On April 10, a webinar was held focusing on one of the key regulatory updates in the fuel sector — Law No. 3817, which came into force on January 1, 2025. The new rules fundamentally reshape the licensing process for fuel operations and are already determining which market players will be allowed to remain in the sector.
Webinar speaker — Andrii Trambovetskyi, lawyer, co-founder and managing partner of the law firm INSENTA. Practicing law since 2010, he specializes in licensing, tax law, and fuel market regulation.
“The new law is more than an administrative update — it’s a filter that forces businesses to either comply with the rules or exit the market. But those who adapt in time will gain a competitive advantage” — emphasized Andrii Trambovetskyi.
What has changed?
Key provisions of Law No. 3817:
• Ban on modular gas stations — Fuel sales are now permitted only from immovable property.
• Mandatory electronic identification — Applies to all applicants without exception.
• Exact storage address required — Errors may be grounds for license cancellation.
• No more automatic license renewals — Documents had to be updated by the end of October 2024.
• New requirements for older facilities — Facilities commissioned before April 30, 2011, can now be legalized using technical passports and BTI documentation.
During the webinar, participants received a detailed breakdown of licensing requirements for various types of fuel-related activities — wholesale, retail, storage, and production. Special attention was given to the distinction between “complex” licenses (trade, storage, production) and “simplified” ones (storage of up to 500 liters, wholesale without a sales location).
A separate focus was placed on facilities commissioned before 2011. Thanks to the new legal framework, these facilities can now be legitimized and licensed using technical passports and BTI documents, without the need for commissioning certificates.
What should businesses do now?
1. Complete electronic identification via the Taxpayer’s Electronic Cabinet.
2. Update Form 20-OPP if the facility address has changed.
3. Monitor fuel purchase volumes to avoid exceeding limits for excise warehouses.
4. Seek legal advice for complex cases or older facilities.
The webinar recording is available on YouTube.
The Fuel and Energy Business Association organized this webinar as part of its ongoing collaborative work with partners to support market participants. We don’t just inform — we help businesses adapt, avoid penalties, preserve their operations, and build trust between the industry and regulatory authorities.
In a year when legislation changes faster than the weather, it is precisely the professional community — equipped with knowledge and experience — that can provide real support for businesses. This is the kind of community we are building: open, expert-driven, and united by trust. More valuable resources, expert insights, and themed events lie ahead.