Briefly
The Ministry of Defense has stated that adding terminals to a "whitelist" via the "Delta" system is sufficient for Starlink to operate. However, several LIGA.net sources from different branches of the armed forces warn that during an audit the absence of terminals on the balance sheet could be interpreted as the unlawful receipt of property by state bodies. This creates a legal risk for units and individuals using the equipment.
Positions and reality
Officially, the Ministry of Defense emphasizes that what matters to them is the result — which terminals are working in Ukraine’s interest and which are not. In practice this is implemented through the "whitelist" and verification of the terminal number in the user's account.
"We don't need anything to be on the balance sheet. If it is, for example, a serviceman, he confirms through his Delta account that he has a Starlink with a given number working. We add that number to the whitelist for operation on the territory of Ukraine,"
— Serhiy (Flash) Beskrestnov, adviser to the Minister of Defense, communications systems specialist
At the same time, 15 LIGA.net interlocutors in various state bodies and armed forces warn that verification by itself does not remove risks before an audit. Verification lists will sooner or later end up with auditing bodies, and then questions will arise about the correspondence of the assets to accounting records.
Legal consequences for institutions and individuals
Many users do not have a full package of documents granting the right to operate the terminals — most often there are only acceptance-transfer acts for free use. Under Ukrainian law (Article 54 of the relevant sectoral law), state bodies are prohibited from receiving material assets for free. Because of this, the lack of formalization can be interpreted as a violation of anti-corruption requirements.
"Although the verification procedure formally does not require terminals to be recorded on the balance sheet, skipping this step is risky. Using equipment without documentary support can be interpreted as the unlawful acquisition of assets by a state body,"
— Dmytro Palyushchenko, head of the business support practice, law firm Juscutum
What this means for defense and how to reduce risks
This issue is not only about paperwork — it's about the legal protection of people and structures that provide communications at the front. A few practical steps suggested by experts and interlocutors in agencies:
1) Formalize the presence of terminals in the relevant accounting systems or on the balance sheet where lawful and possible.
2) Draw up acceptance-transfer acts, agreements, or other confirming documents to avoid claims during an audit.
3) Coordinate in advance with auditing and anti-corruption units to explain the logic of using the equipment in the interests of defense.
4) Maintain transparent reporting on the number of working terminals in each structure so that accounting figures and operational activity align as closely as possible.
Conclusion
The question of legalizing Starlink is not reducible to choosing between the "whitelist" and the balance sheet — it is about protecting people and institutions from legal risks during inspections. This is an example of when operational necessity and accounting must work together. Now the decision lies with the heads of agencies: will they be able to quickly establish a transparent procedure that will protect the front from unnecessary risks while not hindering communications?
