Natural resources: institutional and regulatory shifts in Ukraine

This review outlines the major legislative, institutional, and strategic transformations shaping Ukraine’s natural resources governance and industrial policy framework in 2025 and the first half of 2026, covering legal reforms in critical raw materials (CRMs), subsoil use, waste management, climate policy, and broader EU integration commitments.

Institutional Restructuring: A New Ministry Takes Shape

In mid-2025, a reshuffle of the Cabinet of Ministers of Ukraine triggered institutional and policy adjustments across key regulatory sectors. For the natural resources and environmental sector, this was not simply a change in ministerial leadership — it marked the merger of the Ministry of Environment and Natural Resources with the Ministry of Economy and the Ministry of Agriculture, resulting in the formation of a new united body: the Ministry of Economy, Environment and Agriculture.

Following a transitional period, the environmental dimension of the new ministry continues its work within the expanded structure, retaining a degree of operational autonomy, including through the distribution of responsibilities among deputy ministers.

The restructuring has drawn mixed reactions. Some experts have expressed concern that folding a dedicated environmental ministry into a broader economic institution could dilute the priority given to environmental policy. Others, however, see potential advantages. The integration of environmental considerations into the core economic policy apparatus may elevate the profile of environmental reform as a driver of economic development, rather than treating it as a regulatory constraint.

Although the institutional restructuring initially resulted in a period of transition and coordination challenges, the shared priorities stemming from Ukraine’s EU integration challenges have gradually enhanced cross-sectoral alignment and operational coherence.

The timing of еру institutional restructuring, alongside the signing of the U.S.-Ukraine Reconstruction Investment Fund Agreement, further reinforced the consolidation of subsoil use and critical raw material governance within one ministerial framework.

In July 2026, the institutional structure was revised again: the Ministry of Economy, Environment and Agriculture was renamed the Ministry of Economy and Environment, while the Ministry of Agrarian Policy and Food was restored as a separate ministry.

Critical Raw Materials

Ukraine’s efforts to build a coherent regulatory framework for critical and strategic raw materials continued in 2025, building on the momentum created by the December 2024 amendments to the Subsoil Code of Ukraine. Those amendments introduced formal definitions of critical and strategic minerals and established the specific rules governing the issuance of special permits for sexploration and development of deposits of such minerals. In July 2025, the Cabinet of Ministers of Ukraine approved the lists of minerals and their components deemed to be of strategic and critical importance, along with the list of deposits of minerals of strategic and critical importance, permits for which will be distributed both through electronic auctions and Production Sharing Agreement (PSA) mechanisms. In August 2025, the Government launched the first PSA tender on the distribution of metallic minerals (the lithium Subsoil Area Dobra), finished by determining the winner in January, 2026. The process also initiated work on further amendments to the legislation on PSAs, which has been included in the Ministry’s priority plan.

The Strategy for the Development of Industries Based on Strategic and Critical Raw Materials and Components until 2056 and the Operational Plan for its implementation for 2026–2028 were approved by the Cabinet of Ministers of Ukraine on May 2026. The methodology for classifying minerals and their components as strategic or critical, however, remains to be adopted.

Subsoil Use: Legislative Reforms

Two draft laws aimed at improving the conditions for subsoil use for subsoil investors were developed in close coordination between the Ministry, State Service of Geology and Subsoil, and the relevant parliamentary committee and submitted to the Ukrainian Parliament in 2025.

Draft Law No. 14249, On Amendments to the Subsoil Code of Ukraine regarding Improvement of Legal Regulation of Subsoil Use and Ensuring the Guarantees for Investors aims to improve the mechanisms of automatic prolongation of special permits (along with other relevant conditions of subsoil use) during the period of martial law and 24 months after its end, enable electronic auctions with only one bidder, and introduce guarantees for regulatory stability for licensees working with strategic and critical minerals. The amendments also include the launch of thetransformation of special permits for geological exploration and experimental and industrial development into end-to-end permits during the limited time from the Law coming into force.

Another Draft Law No. 14250, On Amendments to Certain Legislative Acts of Ukraine regarding Clarification of Certain Provisions in the Sphere of Subsoil Use aims tounify the terminology used in various legislative acts and clarify provisions regarding disclosure of information on environmental conservation areas in documentation for the auction.

However, on July 2026, Draft Law No. 15454, On Amendments to Certain Legislative Acts of Ukraine regarding Improvement of the Mechanisms for Granting and Exercising the Right to Use Subsoil through Auctions (Electronic Trading) and under Production Sharing Agreements, was submitted to Parliament. The draft law incorporates and further develops most of the provisions addressed in Draft Laws No. 14249 and No. 14250. Overall, it is aimed at improving the mechanisms for granting and exercising subsoil use rights through auctions and PSAs, improving conditions for investment and the development, enrichment and processing of mineral resources, ensuring the stability of subsoil use, and establishing an appropriate legal framework for Production Sharing Agreements. It also addresses related land and other issues and is intended to support the implementation of the Ukraine Plan and the Ukraine–U.S. Reconstruction Investment Fund Agreement. The main objectives of the draft law are to improve the legal regulation of subsoil use and ensure guarantees for investors; improve the legislative mechanism for granting the right to use mineral deposits through auctions (electronic trading) and under PSAs, while ensuring the rational use of subsoil and taking appropriate measures for environmental protection; and improve certain land and other issues related to the exercise of the right to use subsoil.

It is expected that these amendments will provide the extractive companies a stable and predictable regulatory mechanism in the most critical positions for attracting investments.

Waste Management

On waste management, following the approval of the National Waste Management Plan in late 2024, regions were involved in developing the Regional Waste Management Plans. Though progress has been uneven, the regions are gradually moving forward with the development and approval of the Regional Waste Management Plans (except  Donetsk and Luhansk Regions as well as Crimea, for which development of waste management plans is not possible at present).

Further expected activities include the development of Local Waste Management Plans, as well as the development and adoption of laws regulating specific waste streams (in particular, the ones that shall be covered by the extended producer responsibility schemes). Furthermore, n September 2026, the Cabinet of Ministers approved the Strategy for the Development of Ukraine’s Circular Economy until 2035 and adopted the Action Plan for its implementation for 2026–2028.

In fact, the amendments that came into force in March 2026 introduced the institution of brokers and dealers under the Law on Waste Management, which should be further regulated at bye-law level.

At the by-law level, the main discussions centered on an experimental pilot project on a simplified procedure for obtaining a permit for waste processing operations (launched in August 2024) and on extending the applicable waste management procedure under the relevant by-laws to extractive industry waste through the December 2025 amendments. Without delving into the substance of the discussions in this review, the respective spheres should be advanced and brought into full legal and practical alignment with the EU acquis, subject to reasonable transitional arrangements to facilitate practical implementation.

Overall, according to the National Programme for Adaptation of National Legislation to the EU acquis (NPAA), approved by the Government on April 1, 2026, all relevant legal transpositions of the EU acquis on waste management should be approved by the end of 2027. As of now, the packaging and packaging waste stream have been under the consideration of Parliament, the draft bills on single-use plastic products and WEEE are in the pipeline with the Cabinet of Ministers, while other draft laws on waste streams (including the draft law on management of extractive industries, because the previous draft law was not adopted by Parliament in June 2025) must be developed and submitted to Parliament.

EU Integration Issues

The past year and a half has marked a pivotal milestone in Ukraine’s EU integration efforts in general, and in the areas of environmental protection and natural resource management in particular. The official screening process was completed across all negotiating chapters and clusters, including Chapter 27 The Environment and Climate Change and some relevant issues in other chapters.

Following the conclusion of the screening process, the Government of Ukraine developed and formally approved its negotiation positions, signaling its readiness to advance substantive accession talks on these subject matters. Moreover, in March 2026, Ukraine obtained benchmarks for closing negotiating clusters and, therefore, has a roadmap on further EU integration steps.

To underpin the strategic planning of EU integration work, the Government approved the National Programme for Adaptation of National Legislation to the EU acquis (NPAA) on April 1, 2026. The programme provides a structured roadmap for aligning Ukrainian law with EU standards across sectors, including environmental, natural resources and climate governance.

Among the relevant top priorities for 2026, in addition to the above-mentioned issues, are Draft Laws On the Principles of the Functioning of the National System of Trading in Greenhouse Gas Emissions Quotas and On the Circulation of Goods Associated with Deforestation and/or Forest Degradation, which are currently under consideration by the Parliament.

Overall, given the ongoing and expected intensity of legislative and regulatory developments over the next 18-24 months, structured and continuous regulatory monitoring of both EU initiatives and Ukraine’s domestic reform agenda will be essential. Ensuring timely tracking of developments on both sides will remain critical for effective alignment and implementation.