Ukrainian government adopts critical raw materials development strategy until 2056

On 27 May 2026, the Cabinet of Ministers of Ukraine (CMU) adopted Order No. 569-r approving the Strategy for the Development of Industries Based on Strategic and Critical Raw Materials and Components until 2056 (Strategy) and the Operational Plan for its implementation in 2026-2028 (Operational Plan). Both the Strategy and the Operational Plan are available on the CMU's official website following the link.

The Strategy sets out Ukraine’s long-term vision for developing high-value industries based on their raw material resources with a focus on strategic and critical raw materials, and establishes the regulatory, institutional and investment conditions necessary for Ukraine to become one of leading European hubs for critical raw materials (CRM) for integration into EU and global supply chains.

From an investor's perspective, the Strategy is significant because it creates faster permitting, increased geological data transparency, war-risk insurance, preferential financing, development of domestic processing capacity and closer alignment with the EU Critical Raw Materials Act.

Background

Ukraine is one of Europe’s richest countries in minerals and CRM with 20,000 mineral deposits covering 117 types of minerals and 48% of Ukrainian industrial potential linked to their production and use. Ukraine's strategic and critical raw materials include nickel, lithium, titanium, graphite, cobalt and rare earth elements, all identified as strategically important for the US and EU, especially for energy transition (e.g. batteries, renewables), defence and aerospace, and digital technologies.

The Strategy’s key points

The Strategy is built around four strategic objectives:

Accelerate priority investment projects to increase extraction and processing of strategic and critical raw materials

According to the Strategy, this objective will be achieved through the following:

• establishment of a competence centre providing analytical, coordination and methodological functions for the CRM sector;
• verification of reserves and resources of at least 30 CRM deposits according to international reporting standards;
• annual preparation of a portfolio of at least ten priority investment projects and conducting at least ten auctions for special permits for subsoil use;
• reduction of administrative burden for subsoil users;
• restoration of production capacity utilisation to pre-war levels (85% to 90%) by 2028 and a threefold growth in gross value added by 2030.

Integrate Ukraine into global supply chains

The Strategy calls for:

• attracting at least USD 1 billion in foreign direct investment in CRM extraction and processing projects by 2028;
• reducing the share of unprocessed raw materials in exports from 88.9% (2024) to 59% by 2030;
• concluding strategic trade agreements and memoranda with international partners;
• development of railway corridors with European-gauge track connecting key Ukrainian CRM clusters with major European logistics hubs by 2040.

Enhance competitiveness of mineral-based industries through optimisation of production and logistics costs, workforce development, research and innovation

The strategic objective will be considered achieved when:

• self-sufficiency in electricity through own generating capacities and reducing energy costs in production have been realised;
• at least 1,000 engineering specialists have been trained for the mining sector by 2030 and 3,000 specialists in cooperation with educational institutions of developed countries after 2030.

Promote circular economy through development of systems for extracting strategic and critical raw materials from waste and recycling

The strategic objective will be considered achieved when:

• datasets on waste stream volumes containing CRMs and their concentration levels have been created and are being regularly updated;
• specialised research to assess the potential for extracting CRMs from various waste types, primarily mining industry waste, have been conducted;
• a register of technogenic resources with centralised access to information on CRM-containing waste have been created;
• minimum targets for satisfying CRM demand from secondary resources (aligned with EU Regulation 2024/1252) and a pilot eco-industrial parks focused on CRM recycling have been created.

To implement the Strategy, the CMU has adopted an Operational Plan for 2026 - 2028, which sets out specific legislative, regulatory and investment measures.

The key measures are summarised below. 

Key milestones and targets 

The Strategy sets out both medium-term (by 2031) and long-term (by 2056) targets for the development of Ukraine's strategic and critical raw materials sector. 

By 2031, the Ukrainian government will do the following:

• issue more than 30 new special permits for subsoil use;
• accelerate implementation of at least five priority new projects through access to international financing mechanisms, including war-risk guarantees covering up to 90% of capital expenditure;
• deliver at least 20 exploration and extraction projects, including at least ten at industrial extraction stage (e.g. graphite, titanium, uranium, manganese and recovery from waste);
• conclude at least four investment agreements for processing strategic raw materials in Ukraine and create two pilot net-zero technology acceleration zones (aligned with EU Regulation 2024/1735);
• establish conditions for full domestic production chains for spherical graphite, expansion of natural uranium concentrate production, and high-quality manganese sulphate and titanium sponge production;
• develop a circular economy targeting recycling of 50% of industrial tailings and slag (100 million tonnes).

By 2056, the Strategy states that Ukraine will do the following:

• achieve Ukraine’s EU membership and become recognised as one of Europe’s leading hub for strategic and critical raw materials with five fully integrated net-zero technology acceleration zones;
• operate more than 20 active mines, quarries and processing plants;
• develop full domestic industrial chains for production of metallic titanium, graphite anodes and electrodes, batteries, nuclear fuel assemblies, manganese-based alloys and other metals, and rare earth element oxides (i.e. separation and magnetic metal production);
• recycle more than 90% of industrial waste (e.g. ore processing waste, slag and end-of-life batteries), reducing landfill disposal by more than 10%;
• create at least 40,000 jobs for highly qualified specialists and annual graduation of 3,000 mining and related industry engineers in cooperation with educational institutions of developed countries;
• establish exports of strategic and critical raw materials and derived products as one of the five main sources of foreign exchange earnings (over 5% of export revenues);
• decarbonise industrial processes with real-time environmental monitoring and creation of energy infrastructure (decentralised networks based on renewable sources and energy storage facilities).

The Strategy also categorises strategic and critical raw materials into three priority groups summarised in Table 1 below.

Table 1. Priority groups of strategic and critical raw materials

Implementation stages

The Strategy will be implemented in three phases, as illustrated in Figure 1 below.

Figure 1. Implementation stages of the Strategy

Operational Plan: key measures

The Operational Plan for 2026-2028 sets out specific measures, implementation deadlines and responsible authorities, some of which are outlined in Table 2 below.

Table 2. Priority Reform and Investment Measures for Ukraine’s Strategic and CRM Sector (2026-2028)

Monitoring and coordination

The Ministry of Economy will be responsible for overall coordination and monitoring of the implementation of the Strategy. Ministries and other central executive authorities will be required to submit quarterly progress reports beginning in 2026. The Ministry of Economy will prepare annual reports on Strategy implementation, which will be submitted to the CMU by 1 March of each year, starting in 2027, and published on the Ministry’s official website.

Conclusion and next steps

The adoption of the Strategy represents a significant milestone in Ukraine’s efforts to develop its CRM sector and integrate into EU and global supply chains. For the first time, Ukraine has adopted a long-term policy framework that combines geological exploration, processing, industrial policy, investment incentives and EU regulatory alignment within a single strategic document. The Strategy demonstrates the Ukrainian government’s long-term commitment to positioning Ukraine as a leading European hub for strategic and critical raw materials.

For investors and market participants, the Strategy signals the Government's intention to create a more predictable investment framework for the sector and may create new opportunities in extraction, processing, recycling, infrastructure development and technology transfer. Ukraine’s significant raw materials reserves, combined with the planned regulatory reforms and gradual alignment with EU legislation, may offer attractive entry points for strategic investors, technology providers and offtakers.

At the same time, the Strategy is primarily a policy document, and its successful implementation will depend on the adoption of implementing regulations, access to international financing mechanisms, war risk mitigation instruments, and continued alignment with EU requirements including the CRM Regulation 2024/1252.

Businesses active in the mining, energy, infrastructure, defence, manufacturing and technology sectors should closely monitor implementation of the Operational Plan, as many of the proposed reforms, including changes to permitting, investment incentives, geological data access, financing mechanisms and alignment with EU legislation, will be implemented progressively over the coming years and may have a material impact on investment decisions, project development and contractual arrangements. 

While many of the measures outlined in the Strategy will require further legislation and regulatory implementation, the document provides a clear indication of the government's policy direction and priorities for the coming decades. Investors considering opportunities in Ukraine's critical raw materials sector should closely monitor the implementation of the Operational Plan, as it is expected to shape future permitting, financing and investment conditions across the sector.

For more information, contact your CMS client partner or the CMS energy team: Vitaliy Radchenko, Maryna Ilchuk, Yuliia Pidlisna and Maksym Zhurakovskyi.