August 2025 – On 14 July 2025, the Cabinet of Ministers of Ukraine (CMU) approved the Lists of Minerals and Components of Strategic and Critical Importance (Resolution No. 845, or the Lists). Resolution No. 845 classifies minerals into two categories: strategic minerals (those crucial for the national security of Ukraine and its economic prosperity), comprising 11 elements (e.g., uranium, titanium and strontium) and critical minerals (those essential for modern technologies), comprising 28 elements (e.g., lithium, rare earth ores and cesium).
The above categorisations were developed in accordance with the Updated National Program for the Development of the Mineral Resources Base of Ukraine for the Period up to 2030, adopted in December 2024 (Law No. 4154-IX), as well as in order to implement Section 13 “Critical Materials Management” of the Ukraine Facility Plan. The Ukraine Facility Plan, among other things, requires the Government to create favourable conditions for investors into the mining sector, and to implement digital technologies and ESG reporting, the latter being conditional on the provision of continued EU financial support to Ukraine.
The adoption of the Lists is designed to send a key signal to investors that the Government intends to prioritise the extraction and processing of raw materials and that it is interested in attracting investment into these sectors and is ready to offer the necessary support.
With the same resolution the CMU also approved:
- 60 subsoil areas/deposits containing minerals of strategic and/or critical importance. Special permits for these deposits will be made commercially available via electronic auctions; and
- 26 subsoil areas/deposits containing minerals of strategic or critical importance, that will be allocated through production sharing agreement tenders.
The time framework for the electronic auctions and production-sharing agreement tenders to be conducted in relation to mineral deposits of strategic and critical importance has not yet been set.
The right to use subsoil areas containing minerals of strategic or critical importance may be granted to persons meeting any of the following criteria:
- citizens of Ukraine;
- residents of an OECD member state or another state with which Ukraine has concluded a partnership agreement in the field of minerals of strategic and/or critical importance;
- legal entities that are residents of Ukraine or an OECD member state or another state with which Ukraine has concluded a partnership agreement in the field of minerals of strategic and/or critical importance, provided that significant participation in any such allocation of rights is maintained by the aforelisted entities, and (or) by legal entities registered in such states, and (or) citizens or residents of such states.
The Lists formally include deposits/areas located in the temporarily occupied territories of Ukraine to which access is presently restricted. Such Lists will be subject to review at least once every three years.
The aim of these reforms is to increase the attractiveness of investment in the Ukrainian mining industry, to contribute to the development of industrial production and to stimulate economic growth of Ukraine, including through integration into global supply chains of critical minerals and the resulting products.
Ukraine has already concluded a Memorandum of Understanding with the European Union on a strategic partnership in the field of mineral raw materials, as well as a Memorandum of Understanding with the Government of the United States of America on cooperation to strengthen supply chains in the sector of critical mineral resources for energy, national security and economic development. The adoption of Resolution No. 845 can therefore be understood within the context of Ukraine’s ongoing transformation into a key raw minerals supplier.
For more information on the regulation of mining and minerals, please contact Olena Kuchynska at .