NGO ForestCom Uncovers UAH 6.4 Million in Forestry Violations from 2024-2025: Comprehensive Forest Monitoring Report

ForestCom has released key findings from its monitoring of illegal logging in Ukraine, gathered through its proprietary monitoring system during 2024-2025. The data reveal significant violations and systemic shortcomings in the enforcement system.

Preventing illegal logging and the illicit trade of timber is a core objective of NGO “ForestCom”. Throughout 2024-2025, the organization's experts conducted extensive monitoring of Ukrainian forests, uncovering a range of violations.

The NGO “ForestCom” monitoring system combines advanced technology and field work, including:

• Satellite Monitoring: Tracking changes in forest cover, particularly in primeval natural heritage sites, allows for the rapid detection of potential illegal activity.

• Field Expeditions: Specialists visit identified sites to directly verify the legality of logging activities and gather evidence.

• Expert Support: NGO "ForestCom" provides consultation to law enforcement and regulatory bodies, utilizing botanical and commodity expertise to identify illegal timber within the domestic market and during export operations.

• Criminal Proceeding Monitoring: Tracking the progress of investigations and court cases related to identified illegal logging allows for assessment of the effectiveness of the legal system.

Over two years of observation, experts examined 152 forest plots totaling 3,227 hectares. This resulted in the discovery of 33 cases of illegal logging without the required permits. The total damage inflicted on the state amounted to UAH 6.43 million.

All identified forestry violations were duly documented and reported to forest users, law enforcement agencies, and the State Environmental Inspectorate. However, only 7 criminal proceedings have been initiated, primarily under Article 246 of the Criminal Code of Ukraine (illegal logging).

"The monitoring indicates that the law enforcement response to illegal logging remains inadequate. The situation is complicated by the moratorium on inspections by regulatory bodies, particularly the State Environmental Inspectorate," the report states.

The report highlights critical impediments to combating illegal logging:

• Unacceptable Delays in Response: A glaring example illustrates this problem: the investigation into illegal logging began only 14 months after the initial notification by specialists. During this time, the perpetrators were able to expertly conceal the traces of the crime – camouflaging stumps and removing all illegally obtained timber, significantly hindering further investigation. Experts view this delay as a clear indication of the ineffectiveness of the current system.

• Inadequate Law Enforcement Response: The low number of initiated criminal cases (7 out of 33 identified cases) indicates ineffective mechanisms for holding perpetrators accountable.

• Moratorium on Inspections by Regulatory Bodies: Existing bans on planned inspections by regulatory bodies (particularly the State Environmental Inspectorate) significantly impede the fight against violations, creating favorable conditions for the impunity of forest offenders.

• Concealment of Violations by Foresters: The situation is further complicated by the fact that forestry authorities often fail to publicize detected violations, and sometimes even conceal them, compromising trust in forest users.

Based on practical experience in identifying violations and analyzing judicial practice, NGO "ForestCom" has conducted an in-depth analysis of legislation (Article 246 of the Criminal Code of Ukraine) and the system of fines for illegal logging. To enhance the effectiveness of combating these environmental crimes, 

the organization proposes several concrete legislative changes:

1. Strengthen Criminal Sanctions: Increase the amount of fines to UAH 51,000 – 102,000. This will create a real economic deterrent for potential offenders.

2. Unify Legislation: Harmonize terminology and provisions of the Criminal Code, the Forest Code, and laws concerning the Nature Reserve Fund (NRF). This will eliminate legal conflicts and simplify law enforcement.

3. Decriminalize Minor Logging within NRF: Replace criminal liability with administrative liability, establishing more realistic fines in the amount of 800-1200 non-taxable minimums. This will allow pre-trial investigation bodies to offload their resources, focusing them on combating large-scale crimes.

4. Revise Fines within NRF: Bring the size of penalties into line with the principle of proportionality with the real environmental damage caused by illegal logging in protected areas.

5. Ensure Transparency of Investigations: Guarantee non-governmental organizations the right to receive information on the progress of their appeals within the timeframes established by law. This will promote public oversight and increase the accountability of law enforcement agencies.

"The scale of illegal logging we have uncovered and the systemic problems with its prosecution require immediate legislative changes and increased accountability of all parties involved," the experts state. "Our proposed reforms are aimed at creating effective mechanisms for the protection of Ukrainian forests."

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The detailed report on the monitoring methodology, identified violations, and legislative recommendations is available at: https://drive.google.com/file/d/1UUEvUB3f-nd45sW8B4nqzsRWlBg_Ir1I/view?usp=sharing

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The report is produced by NGO «ForestCom» with the support of the Askold and Dir Fund as a part of the Strong Civil Society of Ukraine –  a Driver towards Reforms and Democracy project, implemented by ISAR Ednannia, funded by Norway and Sweden. The contents of this publication are the sole responsibility of NGO «ForestCom» and can in no way be taken to reflect the views of the Government of Norway, the Government of Sweden and ISAR Ednannia.