On November 27, the Public Association “Energy Union” held an extended meeting with the participation of representatives of the NEURC, the Ministry of Economy, the Ministry of Energy, and members of the Association — electricity suppliers.
The event became a practical and professional discussion on the state of the retail market, the risks of regulatory uncertainty, and the solutions the sector needs ahead of 2026.
It was emphasized that electricity supply is not a simple “buy-sell” activity, but daily work involving analytics, risks, forecasting, and responsibility.
For the fourth year in a row, Ukrainian suppliers have been ensuring uninterrupted electricity supply while operating under conditions of infrastructure destruction, imbalances, a shortage of forward contracts, and sharp price fluctuations.
This is precisely why suppliers stress the need to regulate electricity supply to budget consumers, in order to avoid situations where requirements directly conflict with the capabilities of the public sector.
According to NEURC Resolution No. 1104 dated July 22, 2025, starting from January 1, 2026, the pricing mechanism for Group “A” consumers without AMR systems will change.
A separate issue highlighted was that budget institutions currently face significant legal and financial barriers to installing smart meters and AMR systems.
The requirement exists — but the capability does not: budgets are not allocated and funding is unavailable.
The Energy Union outlined the following critical risks:
- potential losses for budget consumers in 2026;
- risk of mass litigation between budget institutions and suppliers.
We proposed:
- aligning the approaches of the NEURC and the Ministry of Economy;
- postponing the implementation of incentive coefficients specifically for budget consumers.
The issue of active budget consumers and the mechanism of operating through Prozorro remains unresolved.
The Energy Union is preparing additional materials and proposals for submission to the Ministry of Economy, the Ministry of Energy, and the NEURC.
The meeting was attended by and featured speeches from:
From the NEURC:
Oleh Kostrykin, Department for Regulation of Relations and Consumer Protection;
specialists of the Department for Regulation in the Energy Sector.
From the Ministry of Economy:
Iryna Mykhailivna Sopyliuk, Deputy Director of the Department of Public Procurement and Competition Policy.
From the Union members:
Roman Yurynets, Director of PRET Service Energozmin — strategic approaches to supply;
Serhii Truba, Commercial Director of Kharkivenerhozbut — risks of tender contract performance;
Marta Yukhman, lawyer at PRET Service Energozmin LLC — a comprehensive legal report systematizing key issues.
Representatives of the Ministry of Energy were also present.
Other market participants actively joined the discussion, offering constructive solutions.
The discussion was substantive, dynamic, and importantly, marked by a shared sense of responsibility.
The NEURC has already submitted for consideration by the Commission (meeting scheduled for December 2) the issue of postponing the implementation of incentive coefficients for budget consumers for one year.
The regulator is hearing market arguments and taking into account the real capabilities of the public sector.
We expect a positive decision and further constructive cooperation.
We thank all participants and colleagues who contributed to the discussion.