Subsoil users call for regulation of 2025 reporting under Forms No. 5-GR and No. 6-GR

28/ 01/ 2026

Member companies of the Subsoil Use Committee of the European Business Association report technical issues that make it impossible to submit annual reports for 2025 under Forms No. 5-GR and No. 6-GR via the Subsoil User’s Electronic Cabinet on the State Geological Web Portal. According to business representatives, the service currently does not allow users to proceed to completing the reporting forms, while attempts to access the system result in the electronic resource being unavailable. Experts of the Association note that under martial law and amid a challenging energy situation, subsoil users face the risk of being physically unable to prepare and submit their 2025 reports within the statutory deadlines. The preparation of reports under Forms No. 5-GR and No. 6-GR requires significant labour and technical resources, including access to electronic databases, internal accounting systems, primary documentation, stable communication channels, as well as the ability to print, sign, and scan documents. Due to the systemic unavailability of the state electronic resource, there is a risk of widespread non-compliance with the obligation to submit annual reports for 2025 under Forms No. 5-GR and No. 6-GR for reasons objectively beyond the control of subsoil users. In view of the above, the business community has approached the relevant state authorities with a request to allow the submission of 2025 reports under Forms No. 5-GR and No. 6-GR in paper form, and to publish an official clarification regarding this possibility.

According to business representatives, the service currently does not allow users to proceed to completing the reporting forms, while attempts to access the system result in the electronic resource being unavailable.

Experts of the Association note that under martial law and amid a challenging energy situation, subsoil users face the risk of being physically unable to prepare and submit their 2025 reports within the statutory deadlines. The preparation of reports under Forms No. 5-GR and No. 6-GR requires significant labour and technical resources, including access to electronic databases, internal accounting systems, primary documentation, stable communication channels, as well as the ability to print, sign, and scan documents.

Due to the systemic unavailability of the state electronic resource, there is a risk of widespread non-compliance with the obligation to submit annual reports for 2025 under Forms No. 5-GR and No. 6-GR for reasons objectively beyond the control of subsoil users.

In view of the above, the business community has approached the relevant state authorities with a request to allow the submission of 2025 reports under Forms No. 5-GR and No. 6-GR in paper form, and to publish an official clarification regarding this possibility.