What happens to a community when the only, or one of the few, gas stations is destroyed after another attack?

Fuel might be available in the region. The operator may have staff, equipment, legally acquired resources, and be ready to continue working. However, quickly replacing a damaged stationary gas station with a mobile one is virtually impossible today—current legislation does not provide a separate, clear mechanism for this.

This is exactly the problem that the Fuel and Energy Business Association (FEBA) proposes to regulate at the legislative level.

In the Kharkiv region alone, more than 100 gas stations have been damaged or destroyed since the beginning of the full-scale invasion. Therefore, for a frontline community, this is not a question of comfort or competition between gas stations. Fuel is necessary for ambulances, rescue workers, municipal vehicles, evacuation transport, generators, hospitals, water supply systems, communications, and businesses. When a stationary gas station is destroyed, it is not just a retail outlet that disappears—the community loses a piece of critical infrastructure.

What is the legal problem?

Law of Ukraine No. 3817-IX provides for retail trade in fuel at a specific licensed location. However, the legislation does not establish a special regime that would allow for the rapid transition to operation via a mobile fueling station (PazS) after such a location has been destroyed or damaged.

There is no clear procedure for temporarily replacing a stationary gas station, a notification-based order for changing the operating location of a PazS, or a fully regulated model of excise accounting for such an object.

As a result, an operator who worked legally before an attack is essentially forced to choose between a long-term shutdown and the risk of violating rules that were created for peacetime.

This is exactly what needs to change.

What we propose

A PazS should not be a new way to enter the market, nor should it be separate “mobile fuel trading.”

We propose allowing its use as a temporary reserve object for an already licensed operator if the stationary gas station is destroyed, damaged, or cannot operate due to hostilities.

The mechanism could look like this:

• The operator already holds a valid retail fuel license;
• The PazS is included in their license as an additional reserve object;
• A separate license for each new temporary location is not required;
• The operator notifies the State Tax Service of the actual operating location of the PazS;
• The mechanism is applied primarily in frontline and high-risk communities where stationary fuel infrastructure is lost or inaccessible.

Furthermore, it is advisable to allow the registration of a PazS in advance as a reserve. A business should not have to start going through all the procedures only after a missile or drone hits its facility.

Control remains complete

It is not the control that is simplified—it is the ability to quickly resume work that is simplified.

For a PazS, the following must remain mandatory: RRO (Registrar of Settlement Operations) or software RRO, confirmation of the legal origin of the fuel, excise accounting, excise invoices, accounting for movement and balances, verified measuring instruments, quality control, fire, technogenic, and environmental safety.

In other words, the state must understand at any moment:

• who is selling the fuel, exactly where the PazS is operating, where the resource came from, how much of it has been moved, and how much has been sold.

There should be no leniency for illegal fuel, tax evasion, non-fiscalized sales, or security violations.

What changes are needed from the state

The Association proposes a specific package of solutions:

To Law No. 3817-IX: Defining a PazS, allowing its use within the framework of an existing license, a notification principle for changing the operating location, a mechanism for replacing a damaged gas station, advance registration of reserve PazS, and a transitional regime.

To tax legislation: Clear rules for excise accounting, fuel movement, and compiling excise invoices while a PazS is in operation.

At the Government level: Unified technical and safety requirements, a procedure for state accounting of PazS, and notification of supervisory authorities.

Separately, an obvious tax injustice must be resolved: a gas station that is destroyed, damaged, and essentially not selling fuel should not continue to pay advance income tax payments for the period of forced downtime. The Association’s position proposes confirming such circumstances with documents from the SES (State Emergency Service), military administration, National Police, RRO data, and other evidence of ceased operations.

PazS will not replace stationary gas stations. And they should not.

Their task is to close the critical gap between the moment a stationary object is destroyed and the moment the business can restore it.

Ukraine has been living in conditions of systemic attacks on infrastructure for four years now. Therefore, legislation must contain not only rules for working under normal conditions but also a pre-prepared “Plan B” for when normal conditions no longer exist.

For frontline communities, such a “Plan B” can and should become a legal, controlled, and temporary mechanism for using PazS.