On April 10, a webinar was held to discuss one of the key regulatory updates in the fuel sector — Law No. 3817, which came into force on January 1, 2025. The new regulations fundamentally change the licensing approach for fuel operations — and are already determining who will remain in the market.
The webinar speaker was Andrii Trambovetskyi — lawyer, co-founder, and director of the legal firm “INSENTA“, a specialist in licensing, tax law, and legal regulation of the fuel market.

“The new law is not just a change in the rules. It acts as a filter, compelling businesses to either operate transparently or leave the market. But those who adapt quickly will gain a competitive advantage” said Andrii Trambovetskyi.
Key changes introduced by Law No. 3817 include:
• Ban on modular gas stations. Fuel sales are permitted only from immovable property objects.
• Mandatory electronic identification. Required for all applicants without exception.
• Exact storage address. Errors may lead to license revocation.
• Elimination of automatic license renewal. All documents had to be updated by the end of October 2024.
• New conditions for older facilities. Facilities commissioned before April 30, 2011, can be legalized based on technical passports and BTI documentation.
The webinar provided a detailed review of licensing requirements for various types of activities: wholesale, retail, storage, and fuel production. Special attention was given to the so-called “simplified” licenses — storage of up to 500 liters and wholesale trade without a permanent point of sale.
Recommendations for businesses:
1. Complete electronic identification through the Taxpayer’s Electronic Cabinet.
2. Update Form 20-OPP in case of a change in the facility’s address.
3. Monitor fuel procurement volumes to avoid exceeding excise limits.
4. Seek legal advice regarding facilities commissioned before 2011.
The webinar recording is available on the Association’s YouTube channel.
The Fuel and Energy Business Association initiates and implements a range of practical measures to support market participants amid rapid changes. We help not only to navigate the new rules, but also to avoid fines, retain licenses, adapt to regulatory changes, and operate transparently.
More meetings, timely clarifications, and expert materials are ahead. Together, we are building a strong, professional, and trusted community within the fuel market.