A new government strategy to 2056 aims to turn Ukraine from an ore exporter into a processing and manufacturing hub for Europe — and the near-term opportunity sits in advisory, structuring and partnerships, not the mine face. Here is what it means for investors and advisors watching from Zurich and Geneva.

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Executive summary

On 27 May 2026, Ukraine’s Cabinet of Ministers adopted Order No. 569-r, approving the Strategy for the Development of Industries Based on Strategic and Critical Raw Materials and Components until 2056, together with an Operational Plan for 2026–2028. The document is less about geology than governance: it front-loads permitting reform, transparent geological data, war-risk cover and EU regulatory alignment before large-scale extraction. For Swiss capital, it is an early signal of where the regulatory ground in Ukraine is starting to firm up — and where advisory and structuring work will come first.

The announcement

Ukraine holds one of Europe’s deepest mineral endowments: roughly 20,000 deposits across 117 types of minerals, with close to half of the country’s industrial potential tied to their extraction and use. Among them are nickel, lithium, titanium, graphite, cobalt and rare earth elements — all classified as strategically important by both the United States and the European Union for the energy transition, defence and aerospace, and digital technology.

Until now, that endowment has been largely exported unprocessed. The new Strategy, developed by the Ministry of Economy, Environment and Agriculture with expert input including the DiXi Group think tank, is designed to change that — and to anchor Ukraine’s raw-materials sector to its EU accession path and the EU Critical Raw Materials Act (Regulation 2024/1252).

What the strategy actually sets out

The Strategy is built around four strategic objectives, each with concrete 2028–2030 targets rather than slogans.

1. Accelerate priority investment projects

• A dedicated competence centre to coordinate the sector.
• Verification of reserves at ≥30 critical-raw-material deposits to international reporting standards.
• An annual pipeline of at least ten priority investment projects and at least ten auctions for subsoil-use permits.
• Restoring production-capacity utilisation to pre-war levels (85–90% by 2028) and a threefold rise in gross value added by 2030.

2. Integrate Ukraine into global supply chains

• Attract at least USD 1 billion in foreign direct investment into extraction and processing by 2028 (with over USD 2 billion in total sector investment targeted in the first phase).
• Cut the share of unprocessed raw materials in exports from 88.9% (2024) to 59% by 2030.
• Build European-gauge rail corridors linking key Ukrainian clusters to EU logistics hubs by 2040.

3. Strengthen competitiveness — energy, skills and innovation

• Self-sufficiency in electricity for energy-intensive processing.
• Train 1,000 mining-sector engineers a year by 2030, rising to 3,000 thereafter in partnership with universities abroad.

4. Build a circular economy

• Registers and datasets on critical-mineral-bearing waste.
• Recovery of critical materials from mining waste and slag, with recycling of ~50% of tailings in the near term (100+ million tonnes returned to circulation), scaling toward 90%+ of industrial waste by 2056 — aligned with EU Regulation 2024/1252.

Governance before extraction

The most notable feature of the Strategy is its sequencing. The 2026–2028 Operational Plan leads with transparency and institutional capacity — open geological data, verified reserves, streamlined permitting, war-risk mechanisms — and only then moves toward pilot industrial ecosystems and downstream manufacturing.

That order is deliberate, and it responds to a hard starting point. Ukraine’s manufacturing share of GDP fell from 10.3% (2021) to 8.3% (2023); extractive output dropped to 59% of its 2019 level by Q1 2025; metal-ore capacity utilisation has sat below 50%; and a 2025 European Business Association survey found 16% of subsoil companies still fully halted by the war. Mineral potential alone does not attract capital — predictability and institutional capacity do.

Why Switzerland should care

Switzerland is not a mining nation, but it is a capital, trading and legal-services hub for exactly the long-horizon, infrastructure-heavy investment this Strategy is trying to attract. Swiss family offices and commodity trading houses already active in the sector are natural counterparts for the “strategic partnerships” phase the plan sets out for 2027–2028.

The near-term Swiss role is concrete:

• Structuring joint ventures and offtake agreements.
• Advising on war-risk insurance (state cover of up to 90% of capital expenditure against war-related loss).
• Compliance with the EU Critical Raw Materials Act and EU state-aid-compatible incentives.
• Tax and treasury structuring for Ukrainian entities.

The Strategy also sits alongside Ukraine’s 2025 critical-minerals partnership with the United States, so investors will watch closely how Kyiv balances US, EU and other interest in the same deposits.

Practical takeaways for investors and advisors

• Timing beats headlines. The 2026–2028 phase is about governance and permitting reform, not deposit auctions at scale. Near-term value is in advisory, structuring and early partnerships — not direct extraction.
• Watch the permitting reform and the competence centre. A functioning single point of entry is the clearest sign the plan is moving from paper to practice.
• De-risking instruments are explicitly on the table — war-risk cover up to 90% of capex and EU-compatible incentives. Track these when structuring any Ukrainian entity.
• Data transparency is the leading indicator. Open geological databases and verified reserves are the first deliverables promised. Their publication — or delay — will say a lot about implementation.

Conclusion

A 30-year strategy is easy to announce and hard to execute, especially in a country still at war. But the sequencing here — governance first, extraction later — is a more investor-literate approach than Ukraine’s raw-materials sector has had before. For Swiss businesses and investors already engaged in Ukraine’s reconstruction, this is a document worth reading closely now, while the rules are still being written.

Read the full legal breakdown. Want to discuss a project or partnership? Write to us → info@lighthouse-legal.eu

Primary source: Cabinet of Ministers of Ukraine, Order No. 569-r of 27 May 2026 — kmu.gov.ua Further reading:CMS legal update — cms.law · DiXi Group — dixigroup.org