Deregulation and war risk insurance could boost the subsoil use sector, EBA study finds

04/ 09/ 2026

Listen to online Stop   Despite the full-scale war, a significant proportion of businesses continue to invest in Ukraine’s subsoil resources and expect the government to further simplify regulatory and permitting procedures. According to the findings, 56% of surveyed companies invested in subsoil resources between 2022 and 2026: 42% invested up to USD/EUR 10 million, 12% invested more than USD/EUR 15 million, and a further 2% invested between USD/EUR 10 million and USD/EUR 15 million. These are the findings of the survey “Subsoil Use in Wartime and Development Prospects”, conducted by the European Business Association among representatives of the sector. In 2026, 41.7% of companies are operating under normal conditions. At the same time, 26.7% of companies whose operations were suspended following the full-scale invasion have already fully resumed their activities, while a further 25% have resumed operations partially. Meanwhile, 6.7% of surveyed companies reported that their activities remain completely suspended. At the same time, 35% of companies have suffered losses to production capacity or infrastructure as a result of the war. Some 27% of companies have not experienced a decline in revenue this year, while a further 15% reported an increase. At the same time, 25% of companies saw their revenues decrease by less than 10%, 15% reported a decline of 11–30%, 10% reported a decline of 31–50%, and a further 8% experienced a decrease of more than 50%. According to businesses, the highest priorities for improving operations in the subsoil use sector are access to land plots (74%) and environmental impact assessment (64%). These are followed, with a somewhat lower priority, by waste management, the calculation of fees for special permits, and production sharing agreements. Companies’ open-ended responses also confirm that these are among the most problematic procedures. The difficulties most frequently mentioned include obtaining and registering rights to land plots, undergoing environmental impact assessments, obtaining approvals for documentation, making amendments to and extending special permits, as well as insufficient coordination between different government authorities. Respondents emphasised that the problem lies not so much in individual procedures as in the need to go through numerous approval processes, their lengthy duration, and insufficient inter-agency coordination. Engagement with government authorities remains another significant challenge for businesses. 66% of surveyed companies reported experiencing pressure from law enforcement or regulatory authorities in the course of their activities. Business views on the potential reorganisation and streamlining of the Ukrainian Geological Survey are divided: 52% do not support the idea, while 48% would be prepared to support it. The procedure for selling special subsoil use permits remains an important issue for the sector. 84% of respondents believe that the rules for auctions where there is only one participant need to be clarified, while 16% are opposed to such changes. 62% of companies consider geological information insufficiently accessible for making investment decisions, while 38% believe that its availability is adequate. Businesses also assessed the potential impact of the Agreement between the Governments of Ukraine and the United States on the establishment of the Reconstruction Investment Fund on increasing investment in the sector, including during martial law. The average score was 2.48 out of 5. The biggest wartime challenge identified by companies is the mobilisation of key employees and the shortage of qualified personnel, accounting for 72% of all selected responses. This was followed by corruption risks in the sector (52%), problems with energy supply (37%), and limited access to ports, disruptions to rail transport, and difficulties with imports and exports (33%). Among government measures that could stimulate the sector’s development and support it during the war, the largest share of companies identified simplifying land allocation procedures (66%) and simplifying environmental impact assessment procedures (57%). Other priorities included war risk insurance (51%), a temporary reduction in royalty rates for subsoil use (49%), simplified permitting procedures (41%), tax incentives for new investment projects (39%), and ensuring stability of tax and regulatory legislation (38%). For reference: The “Subsoil Use in Wartime and Development Prospects” survey has been conducted by the European Business Association since 2023. In 2026, 61 companies operating in the subsoil use sector took part in the survey, which was conducted from 13 July to 10 August.

Despite the full-scale war, a significant proportion of businesses continue to invest in Ukraine’s subsoil resources and expect the government to further simplify regulatory and permitting procedures.

According to the findings, 56% of surveyed companies invested in subsoil resources between 2022 and 2026: 42% invested up to USD/EUR 10 million, 12% invested more than USD/EUR 15 million, and a further 2% invested between USD/EUR 10 million and USD/EUR 15 million.

These are the findings of the survey “Subsoil Use in Wartime and Development Prospects”, conducted by the European Business Association among representatives of the sector.

In 2026, 41.7% of companies are operating under normal conditions. At the same time, 26.7% of companies whose operations were suspended following the full-scale invasion have already fully resumed their activities, while a further 25% have resumed operations partially. Meanwhile, 6.7% of surveyed companies reported that their activities remain completely suspended.

At the same time, 35% of companies have suffered losses to production capacity or infrastructure as a result of the war.

Some 27% of companies have not experienced a decline in revenue this year, while a further 15% reported an increase. At the same time, 25% of companies saw their revenues decrease by less than 10%, 15% reported a decline of 11–30%, 10% reported a decline of 31–50%, and a further 8% experienced a decrease of more than 50%.

According to businesses, the highest priorities for improving operations in the subsoil use sector are access to land plots (74%) and environmental impact assessment (64%). These are followed, with a somewhat lower priority, by waste management, the calculation of fees for special permits, and production sharing agreements.

Companies’ open-ended responses also confirm that these are among the most problematic procedures. The difficulties most frequently mentioned include obtaining and registering rights to land plots, undergoing environmental impact assessments, obtaining approvals for documentation, making amendments to and extending special permits, as well as insufficient coordination between different government authorities.

Respondents emphasised that the problem lies not so much in individual procedures as in the need to go through numerous approval processes, their lengthy duration, and insufficient inter-agency coordination.

Engagement with government authorities remains another significant challenge for businesses. 66% of surveyed companies reported experiencing pressure from law enforcement or regulatory authorities in the course of their activities.

Business views on the potential reorganisation and streamlining of the Ukrainian Geological Survey are divided: 52% do not support the idea, while 48% would be prepared to support it.

The procedure for selling special subsoil use permits remains an important issue for the sector. 84% of respondents believe that the rules for auctions where there is only one participant need to be clarified, while 16% are opposed to such changes.

62% of companies consider geological information insufficiently accessible for making investment decisions, while 38% believe that its availability is adequate.

Businesses also assessed the potential impact of the Agreement between the Governments of Ukraine and the United States on the establishment of the Reconstruction Investment Fund on increasing investment in the sector, including during martial law. The average score was 2.48 out of 5.

The biggest wartime challenge identified by companies is the mobilisation of key employees and the shortage of qualified personnel, accounting for 72% of all selected responses. This was followed by corruption risks in the sector (52%), problems with energy supply (37%), and limited access to ports, disruptions to rail transport, and difficulties with imports and exports (33%).

Among government measures that could stimulate the sector’s development and support it during the war, the largest share of companies identified simplifying land allocation procedures (66%) and simplifying environmental impact assessment procedures (57%). Other priorities included war risk insurance (51%), a temporary reduction in royalty rates for subsoil use (49%), simplified permitting procedures (41%), tax incentives for new investment projects (39%), and ensuring stability of tax and regulatory legislation (38%).

For reference:

The “Subsoil Use in Wartime and Development Prospects” survey has been conducted by the European Business Association since 2023.

In 2026, 61 companies operating in the subsoil use sector took part in the survey, which was conducted from 13 July to 10 August.