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Ukraine Simplifies Licensing and Permitting Procedures During Martial Law

On 18 March 2022, the Cabinet of Ministers of Ukraine adopted Resolution No. 314 “On Certain Matters for Ensuring Business Activity During Martial Law”. For the duration of martial law, the Resolution provides a temporary declarative procedure for obtaining rights to carry out businesses, which, in peaceful times, were subject to licensing or permission. The Resolution also prolongs the effect of lapsed licenses and permits.

Companies that use this temporary release will have to apply for the relevant licenses or permissions immediately after the end of martial law, but not later than one month.

Simultaneously, the Resolution provides an exhaustive list of risky business activities and permits excluded from the general declarative rule and will not be prolonged automatically. The list includes operations in the realm of nuclear power, maintaining radioactive materials and equipment, production of explosive and hazardous chemical materials, manufacturing of medicines (with a caveat for current manufacturing license holders explained below), environmental impact assessment, special water usage, forestry, and permits for developers to carry out construction work regarding CC2 and CC3 objects. The excluded business activities that are not subject to declarative rule also include TV and radio broadcasting activities, use of radiofrequency resource, and gambling activities.

Note that oil and gas subsoil permits will not be extended automatically. Moreover, the Law on Amendments to Certain Legislative Acts of Ukraine on Environmental activities and civil protection for the period of martial law No. 2132-IX dated 15 March 2022 authorises military administrations of settlements in the relevant territory to issue permits for subsoil use – except for oil and gas – for no more than one year in accordance with the approved list and procedure. Thus, the following activities are excluded from the list that falls under the general declarative rule:

  • exploration of oil and gas subsoil, including research and development of fields, research and industrial development of fields with subsequent oil and gas production (industrial field development), oil and gas production (industrial field development);
  • exploration, including research and development of mineral deposits of national importance, extraction of minerals, performance of works (activities) provided for in the production sharing agreement;
  • exploration of amber subsoil, including research and development of deposits with subsequent amber mining (industrial development of deposits);
  • exploration, including research and development, and extraction of minerals of strategic importance for sustainable economic development and defence capabilities of the state.

The businesses and activities that can apply the eased rules include:

  • import, wholesale and retail trade of medicines, as well as manufacturing, but only for current manufacturing license holders (we assume this pertains to any extension/variation of current manufacturing activities, such as manufacturing of new pharmaceutical forms);
  • appraisal services;
  • security services;
  • waste-disposal services;
  • placement of outdoor advertising;
  • high-risk works and use of machinery and equipment;
  • dredging works;
  • air emission.

Declarative procedure

A company should submit a declaration in electronic (through the Unified state web-portal of electronic services) or paper (through local Centres of administrative services) form to the Ministry of Economy of Ukraine.

The declaration should contain the following information:

  • company type, name, registration code, and address;
  • company’s current place of business;
  • type of activity that a company intends to carry out;
  • permitting documentation, which is being replaced by the declaration during martial law; and
  • confirmation that the applicant has acknowledged and will align with legislative requirements for the relevant activity.

Ukraine's Ministry of Economy will then hand the declaration to the authority responsible for issuing a relevant license or permitting document.

Legislation: Resolution No. 314 “On Some Issues of Ensuring Business Activity During Martial Law”.

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