Soon, on December 24, 2024, the Law of Ukraine “On Minimum Reserves of Oil and Petroleum Products” (No. 3484-IX) will enter into force. This step is important for increasing the country’s energy security, ensuring uninterrupted fuel supply during crisis situations, and fulfilling international obligations to the EU.
However, the implementation of the Law raises a number of questions among market participants, in particular regarding:
– Dates of the beginning of formation of minimum reserves.
– Algorithm for meeting new requirements.
– Absence of an approved implementation mechanism.
Based on the appeals of the market participants, the Association sent an official letter to the Ministry of Energy of Ukraine, in which it emphasized the importance of urgently clarifying the key provisions of the Law.
The main provisions of the Law that require clarification:
- Date of liability. According to the Law, the obligation to stockpile occurs 6 months after the end of martial law, but not before the Law comes into force. Given the current extension of martial law until February 8, 2025, there is a need to clearly define this date.
- Absence of an approved order. Currently, there is no mechanism for creating and managing minimum stocks accepted by the Cabinet of Ministers, which leaves business in a state of legal uncertainty.
Why is this important?
Ukraine’s energy security depends on the market’s readiness to act in emergency situations. At the same time, entrepreneurs need clear and transparent conditions for fulfilling their obligations.
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