Prior to the 2022 Russia’s invasion, Ukraine made significant progress in open government, Internet Governance, and effective data governance, ranking among the leaders in Open Data and Global Data Barometers. However, in 2022, the country’s approach to data governance shifted. During the early weeks of Russia’s full-scale invasion, Ukraine’s government closed most of its data registries and changed relevant legislation to introduce more data regulations and restrictions. This strategy faced severe criticism from the media, tech sector, and civil society. Under pressure, the government is reversing some of its earlier restrictions, which strongly affected transparency and monitoring capacities of various watchdogs and active citizens in the country; and it is also readjusting its strategy toward open government. However, Ukraine has not returned to its previous approach of transparent and collaborative data governance, and the courts side with the legislators when it comes to access to certain datasets. State vulnerability, extreme conditions, and the usage of open data by the enemy are often cited as the main reasons for such restrictions. This research examines the legal framework for the current state of affairs and compares Ukraine’s previous data governance model with the one proposed by the legislators amid the Russo-Ukrainian war. Further, the work analyzes implications for different state institutions and civil society amid the ongoing tensions with the government. The paper provides an overview of approaches recommended by the relevant experts for a better balance between transparency and security. The conclusions of the research highlight important parallels and lessons learned for other similar environments where changing data governance models are being considered under similar conditions, and how inclusivity and privacy are maintained while safety and data regulations are preserved.