On 9 September 2025, the Government approved amendments to the Procedure for importing new equipment (machinery) and components into the customs territory of Ukraine and their targeted use, which are imported by an investor with significant investments exclusively for their own use in the implementation of an investment project with significant investments in accordance with a special investment agreement, concluded in accordance with the Law of Ukraine “On State Support for Investment Projects with Significant Investments in Ukraine” (the “Amendments” and the “Procedure” respectively). The basic Procedure was approved by Resolution of the Cabinet of Ministers No. 860 of 11 August 2021.

Information about the Amendments has been published on the website of the Ministry of Economy.

What are the Amendments about?

The aim is to cut red tape for investors implementing special investment agreements. The amendments concern the deadline for submitting equipment lists, the requirement to indicate country of origin, and the method of calculating estimated value.

The purpose is to align regulation with real business processes, making it simpler and quicker to import equipment for investment projects.

What exactly has changed?

  • Deadline for submitting a written request to the Ministry of Economy of Ukraine

The Amendments establish a new deadline for investors to submit a list and volumes of equipment — instead of five days, it is now twelve months from the date of receipt of the conclusion on the feasibility of the project.

  • The requirement to indicate the country of origin in the list of equipment has been abolished

This eliminates the need to re-approve documents when changing a manufacturer or sub-supplier, which is particularly important for international supply chains.

  • The definition of the ratio between the estimated and customs value of equipment has been clarified

The cost of equipment is now indicated in the currency of the supply contract with a parallel reflection of the total amount in hryvnia, which reduces the risk of discrepancies due to currency fluctuations.

It should be noted that the key conditions for participating in the programme remain unchanged: investment of more than €12 million, the creation of at least 10 jobs, projects implemented in defined sectors (from manufacturing and transport to healthcare, education, and tourism), and a maximum implementation period of five years.

What does this mean in practice?

Based on the available information, the following conclusions can be drawn:

  • extending the deadline to twelve months gives investors greater flexibility and time to run tenders and procurement without rushed decisions;
  • dropping the country-of-origin requirement removes unnecessary bureaucracy and repeated approvals when suppliers change;
  • the updated valuation rules, linking prices to the contract currency with parallel hryvnia figures, lower currency-related risks, and simplifying customs procedures; and
  • the fact that the core eligibility criteria remain the same confirms the stability of the state support model — the amendments are targeted simplifications rather than a complete redesign.

Authors:

Oleksandr Melnyk, Partner at GOLAW, Head of Corporate Law and M&A Practice, Attorney at Law

Vladyslava Zaichko, Paralegal at Corporate Law and M&A Practice at GOLAW

More from GOLAW