Russian attacks on gas stations are continuing, and their geography is gradually expanding deeper into the country. The situation is deteriorating virtually every day and taking on an increasingly threatening character—it is no longer just about the damage to individual facilities, but about the loss of fuel infrastructure in entire hromadas and along individual transport routes.

As a result of another wave of Russian attacks, a number of gas stations along the Kharkiv – Poltava route were destroyed or damaged, including fuel infrastructure in Chutove. On the night of July 25, four gas stations in the Poltava district were hit simultaneously. As of July 27, the scale of destruction in this direction no longer points to isolated attacks on individual facilities, but to the systematic destruction of fuel infrastructure along one of the important transport routes. The situation is worsening every day, becoming increasingly threatening, and could lead to the loss of access to fuel in individual hromadas and along critical road routes.

These events demonstrate how quickly local destruction can turn into a systemic threat to the fuel supply of individual territories. There is no time to delay: the state, local authorities, and market participants must urgently move to adopt a comprehensive crisis action plan. It should provide not only for a response to already inflicted destruction, but also a pre-prepared “Plan B” in case the attacks spread further to other regions and key transport corridors of Ukraine.

Fuel is sufficient, but access to it is becoming more vulnerable

Currently, there are no grounds to speak of a nationwide fuel shortage. Import supplies continue, the market is provided with resources, and operators are rebuilding routes and redistributing volumes between regions.

However, the presence of fuel in the country does not guarantee its physical availability in every hromada. If all gas stations are destroyed in a certain territory or along an important route, fuel may be available at terminals and warehouses, but people, carriers, emergency services, and businesses will not have the opportunity to promptly obtain it.

That is why the main risk is not only a general shortage, but the emergence of local “fuel deserts”—territories where stationary fuel infrastructure is destroyed, damaged, or operating with significant restrictions.

For the population, this means the need to travel tens of kilometers to the nearest gas station. For hromadas, it means complications in the work of ambulances, rescue workers, municipal equipment, evacuation transport, and generators. For businesses, it means rising transportation costs, disruption of delivery schedules, and additional operating expenses.

Therefore, a scenario must be prepared right now in which attacks on fuel infrastructure could spread to other regions.

What needs to be done urgently

1. Create a nationwide continuous fuel supply plan

Ukraine needs not a set of situational decisions after each attack, but a pre-prepared action plan for various scenarios: from the damage of a single gas station to the loss of all fuel infrastructure in a hromada or a separate transport corridor.

At the level of each region (oblast), it is necessary to determine:

• alternative ways of supplying hromadas with fuel;
• the needs of emergency, medical, municipal, and evacuation services;
• the procedure for priority fuel dispensing in a crisis situation;
• opportunities for the prompt redistribution of resources between hromadas;
• backup equipment and sites for temporary fuel dispensing;
• those responsible for coordination between oblast military administrations (OVA), hromadas, operators, and regulatory authorities.

Such plans must be developed in advance and updated regularly. Operational details, routes, and resource storage locations must not be public.

2. Legally regulate the operation of mobile gas stations

Mobile and modular refueling solutions can provide a minimum fuel supply during the period between the destruction of a stationary gas station and its restoration. However, current legislation does not provide a fully defined mechanism for their operational use for the retail sale of fuel.

We consider it necessary to introduce amendments to the Law of Ukraine No. 3817-IX that will allow current licensed operators to:

• register a mobile gas station as a backup fuel supply tool;
• use it as an additional facility under the existing license;
• change the place of operation based on a notification principle;
• promptly put it into operation after the destruction or damage of a stationary gas station.

Such a mechanism must preserve fiscal control, excise accounting, confirmation of the origin and quality of fuel, the use of cash registers (PRRO), as well as fire, technogenic, and environmental safety requirements.

A mobile gas station is not a replacement for a stationary network. It is a backup tool that allows a hromada not to be left without fuel while the main infrastructure is being restored.

3. Immediately abolish advance payments for damaged and non-operating gas stations

The collection of advance payments from enterprises for facilities that are destroyed, damaged as a result of Russian attacks, or actually do not carry out economic activities is unacceptable. Businesses cannot pay tax on activities that physically do not exist. This practice additionally deprives enterprises of the resources necessary to restore facilities and maintain the fuel supply of hromadas. The payment of advance payments for damaged and non-operating gas stations must be immediately abolished.

4. Introduce special conditions for the restoration of fuel infrastructure

For high-risk territories, it is necessary to provide:

• accelerated permitting procedures without lowering safety requirements;
• preferential financing for the restoration of gas stations and the acquisition of backup equipment;
• compensation for part of the costs of engineering protection;
• the possibility of reserving employees necessary for safe and continuous operation;
• mechanisms for compensation of the value of damaged or destroyed property;
• targeted incentives for operators that continue to supply fuel to frontline hromadas.

Preserving gas stations in such regions is a matter not only of commercial expediency, but also of maintaining the livelihoods of the territories.

War risk insurance: three-party participation is needed

One of the key elements of fuel infrastructure restoration must be affordable war risk insurance.

However, creating a full-fledged insurance product solely within the framework of interaction between fuel companies and insurers is practically impossible. The scale of potential losses, the repeatability of attacks, and the concentration of risk in individual regions exceed the capabilities of ordinary commercial insurance.

Therefore, a trilateral cooperation model is needed:

• Fuel business must provide objective data on facilities and risks, implement agreed safety, engineering protection, and emergency response measures, and participate in the formation of a geographically diversified insurance portfolio.
• Insurance companies must develop unified approaches to risk assessment, insurance tariffs, and loss settlement, form an insurance pool, and attract the capabilities of Ukrainian and international reinsurance.
• The state must provide the regulatory framework, partial guarantees or reinsurance for catastrophic levels of loss, support for insurance premiums for enterprises in high-risk regions, and participation in financing protection measures.

In this model, the state does not replace the insurance market and does not take on all risks. Its task is to cover that part of the war risk that the private market objectively cannot accept on its own.

Without such participation, insurance will either remain unaffordable in price or will not cover the territories where it is most needed. And without insurance protection, it is difficult for businesses to make decisions about reinvesting in facilities that have already been destroyed and may find themselves under attack again.

Preparation must be made for the most difficult scenario

Today, fuel is available in Ukraine, and the market continues to operate. However, the destruction of all gas stations along individual routes shows that the availability of resources alone does not guarantee the availability of fuel for the population, businesses, and critical services.

Right now, it is necessary to create a backup system that will allow:

• promptly replacing destroyed gas stations with mobile solutions;
• maintaining the fuel supply of hromadas and critical services;
• rapidly restoring damaged infrastructure;
• reducing financial risks for operators;
• preventing local problems from escalating into a systemic fuel crisis.

Our task is not to wait until a critical situation arises in the next region, but to prepare legal, financial, and operational tools right now that will ensure Ukraine’s fuel resilience under any scenario.