The situation surrounding the Stynavskyi oil and gas field in the Lviv region could lead to a dispute over the future allocation of development rights after the special permit held by the Borislav Oil Company (BOC) expires. The problem stems from the fact that another special permit—No. 5398 for the Semiginovskoye field, issued back in 2011 to the company “PARI,” whose legal successor is “PARI NEFTEGAZ”—is in effect for the same territory.
As the publication “Kapital” noted, the geological peculiarity is that the Stinavskoye and Semiginovskoye fields are actually located one directly beneath the other. The Stinavskoye deposits lie at depths of approximately 2.8–3.6 km, while the Semiginovskoye deposits begin deeper. However, the documents for Permit No. 5398 do not clearly specify a vertical depth limit for the plot, which has created a legal conflict when attempting to designate a new subsoil user.
Official documents from the State Service of Geology and Subsurface Resources confirm that Special Permit No. 5398 was issued on October 25, 2011, for the extraction of oil, natural gas, condensate, and other hydrocarbons from the Semiginovo field. In the 2019 version of the agreement published by the State Service of Geology and Subsoil, LLC “PARI” is listed as the subsoil user. Later, LLC “PARI NEFTEGAZ” became the company’s legal successor.
Until recently, the Stinavskoye field was developed by the “Borislav Oil Company” under Special Permit No. 1211 dated January 20, 1998, the validity of which had been extended until 2038.
The situation changed in the summer of 2026. Presidential Decree No. 704/2026 of August 3 enacted a decision by the National Security and Defense Council (NSDC) to impose sanctions, which affected, among others, the “Borislav Oil Company.” The sanctions regime against the company was later clarified by Decree No. 747/2026.
Court documents confirm that the restrictions against BNC are in effect for a period of ten years.
Following the imposition of sanctions, the company announced that it had halted hydrocarbon production at the Stinava field as of August 4.
On September 18, the State Service of Geology and Subsoil of Ukraine issued Order No. 449 “On the Termination of Special Permits for Subsoil Use.” According to court documents, the first item in the appendix to this order terminated Special Permit No. 1211, which belonged to the “Borislav Oil Company.”
BNK is challenging this decision. In late September, the Lviv District Administrative Court considered the company’s motion for preliminary relief, in which it requested that Order No. 449 of the State Service of Geology and Subsoil Resources be suspended—specifically regarding the revocation of its special permit—pending a final court ruling.
Prior to the imposition of sanctions, the Stynava field was an active production asset. According to *Kapital*, the field produced an average of about 43 metric tons of oil and 68,000 cubic meters of natural gas per day.
According to the publication, after the permit was revoked, BNK considered the possibility of putting the rights to the Stynavskoye field up for a new auction. However, the overlap of the area with existing License No. 5398 for the Semiginovo field created an obstacle to holding the auction.
As a result, several scenarios are possible. The first involves the legal and geological demarcation of the two fields, followed by the Stinavskoye block being put up for an open auction. The second involves changing the boundaries or parameters of the existing permit for the Semiginovo field, provided there is a legal basis for doing so. The third option is to maintain the current state of uncertainty until administrative and judicial proceedings are concluded.
However, it is premature to assert that the current holder of Permit No. 5398 automatically obtains rights to the reserves of the Stinavskoye field. This would require corresponding decisions by the State Geological and Subsurface Resources Agency and compliance with current legislation on subsoil use. The mere fact that the plots overlap geographically does not imply an automatic transfer of reserves to another subsoil user.
As “Kapital” notes, the situation is drawing additional attention due to the ownership structure of “PARI NEFTEGAZ”: publicly available data lists Anna and Karina Zlochevskaya, daughters of former Minister of Ecology and Natural Resources Mykola Zlochevsky, among the company’s ultimate beneficiaries. Permit No. 5398 was originally issued in October 2011, when Zlochevsky headed the Ministry of Ecology and Natural Resources.
Thus, the key issue remains not only the future of production at the Stinavskoye field, but also how the state will legally divide the rights to the two facilities located at different depths and whether the new right to develop the Stinavskoye field will be granted through an open auction.
Sources: State Service of Geology and Subsoil – Special Permit No. 5398, Derzhgeonadra – Order No. 449 of September 18, 2026, President of Ukraine – Decree No. 704/2026, article from “Kapital”.
AUCTION, mineral resources, oil and gas, special permit, State Geological Service, Stynavskoye field, UKRAINE, ZLOCHEVSKY
