According to Resolution of the National Energy and Utilities Regulatory Commission of Ukraine (NEURC) No. 1104 dated July 22, 2025, the pricing mechanism for consumers in Group “A’ without AMR” will change starting January 1, 2026.
Over the past two years, all categories of consumers, including public sector institutions, have been given a sufficient transition period to align their commercial metering systems with the requirements of the Commercial Electricity Metering Code.
The implementation of AMR (Automated Meter Reading) and hourly metering had a clear, transparent, and fair objective:
- to pay only for actual consumption;
- to ensure transparency and reliability of data;
- to provide fair settlements between consumers, DSOs, and suppliers;
- to eliminate cross-subsidization.
This is the foundation of the European market model — and, essentially, the principle of “pay for what you consume.”
However, some consumers have still not met the technical requirements. As of January 1, 2026, the current legislation will automatically apply the incentive schedule (Group “A’”).
Why has this issue become critical now?
Energy suppliers already have difficult experience working with public and municipal institutions in previous years:
- price increases of more than 10% followed by disputes;
- court proceedings and differing interpretations of regulations;
- cases where businesses financed supply during the most difficult periods and are now forced to recover funds;
- accusations against suppliers regarding the “incorrect” application of pricing formulas.
Unfortunately, there is a high risk that this situation will repeat in 2026, because:
- many consumers still have not installed AMR systems;
- no changes have been reflected in the Prozorro procurement system;
- NEURC regulations have already been adopted, and the incentive schedule will be applied.
The result may mirror the previous 10% price increase situation: after several months, supervisory authorities raise questions that no one is willing to answer. What should be said to public sector consumers? That they were waiting for guidance from the Ministry of Economy, which never came?
As a result, both consumers and suppliers may face complex challenges explaining why Group “A’” was not considered in tenders.
There is also a second issue already emerging: procurement procedures in Prozorro for active consumers. While the regulatory framework has been adopted, solar installations are being developed, and communication campaigns are ongoing, the mechanism for selling surplus electricity by active consumers is still not reflected in Prozorro tenders.
Therefore, we emphasize:
It is critically important for businesses that these changes are reflected in Prozorro documentation and methodological guidelines. Otherwise, responsible suppliers will simply be unable to participate in such tenders, and consumers will automatically be transferred to the Supplier of Last Resort — leading to a direct increase in costs for public budgets.
This raises a logical question: who will be held responsible — businesses that comply with the law, or institutions that were expected to track regulatory changes, update frameworks, and ensure consistent market rules?
The Public Association “Energy Union” is organizing an internal meeting for its members to address the necessity of incorporating Group “A’ without AMR” into the preparation of 2026 tenders and to discuss amendments to the methodological recommendations.
Date: November 27, 2025
Time: 11:00
Format: Online (Zoom)
Topic: “Amendments to the Methodological Recommendations for Electricity Procurement by Public Sector Consumers regarding the application of Group ‘A’ without AMR’”