On August 20, 2024, the Resolution of the Cabinet of Ministers of Ukraine No. 712 dated June 18, 2024, “On Amendments to the Licensing Conditions for Business Activities Related to Passenger Transportation, Transportation of Dangerous Goods and Hazardous Waste by Road, as well as International Passenger and Freight Transportation by Road” (hereinafter – Resolution No. 712) came into force. In compliance with this resolution, the State Service of Ukraine for Transport Safety (Ukrtransbezpeka) has ceased issuing licenses during martial law. These licenses were previously granted under a simplified procedure that did not require applicants to confirm three years of experience in the specified types of business activities.
According to the second paragraph of Clause 2 of Resolution No. 712, license holders (except for those who were issued licenses specifically for the duration of martial law in Ukraine) must update their license data if their licenses were issued before August 20, 2024. This is done by submitting the necessary documents and information specified in Subparagraph 2, Clause 7 of the Licensing Conditions (Annex 3 on Vehicles) to the licensing authority no later than six months from the date the resolution takes effect (i.e., by February 20, 2025).
License holders who expanded or narrowed the scope of their license within these six months are not required to submit this notification. At the same time, there has been growing concern within the business community regarding the need to transition from a martial law license to a permanent license by February 20, 2025.
The Fuel and Energy Business Association has thoroughly reviewed this issue.
An analysis of the third and fourth paragraphs of Clause 2 of Resolution No. 712 suggests that licenses issued for the duration of martial law remain valid for two years after the termination or cancellation of martial law in Ukraine, provided that the license holder submits the required documents and information specified in Clause 7 of the Licensing Conditions to the licensing authority and complies with the established Licensing Conditions.
If a license holder fails to meet these requirements, their license issued during martial law will be subject to cancellation within 60 calendar days. Thus, license holders who received their licenses during martial law in Ukraine are not required to transition to permanent licenses by February 20, 2025. This was confirmed by a specialist from the Ukrtransbezpeka information support line in a telephone conversation with a representative of the Fuel and Energy Business Association at +38 044 350 43 04.
Therefore, once license holders who received their licenses during martial law gain the required three years of experience in the specified types of business activities, they may submit an application to transition to permanent licenses, provided they comply with the requirements outlined in the third and fourth paragraphs of Clause 2 of Resolution No. 712.