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The situation is familiar to thousands of Ukrainian drivers: a speeding notice appears in your Driver’s Cabinet (the police online account for drivers), in the Diia app or in your letterbox, and you know for certain that on that day the car was driven by your son, your wife, a friend or a hired driver. In this case the law does not ask who was behind the wheel: the notice is issued automatically against the responsible person, that is, as a rule, against whoever the car is registered to. For brevity we use the word “owner” below, although the legally precise term is “responsible person”. Yet the same law provides a mechanism that either removes liability from the owner entirely or transfers it to the person who actually broke the rules. This is the substitution of the liable person, and it comes with a hard deadline, several mandatory conditions and quite a few practical traps. Here is the procedure step by step: from why the fine reaches the owner at all, to what to do once the 20 days have passed.
This material is for information only and is not legal advice. Legislation and the practice of applying it change, so before making decisions in a specific situation we recommend consulting a lawyer.
A camera sees only the number plate and does not identify the driver, so for automatic enforcement the legislator introduced a special rule. Article 14-2 of the CUAO defines who answers for such offences:
The notice is issued without a protocol and without the owner being present, and is then sent to the owner. The law starts from the assumption that the owner controls who gets the keys and is best placed to identify the actual driver. That assumption is rebuttable: part three of Article 14-2 states directly that the responsible person is released from liability in the cases provided for by Article 279-3 of the CUAO.
This model has already been tested before the Constitutional Court: by the Decision of the First Senate of the Constitutional Court of Ukraine of 11 December 2025 No. 7-r(I)/2025, an analogous construction of liability for offences in the field of road transport safety (Article 14-3, part one, and Article 132-1, part two, of the CUAO) was found to be constitutional. The Court noted that the provision contains a presumption of fact as to who was driving the vehicle, and that this presumption may be rebutted by the responsible person in the manner established by law. The decision concerns a neighbouring provision, but the logic is the same: the owner is liable by default until the statutory mechanism is used.
We covered the offences that cameras record and the size of the fines in a separate piece about Article 122 of the CUAO. Here we focus on the procedure.
Article 279-3 of the CUAO provides two independent grounds. They work differently, and they should not be confused.
The owner submits a document confirming that, before the offence, the car left their possession through the unlawful acts of other persons, or that other persons unlawfully used the owner’s number plates. Examples: the car was stolen, the plates were removed and fitted to another vehicle, or someone is driving with “cloned” plates.
Result: the notice is cancelled by the same authority that issued it. Nobody becomes the liable person, because the offender still has to be found.
An important nuance: “leaving possession through unlawful acts” does not cover the situation where you voluntarily handed the car to a friend, a relative or a renter. A lease agreement, a power of attorney or an insurance policy naming another driver are not grounds for cancelling the notice under this option. For a voluntary handover of the car there is the second route.
The person who was in fact driving the car at the moment of the offence applies in person to the authority empowered to consider such cases, with a statement admitting the offence and consenting to being held administratively liable, and also submits a document (a receipt) confirming payment of the corresponding fine.
Result: the notice already issued is amended as to the subject of the offence. No new notice is issued, and the owner drops out of the existing one. Since the driver becomes the subject of the offence, the further consequences, in particular the record of repeat offending, should as a general rule attach to the driver.
Three mandatory elements: the application is filed by the driver, not by the owner; it contains an admission of the offence and consent to liability; and it has the payment receipt attached. Without any one of them the police will not grant the application.
The deadline for both options is the same: 20 calendar days. But the law names two starting points: the day the offence was committed, or the day the notice became legally effective.
The notice is often issued several days or weeks after the offence, and reaches the owner later still. If the count ran only from the day of the offence, in many cases the deadline would expire before the person even learned about the fine. The law does not explain which of the two moments prevails, so in practice it is safer to work from whichever date falls earlier, and to file as soon as possible after you learn about the notice.
Under Article 291 of the CUAO, an automatic enforcement notice becomes legally effective once it has been served on the person, or once the postal confirmation of delivery, of refusal to accept, or of return of the letter marked as undelivered has been received. In other words, there is no point in ignoring a letter from the police: a returned envelope also starts the clock.
Practical advice on the deadline:
An application under Article 279-3 is filed with the authorised unit of the National Police. For offences recorded by cameras this is the Patrol Police Department and its regional directorates. Official sources confirm two ways of filing.
Electronic identification performs the function of the “personal application” referred to in Article 279-3: the signature identifies the applicant unambiguously, so there is no need to travel to a police unit.
In the Driver’s Cabinet (e-driver.mvs.gov.ua) and in Diia (Ukraine’s state services app) you can view the notice, check its status and pay the fine. But as of 2026 the official instructions tie the filing of the Article 279-3 application itself to bdr.mvs.gov.ua and to applying in person. Diia and the Driver’s Cabinet do, however, fully cover a different task: designating an authorised user, so that future fines go straight to the person who actually drives.
Some lawyers mention the possibility of emailing the application signed with a QES to the police unit. This route is not described in the official instructions, so we do not advise relying on it as your only option: if the email goes astray, the deadline is lost.
The law prescribes no rigid form: Article 279-3 requires only an admission of the offence, consent to being held liable and a receipt for payment of the fine. The remaining details come from the official template that the patrol police have published on their website. In practice the actual driver’s application contains:
The attachments are the receipt for payment of the fine (mandatory), copies of the applicant’s driving licence and passport, and a copy of the notice or its number.
Formally the law requires only the application and the receipt. Still, it is useful to have evidence at hand that the driver really did use the car: an insurance policy naming that driver, a lease or loan-for-use agreement, a power of attorney, a waybill. For Option 2 these are not mandatory, but they will help if the matter reaches a court.
For Option 1 (the car left your possession) documents are exactly what you need:
Key piece of advice: report the theft of the car or the plates to the police the moment you discover it, not after the fine arrives. A document dated after the notice raises legitimate doubts.
Under Article 14-2 of the CUAO, if the car is registered to a legal entity, the fine goes to its head as an individual. Not to the company, but to the director personally. The director of a business with a fleet of 50 cars receives every notice and has 20 days in each case to arrange the substitution of the liable person.
What a company should do:
Renting and leasing. A leased car is registered to the leasing company, so the notice goes to that company’s head. A lessor of a rental car is in the same position. A lease or rental agreement does not amount to “leaving possession through unlawful acts”, so cancelling the notice under the first option will not work. What works is either an authorised user designated in advance, or an application by the actual driver under the second option. Leasing and car rental companies usually write into their contracts an obligation for the client to settle such fines within a few days, plus penalties for failing to do so. If you are the renter, read that clause carefully: it is often cheaper to admit the fine yourself than to pay the company an inflated compensation.
Article 279-3 makes no provision for reinstating a missed deadline. After 20 days the police will not amend the notice even if the driver’s application and the receipt are there. But the owner still has options.
Appealing the notice. Under Articles 288 and 289 of the CUAO, an automatic enforcement notice can be appealed within 10 days from the day it became legally effective, either to a higher authority (a senior official) or to a court. If that deadline is also missed for valid reasons (illness, a business trip, being abroad, military service), you can ask for it to be reinstated. Whether the reasons are valid is assessed by the authority or the court, and explanations along the lines of “I did not see the letter” usually do not work.
In the appeal the owner does not admit the offence but proves that they were not driving. Evidence: written explanations from the actual driver, that driver’s licence, an insurance policy, a contract, proof that the owner was elsewhere (tickets, business trip records, geolocation data, camera footage) and company documents.
The case law, as we observe it, is inconsistent. Some courts cancel notices where the owner convincingly proves that a different, identified person was driving, relying on the personal nature of liability. Others refuse, pointing out that the law has established a special mechanism in Article 279-3 with its own deadline, and that an owner who did not use it answers under Article 14-2. The forecast therefore depends on the quality of the evidence and on how the legal position is framed.
Paying and settling it privately. Sometimes this is the most sensible route, especially where the amount is small. The key point to remember: if the fine is not paid within 30 days from the day the notice became legally effective, it goes to enforced collection, and under Article 308 of the CUAO double the amount of the fine is recovered from the offender. Doing nothing is the most expensive option of all.
All the key periods run from the day the notice became legally effective:
The discount and the substitution are compatible. If the actual driver pays the fine within the first 10 days, that driver pays half, and it is this receipt that goes with the application. If the application is filed on day 15, the full amount has to be paid. The optimal tactic: the driver pays within the first 10 days and files immediately. If the owner has already paid and the driver then pays as well, the money paid in error can be recovered: the patrol police operate a separate refund procedure for mistakenly transferred funds, with template applications.
An appeal and a substitution rest on different logic. Substitution rests on the actual driver admitting the offence. An appeal rests on denial: the owner argues that the notice against them is unlawful because they were not driving. You can file both documents at once, but it looks contradictory. The rational sequence: if the driver is known and willing, start with the substitution; if the driver refuses or cannot be identified, appeal within the 10 days. Under Article 300-1, filing an appeal suspends the running of the payment deadlines, so the risk of a double fine while the appeal is pending disappears.
In a simple case (the driver agrees, the deadlines are not tight, the payment has gone through) you can handle the procedure yourself. A lawyer is needed once complications appear:
A lawyer assesses the prospects, prepares the application or the appeal, gathers evidence and represents you before the police and in court. A lawyer cannot guarantee the outcome, because it is determined by the authority or the court on the basis of the evidence, but a lawyer substantially improves the odds and prevents mistakes that cannot be undone later.
Can the owner simply tell the police who was driving, without the driver taking part?
No. Article 279-3 of the CUAO requires the actual driver to apply personally with a statement admitting the offence, to consent to being held liable and to provide a receipt for payment of the fine. A report from the owner without the driver’s application is not a ground for amending the notice. If the driver refuses, all that remains for the owner is to appeal the notice with evidence that they were not driving the car.
From which day are the 20 days counted?
The law names two starting points: the day the offence was committed, or the day the notice became legally effective. An automatic enforcement notice becomes effective once it is served, or once the postal confirmation of delivery, of refusal to accept, or of return of the letter is received. In practice, work from the day the notice took effect, but do not leave filing to the last days, because the fine still has to be paid before the application.
Who pays the fine when the liable person is substituted, and how much?
The actual driver pays, because it is that driver’s receipt that goes with the application. If payment is made within the first 10 days after the notice became legally effective, the 50% discount under Article 300-1 of the CUAO applies. Later, the full amount has to be paid. If the owner has already managed to pay, the money can be recovered through a separate procedure at the patrol police.
Can the application be filed through Diia or the Driver’s Cabinet?
As of 2026, the official instructions of the Ministry of Internal Affairs and the patrol police describe two methods: online through bdr.mvs.gov.ua with a qualified electronic signature, and in person at a patrol police unit. In Diia and the Driver’s Cabinet you can view the notice, pay the fine and designate an authorised user for the future, and since May 2026 the Diia.AI chat also helps you make sense of traffic fines. As a way of filing the Article 279-3 application itself, however, the official sources still name bdr.mvs.gov.ua and applying in person, so those are the ones to treat as primary.
What happens if the 20 days are missed?
The police will not amend the notice, because Article 279-3 makes no provision for reinstating this deadline. What remains is an appeal to a higher authority or to a court within 10 days from the day the notice became legally effective, and if that deadline has passed too, an appeal together with a request to reinstate it for valid reasons. The case law in such matters is inconsistent, so everything depends on the evidence.
The car is leased. Who receives the fine and what should be done?
The notice goes to the head of the leasing company the car is registered to. A leasing contract is not a ground for cancelling the notice. Two instruments work: an authorised user designated in advance (fines then go straight to the lessee or the lessee’s driver), or an application by the actual driver under Article 279-3 within the 20 days. Check your contract for the obligations and penalties it sets out for you in the event of fines.
Are there risks for a driver who takes the offence on?
Yes. That driver becomes the subject of the offence with all the consequences, including the record of repeat offending. If the same driver commits a similar offence again within a year, the penalty can be harsher. So admit an offence only where you genuinely were driving the car.
LEXON lawyers work with automatic camera fines every day: we check deadlines, prepare applications and appeals, gather evidence and represent clients before the police and in the courts of Kyiv and across Ukraine. We are available 24/7.
Call: 097 037 73 33, or leave a request through the form on lexon.in.ua and we will get back to you as soon as possible.
Related service: auto lawyer in Kyiv.
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