President Signs Law No. 4831-IX 'Industrial Visa-Free Regime' — Start of ACAA Implementation

On April 21, 2026 the President signed Law No. 4831-IX 'Industrial Visa-Free Regime'. The signature activated NAAU peer evaluation in EA and started a 12-18-month countdown to ratification of the ACAA agreement.

14 days passed between Verkhovna Rada adoption on April 7 and the President's signature — a standard executive cycle for laws of this class. According to eurointegration.com.ua, the document was published the same day; entry into force will follow the timing set in the final provisions.

The substance of Law No. 4831-IX (alignment with EU Regulation 765/2008 and EU Decision 768/2008, priority sectors LVD/EMC/Machinery) was covered in the previous piece — Verkhovna Rada adopted Law No. 4831-IX — details and content. This text does not repeat the legislative part — the focus is strictly on what was activated on April 21 and what manufacturers, certification bodies, and laboratories should do about it.

The signature is not a mere formality. It launches three parallel processes at once, each with its own owner and deadline.

1. NAAU files a peer evaluation application with EA. The National Accreditation Agency of Ukraine (NAAU) is already an MLA signatory for several scopes (testing, calibration, inspection, certification of management systems, product certification, validation/verification — confirmed by the extension on July 30, 2024). ACAA requires an MLA extension to a broader priority scope under 768/2008 — this is a separate procedure, not a full re-evaluation. Status details are on naau.org.ua.

2. The Ministry of Economy publishes the 2026 technical regulations harmonization plan. The reference point is order No. 4964 of April 15, 2026, which sets the sequence for adopting UA equivalents of Directives 2014/35, 2014/30, and 2006/42 in the editions aligned with the EU updates.

3. Ukraine as a state gains formal grounds to submit an offer on the ACAA Agreement. Until this moment, the absence of a harmonized accreditation law had blocked the negotiation track.

For business this means the previous 'waiting for the law' status is closed; the new status is 'preparing the system for peer-evaluated certificates'.

The European co-operation for Accreditation (EA) mutual recognition procedure is described on european-accreditation.org. For ACAA it is critical: without peer-evaluated NAAU accreditation under the relevant scope, a Ukrainian certificate will not gain automatic recognition in the EU.

Step 1. Application. NAAU files an application for specific MLA scopes that match ACAA priority sectors. The Multilateral Agreement Council (MAC) within EA appoints an evaluation team — usually 4-6 experts from EU accreditation bodies.

Step 2. Document and on-site review. The team assesses the NAAU management system, the full documentation package, and runs observation of assessments — watching how NAAU actually evaluates certification bodies and laboratories. This is the longest stage (typically 4-6 months).

Step 3. Reporting. The evaluation team produces a written report with conformance and non-conformance findings and formulates a scope recommendation for MAC.

Step 4. Decision (MAC). The Multilateral Agreement Council of EA approves the scope and grants NAAU MLA signatory status in the relevant area.

The previous regular peer evaluation of NAAU took place in June 2023 — confirming that EA already recognizes the underlying accreditation system. The additional evaluation under ACAA is an extension of the existing MLA, not a new cycle from scratch. This nuance is often confused in the media: NAAU is not starting recognition 'from zero' but expanding scope under 768/2008 modules.

How NAAU peer evaluation differs from ISO/IEC 17025 laboratory accreditation. A laboratory is accredited under ISO/IEC 17025 by NAAU itself — this is the regular service of an accreditation body. NAAU peer evaluation is an assessment of NAAU itself by EA peers. A laboratory does not undergo peer evaluation personally, but it benefits: after a positive MAC decision, its accreditation is automatically recognized in EA MLA member countries.

The total period from signature to mutual recognition of certificates is 12-18 months, with the earliest window in Q4 2027. Here is the phase-by-phase breakdown tied to the calendar.

Months 0-3 (May-July 2026). Official publication of the law, entry into force, NAAU application filed with EA, Ministry of Economy publishes the updated register of technical regulations under 768/2008.

Months 3-9 (August 2026 - February 2027). EA team document review and on-site visit. In parallel, certification bodies prepare technical procedures under modules B/C/D/H, and laboratories extend their ISO/IEC 17025 scope to EN series.

Months 9-12 (March-June 2027). EA Reporting → MAC Decision. In parallel, the European Commission runs its own pre-assessment of Ukraine's ACAA readiness based on the EA report and internal due diligence.

Months 12-18 (July-October 2027). Formal negotiations of the ACAA text, signing, ratification by the European Parliament and the Verkhovna Rada. Real mutual recognition of certificates is possible no earlier than Q4 2027, realistically Q1-Q2 2028.

This is not a reason to wait. Manufacturers in priority sectors who do not build a certification system aligned with ACAA before ratification will not get it instantly — the bottleneck is peer-evaluated CB accreditation, not the ratification itself. Preparation should start at month 0, not month 18.

Here are concrete actions for the three priority sectors: LVD (2014/35), EMC (2014/30), Machinery (2006/42). Three phases of 6 months each.

Phase A — months 0-6 (May-October 2026): diagnostics and foundation.

• Gap audit of QMS against the requirements of 768/2008 modules (Module B — type examination; Module C — conformity to type; Module D — production quality assurance; Module H — full quality assurance).
• Verify whether the current CB is preparing for peer-evaluated accreditation under the relevant scope. If not — search for an alternative body with NB-equivalent status post-ACAA.
• Review of technical files against harmonized EN standards: for LVD — the EN IEC 60335 and EN 61058 series; for EMC — EN 55014, EN 55032, EN 61000; for Machinery — EN ISO 12100, EN ISO 13849.
• Internal decision: revision-style transition (extending the existing system) or parallel system (a separate structure with UA + EU loops). For most manufacturers the rationale is revision.
• Order an ACAA-readiness diagnostic audit to fix the starting point.

Phase B — months 6-12 (November 2026 - April 2027): closing gaps and Stage 1/2.

• Closing gaps found in Phase A: procedure updates, staff training, monitoring plans, supplier verification. This is the implementation of QMS for ACAA requirements.
• Stage 1 and Stage 2 audits with a peer-ready CB.
• Test reports from a laboratory with ISO/IEC 17025 accreditation and a scope matching EU notified body equivalents.
• Declaration of conformity in UA format synchronized with the EU CE-DoC. At this stage Stage 1/2 audit support is useful.
• Integration of leadership requirements in ISO 9001 into the system — clause 5 of ISO 9001 is the baseline without which a peer-ready CB will not close Stage 2.

Phase C — months 12-18 (May-October 2027): supervision and swap.

• CB-scheduled surveillance audit cycle.
• Documentation prep for the automatic 'swap' of a UA certificate to an EU-recognized one — this is not new certification but a status upgrade, provided the CB has passed peer-evaluated accreditation.
• Documentation for customs and EU customers on ACAA coverage: English-language DoCs, technical files in the format accepted by EU notified bodies.
• Annual system support for surveillance and certificate maintenance during the transition period.

Cost-benefit: a manufacturer that completes phases A-C in sync with the EA schedule saves 15-30% on duplicate certifications across EU states after ratification and shortens time-to-market by 4-6 months. For exporters in machinery and adjacent industries, this is the difference between a quarterly and an annual cycle for entering a new market.

The Ekontrol team supports the transition to ACAA as a project with clear phases:

• ACAA-readiness diagnostic audit for a manufacturer, CB, or laboratory — gap analysis against 768/2008 modules.
• QMS implementation for ACAA requirements based on ISO 9001 with integration of 768/2008 modules and clause 5 leadership requirements.
• Stage 1 and Stage 2 audit support with a peer-ready CB.
• Annual system support for surveillance and certificate maintenance until ACAA ratification.

For laboratories — a separate track for ISO/IEC 17025 accreditation and scope extension to EU technical standards. Baseline context is in the ISO 9001 implementation guide, the 2026 ISO certification market overview, and the 2026 compliance practicum.

• eurointegration.com.ua — President signs Law No. 4831-IX (April 21, 2026)
• zakon.rada.gov.ua — text of Law No. 4831-IX
• european-accreditation.org — peer evaluation procedure
• naau.org.ua — Cooperation with EA, MLA scopes
• Verkhovna Rada adopted Law No. 4831-IX — previous piece on the site: details and content of the law

Need expert support implementing the changes covered above? Contact the Ekontrol team for a free consultation.