On 15 July 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 941, updating the Licensing Conditions for the carriage of passengers, dangerous goods and hazardous waste by air.

The amendments apply both to existing air carriers and to companies intending to obtain a licence in Ukraine.

Key changes

Licence applicants must confirm that they:

• are not controlled by residents of a state committing armed aggression against Ukraine; and
• have no trade relations with such residents.

These requirements also apply to existing licensees. The relevant information must be submitted using a newly prescribed form.

New accessibility requirements have also been introduced for premises where air tickets are sold, for the benefit of persons with disabilities and other persons with reduced mobility. These requirements will apply following the termination or lifting of martial law.

The Resolution introduces new application forms for the grant, reissue, extension, suspension, reinstatement and termination of a licence. It also clarifies that dangerous goods may only be carried where the air carrier holds the relevant approval specified in its operations specifications.

Deadlines for air carriers

Resolution No. 941 will enter into force two months after its official publication, on 16 September 2026.

Existing licensees will then have two months to submit information confirming the absence of control and trade relations involving residents of the aggressor state.

Air carriers should therefore review their ownership structures and relationships with counterparties in advance and prepare the required documents using the newly prescribed forms.