Over two years since the Government of Ukraine initiated the unbundling of Naftogaz (by Resolution No 496 of 1 July 2016) the process has still not made any notable progress in real terms. The establishment of Magistralni Gazoprovody Ukrainy (MGU) as the new transmission system operator for Ukraine remained without any tangible follow-up. The company remains without assets or business activities, the legal changes required for unbundling were not proposed to Parliament, and Naftogaz - the vertically integrated gas company - remains in control of all gas transmission, production and supply activities. The memorandum signed between two supervisory boards is not underpinned by a roadmap for transferring tasks, assets and human resources to MGU. The unbundling process needs primarily to involve Ukrainian authorities acting in the public interest. A principle of accountability, transparency and reliability requests that unbundling is done with stronger involvement of the state authorities and not interested companies.