OVER 500 ILLEGAL FILLING STATIONS: THE SYNERGY BETWEEN UKRAINIAN OIL&GAS ASSOCIATION AND THE BUREAU OF ECONOMIC SECURITY OF UKRAINE REVEALS THE TRUE SCALE OF UKRAINE’S SHADOW FUEL MARKET

In 2025, the Bureau of Economic Security of Ukraine (BES) delivered record results in combating the illegal fuel market. As part of its systematic efforts, 538 problematic filling stations were identified. Of these, 421 sites were flagged on the basis of sectoral analysis conducted by The Ukrainian Oil&Gas Association, while a further 117 were detected directly by BES units.

According to BES data, a total of 76 illegal filling stations were dismantled in 2025, with a further 22 removed in January 2026. As of early 2026, the number of problematic sites had been reduced to 91, all of which remain under active investigation by the BES.

Alongside the dismantling of infrastructure, more than 3,000 tonnes of fuel (diesel, petrol and liquefied gas), as well as fuel vouchers and equipment, were seized from illegal circulation in 2025. The estimated total value of the confiscated fuels, vouchers and technical assets exceeded UAH 250 million. Law enforcement actions were aimed not only at halting individual violations, but also at dismantling the logistics and infrastructure of the shadow market as a whole—from storage facilities to transportation and retail channels.

Yaroslav Starovoitenko, President of The Ukrainian Oil&Gas Association, commented:

“We have consistently emphasised that the actual number of illegal fuel retail outlets exceeds those shown on the PerevirAZS map. This tool is based on consumer reports and, by definition, does not cover the entire shadow segment. The data published by the Bureau of Economic Security of Ukraine have confirmed the depth of the problem and supplemented UOGA’s sectoral analysis: of the 538 identified filling stations, 421 were compiled on the basis of the Association’s information, while a further 117 were detected directly by BES units. This clearly demonstrates the scale of the hidden segment of the market.”

According to Mr Starovoitenko, it was precisely the synergy between industry expertise and the instruments available to the BES that made it possible to move from identifying isolated illegal sites to the systematic dismantling of shadow infrastructure:

“We support both the position and the practical actions of the Bureau of Economic Security of Ukraine in countering the shadow fuel market. Under the leadership of Oleksandr Tsyvinskyi, the work has entered a systemic phase—shifting from responding to individual violations to dismantling the entire infrastructure of the illegal segment. At the same time, this is only the beginning of the journey: the issue extends beyond illegal filling stations to include tax manipulation and unlawful production. We see and welcome the BES’s readiness to address all components of the illegal fuel market—both those visible to consumers and those that remain out of sight, yet inflict billions of hryvnias in losses on the state budget and, consequently, on the defence forces. We hope that 2026 will become the final year in which the illegal segment exists as a systemic phenomenon.”

According to BES estimates, as a result of consistent de-shadowing measures, legal turnover in the fuel market increased by UAH 23.06 billion in 2025 (+6.1%). In just two months of intensified activity at the end of the year, the state budget received an additional UAH 3.09 billion, against BES expenditures of approximately UAH 4.3 million—evidence of the high economic efficiency of these measures.

The Ukrainian Oil&Gas Association is confident that further progress will depend on strengthening legislation, consolidating the efforts of state and supervisory authorities, and securing support from local governments.

The Ukrainian Oil&Gas Association will continue to serve as a reliable partner to the state in implementing best practices of transparent and responsible business conduct in the petroleum products market.

The Ukrainian Oil&Gas Association is an industry association representing the interests of the largest players in the oil and gas market. Its membership currently includes leading wholesale, retail, extraction and processing companies representing national, international, private and state-owned businesses, among them WOG, OKKO, AMIC Ukraine, SOCAR, KLO, UPG, Orlen, Parallel, Ukrgasvydobuvannya and Ukrnafta. The Association plays an active role in developing the country’s legislative framework, monitoring and addressing key sectoral challenges, and engaging closely with public authorities, private and state-owned enterprises, industry and consumer associations, consulting agencies and the media, with the aim of implementing and upholding European standards of service quality in the market, as well as protecting the interests of its members.