The suspension of key electricity market data publication in Ukraine remains one of the most pressing and controversial issues in the sector. This lack of transparency has already raised serious concerns among European partners.
To ensure a stable, competitive, and predictable market, Ukraine’s National Regulator must implement the recommendations of the European Commission. Without this, further integration into the European energy space — and the preservation of trust in the market — will not be possible.
The moment for decisive action has come.
Returning to transparency, open data, and adherence to European standards is not only a condition for trust, but also a prerequisite for the sustainable development of Ukraine’s energy sector.
Since the start of the full-scale war in 2022, Ukraine has suspended the publication of key energy system information. Market participants — particularly electricity suppliers — have found themselves in complete uncertainty: no data is available on projected generation volumes, production-consumption balance, or market structure and price benchmarks. In such conditions, it’s impossible to plan purchases, build balanced supply portfolios, or forecast pricing. The lack of transparency has blocked any realistic understanding of fair end-user electricity pricing.
Suppliers have had to operate almost “blindly,” incurring significant financial losses. Some companies couldn’t withstand the pressure and were forced to declare default. Most worrying is that, amid this information blackout, consumers have also lost the ability to predict their electricity costs — even for the coming month.
On December 30, 2024, the Market Operator and Ukrainian Energy Exchange officially announced the suspension of data publication, citing a relevant directive. This decision effectively formalized the information blackout that had already existed since 2022 and sparked serious alarm among market players.
The lack of open data became critical for both suppliers and consumers. Budget institutions — which traditionally relied on open sources like the Market Operator’s website to track day-ahead (DAM) and intraday (IDM) market prices for procurement — were hit particularly hard.
This move triggered a wave of protest from suppliers, consumers, associations, and experts. Mass appeals were sent to the Regulator, Ministry of Energy, Market Operator, and the Energy Community Secretariat demanding the restoration of open data publication. The response was so widespread that some data was partially restored within days.
However, suppliers still do not have a full picture of the energy system or market. Operating based on rumors, fragmented media statements, and partial website updates is no way to run a modern energy market.
The Energy Community Secretariat strongly criticized this approach. In its Assessment 2/25, the Secretariat clearly stated that the decision based on Order No. 27-dsk was non-transparent, contradicts Ukrainian national law, and does not align with Ukraine’s obligations under the EU energy acquis.
Key Points from the Secretariat:
- Under REMIT, DAM and IDM trading results are classified as inside information, which must be publicly disclosed.
- Suppressing this information creates risks of insider trading.
- The suspension of critical data publication poses a systemic threat to transparency in Ukraine’s electricity market and harms the sector’s investment appeal.
Thus, restricting access to market data not only violates EU standards but also undermines trust in the Ukrainian electricity market and creates barriers to fair, competitive operations.
According to REMIT, DAM and IDM trading results must be disclosed as inside information. The lack of such publication enables unfair market behavior, including insider trading, and undermines transparency and investment stability.
Meanwhile, Ukraine’s energy authorities justify this secrecy with martial law, treating it as force majeure that, in their view, excuses deviations from transparency and EU requirements.
As a result, the situation has devolved into a bureaucratic blame game, where requests from market players receive vague, non-substantive replies.
For example, in response to an official appeal from the Public Association “Energy Union”, the NEURC failed to provide any clear reasoning for restricting access to data, citing only general legal compliance. The Market Operator responded in much the same way.
Consequently, “Energy Union” submitted a request to the Energy Community Secretariat, asking for an expert evaluation and support in restoring public data disclosure — as required by Ukrainian law and international obligations.
This uncertainty regarding access to fundamental market information continues to seriously complicate suppliers’ work.
They are forced to make decisions without reliable data, which undermines pricing strategy, financial modeling, and long-term planning.
Ultimately, all of this affects end-user electricity prices, making the market less predictable and less trusted.
According to Olha Tahiieva, Head of the Public Association “Energy Union”, it is critically important for electricity suppliers — who work in real-time and interact with the Market Operator and the Ukrainian Energy Exchange — to have up-to-date data on generation status.
This data should be made available on request to active market participants, so suppliers can properly assess production volumes and generation structure to prepare offers for their clients.
One particularly important issue is the lack of supplier representation in the Auction Committee under the Ministry of Energy.
Suppliers are not currently represented in this body, despite being essential players in the market and directly interacting with consumers.
The Committee should reflect the interests of all segments, including suppliers — a key link in creating a competitive environment.
Ensuring access to structured, timely, and reliable information is not just the state’s responsibility — it’s a fundamental requirement for market stability and consumer protection.
It is also essential to create the conditions for:
- Improving bilateral contract market mechanisms
- Introducing continuous trading of standardized products
- Developing a futures market based on EFET-standardized contracts, in line with best European practices
This would be a key step toward establishing fair pricing, reducing volatility in the DAM, and improving the market environment — ensuring stability, predictability, and trust among domestic and foreign stakeholders.
In this context, the constructive proposals of suppliers working in real-time must be heard.
It is also critical to implement all recommendations made by the Energy Community, as a step toward a transparent, competitive, and sustainable energy future for Ukraine.
Public Association “Energy Union”