Members of the European Business Association (EBA) have called for the rejection of the draft resolution on the resumption of scheduled inspections of subsoil users.
The corresponding appeal to officials is posted on the EBA website.
The EBA reported that on February 26, 2025, the State Service of Geology and Subsoil of Ukraine published a draft resolution of the Cabinet of Ministers of Ukraine, which proposes to amend Government Resolution No. 303 of March 13, 2022. In particular, the document provides for the resumption of scheduled and unscheduled inspections of subsoil users whose activities are of a high risk.
Why this project was developed
After analyzing the published document, EBA experts concluded that its main purpose is to identify and prevent the formation of so-called “dormant permits”. They noted that there could potentially be only 29 of them, but more than 300 companies would be subject to inspections.
Why the EBA considers its adoption irrational
The EBA experts reminded of two important circumstances:
- the current legislation already provides for the possibility of unscheduled inspections in case of a threat to the rights of citizens, the environment, or the security of the state;
- in accordance with the Subsoil Code of Ukraine, the grounds for termination of a special permit are failure to take measures to eliminate violations after they are detected during the control.
Based on this, the problem of “dormant permits” can be solved without massive inspections of all subsoil users, experts believe.
“Under martial law, a significant part of the industry operates in extremely difficult conditions due to security risks, staff shortages, disruption of logistics chains and energy supply,” the EBA reminded.
Therefore, the EBA members warned that the introduction of large-scale inspections affecting hundreds of companies would create additional administrative and financial pressure, which in turn could lead to a halt in production processes.
With this in mind, EBA members asked to reject this draft resolution.
In January, business representatives insisted on additional work on draft law No. 12188 “On Mining Waste,” and the Committee on Environmental Policy and Nature Management agreed to their proposal to extend the deadline for submitting and processing proposals to this draft law to 3 weeks.
EcoPolitic also informed that the Ministry of Environmental Protection and Natural Resources of Ukraine proposes to cancel the permit for special use of natural resources for minerals.
