29.05.2025
Energy Club, Ukraine’s largest business community of energy companies, has received an official response from the Ministry for Communities, Territories and Infrastructure Development of Ukraine (Ministry of Infrastructure) to its appeal regarding new regulatory requirements for the vehicles of Distribution System Operators (DSOs).
Previously, on May 12, 2025, Energy Club sent an appeal to the Prime Minister of Ukraine, the Minister of Energy, and the Head of the National Energy and Utilities Regulatory Commission (NEURC). The appeal highlighted the critical challenges for DSOs related to the Order of the Ministry of Transport and Communications of Ukraine No. 340 dated 07.06.2010 (as amended), which mandates the equipping of trucks with a total weight exceeding 3.5 tons with tachographs. The key problem identified was the lack of предусмотренного funding for the installation of tachographs in the DSOs’ investment programs for 2025, creating a threat to the stable operation of critical infrastructure enterprises, especially under martial law and continuous restoration work.
Energy Club emphasized that the cost of installing one tachograph ranges from UAH 50,000 to UAH 60,000, and the total expenses for one company could exceed ten million hryvnias. Meanwhile, the State Service of Ukraine for Transport Safety has already begun to issue violation notices, with fines of UAH 34,000 for each case. This, in turn, could lead to the inability of DSOs to use their trucks for repair work, substation protection, and other critically important tasks.
In its appeal, prepared following the Energy Freedom by Energy Club meeting on “New regulatory requirements for DSO vehicles: Challenges and solutions” on May 8, 2025, Energy Club proposed amending paragraph 1.4 of Section I of the Regulation on the working time and rest periods of drivers, by adding an exemption for vehicles of electricity transmission and distribution system operators, provided they operate within their licensed territory.
In its response dated May 26, 2025, signed by Deputy Minister Serhii Derkach, the Ministry of Infrastructure stated that it had processed Energy Club’s proposal. The Ministry noted that the requirement to equip trucks with tachographs was established back in 2010 and has not undergone changes in this regard.
At the same time, the Ministry of Infrastructure acknowledged the urgency of the issue, especially for territories of possible hostilities. It is reported that the Ministry is currently processing Energy Club’s proposal along with similar appeals from other business entities. The development of amendments to the Regulation is being carried out taking into account the need to adapt national legislation to EU law, in particular, Regulation (EC) No 561/2006 of the European Parliament and of the Council.
The Ministry also drew attention to the fact that the current Regulation already contains exceptions; in particular, it does not apply to transportation during natural disasters, accidents, and other emergency situations, which, according to the Classifier of Emergency Situations, also include military-related emergencies.
Energy Club will continue to actively advocate for the interests of its members and contribute to finding solutions that will ensure the stable and uninterrupted operation of Distribution System Operators, which is critical for Ukraine’s energy security.
