On the Ukrainian Geological Survey rejection of all business associations’ comments and the meeting at the State Regulatory Service of Ukraine

As previously reported (see the information in the News section dated February 27, 2025), the Ukrainian Geological Survey has developed a draft resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolution of the Cabinet of Ministers of Ukraine dated March 13, 2022 No. 303”, which provides for the resumption of planned and unscheduled measures of state supervision (control) over compliance with the requirements of the legislation in the field of geological exploration and rational use of subsoil for high-risk business entities.

The Association of Aggregates Producers of Ukraine (see information in the News section as of March 12, 2025), as well as the NGO Association of Gas Producers of Ukraine, the National Association of Extractive Industries of Ukraine, the European Business Association provided their comments to this draft resolution, which concerned the absence of the term “dormant permits” in the current legislation and the possibility of their detection through the analysis of statistical and financial statements; creation of additional complications and risks for economic activity.

However, all the comments of the above business associations were rejected by the Ukrainian Geological Survey.

At the same time, the statement of the Ukrainian Geological Survey that “the shortfall in planned budget revenues from dormant permits with a high degree of risk is significantly higher than for dormant permits with a medium and low degree of risk” was not supported by any figures.

As for the absence of the terms “dormant permit” or “dormant permits” in the current Ukrainian legislation, the reference of the State Service of Geology and Mineral Resources of Ukraine to the fact that “the legislation does not establish the concept of ‘dormant permit’, while the term is used by members of the Verkhovna Rada of Ukraine, the President of Ukraine and law enforcement officials in reports and justifications for the need to bring subsoil users’ activities in line with the requirements of the legislation in the field of geological exploration and rational use of subsoil” does not stand up to any criticism.
Therefore, on April 04, 2025, the State Regulatory Service of Ukraine held a meeting to discuss the draft resolution of the Cabinet of Ministers of Ukraine “On Amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 303 of March 13, 2022”.

At the end of the meeting, the First Deputy Head of the State Regulatory Service of Ukraine, O.V. Krasnolutskyi, who chaired it, said that the meeting would be followed by a corresponding protocol that would be sent to all those present.
As of the date of preparation of this section of the News, the Association has not received the above-mentioned minutes.

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