A large international company that exports air conditioners via Ukraine had, for years, obtained export licenses from the Ministry of Economy without any issues. The goods, the manufacturer, and the delivery terms remained unchanged—only the addenda to the contract were updated.
In 2025, the Ministry suddenly refused to issue the next license. Officials claimed that the expert opinion issued by the Chamber of Commerce and Industry (CCI), which the company had submitted before, was now “outdated” because it had been issued before the new contract addendum was signed. Informally, this looked like an attempt to force the business to order a new paid document each time, even though the product itself had not changed.
At first, the company acted on its own: it submitted the document package several times, obtained official confirmation from the CCI that the opinion remained valid, and approached the public authority through business associations. The response was formal remarks and no decision.
The business then turned to the Business Ombudsman Council. The Council’s inspector established direct contact with the responsible officer at the Ministry and explained that the demand to “renew” the opinion had no basis in law. In parallel, the Council sent an official letter to the Ministry with legal arguments and a request to issue the license based on the documents already provided. The letter noted that regulations do not require the CCI opinion to be “renewed” for every contract addendum, and that the opinions submitted by the company, together with the Chamber’s letter, confirmed their validity. Therefore, refusing to issue a license under such circumstances could indicate an unlawful restriction of the business’s rights.
As a result, the Ministry issued the license without requiring a new CCI opinion. The company was able to fulfill the contract on time and avoid financial losses, and the Council closed the case as successfully resolved.
