FEBA welcomes a consistent step forward in building a constructive dialogue between the renewed Bureau of Economic Security (BEB) and the business community during the conference “Cooperation between the Renewed BEB and Transparent Business — First Half-Year.” The event brought together nearly 100 participants: the Business Ombudsman of Ukraine, heads of leading business associations, law firms, international chambers of commerce, and company executives.
The event signaled a shift in approach: from force-based responses to analytical work, and from formal control to a professional discussion about the systemic causes of shadow economic activity. This is vital for the entire economy—and especially for fuel retail.

Illegal Gas Stations: An Old Problem, a Systematic Fight
Let’s be direct: illegal gas stations did not appear yesterday. They have existed for years. The market knew about them, and honest businesses were forced to operate alongside them in vastly unequal conditions.
Therefore, the systematic work of law enforcement and analytical bodies to identify and shut down illegal stations—those operating without licenses or with gross violations—is an unequivocally positive signal. It is a step toward cleansing the competitive environment. This is the real fight against the “shadow,” and it is exactly the approach FEBA consistently supports. However, it is equally important not to conflate different processes and to call things by their real names.
600 Revoked Licenses: Where Detshadowing Ends and Pressure Begins
Following the introduction of the advance corporate income tax payment mechanism for retail licensees, approximately 600 licenses were revoked. For the fuel market, this is a significant number.
It is fundamentally important to differentiate between two scenarios:
- Liquidation of illegal gas stations (operating without permits): This is a necessary market cleansing.
- Revocation of licenses for legal, small, and independent operators who simply could not adapt to the new fiscal model: This is a different economic process entirely.
In the second case, we are dealing not just with “detshadowing” (reducing the shadow economy), but with a structural transformation of the market under the weight of regulatory decisions.

The Core Question: Why Part of the Business Went into the Shadows
FEBA emphasizes: many operators were forced out of the legal field not because of a desire to evade taxes, but because of the impossibility of operating under the new rules.
The advance payment mechanism:
- Does not account for the scale of the business;
- Ignores regional specifics;
- Does not reflect actual profitability;
- Creates a disproportionate burden specifically on SMEs.
For large retail chains, this is merely a financial model. For a small operator, it often results in a cash gap or a total loss of liquidity. In this situation, business owners are forced to:
- Shut down operations;
- Sell off assets;
- Or, worst of all, be pushed into the shadows, where tax control and transparency vanish entirely.
This is the key paradox: a tool declared as “anti-tax avoidance” can, in specific cases, act as a factor for shadowization.

FEBA Consistently Advocates For:
- Systematic combat against illegal gas stations;
- Professional analytical work by the BEB;
- Cooperation between the state and transparent business;
- Detshadowing without discriminatory tools;
- Reviewing regulatory decisions that push legal SMEs out of the market.
Moving Forward
The cooperation between the renewed BEB and business is a necessary and correct direction. Closing illegal gas stations is an absolute positive. However, detshadowing cannot be reduced merely to fiscal results or the number of revoked licenses.
True success must mean:
- A reduction of the actual shadow segment.
- The preservation of legal small and medium businesses.
- A competitive, balanced, and resilient fuel market.
We will all have to work in the environment we are shaping today. It is better to speak honestly and professionally about these issues now than to deal with market distortions later.