Integrated Environmental Permit: New Permit Documentation for the Industrial Sector

On 8 August 2025, Law No. 3855-IX (the “Law”) came into force, introducing a mandatory integrated environmental permit (the “IEP” or the “Permit”) for industrial installations, including factories, plants, and other stationary facilities.

Significance

The Law aligns national legislation with EU standards by introducing a unified approach to assessing the environmental impact of industrial installations.

Instead of obtaining three separate permits — for air emissions, water use, and waste management — companies will now receive a single, integrated permit.

This shift is designed to:

• ease access to EU markets by demonstrating compliance with European environmental standards;
• reduce regulatory hurdles;
• ensure smoother inspections;
• lower the risk of supply chain delays;
• boost competitiveness on the global stage.

Conditions for obtaining the permit

Regulated object. The IEP is issued for the installation — a stationary facility with technically connected production processes that work as one system and have an environmental impact.

The Permit may cover:

• a single installation with all connected production processes;
• a group of installations, if they are located within the same industrial site and operated by the same company (operator).

Criteria. The IEP is mandatory for active installations that meet both of the following criteria:

• at least one of the following permits has already been obtained for the operation of the installation: air emissions, special water use, or waste management operations;
• the installation conducts a type of activity listed in the annex to the Law (e.g. in the energy sector, chemical industry, or metal processing and production etc).

For new installations, obtaining an IEP is based on performing an activity specified in the annex of the Law.

BAT. Every company applying for the Permit must operate in accordance with the Best Available Techniques (the “BAT”) — documents establishing environmental standards for emissions, energy efficiency, monitoring, and sustainable production practices to reduce industrial pollution.

Since BAT conclusions are not yet implemented, the Law’s criteria will apply — including requirements for low-waste technologies and the use of safer substances:

• for active installations — until the BAT conclusions are implemented, but not earlier than 8 August 2029;
• for new installations — until the BAT conclusions are implemented.

For active installations, the initial issuance of the Permit may allow for less stringent standards.

Procedure for obtaining the Permit

• Responsible authority: Ministry of Environmental Protection and Natural Resources.
• Submission: through the user account of the Unified State Register of IEPs (the “Register”), operational since 17 September 2025.
• Document review procedure: includes inspection of the installation, issuance of conclusions by competent authorities (State Environmental Inspectorate, Ministry of Energy, etc.), public consultation through the Register, and possible cross-border consultations in cases of potential significant transboundary environmental impacts.
• Review period: approx. 4–5 months, assuming all documents are complete and no cross-border consultations are needed.
• Validity: indefinite.

Transitional period

For active installations, the IEP must be obtained within 4 years:

• by 8 August 2028, operators must submit their application and supporting documents via the Register user account;
• permits for emissions to air, special water use, and waste management operations will cease to be valid once the IEP is issued, but no later than 8 August 2029.

Operators of new installations planning to commence operations before 8 August 2026 must submit their IEP application no later than 8 November 2025.

⚠️ Failing to submit documents on time to obtain or renew an IEP may lead to significant legal risks, including administrative or criminal liability if operations are conducted and environmental impacts occur without the required permits.

Recommendation

Due to the complexity and timeline of the IEP application process, we recommend confirming early whether your installation is subject to this requirement.

📩 For more details, please contact: Maryan Martynyuk, Senior Partner ✉️ m.martynyuk@moris.law

This legal alert is for general information purposes only and does not constitute legal advice.