does not turn monitoring itself into an instrument of pressure.

Make the response graduated and fast. Fines should be scaled to the reach purchased rather than the sum paid. Instances of violation of the regulations should be prosecuted, and organizers must face sanctions personally. Speed is the operative word: A tool that works three years after the vote does not protect an election, it records that the election was unfair. Two conditions are non-negotiable: Published criteria should replace official discretion, and there should be a traceable evidentiary basis that can be challenged in court.

A Narrow Window

The Verkhovna Rada extended martial law for the twentieth time on July 14, 2026, and elections remain prohibited while it is in force.

The absence of an electoral cycle is usually perceived as a problem. In this instance, it is also an advantage, albeit a temporary one. With no specific candidates, lists, or campaigns, the discussion can focus on the design of principled, nonpartisan election regulations. Such rules must be written before the game; what gets written during the game is often not a rule, but an advantage for one of the players.

This article draws on the policy report “Preparing for Ukraine's First Post-War Elections”, produced by the foreign policy council "Ukrainian Prism" together with the German Marshall Fund of the United States Transatlantic Foundation (GMF TF) under the ProElect project. You can read the full report here.

This publication was produced with the financial support of the EU and GMF TF. The views expressed herein are those solely of the author(s). GMF as an institution does not take positions.