09.05.2025
New regulatory requirements for distribution system operators’ (DSOs) vehicles, challenges, and ways to find solutions were discussed on May 8th during the Energy Freedom talk show by Energy Club.
The basis for the discussion was the entry into force of Order No. 1432 of the Ministry of Communities and Territories Development of Ukraine dated December 6, 2024, which mandates the use of tachographs on freight vehicles with a maximum mass exceeding 3.5 tons. The lack of предусмотренное funding for the installation of tachographs in the Investment Program for 2025 jeopardizes the stable operation of DSOs, which are critical energy infrastructure facilities and daily carry out restoration and repair work after enemy shelling.
Representatives of DSOs participated in the discussion, sharing the situation at their enterprises and emphasizing the impracticality of installing tachographs under the current conditions due to a lack of funding, outdated equipment, and the existence of individual driver control books and schedules used to track the work of personnel and vehicles.
The moderator of the meeting, Energy Club Vice President Valeriy Bezus, stated that the discussion was initiated following an appeal to the Club from electricity distribution system operators who, due to the need to comply with Order No. 1432 of the Ministry of Communities and Territories Development of Ukraine dated December 6, 2024, faced a serious challenge in implementing its requirements mid-year with previously approved investment programs.
The heads of regional energy companies spoke about the difficulties, or rather, the impossibility of complying with the norms of the Order.
Thus, Serhiy Shatalov, First Deputy Executive Director of PJSC “Zaporizhzhiaoblenergo,” said: “We already have such experience, and some old vehicles have tachographs, so-called ‘washers,’ that recorded movement on paper. We have 46 vehicles that fall under this regulation, and the ‘newest’ of the vehicles was manufactured in 2013. We do not feel any problems with the implementation of this provision: in the frontline region, we have good relations with the transport police. At the same time, we understand that if this document comes into force, we, like all DSOs, will have several questions. Firstly, technical implementation. This requires a financial source – an investment program. Colleagues will confirm that we will be able to implement changes only at the end of summer, meaning there is no chance of meeting the requirements by the end of the year. Moreover, our DSO’s Section 6, aimed at implementing transport measures, is zeroed out. There is nowhere to reallocate funds from. We, as a DSO, operate around the clock. During emergencies, all personnel, including drivers, are involved in completing tasks. Therefore, the presence of an installed tachograph or, as an alternative, a driver’s working time control log, is unlikely to limit the speed and other data that this device is supposed to record.
We propose to amend clauses 1.3 and 1.4 of this Order so that the changes do not apply to the special transport of DSOs.”
Serhiy Shatalov’s colleagues from other enterprises fully supported him.
“We have not yet encountered the problem of fines or sanctions regarding the absence of tachographs, but first of all, it is necessary to determine the list of vehicles with a maximum mass of up to 3.5 tons mentioned in the Ministry’s Order,” noted Serhiy Shashkov, Director of Operational Support at JSC “Sumyoblenergo.” “Like everyone else, we have vehicles that directly transport goods and aerial platforms that, according to their vehicle passports, are considered special mechanisms but are actually on a freight chassis and have a maximum mass exceeding 3.5 tons. That is, clarifications are needed that clearly define which vehicles must have tachographs installed.
We analyzed court practice: there are cases where the court concluded that the procedure for equipping a vehicle with a tachograph is provided by law only for persons providing freight and passenger transportation services. All distribution system operators, of course, do not engage in this, because we are not transport companies and perform work exclusively and primarily for our own needs – in particular, for eliminating emergency situations.
The 2025 investment programs have already been approved, and most DSOs have already completed all tenders and made purchases. Increased funding is not предусмотрено. And the additional burden on the investment program and the purchase of tachographs will occur at the expense of reducing expenditures on other items that are more necessary for the production process. It is imperative that public organizations appeal to the relevant ministry to amend clause 1.4 to exempt DSOs and TSOs from this obligation. After all, damage elimination can occur around the clock, and the distribution system operator becomes a hostage of the situation: being punished for overtime work or for not restoring power supply to consumers in a timely manner. Today, especially under martial law, this is unacceptable.”
Mykola Hlushchenko, Head of the Central Transport Service at JSC “Kharkivoblenergo,” confirmed the emergence of problems due to the entry into force of the Order. In April, a protocol was drawn up against the enterprise, and court proceedings are ongoing. The legal department of “Kharkivoblenergo” is working on resolving this issue. The Kharkiv region is also a frontline area where hostilities are constantly ongoing, and the company’s vehicles are involved around the clock in urgent work to eliminate the consequences of destruction and damage. No one has time to fill out logs, as the primary task is to restore the energy system.
“Kharkivoblenergo” has 327 units of equipment that need to be equipped with tachographs. The average market price of one tachograph is 50-60 thousand hryvnias, plus installation costs. In total, equipping the vehicles with tachographs requires about 16 million hryvnias. The time for these works must also be considered – only one enterprise in the Kharkiv region can do this, and a maximum of 2-3 devices can be installed per day. That is, the process will take 6-7 months. “Kharkivoblenergo” also does not have the financial resources to implement the Resolution.
The prospect of installing tachographs on vehicles weighing 2.5 tons could also negatively affect the company’s efficiency,” said Mykola Hlushchenko.
“Our company has already encountered “Ukrtransbezpeka” several times and paid two fines of 17 thousand hryvnias each. Currently, at the suggestion of “Ukrtransbezpeka,” we have distributed individual control books to all our drivers. Recently, we had a case where our empty freight train was stopped for a tachograph check. The driver showed the individual control book, and he was released,” shared Serhiy Khondohiy, Head of the Logistics and Transport Department at JSC “Ternopiloblenergo.” “But what will happen after the Order comes into force? Our company has 160 units of equipment that fall under the definition of freight vehicles with a mass exceeding 3.5 tons. To equip them with new digital tachographs (because they no longer recommend installing analog ones), we need 9 million hryvnias just for the devices themselves, and also a chip card for each driver, the cost of which is 4-5 thousand hryvnias per unit. Thus, to verify and install a tachograph and produce a chip card for the driver takes a month. This will drag on for years and entails a significant financial burden.
I see no expediency in installing tachographs on the vehicles of DSOs, because all companies already have internal control over working and rest regimes. The daily schedule, vehicle entry-exit logs, and worktime records clearly specify the specific work. Our work schedule is irregular and can distort the operation and data of the tachograph. For example: a car leaves the central base 20 km away, travels 30 minutes further down the road, then goes into a field, travels 10 km, and may stop along the way. And digital tachographs record all this. If “Ukrtransbezpeka” stops it on the road, many questions arise about whether the driver has already worked too much.
We propose to amend the Order and exclude DSOs from the list of those who must equip freight vehicles with tachographs or allow them not to install the devices if they use their transport for the maintenance of power grids.”
A similar situation has developed at PJSC “Cherkasyoblenergo”: the company has 198 vehicles with a maximum mass exceeding 3.5 tons. Equipping them with tachographs will require 10-12 million hryvnias. “We do not see the expediency in this because we carry out our licensed activities within our assigned territory, the boundaries of which do not allow exceeding 8 hours of working time. There are questions regarding the installation of tachographs on domestically produced Soviet-era vehicles. I cannot imagine how this can be done technically. We propose to appeal to the ministry with a request to amend the Order and exclude DSO enterprises and our special equipment from it,” added Oleksandr Homenyuk, Executive Director of PJSC “Cherkasyoblenergo,” joining the initiative of his colleagues.
Andriy Horyachev, Brand Manager for Special Equipment at LLC “Trading House Tekhkomplekt,” studied the situation in the market for the installation, adjustment, and calibration of tachographs. According to him, for half of the transport with a significant period of operation, enterprises will need to install analog tachographs, and there simply won’t be enough of them, even if they collect used ones from Europe. Another question is how long such devices will work?
“All freight transport manufactured from 2012-2013 should have been equipped with tachographs from the factory, otherwise, the law prohibited the import of such equipment into Ukraine. There may have been cases with some brands, but if you take truck-mounted aerial platforms on Iveco Daily 60 and above, they should all be equipped with tachographs,” clarified Andriy Horyachev. “Regarding the operation of this device, there is GPS vehicle monitoring, electronic logs of traffic schedules, vehicle downtime, engine start and stop. Can such schedules be used during “Ukrtransbezpeka” inspections if it is an electronic log that also monitors the operation of the equipment? DSOs do not carry out interregional, commercial transportation of goods or passengers; their transport has a special purpose and is used for conducting economic activities within their territory. That is, there are at least four parameters that justify the exclusion of oblenergo vehicles from this Order. I spoke with other oblenergos that use GPS monitoring. In my personal opinion, we have a calculator, but they force us to buy and use abacuses.”
Summarizing the discussion, Energy Club Vice President Valeriy Bezus stated: “Is there logic in forcing DSOs and other critical infrastructure enterprises to comply with the norms of the mentioned Order? If the ministry sees that there is, then how can we help enterprises go through this process as constructively as possible and with minimal losses, and only after that can we consider whether the existing DSO resources can be used to meet these requirements?
Energy Club will process all proposals, formulate recommendations, and send an appeal to the ministry regarding the settlement of this situation. The Order does not take into account many important aspects for DSOs, and this should be the subject of consideration by the ministry. Otherwise, the costs associated with the need for its implementation will actually be passed on to electricity consumers. We are not talking about the freight transportation services market, where there is a certain logic in passing on costs to customers. But is it worth burdening investment programs, DSOs, and electricity consumers? Therefore, we are integrating the proposals of the discussion participants into our appeal to the Ministry of Communities and Territories Development regarding the need to amend regulatory acts, taking into account the specifics of the activities of Distribution System Operators in the current realities.”
