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Resolution No. 845 is a Cabinet of Ministers act (підзаконний акт) that sits one rung below the underlying primary law — Law of Ukraine No. 4154-IX of 18 December 2024 ("On amendments to certain legislative acts of Ukraine concerning the update of the State Programme for the Development of the Mineral Resource Base of Ukraine to 2030 and the regulation of certain issues related to minerals and components of strategic and critical importance"), which entered into force on 17 January 2025 and required the government to publish the implementing taxonomy and deposit lists.
The resolution does four distinct things in one instrument:
1. Strategic-minerals list (11 items). Minerals "crucial for the national security of Ukraine and its economic prosperity": uranium, titanium, zirconium, copper, nickel, tantalum, strontium, niobium, beryllium, aluminium, fluorite. Several of these (uranium, titanium, zirconium) reflect Soviet-era domestic production strengths; others (tantalum, niobium, beryllium) reflect strategic-defence relevance for the post-2022 trajectory.
2. Critical-minerals list (28 items). Minerals "essential for modern technologies" and where there is "no substitute and a high risk of disruptions in supply": lithium, rare earth ores, vanadium, gallium, indium, caesium, tin, and 21 further items broadly aligned with the EU Critical Raw Materials Act strategic-and-critical lists. The alignment is deliberate — Ukraine is a CRMA strategic-partnership country and the taxonomy was negotiated to be CRMA-interoperable.
3. 60 subsoil-area auction list. Sixty named blocks / deposits across the strategic-and-critical universe are designated for electronic auction of special permits for subsoil use under the Subsoil Code procedures, replacing the prior discretionary Cabinet-allocation regime. This is the licensing channel through which most foreign-investor entry for mid- and small-scale projects will flow.
4. 26-deposit PSA tender list. Twenty-six larger deposits are designated for competitive tender for entry into Production Sharing Agreements. PSAs are the heavier-weight instrument used for flagship deposits where the state retains a direct take of physical production; this is the channel envisaged for the largest titanium, lithium, and graphite plays and for the US-Ukraine Reconstruction Investment Fund deal flow.
Severity is set at 3 (qual basis) because:
export control or tariff. It does not by itself raise barriers or change trade flows; it sets the gate through which all future foreign-investor critical-minerals access into Ukraine must pass. Severity should rise to 4 if the auction / PSA channel is later restricted to FEOC-clean buyers (US- or EU-aligned), which would be a material WTO-class restriction.
materially-producing critical-minerals jurisdiction: the country holds approximately 5% of global REE reserves and meaningful titanium, zirconium, lithium and graphite deposits, but production is small and concentrated in titanium-zirconium placers and uranium. The 86-deposit list is an option-value instrument: severity scales with the rate at which the auctions / PSA tenders actually clear and projects reach FID.
the jurisdiction at a moment when it is the central node in the 2025-26 US/EU critical-minerals geopolitics.
This filing places Ukraine in the EM resource-upstream-capture theme alongside Kazakhstan (2023-12-28 rare-earth-metals comprehensive plan), Uzbekistan (2025-03-07 critical-minerals national programme), and Mongolia (2024-04-19 sovereign-wealth- fund law) — the post-Soviet / Central Asia critical-minerals governance architecture that is being knit together by parallel US "FORGE" and EU CRMA strategic-partnership instruments.
The geopolitical context is the fulcrum of the action:
Resources Agreement" (also called the Reconstruction Investment Fund agreement) is the bilateral umbrella; its operationalisation depends on a working domestic licensing channel inside Ukraine. Resolution No. 845 is that channel — the auction and PSA pipelines are the legal mechanism through which US-side beneficial owners can access UA deposits.
country; the EU has flagged Ukrainian titanium, lithium, and graphite as strategic-supply-chain priorities. The list-design is deliberately CRMA-interoperable.
state's mechanism to retain physical production share — a fiscal and resource-sovereignty hedge against the IMF / EU / US pressure to deregulate-and-privatise post-war reconstruction.
diversification benefit if even a fraction of the 86 deposits reach production. Multi-year tail.
is the deal-flow vehicle for large-scale Western entries; watch the ministerial tender announcements through 2026.
845 makes the Fund operationable at the licensing layer; FID on the first PSA-track project will be the next inflection.
will almost certainly be paired with secondary instruments excluding Russian-aligned and (likely) Chinese-aligned beneficial owners — the explicit FEOC pattern. File any such exclusion regulation as a separate amendment.
critical minerals at the Ukrainian level is a precondition for recognition as CRMA strategic projects, unlocking EU IPCEI / Innovation-Fund eligibility.
resolution and annexes (with the 11+28 list and the 86-deposit list) should be sourced from zakon.rada.gov.ua at /laws/show/845-2025-%D0%BF once the document index updates. Until then the kmu.gov.ua press-page is the primary citation.
Service of Geology and Subsoil (Derzhgeonadra) to publish the auction calendar; the first batches were targeted for late 2025 / early 2026. File a follow-on action for each cleared auction batch with material foreign-investor participation.
flagship plays (Polokhivske / Dobra lithium, Synshyna / Vil'noye titanium-zirconium placers, Zavallivske graphite). Each tender award is a candidate amendment / new filing.
Cabinet resolution defining FEOC-clean beneficial-ownership requirements for auction / PSA participation has been signalled but not yet promulgated as of filing date. Watch.
30 April 2025 agreement should itself be filed as a separate IPTM action and Resolution No. 845 should responds_to it once the predecessor is in the register.