The Association draws attention to the following!

The National EITI Secretariat (Extractive Industries Transparency Initiative – EITI) has published a preliminary list of extractive companies that hold special subsoil use permits for the extraction of mineral resources and are required to report in accordance with the Law of Ukraine “On Ensuring Transparency in the Extractive Industries” (available at: https://eiti.gov.ua/pidpriyemstva-ta-organizaciyi/pidzvitni-kompaniyi-vidobuvnogo-sektoru/).

This list, which includes a significant number of crushed stone producers, is subject to further clarification.

The Law of Ukraine “On Ensuring Transparency in the Extractive Industries” establishes the legal framework for collecting, disclosing, and disseminating information to ensure transparency and prevent corruption in Ukraine’s extractive sectors.

In particular, the Law stipulates:

1. Extractive industries refer to sectors involved in geological exploration of subsoil, including pilot industrial development of mineral deposits of national importance, extraction of such minerals, and the sale of extracted products — all conducted based on a special subsoil use permit and an agreement on the terms of subsoil use (third paragraph of part one of Article 1).
2. Reporting entities include business entities operating in the extractive industries as well as parent companies in the sector (part one of Article 4).
3. Business entities engaged in extractive activities are required to disclose their (consolidated) reports on payments to the state annually, no later than September 1 of the year following the reporting period (first paragraph of part one of Article 12).
4. Failure to disclose information or delays in reporting, as stipulated in Article 12 of the Law, may result in a fine of five thousand tax-exempt minimum personal incomes (UAH 85,000) for both operating and parent companies in the extractive industries (part one of Article 14).

The Association also informs that, by Resolution No. 388 dated April 8, 2025, the Cabinet of Ministers of Ukraine has amended Annexes 1–3 (Report on Payments to the State, Consolidated Report on Payments to the State, and Report on Received Payments) to Resolution No. 858 dated September 23, 2020, “Certain Issues of Ensuring Transparency in the Extractive Industries,” adopting updated versions of these forms.

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