Report on the results of electronic consultations with the public on the draft order of the Ministry of Internal Affairs of Ukraine “On Amendments to the Order of the Ministry of Internal Affairs of Ukraine of November 06, 2019 № 928”

November 08, 2023

The Ministry of Internal Affairs of Ukraine, in accordance with the Procedure for Public Consultations on the Formation and Implementation of State Policy, approved by the Resolution of the Cabinet of Ministers of Ukraine of November 03, 2010 No. 996, conducted electronic consultations with the public on the draft order of the Ministry of Internal Affairs of Ukraine “On Amendments to the Order of the Ministry of Internal Affairs of Ukraine dated November 06, 2019 No. 928” (hereinafter — the draft order), which was published on September 25, 2023 in the subheading “Projects regulations” heading “Normative base of the Ministry of Internal Affairs” of the official web portal of the Ministry of Internal Affairs of Ukraine: here.

Information on proposals received during electronic consultations with the public on the draft order and on the results of their consideration is given in the table:

No. of sales/n

Offer Information

Author of the proposal

Offer Consideration Information

! 1

Proposal for the separation of the “verified” and “invalid” statuses and the interpretation of paragraph 6 of the Procedure for monitoring information on the results of mandatory technical control transmitted by the subjects of mandatory technical control to the nationwide database approved by the order of the Ministry of Internal Affairs of Ukraine No. 928 of November 06, 2019 next edition: “6.
According to the results of the monitoring, the authorized person of the center of the Ministry of Internal Affairs who carried it out shall place in the register of the OTC the mark “verified” in the case of the absence of the grounds provided for in paragraph 7 of this Procedure, and in the case of establishing one or more grounds provided for in paragraph 7 of this Procedure, affixes the mark “invalid”.

Public Union “Subjects of testing vehicles for serviceability”

Not taken into account.
The proposal does not concern the subject of regulation of the draft order. In
accordance with the rules of the normative design technique, the normative legal act must correspond to the scope of regulation specified in it to the subject of legal regulation.

! 2

Proposal on the possibility of making technical errors when entering information on the results of mandatory technical inspection of vehicles into the national database and protocol for checking the technical condition of vehicles

Public Union “Subjects of testing vehicles for serviceability”

Not taken into account.
The proposal does not comply with the act of higher legal force, namely with paragraph 6, paragraph 18 of the Procedure for conducting mandatory technical control and the scope of checking the technical condition of vehicles, approved by the Resolution of the Cabinet of Ministers of Ukraine No. 137 of January 30, 2012 (hereinafter — the Procedure for conducting OTC), which recognizes states that the technical condition inspection protocol of vehicles issued in violation of this procedure and inspection requirements or which contains incomplete and/or inaccurate information is invalid.

! 3

Proposal for the interpretation of paragraph 2 of the ninth subparagraph of paragraph 3 of the draft order in the following version:
“general photo of the interior of the vehicle, without a driver's seat (in case of mandatory technical inspection of vehicles of categories M2 and M3)

LLC “CSC-Concord”

Not taken into account.
The proposal is not consistent with the act of higher legal force, namely with paragraph 18 of paragraph 16 of the Procedure for Conducting the OTC, which stipulates that in the case of mandatory technical inspection of vehicles of categories M2 and M3, photo-fixation of the vehicle interior is additionally carried out with fixation of seats without taking into account the seat action.

! 4

Proposals for amendments to the grounds for declaring the protocol of inspection of the technical condition of the vehicle invalid and amending paragraph 3 of the draft order, in particular the exclusion of certain terms “additional equipment”, “other bearing elements”, “workplace of the driver”

Public Union “Subjects of testing vehicles for serviceability”; LLC “KSC-Concord”

It is taken into account editorially (in accordance with the rules of standard design technique).


As a result of electronic consultations with the public on the draft order, it was decided to take into account the comments and suggestions of public representatives, to finalize the draft order and publish its revised version on the official website of the Ministry of Internal Affairs and to resubmit it for approval of the interested bodies.

Head of the Main Service Center of the Ministry of Internal Affairs of
Ukraine
  Mykola RUDYK