Ukraine’s Oil Reserve Law Remains Active: What Requirements Apply During Wartime.

Ukraine's Law on Minimum Oil and Petroleum Product Reserves

According to Espreso.tv: At the Petroleum Ukraine conference, Yaroslav Starovoitenko confirmed that the Law of Ukraine 'On Minimum Oil and Petroleum Product Reserves' is still in effect, despite penalties for non-compliance being deferred for the duration of martial law. The government is actively developing operational models for the minimum oil and petroleum product reserves (MOPPR) system to function during the war. This law, which came into force in December 2024, is a key part of Ukraine’s energy security strategy, especially amid ongoing conflict.

Although the law remains valid, responsibility for failing to meet its requirements has been postponed until the end of martial law. In the first year of implementation, market participants must maintain minimum reserves equivalent to 3% of their import or production volumes, with a floor of at least 250 tons annually. Thereafter, the mandatory reserve levels will increase incrementally:

• 6% in the second year
• 9% in the third year
• 12% in the fourth year
• 15% in the fifth year
• 18% in the sixth year
• 21% in the seventh year of the system’s operation

Starting from the eighth year, the minimum reserve requirement will reach 24% of the corresponding import or production volumes.

The Law of Ukraine 'On Minimum Oil and Petroleum Product Reserves' remains in force, even though liability for non-compliance with certain provisions has been postponed for the period of martial law.

Yaroslav Starovoitenko

In light of these developments, Vasyl Danylyak emphasized that 'we are planning our investments and growth while accounting for the risks we live with.' This highlights the market’s need to adapt to new conditions and challenges arising from the war and its impact on Ukraine’s energy security. The deferral of penalties gives businesses time to adjust, but the long-term goal is a stable and resilient fuel supply system.

Maintaining minimum oil and petroleum product reserves is a critical component of national energy security, especially during wartime. The postponement of penalties for non-compliance allows the market to navigate the difficult circumstances facing participants. At the same time, it is essential for the government to establish an effective operational model for the MOPPR system that ensures supply stability and reduces risks to the country’s economy. This issue remains highly relevant as Ukraine looks toward the future recovery and development of its energy sector.