Subsoil users do not support the resumption of unscheduled inspections during martial law

05/ 02/ 2026

Member companies of the Subsoil Use Committee of the European Business Association have expressed concern over the Government’s decision to resume unscheduled state geological control measures during the period of martial law. Despite the fact that the Programme of Activities of the Cabinet of Ministers of Ukraine provides for a moratorium on business inspections, on 28 January 2026 the Government adopted Resolution No. 121, allowing unscheduled inspections in the field of state geological control during martial law. According to the Association’s member companies, the resumption of inspections will create additional pressure on businesses that are already operating under extremely challenging conditions, including constant shelling, destruction, the need to restore infrastructure, power supply disruptions, and other wartime challenges. The Association has repeatedly emphasised that the resumption of state geological control contradicts the position of the State Regulatory Service of Ukraine, which had previously refused to approve draft regulations aimed at restoring such inspections during martial law. Furthermore, the decision is inconsistent with the Government’s declared priorities, as the Programme of Activities of the Cabinet of Ministers provides for a five-year moratorium on business inspections. The business community is also concerned that draft Resolution No. 121 was not published for public consultation, making it impossible for businesses to conduct a comprehensive analysis of the document and prepare well-founded proposals and comments. Subsoil users expect the Government to adopt a balanced decision that would allow unscheduled state supervision (control) measures in the field of geological exploration and the rational use of subsoil resources only on justified grounds and based on a decision of the Ministry of Economy, Environment and Agriculture of Ukraine.

Despite the fact that the Programme of Activities of the Cabinet of Ministers of Ukraine provides for a moratorium on business inspections, on 28 January 2026 the Government adopted Resolution No. 121, allowing unscheduled inspections in the field of state geological control during martial law.

According to the Association’s member companies, the resumption of inspections will create additional pressure on businesses that are already operating under extremely challenging conditions, including constant shelling, destruction, the need to restore infrastructure, power supply disruptions, and other wartime challenges.

The Association has repeatedly emphasised that the resumption of state geological control contradicts the position of the State Regulatory Service of Ukraine, which had previously refused to approve draft regulations aimed at restoring such inspections during martial law. Furthermore, the decision is inconsistent with the Government’s declared priorities, as the Programme of Activities of the Cabinet of Ministers provides for a five-year moratorium on business inspections.

The business community is also concerned that draft Resolution No. 121 was not published for public consultation, making it impossible for businesses to conduct a comprehensive analysis of the document and prepare well-founded proposals and comments.

Subsoil users expect the Government to adopt a balanced decision that would allow unscheduled state supervision (control) measures in the field of geological exploration and the rational use of subsoil resources only on justified grounds and based on a decision of the Ministry of Economy, Environment and Agriculture of Ukraine.