LNG Facility Services License in Ukraine: How to Obtain It Under the 2026 Rules

A client approached us for an oral legal consultation on a planned liquefied natural gas (LNG) project. The main question was straightforward: what must be completed before applying to NEURC so that the company can lawfully begin operations?

At the time of the consultation, the client was still developing the project model. We needed to determine which activities require licensing, which company may act as the LNG facility operator, what requirements apply to the facility itself, and which documents must be prepared before filing with NEURC.

The 2026 regulatory changes also had to be taken into account. Since July 28, 2026, this activity has been governed by separate Licensing Conditions approved by NEURC Resolution No. 788 dated May 26, 2026Law of Ukraine “On the Natural Gas Market”. The obligation to obtain a license for LNG facility services already existed under the Law of Ukraine “On the Natural Gas Market,” but the new Licensing Conditions introduced specific requirements for the license applicant, the LNG facility, the application package, and the operator’s subsequent activities.

During the consultation, we therefore worked through, step by step, what the client needed to verify and prepare before submitting the license application.

Step 1. Determine What Service the Company Will Actually Provide and Whether an LNG Facility Services License Is Required

The future service should be defined before choosing the licensing route. Under the Law of Ukraine “On the Natural Gas Market,” LNG facility services include natural gas liquefaction or LNG regasification using an LNG facility.

To show the client how the licensing route is determined, we analyzed one possible scenario: the company plans to regasify LNG for other market participants. This is a critical distinction because the facility operator will be providing a service to customers. If a business uses the facility solely for its own technological process and does not provide services to third parties, the legal assessment must be based on its actual operating model. Particular attention is required where the gas will later be transferred or sold to third parties.

The activities of an LNG facility operator should not be confused with natural gas supply or equipment installation. A gas supplier sells gas, an installation contractor performs work on equipment, while an LNG facility operator provides facility services. A natural gas supply license does not replace a license to provide LNG facility services.

Gas storage also requires a separate assessment. If a tank within the facility is actually used to store natural gas, a different licensed activity may be involved. Natural gas storage is itself a separate regulated activity. If an LNG facility tank is used specifically for gas storage, the law may treat it as a gas storage facility, which requires a separate license. An exception applies to capacity used solely for the facility’s own operational needs.

The result of Step 1 should therefore be a clear description of the service, its customer, and the role of the future operator. Without this, the company may prepare documents for an activity that does not match the actual project.

Energy-sector companies planning operations in 2027 may also find this article useful: “New KVED Codes 2027 for Licensed Businesses: How the Transition to NACE 2.1-UA Will Affect Licenses”

Step 2. LNG Facility Services License: How to Obtain It After the 2026 Changes

The Licensing Conditions apply to LNG facilities whose combined technical capacity or throughput exceeds 1 million m³ per year or 200 m³ per hour. If there are several facilities, their combined technical capacity is relevant. The future operator must also hold a legally recognized right to the declared facility, such as ownership, a right of use, or another proprietary right.

During the consultation, we also explained how the facility’s technical characteristics and the operator’s legal right to use it affect the licensing route. For example, if the facility has a technical capacity of 250 m³ per hour and the company uses it under an agreement, there are two separate tasks: confirm the equipment specifications and verify that the relevant right to the facility is properly documented in the name of the future license applicant. These figures are illustrative, but they show the logic of the review.

Before filing, the facility name, address, and capacity should be cross-checked across the technical documentation, property documents, right-of-use agreement, and the information to be submitted to NEURC. If the data do not match, the document containing the error should be corrected. For example, an error in a declaration of readiness may require filing a corrected declaration, while a technical error in a certificate may be corrected by notifying the relevant state architectural and construction control authority. If the discrepancy is in the right-of-use agreement, the agreement itself must be brought into alignment.

The statement submitted to NEURC should be prepared using documents that have already been verified. Copying one of several conflicting figures into the NEURC form does not resolve the underlying inconsistency.

Why should this be done before filing? Discrepancies between documents cannot always be cured by an explanation in a cover letter. NEURC’s licensing procedure permits an application to be left without movement only on specified grounds. Inconsistent information may be treated as non-compliance with the Licensing Conditions or as submission of inaccurate information and may lead to refusal. If a refusal is based on inaccurate data, a new application may not be filed until at least three months later. If the error is discovered after filing, it may be worth considering withdrawal of the application, correction of the documents, and refiling a consistent package.

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Step 3. Before Assembling the Application: Check Whether the Future LNG Facility Operator Meets the Requirements

A separate part of the consultation concerned the future business structure. We analyzed a scenario in which a group of companies plans not only to provide LNG facility services but also to supply natural gas itself. At that stage, the key issue is no longer the equipment, but which company may act as the operator and how functions are allocated within the group.

The Licensing Conditions prohibit an LNG facility operator from engaging in natural gas production or supply. They also impose requirements concerning the operator’s independence and the involvement of its officers in companies connected with natural gas production or supply. For example, if the LNG facility operator and the gas supplier have the same director, simply creating two separate legal entities does not in itself resolve the compliance issue.

Before assembling the application, the group should therefore determine which company will be the operator, what functions the other group companies will perform, who manages them, and how control is exercised. The Licensing Conditions also require information confirming the absence of prohibited control by residents of states carrying out armed aggression against Ukraine.

You may also find this useful: Beneficial Owner Checks for a Ukrainian Company: Sanctions and Reputational Risks

The practical conclusion for the client was clear: first build a compliant operator model and, if the project also involves gas supply, separate those functions. Only then should the license application be filed by the selected company. Any natural gas supply licensing route should be addressed separately.

Step 4. Prepare the LNG Facility Readiness Document and Tariff Calculation

Even the correctly selected operating company cannot submit a complete package unless the LNG facility’s readiness for operation has been formally confirmed. The application must include a document confirming readiness, issued in accordance with Ukrainian urban-planning and construction legislation.

Which document confirms that the facility is ready for operation depends on the type of facility and the procedure used to commission it:

• For CC1 consequence-class facilities and facilities constructed under a construction passport, this is a registered declaration of readiness for operation.
• For CC2 and CC3 consequence-class facilities, this is a certificate confirming acceptance into operation of the completed construction facility.
• If the facility was commissioned earlier under a different procedure, the company should determine which readiness document was required at that time.

We also discussed a situation where the equipment has already been installed but the formal readiness document has not yet been obtained. An equipment purchase agreement, photographs of the facility, or a launch schedule do not replace that document. Preparing the license application therefore begins not with filling out the form, but with identifying and obtaining the proper readiness document for the specific facility.

The second documentary block is the tariff calculation for LNG facility services under the methodology approved by NEURC. It is expressly listed among the application attachments. A commercial price list or an investor financial model is not the same as a regulatory tariff calculation. The applicable methodology and source data should be checked against the official rules in force when the application package is prepared; once licensed, the services are provided at tariffs established by NEURC.

These two issues should be resolved before the application form is completed. Otherwise, time may be spent preparing formal forms while the key facility readiness document or tariff calculation is still missing.

Step 5. Assemble and Submit the NEURC Application: Documents Required for an LNG Facility Services License

Once the correct operator has been identified, the LNG facility has been checked, and the readiness and tariff documents have been prepared, the application package can be assembled. The Licensing Conditions require:

• an application for a license using the form in Appendix 1;
• a statement of the places and means used to conduct the licensed activity under Appendix 2;
• a copy of the document confirming that the LNG facility is ready for operation;
• a tariff calculation for LNG facility services;
• information confirming the absence of prohibited control under Appendix 3;
• a list of the documents submitted under Appendix 4.

For an individual entrepreneur who has refused a Ukrainian taxpayer registration number on religious grounds, the Licensing Conditions also require the specified copy of the passport.

Before filing, check once again:

• whether the same applicant, LNG facility, and address are stated throughout the package;
• whether all required forms have been signed;
• whether the authority to act on behalf of the company has been properly confirmed.

 The application is submitted to NEURC using one of the methods it provides. Current forms and the official list of required documents should be checked on NEURC’s Natural Gas licensing page.

Submitting the package does not mean that the license has already been granted.

What Happens After the Application Is Filed?

For project planning, it is reasonable to allow approximately one month for review of a complete and internally consistent application package. If the application is left without movement, the actual process will take longer. NEURC Licensing Procedure No. 548 provides for the following stages:

• Within three business days, NEURC checks whether there are grounds to leave the application without movement. If there are, the Regulator specifies what must be corrected and within what period. The review period is suspended while the deficiencies are being corrected.
• NEURC then decides whether to grant or refuse the license. The procedure allows 10 business days from receipt of the application for adjacent markets and 30 calendar days for natural monopoly activities. If a decision is not made within the relevant period, it is considered at the next scheduled meeting.
• A decision granting the license is published on the NEURC website and entered into the licensing register no later than three business days after it is adopted.
• Within ten business days after publication of the decision, the licensee pays the one-time license fee in the amount of one subsistence minimum for an able-bodied person and submits proof of payment to NEURC.

In practice, preparation often takes considerably longer than the NEURC review itself: commissioning the facility, aligning the facility documentation, structuring a compliant operator model, and preparing the tariff calculation. If the application is refused, the decision must state the grounds and how they can be remedied; the decision may be challenged before an administrative court.

Step 6. Organize Ongoing Compliance After the License Is Granted

Obtaining the license does not end the regulatory requirements. Before operations begin, the LNG facility operator should establish the ongoing processes it must maintain after licensing:

1. maintain separate accounting records for the licensed activity;
2. provide non-discriminatory access to the LNG facility;
3. apply the tariffs established by NEURC;
4. comply with website and reporting requirements.

The Licensing Conditions also require the operator to prepare and submit, every year by October 31, a ten-year LNG facility development plan. These processes should be built into the budget and allocation of responsibilities before operations begin, rather than after the first customer request.

What the Client Gained From the Consultation

As a result of the consultation, the client gained a clear understanding of how the requirements for the operator, the LNG facility itself, and the supporting documents would affect the project’s licensing process.

This made it possible to assess, at the planning stage, which decisions need to be addressed before launch and where difficulties may arise if the organizational model or documents are prepared without taking NEURC requirements into account.

The company can now decide whether to move forward with practical implementation of the project on a sound legal basis. If the project proceeds, we can support the next stage: preparation for licensing and the NEURC application process.

 Planning to provide LNG facility services? Prepare a short description of the intended operations, the facility’s capacity data, and the documents already available for the site. You can then contact us for an online legal consultation to determine the appropriate legal route and the next steps before filing. If the project is already ready to move into licensing, order full legal support and leave the regulatory paperwork to our specialists.