Features of mineral extraction, in particular hydrocarbons, under martial law

Based on the results of the webinar ‘Subsurface Use in Ukraine: Legal Challenges, Judicial Practice and Investment Opportunities’.

Key points:

• Ukraine went through three heating seasons (2022-2023-2024) with confident and stable gas consumption and supply from its own production. Companies began to restore production volumes, and by the end of 2024, it amounted to 19.1 billion cubic metres, meaning that Ukraine had almost reached pre-war levels.
• During the first three months of 2025, the enemy carried out eight attacks on gas infrastructure, which affected the gas balance in the country. Therefore, a decision was made at the state level to increase imports. The next year will be difficult, with the state announcing imports of 1 billion cubic metres.
• The suspension of transit through Ukraine has led to a change in the physical characteristics of natural gas in the system. We need to change the gas standards in the system because they differ from those that were in place during transit. The issue is currently being considered by the NEURC.
• There is still a price distortion between the commercial segment and the PSO, which is in effect. Such price distortions are detrimental to Ukrainian producers. The difference between prices in different market segments in Ukraine is 25-30%.
• Gas storage tariffs in Ukraine's underground gas storage facilities are very attractive to global traders and companies. Given the expected shortage on foreign natural gas markets and high demand for natural gas, we need to make every effort to increase production and continue working to attract companies to store gas in Ukraine's underground gas storage facilities.
• Shutdown of operating wells. During martial law, the State Service of Geology and Subsoil suspended special permits for companies whose beneficiaries are subject to sanctions. These decisions must be made in such a way that gas production is not physically halted.