Ukraine issues first fine for electricity market manipulation under REMIT 

In the first REMIT enforcement decision in the Energy Community, NEURC fines ENERGIYA-1 for manipulation on the Ukrainian wholesale electricity market

The National Energy and Utilities Regulatory Commission of Ukraine (NEURC) has adopted the first enforcement decision under the Energy Community’s REMIT (Regulation on Wholesale Energy Market Integrity and Transparency), imposing a fine on LLC ENERGIYA-1 for manipulation on the wholesale electricity market. Like the European Union’s corresponding regulation, the Energy Community’s REMIT sets rules to prevent insider trading and market manipulation in wholesale electricity and gas markets. Ukraine has incorporated these rules into its national legal framework.

This decision marks the first REMIT-type penalty in the Energy Community, representing a milestone in strengthening market integrity. 

According to NEURC’s investigation, the misconduct occurred between 1 and 3 November 2024, when ENERGIYA-1 submitted a series of erroneous balancing orders (offers used to help match electricity supply and demand in real time) at the highest permitted price levels during several hourly periods. These bids artificially pushed balancing electricity prices upward, sending misleading signals to the market and therefore constituting market manipulation within the meaning of Article 11-2 of the Ukrainian Law on the Electricity Market. 

NEURC identified a negative financial impact on other market participants amounting to more than UAH 23 million (just under EUR 500,000 market at the current exchange rate), resulting from distorted balancing prices during the affected hours. Following an investigation, NEURC imposed an administrative fine of UAH 1,079,976 (approximately EUR 22,000), capped at 10% of the company’s annual wholesale market turnover for 2024.  

NEURC additionally recommended that ENERGIYA-1 implement an internal compliance and control system by 1 April 2026 to prevent future breaches of market integrity rules, and report back to the regulator on its implementation. 

The decision was consulted with the Energy Community Secretariat, demonstrating NEURC’s commitment to cooperation and to aligning its REMIT enforcement with European regulatory practice. 

This is a major milestone for both Ukraine and the Energy Community as a whole, demonstrating Ukraine’s active implementation of REMIT principles and highlighting the growing importance of vigorous enforcement to ensure confidence in wholesale energy markets and to protect consumers from market abuse. It also sends a strong signal of Ukraine’s continued progress toward deeper integration with the EU internal energy market.   

Access NEURC’s notice and the respective decision (in Ukrainian).