The Fuel and Energy Business Association continues to receive inquiries from market participants regarding whether enterprises designated as critically important by the Ministry of Energy are required to comply with the instructions set out in the letter from the Ministry of Economy dated May 19, 2025, No. 27-11/37509-07.

We remind that the Ministry of Economy, in its letter dated May 19, 2025, No. 27-11/37509-07, announced that it is conducting a verification of whether critically important enterprises continue to meet the established criteria from the date of the decision granting or confirming such status.

To carry out this verification, the Commission of the Ministry of Economy on the Designation of Enterprises, Institutions, and Organizations as Critically Important for the Economy recommended that the documents specified in the letter be submitted to the Ministry’s email address no later than May 28, 2025.

This applies exclusively to those enterprises whose critically important status was granted by the Ministry of Economy itself.
According to clause 6-1 of the Criteria and Procedure for designating enterprises, institutions, and organizations as critically important for the functioning of the economy and ensuring the livelihood of the population during a special period, as well as for meeting the needs of the Armed Forces and other military formations during a special period—approved by the Resolution of the Cabinet of Ministers of Ukraine dated January 27, 2023, No. 76 (as amended by the Resolution of the Cabinet of Ministers of Ukraine dated June 5, 2024, No. 650)—the authority that made the designation decision must monitor the activities of such enterprises for the reporting tax period. This includes compliance with the requirements outlined in the third paragraph of clause 8 of the Procedure for Reserving Conscripts during Mobilization and Martial Law, approved by Resolution No. 76 of the Cabinet of Ministers of Ukraine dated January 27, 2023 (Official Gazette of Ukraine, 2023, No. 15, Art. 940), as amended by Resolution No. 1362 dated November 29, 2024. Where necessary, the authority may verify whether the enterprise continues to meet the criteria outlined in clause 2 of the said Criteria and Procedure throughout the period from the date the critically important status was granted.

Accordingly, enterprises that received their critically important status by decision of the Ministry of Energy are not required to submit any data to the Ministry of Economy in response to the letter dated May 19, 2025, No. 27-11/37509-07.

This has been confirmed by the Ministry of Energy, which clarified: if the letter dated May 19, 2025, No. 27-11/37509-07 was not sent directly to your company by the Ministry of Economy, no action is required.