From the beginning of 2027, Ukraine will launch an experimental project on the underground storage of petroleum products from the composition of the minimum reserves of oil and petroleum products (MZNN), according to Cabinet of Ministers Resolution No. 1037 of August 13, 2026, published on the government portal.
According to the resolution, the experimental project initiated by the Ministry of Energy should last no more than two years years.
"From the beginning of the third base year (2027), market subjects and operators are obliged to store a part of the volume of diesel fuel, which is at least 20% of the total volume of this type of petroleum products, from the reserves of the Ministry of Internal Affairs and Communications in underground storages of petroleum products," says the procedure for the implementation of the experimental project to the resolution.
The project provides for the creation of an extensive system of underground storages of petroleum products and conditions for their safe storage, it is noted in the order.
The Ministry of Energy is designated as the coordinator of the experimental project, JSC "Ukrtransnafta" is the specialized responsible custodian.
At the same time, the operation of the specialized responsible custodian gives the right to other market subjects to store oil products in their own underground storage facilities.
The list of state objects whose property can be used as underground storage facilities is defined in the closed part
The Ministry of Energy must ensure the implementation of the project together, in particular, with OJSC Naftogaz of Ukraine, Ukrtransnafta and Market Operator.
Director of the A-95 consulting company Serhiy Kuyun said regarding the experimental project that there are currently no underground storage facilities in the country, and no one will have time to even develop the project four months before the deadline. At the same time, he drew attention to the fact that the resolution provides for the use of oil pipelines, salt caverns, depleted oil or gas deposits and other geological formations for these purposes.
Kuyun also noted that in the near future, state banks, by decision of the government, may start lending to projects of underground storage of petroleum products at 10% per annum with state compensation for the remaining interest. The amount of lending, according to his information, can range from UAH 100 million to UAH 1 billion. At the same time, Kuyun suggested that in such cases, a strict condition for putting storage facilities into operation within a year is assumed.
At the same time, in his opinion, a year is an unrealistic term, so the government needs to speed up the coordination of documentation for the project, the term of which is now one and a half years. At the same time, the director of A-95 noted that the private operators of gas station networks have already started the construction of underground storage facilities "at their own peril and risk", coordinating projects in parallel.
He also drew attention to the general issue of storing MZNN from 2027.
"The law (on MZNN), although blocked by secondary legislation, is formally in effect, and currently the standard of MZNN is 6% (of the market - ER), or approximately 600,000 tons. The amount that cannot be physically stored anywhere - neither underground nor above ground. And no one will keep it on the ground, because it is suicide for business. If nothing changes, the norm will automatically increase to 9% from 2027," Kuyun described the situation.
At the same time, he added that the Ministry of Energy understands the problem and has prepared amendments to the law, which already number 300 amendments.
"The positions are as follows: everyone without exception understands the main thing - reserves are needed, but they must be protected. And these stocks should be in Ukraine, fantasies about storage abroad are quickly dispelled," summed up the director of A-95.
As reported, the parliament adopted the law on the Ministry of Foreign Affairs on November 21, 2023.
In the explanatory note to draft law No. 9024-d, it was noted that its adoption will allow the creation of a system of minimum reserves of oil and petroleum products in Ukraine and will regulate relations in the field of managing such minimal reserves, and will also ensure the fulfillment of Ukraine's obligations regarding the implementation of Directive 2009/119/EU.
According to the general director of OKKO Group, Vasyl Danylyak, it is advisable to create an MZNN only when Ukraine has a sufficient underground reservoir park.
