On July 1, 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 904, which amended Resolution of the Cabinet of Ministers of Ukraine of March 13, 2022, No. 303 "On the Termination of State Supervision (Control) Measures Under Martial Law."

What exactly has changed in the procedure for carrying out state supervision and control measures under martial law is explained by experts of the Ukrainian Agri Council, within the framework of a project to support Ukrainian agricultural producers from affected regions in partnership with the international humanitarian organization Mercy Corps.

According to the amendments introduced, it has been clarified that unscheduled measures to check the fulfillment of orders and directives without an application by a person, that is, on the initiative of the control body, may be carried out only with regard to those documents that were issued as a result of measures that took place no earlier than February 24, 2022.

It has also been clarified that, at a person's request, an inspection of their fulfillment of orders or directives issued as a result of previous control measures may be carried out, among other things.

A prohibition has been established on carrying out inspections of the fulfillment of orders, directives, or other documents if they concern real estate objects for which at least one of the following circumstances exists:

• information about the object has been entered into the State Register of Property Damaged and Destroyed as a Result of Hostilities, Terrorist Acts, or Sabotage;
• the object is located in territories of active or possible hostilities for which no date of completion or cessation has been determined, or in temporarily occupied territories of Ukraine according to the list of the Ministry of Development;
• the object is located on land plots classified as zones of risky farming;
• the object is located in territories included in the Register of Territories Contaminated or Presumably Contaminated with Explosive Objects

The resolution has also been supplemented with a new paragraph 1-1. It stipulates that the provisions of this resolution do not apply to carrying out inspections of state authorities, local self-government bodies, and other state bodies.

In addition, the grounds for carrying out unscheduled measures by decision of the central executive authority (CEA) have been expanded. References to paragraphs seven, eight, and twelve of part three of Article 19 of the Law of Ukraine "On the Licensing of Types of Economic Activity" have been added to them.

Previously, the resolution mentioned only paragraph eleven of this article — regarding the existence of a threat to the life or health of people, the natural environment, or state security that is directly related to the licensee's conduct of a type of economic activity.

After the changes, the following have also been added to the grounds:

• a directive on eliminating violations of licensing conditions, issued as a result of carrying out a state supervision or control measure — for the purpose of checking its fulfillment;
• a substantiated appeal by an individual, an individual entrepreneur, or a legal entity stating that, as a result of the licensee's violation of licensing conditions, such person or persons were caused material damage or their legitimate rights or interests were violated — for the purpose of checking the licensee's compliance with the licensing conditions in the relevant part;
• the submission by a licensee of a written application to the licensing body for carrying out a state supervision or control measure at their request.

At the same time, an exception to the general rule prohibiting inspections in dangerous territories has been added. The restrictions on real estate in dangerous zones or damaged objects do not apply to control measures carried out by the State Service for Food Safety and Consumer Protection in accordance with certain provisions of the resolution.

This concerns control measures carried out:

• in accordance with paragraph 1 of the resolution — by court decision, upon the application of the person being inspected, or to check the fulfillment of orders;
• in accordance with paragraph 4-5 of the resolution — regarding the quality of food products for the Defense Forces;
• in accordance with paragraph 9 of the resolution — regarding the requirements of veterinary practice and the production of veterinary preparations;
• in accordance with paragraphs four and five of paragraph 4-1 of the resolution — regarding legislation on food products, feed, animal by-products, animal health and welfare, as well as state regulated prices, metrological supervision, and consumer rights protection in the sphere of the provision of housing and communal services.

The procedure for making decisions on unscheduled inspections regarding state regulated prices, metrological supervision, and consumer rights protection, in particular in the sphere of housing and communal services, has also been changed. Now such decisions can be made not only by the central apparatus of the State Service for Food Safety and Consumer Protection, but also by its territorial bodies.

Separately, paragraph 4-5 of the resolution has been clarified, which provides for unscheduled measures in the event of establishing facts of the non-compliance of food products with safety and quality requirements, which poses a threat to servicemembers of the Armed Forces of Ukraine, the National Guard of Ukraine, the State Border Guard Service of Ukraine, and the State Guard Directorate of Ukraine.

The state customer service of the Ministry of Defense of Ukraine has been directly added to the list of initiators of such inspections. Such an appeal is submitted in agreement with the Ministry of Defense of Ukraine.

It has also been clarified that the grounds for such inspections are the risks of the emergence and spread of infectious diseases and poisonings that have or may have a negative impact on defense capability, the rights, legitimate interests, life, and health of servicemembers.

In addition, the terminology has been updated throughout the text of the resolution. In particular, the words "legal and natural persons, individual entrepreneurs" and the term "business entity" have been replaced with the wording "legal entities, individual entrepreneurs, and natural persons" in the relevant cases.

As a reminder, with questions arising in the operation of farms — in particular regarding state supervision and control, land relations, the reservation of workers, confirmation of criticality, tax accounting, and participation in state support programs — agricultural producers can contact the UAC legal advisory line free of charge.

To get a consultation, submit your request via the electronic form: https://forms.gle/v56UzTAsrD9Zrx998

For extra information, contact the legal advisory line at: +38 067 522-03-43

For reference:

MERCY CORPS is an international humanitarian organization that operates in more than 40 countries worldwide and provides assistance to people affected by disasters, wars, poverty, and the consequences of climate change.