This Resolution of the Cabinet of Ministers of Ukraine No. 805 dated June 17, 2026, introduces significant amendments to the procedure for reconciling debt arising from the difference in tariffs for heat and water supply enterprises. The main purpose of the document is to clearly regulate reporting, establish strict deadlines for document submission, and exclude debts incurred in temporarily occupied territories from the reconciliation process.
### Structure and Key Changes
The Resolution updates the Model Regulation on the Territorial Commission, focusing on four key aspects:
1. **Exclusion of Occupation:** A prohibition has been established on the reconciliation of debt incurred in temporarily occupied territories.
2. **Regulation of Reporting:** The list of documents that enterprises must submit to commissions has been expanded, specifically by adding new NEURC (National Energy and Utilities Regulatory Commission) reporting forms.
3. **Establishment of Deadlines:** A clear schedule for submitting applications and calculations has been introduced (quarterly during martial law), as well as consequences for violating these deadlines — the return of documents without consideration.
4. **Verification Procedure:** The mechanism for identifying errors in calculations, the procedure for their revision, and the mandatory publication of data on the websites of state administrations and the NEURC have been detailed.
### Most Important Provisions for Practice
For lawyers and enterprise executives, the following provisions are most critical:
* **Strict Deadlines:** Documents must be submitted by the 10th day of the second month following the reporting period (for the 4th quarter — by March 10). Missing this deadline results in an automatic refusal to consider the documents until the next period.
* **Mandatory Submission:** Enterprises are required to submit calculations regardless of whether the debt is positive, negative, or zero.
* **Voting Procedure:** A commission decision is now considered approved only if supported by two-thirds of those present, with the mandatory attendance of a representative from the State Audit Service.
* **Adjustment of Past Periods:** The Resolution provides a mechanism for accounting for changes in calculations for previous periods if they affect already financed debt volumes, which allows for the legal adjustment of financial indicators.
These changes significantly strengthen control over data accuracy and discipline business entities regarding reporting to territorial commissions.
