The fuel and lubricants market has traditionally been one of the most shadow-heavy sectors of the economy due to illegal production, the sale of fuel without proper licensing, and evasion of taxes and excise duties.
The Economic Security Bureau of Ukraine combats the shadow economy systemically rather than through isolated actions, focusing on overcoming a negative phenomenon that has persisted for at least 30 years.
The ESBU’s approach to de-shadowing the fuel and lubricants market:
A deep market analysis is conducted: how the schemes operate, who is involved, the mechanisms behind their existence, and why they remain profitable.
The ESBU’s actions are aimed not only at holding offenders accountable but also at dismantling the schemes themselves. The Bureau’s task is to make illegal activities economically unviable so that they simply cease to make sense. Rather than fighting isolated violations, the ESBU targets the entire system that allows shadow businesses to operate. Therefore, the impact is directed at infrastructure and logistics: equipment, premises, transport, supply chains, and storage channels.
The level of de-shadowing is subject to constant monitoring. The public is also involved in this process. Specifically, through the StopShadowBot, anyone can report potential violations, enabling faster response and maintaining control over the situation.
Furthermore, there has been a transformation in the approach to addressing illegal gas stations—moving beyond mere prosecution to increasing pressure on the shadow sector through the dismantling of illegal facilities, as well as the seizure of fuel tankers and other assets essential to the functioning of these schemes. This allows for the final termination of illegal activities rather than just a temporary suspension of violations.
The key indicator of the effectiveness of this work is real market change, specifically the growth in sales among legal participants and the absence of illegal gas stations.
The Economic Security Bureau of Ukraine systematically exposes and shuts down shadow schemes by blocking the activities of illegal gas stations, clandestine production facilities, and fictitious fuel supply chains.
In 2025, the total estimated value of seized fuel and lubricants, fuel coupons, and equipment related to illegal circulation amounted to over UAH 250 million.
As part of the measures taken, the following items were seized:
The liquidation of the shadow market infrastructure involves not only the seizure of illegal fuel but also the termination of its storage facilities, as well as its transportation and distribution channels.
In 2025, the Economic Security Bureau of Ukraine nearly tripled its results in countering the illegal circulation of fuel and lubricants, as well as the operations of illegal gas stations, compared to 2024. This demonstrates the Bureau's systemic efforts toward de-shadowing the fuel market.
For comparison: in 2024, ESBU detectives seized 1,069 tons of fuel and 88 units of equipment from illegal circulation, with a total value of UAH 94.1 million. By 2025, these figures had surged significantly—with over 3,000 tons of gasoline, gas, and diesel fuel, 71.8 tons of fuel coupons, and 171 units of equipment being seized.
The total value of assets seized in 2025 exceeded UAH 250 million, which is nearly three times higher than the previous year.
In 2025, as a result of the work of ESBU detectives, 102 criminal proceedings were entered into the Unified Register of Pre-trial Investigations (ERDR), 47 of which were referred to court.
Following judicial review, 33 guilty verdicts have been issued, representing 70% of the cases transferred to court. Such a result demonstrates the high quality of the evidence base and the effectiveness of the pre-trial investigation.
The figures on the map reflect the regional distribution of identified problematic facilities as of November 2025. This period marked the beginning of the ESBU's systemic operations against illegal gas stations.
In total, 538 gas stations were identified, including 421 facilities based on information from the Ukrainian Oil and Gas Association and an additional 117 detected independently by ESBU units.
The legality of 158 facilities has been confirmed, while 44 gas stations were dismantled. The remaining stations were non-operational at the time of the review; however, they remain under ESBU monitoring as they may resume their activities.
Overall, 76 illegal gas stations were dismantled in 2025, with an additional 22 dismantled in January 2026 alone.
As of January 2026, the number of problematic gas stations has decreased to 91 as a result of the Bureau’s operations. These are currently being processed by the ESBU.
The provided figures reflect the number of such gas stations by region.
As a result of consistent actions and the transformation of the ESBU's approaches, the following results have been achieved.
In 2025, an increase in legal sales was recorded, rising from UAH 380.41 billion in 2024 to UAH 403.47 billion in 2025, which represents a growth of +UAH 23.06 billion (+6.1%).
Additionally, a positive trend in revenue growth was observed in the fourth quarter of 2025 compared to the same period in 2024:
Stable dynamics were demonstrated in the fourth quarter of 2025 regarding the growth of fuel sales volumes compared to the same period in 2024:
The ESBU's priority is to invest resources where they yield a real financial impact for the state—primarily in the fight against the shadow economy.
In November and December 2025, the ESBU's expenditures for detective operations during the crackdown on illegal gas stations (including salaries, transport costs, fuel, communications, and operational and procedural actions) amounted to approximately UAH 4.3 million.
The result: +UAH 3,091.94 million in additional budget revenue over these two months.
Efficiency: An investment of UAH 4.3 million → UAH 3.09 billion in revenue. This means every hryvnia invested by the state is returned to the budget nearly a thousandfold.
Going forward, law enforcement expenditures will decrease while budget revenues will continue to grow as a result of market legalization.
The ESBU considers this specific approach—increasing budget revenues through targeted actions—to be more relevant than simply measuring performance by the number of cases per detective.
The ESBU proposes to strengthen the liability for legislative violators and is initiating the reclassification of crimes under Parts 1–2 of Article 204 of the Criminal Code of Ukraine as serious offenses. This would enable the use of covert investigative actions, the confiscation of all property, and the overall strengthening of criminal liability. The current liability system provides for the confiscation of equipment only, while other property of the offenders remains in their possession.
In accordance with current legislation, all law enforcement agencies are granted the authority to use special technical means for the covert collection of information. Following the adoption of the Law of Ukraine 'On the Economic Security Bureau of Ukraine,' no amendments were made to the Cabinet of Ministers of Ukraine (CMU) Resolution No. 1450, dated October 27, 2001; thus, the right to use special technical means remained with the State Tax Administration of Ukraine. The absence of these amendments critically impacts the ESBU's ability to conduct covert investigative actions.
The Economic Security Bureau of Ukraine has designated the fight against the illicit fuel and lubricants market as one of its priority areas for 2026. The complete cessation of illegal gas station operations in the first half of 2026 is the first stage in de-shadowing this market.