The frontline region of Kharkiv has suspended its environmental programmes due to the war. Where is the environmental tax going?

The frontline region of Kharkiv has suspended its environmental programmes due to the war. Where is the environmental tax going? Shutterstock
Maria Semenova

The last time funds were allocated from the ONPS fund was for the disposal of incandescent light bulbs in 2024

Kharkiv region had ambitious plans for environmental protection. However, over time, funding for environmental measures in the region from the environmental protection fund ceased entirely. In smaller towns, eco-programs were approved already during the full-scale war. There, as usual, the leading priorities are wastewater and waste management.

EcoPolitic continued to analyze how the environmental tax is used in the regions of Ukraine. The situation in Kharkiv region is unique, as it is located on the frontline, and the regional center suffers from enemy shelling daily. So is there still room for ecology here?

Environmental plans of the region

Kharkiv region received its environmental program at the end of December 2020. The document, approved by the regional council, covers the period from 2021 to 2027.

At that time, with no idea that the region would become a frontline area and that part of it would even experience temporary occupation, officials identified 10 main directions for environmental work.

It should be noted that the document does not include even estimated amounts of funding for specific measures. At the same time, every section lists the regional Environmental Protection Fund (EPF) as the source of financing. There is also a lack of specifics in the measures described only general characteristics are provided.

  1. Protection and rational use of water resources. This includes the construction and reconstruction of facilities for wastewater treatment, water supply systems, purchase of pumping equipment, surveys, registration and cleaning of water bodies, and more.
  2. Protection of atmospheric air. This block encompasses measures to reduce air pollution through treatment of industrial and transport emissions, implementation of environmental technologies, creation of air quality monitoring systems, and inventory of pollution sources.
  3. Protection and rational use of land. This section also covers a broad range of measures from the construction of anti-erosion and hydraulic structures to forest restoration and reclamation of municipal solid waste landfills.
  4. Protection and rational use of mineral resources. This refers to the introduction of environmentally safe technologies in the mining industry, deposit protection, landfill remediation on contaminated areas, and more.
  5. Protection and rational use of natural plant resources. This section combines waste disposal from wood processing, mitigation of storm damage, and landscaping of settlements.
  6. Protection and rational use of animal resources. The section mentions animal shelters, nurseries for birds and juvenile commercial fish, and maintaining an animal resources cadastre.
  7. Preservation of nature reserve fund. In this block, both the creation of centers for breeding rare species and the repair of reserve institution buildings are included.
  8. Rational use and storage of industrial and household waste.
  9. Nuclear and radiation safety.
  10. Scientific and information-educational activities.

So what measures have been taken and how much of the environmental tax was spent on them? This is more difficult to determine, as the data are either unavailable or provided only upon request for access to public information.

Among other things, EcoPolityka received a document from the Kharkiv Regional State Administration regarding the implementation of the comprehensive environmental program for 2023. It was revealed that only one activity from the “Waste Disposal” section was financed. Funding was planned at more than UAH 2.2 million, but only about 48% of that amount was used – UAH 1.06 million.

In the regional document database, we also found information about the implementation of environmental protection program activities in 2024. This database also mentions a waste disposal activity, for which UAH 16,362 from the regional Environmental Protection Fund (ONPS) was allocated. This involved the disposal of incandescent bulbs that the public turned in to JSC Ukrposhta.

By 2025, however, no activities were implemented at the expense of the environmental tax at all. It is also ironically notable that the decision of the regional council was to “continue work on the implementation of the comprehensive Environmental Protection Program of Kharkiv Region for 2021–2027.”

However, this does not mean that polluting enterprises have stopped paying the environmental tax. In just the first eight months of 2025, they contributed UAH 116.7 million to the consolidated budget. For the first five months of 2026, the amount of the environmental tax was UAH 56.3 million.

We assume that the ONPS fund resources were reallocated according to wartime needs. However, no specific decisions on redirecting environmental funds for other initiatives were found – it is likely that these resources are dispersed within the special regional budget fund.

In the city of Kharkiv, the environmental program was also approved in 2020. Its contents closely echo the regional program, except that it contains somewhat fewer activities and does not include sections on mineral resources or nuclear safety.

Ecology in smaller cities

In the city of Derhachi, an environmental program was adopted in autumn 2025. Over five years, they planned to allocate UAH 169.1 million for environmental protection. The funding sources state, regional, and city budgets, as well as “other sources.”

If we look at the most expensive activities, everything is quite predictable. The main project, with a total cost of UAH 148.5 million, is the reconstruction of the wastewater treatment facilities. Around UAH 1.5 million is allocated for the development of design documentation.

Over five years, another UAH 10.1 million is planned for the arrangement of waste collection sites, and UAH 5 million for the purchase of waste containers. UAH 4 million is set aside for the elimination of unauthorized dumpsites.

In the city of Merefa, the environmental protection program covers the period from 2026 to 2028. In its section 3, we see indicative activities, although without allocated funding. These include reconstruction and new construction of treatment facilities in the city and surrounding settlements, anti-erosion measures, creation of a waste transfer station, and an organic waste composting facility.

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