Uncertainty Surrounding the Moratorium on Business Inspections: Business and Regulators Once Again Fail to Reach Consensus

As previously reported (see the “News” section dated 26 June 2025), the Association has once again opposed the approval of the revised draft resolution of the Cabinet of Ministers of Ukraine, developed by the State Service of Geology and Mineral Resources of Ukraine. This draft proposes amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 303 dated 13 March 2022, which would reinstate scheduled and unscheduled state oversight (control) measures to ensure compliance by all business entities with legislation in the field of geological exploration and rational use of subsoil resources.

The draft regulatory act was also not supported by the National Association of Mining Industry of Ukraine and the European Business Association.

The State Regulatory Service of Ukraine has also presented its position on this matter.

From the Association’s perspective, it is evident that the interests of the State Service of Geology and Mineral Resources of Ukraine, as the developer of the aforementioned draft resolution, and those of subsoil users, are fundamentally opposed.

It remains to be seen what decision the State Regulatory Service of Ukraine will take next. Will another joint meeting be held?

It is also of interest how quickly the Government will respond to the instruction of the President of Ukraine to develop a decision on the introduction of a “long-term moratorium on business inspections” (see the “News” section dated 30 June 2025), and what this decision will look like in practice.

Annex: Letter from the State Regulatory Service of Ukraine dated 01 July 2025, No. 2943/20-25.

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