To improve the management of mineral resources and align with national and international priorities, the Cabinet of Ministers of Ukraine adopted Resolution No. 845 “On the approval of the lists of minerals and components of strategic and critical importance, and the lists of subsoil areas (i.e mineral deposits) of strategic and/or critical importance” dated 14 July 2025 (the “Resolution”), which establishes the national list of critical and strategic minerals and lays the groundwork for a more transparent and investment-oriented regulatory framework.

Background

Ukraine possesses a rich and diverse mineral base, including significant reserves of iron ore, manganese, coal, uranium, and critical raw materials, such as lithium, graphite, titanium, and rare earth elements. These resources are vital for industrial development, defence, green energy transition and the economic growth (to learn more about the economic potential of Ukrainian mineral resources see Picture 1. Regional value of Ukraine`s mineral resources). In response to growing geopolitical and economic challenges, the Ukrainian government has prioritised the strategic management of its mineral wealth.

Picture 1. Regional value of Ukraine’s mineral resources

Source: Ukraine Invest

Newly approved lists of minerals of strategic and critical importance

As stated, Resolution No. 845 establishes the national list of critical and strategic minerals and lays the groundwork for an improved regulatory framework.

The Resolution No.845 aims to ensure proper implementation of the objectives set out in Chapter 13 (Critical Raw Materials Management) of Ukraine’s Plan under the Ukraine Facility №244-p dated 18 March 2024. The Resolution No.845 and its annexes are available at the following link.

With the adoption of the Resolution No.845, the Ukrainian Government reviewed and classified the country`s mineral resources into two categories: 

• minerals of strategic importance; and 
• minerals of critical importance (see below the Table 1. Approved lists of minerals of strategic and critical importance).

Table 1. Approved Lists of Minerals of Strategic and Critical Importance

List of minerals and components of strategic importance (11 minerals):
Aluminum, beryllium, copper, nickel, niobium, strontium, tantalum, titanium, uranium, zirconium ores and fluorite.

List of minerals and components of critical importance (28 minerals):
Aluminium, beryllium, copper, nickel, niobium, strontium, tantalum, titanium, uranium, zirconium, fluorite, vanadium, bismuth, tungsten, gallium, hafnium, indium, rare earth elements, lithium, arsenic, tin, lead, scandium, antimony, tellurium, cesium, zinc, potash salt.

The main difference between strategic and critical minerals under the Subsoil Code of Ukraine No.132/94-BP dated 27 July 1994 lies in their designated function and the associated supply considerations. Strategic minerals are those metallic and non-metallic resources of national importance that are essential for long-term economic development, technological innovation, defence capability, and energy transition within Ukraine. They are prioritised for their role in supporting key domestic industries, export potential, and national security.

Critical minerals, however, include those already deemed strategic and others that are vital for the economy and defence, but are characterised by a lack of substitutes and a high risk of supply disruptions on the international market. Their criticality arises primarily from vulnerability to external supply shocks and their indispensable role in industrial processes, particularly where no viable alternatives exist at the current technological level.

In practice, this distinction may affect how the state prioritises exploration, licensing, investment incentives, and international cooperation, with critical minerals often subject to heightened monitoring of supply risks, while strategic minerals are more closely tied to national development and defence planning.

Procedures for granting access to strategic and critical subsoil areas

Additionally, Resolution No. 845 establishes a list of specific subsoil areas (mineral deposits) of strategic and/or critical importance to be granted for use through the following mechanisms: 

• auctions (electronic bidding) for the sale of special permits for subsoil use: 60 subsoil areas and mineral deposits are included; and
• competitive selection procedures for entering into Production Sharing Agreements (PSAs): 26 subsoil areas and mineral deposits are included.

These mechanisms are expected to increase transparency and predictability in subsoil access, thereby boosting investor interest and attracting sustained investment into Ukraine’s extractive sector. Over time, this should support the modernisation of mining operations, increase state revenues, and enhance Ukraine’s integration into global supply chains for critical raw materials.

The adoption of the Resolution No. 845 reflects the ongoing development of Ukraine’s extractive sector, prompted by the heightened interest of international partners, particularly, the United States of America, with who Ukraine has recently signed a “Minerals Deal”.

US-Ukraine Minerals Deal

On 30 April 2025, Ukraine signed a strategic partnership with the United States of America focused on the development of critical mineral supply chains essential to both countries' security and economic resilience. (To learn more about the Ukraine-US Agreement on the establishment of a Reconstruction Investment Fund dated 30 April 2025, see this CMS overview.)

To implement the Minerals Deal and establish the Reconstruction Fund, however, Ukraine must undertake significant reforms of its legislation, including amendments to laws such as the Budget Code, Subsoil Code, Law “On Production Sharing Agreements”, Law “On Oil and Gas”, and various sub-legislative regulations.

Upcoming development of Dobra lithium deposit

On 17 June 2025, First Deputy Prime Minister and Minister of Economy of Ukraine, Yuliia Svyrydenko (recently appointed as Prime Minister of Ukraine), announced that the Interagency Commission on the Organisation of Conclusion and Implementation of PSAs (PSA Commission) is preparing a tender for the conclusion of a PSA for the Dobra lithium deposit, located in the Kirovohrad region.

The Dobra site falls under the mandate of the US-Ukraine Reconstruction Fund and may become the first pilot project within the framework of joint investment efforts. The tender terms for entering into a PSA for this deposit are expected to be approved and announced shortly.

Detailed information on the location, available minerals, and estimated reserves of the Dobra site is available on the official website of the State Service of Geology and Subsoil of Ukraine at the following link. 

To learn more about Ukraine`s natural resources, mining, and oil & gas sector, see the recently updated CMS Ukraine Investing and Doing Business in Ukraine 2025 Guide, available at the following link.

For more information on Ukrainian natural resources regulation and subsoil use, contact your CMS client partner or reach out to the following experts: Vitaliy Radchenko, Maryna Ilchuk.