Faster energy reforms critical for Ukraine’s EU integration and winter security, says Energy Community Secretariat report 

Despite ongoing attacks on its energy infrastructure, Ukraine continues to advance—but has yet to complete—crucial reforms needed for full integration with the EU energy market, the Energy Community Secretariat’s Q3 2025 Ukraine Energy Market Observatory Report finds. 

The report, covering developments between July and September 2025, finds that Ukraine has strengthened its regulatory framework for electricity and gas markets and restored the full composition of its national energy regulator (NEURC) — a key step to safeguard regulatory independence — all while expanding the allocation of cross-border electricity capacity to long-term timeframes and bringing gas market rules closer to EU rules. While the key legal amendments necessary for the transposition of the Energy Community acquis have been initiated, their final approval is still pending, including those related to the EIP, NEURC independence and corporate governance of both electricity and gas TSOs. 

 The report notes that intensified Russian attacks and colder weather have driven day-ahead market prices to regulated caps more frequently. Between August and October 2025, prices reached their maximum cap 115  times, mainly during morning and evening peaks — underscoring the strain on generation and the limits of existing price regulation. Key developments include: 

EU-aligned electricity and gas legislation advancing 

Ukraine’s parliament adopted in first reading the Electricity Integration Package draft law (No. 12087-d), a milestone for EU market alignment. Its finalisation is ongoing in consultation with the Secretariat and Ukrainian stakeholders.  The draft law transposing the TEN-E Regulation, however, was returned for revision following its first consideration, delaying progress on cross-border infrastructure development. 

Meanwhile, NEURC approved long-term capacity allocation rules for Ukraine’s interconnections with Hungary, Romania, and Slovakia, with the first long-term auctions planned for Q4 2025. In parallel, upon NEURC approval, Ukrenergo increased its 2025 investment plan by about 21 percent, financed through congestion revenues, to strengthen grid resilience and prepare for these auctions. 

Restoration and strengthening of regulatory independence 

In September 2025, the Cabinet of Ministers appointed three new members to NEURC, restoring its full seven-member composition and ensuring decision-making continuity. The Secretariat welcomed this as a critical step to safeguard regulatory independence and market confidence.  

 The report notes that the regulator had previously operated below quorum, resulting in delays to key decisions on tariffs and licensing. In response, the Secretariat presented a set of forward-looking recommendations, grounded in the key principles and provisions of the Energy Community acquis, to ensure the regulator’s independence and support the finalisation of the draft Law of Ukraine “On Amendments to Certain Laws of Ukraine Regarding Strengthening Guarantees for the Exercise of the Regulator's Powers in the Spheres of Energy and Utilities.” 

Renewable energy support revived 

In July, Ukraine held its first successful renewable-energy auction of 2025 after three unsuccessful rounds earlier in the year, allocating 120 MW of wind capacity at €0.0796 per kWh — a positive signal for investors. Parliament also advanced Draft Law 13219 to improve the RES support scheme, while the Government and NEURC progressed with the implementation of the Roadmap for Separating the Renewable Energy Surcharge from Transmission Tariffs, enhancing transparency and alignment with the EU acquis. 

Reinforcing Corporate Independence of Ukrenergo and GTSOU 

In September 2025, the NEURC consulted the Secretariat on a draft law to strengthen certification and unbundling of Ukraine’s electricity and gas transmission system operators. The Secretariat found the draft largely in line with EU requirements and said its adoption would further reinforce the independence of Ukrenergo and GTSOU. 

The Secretariat’s assessment of the Gas Transmission System Operator of Ukraine (GTSOU) found that further steps are needed to bring its governance in line with Energy Community principles. The report urges amending GTSOU’s Charter to strengthen Supervisory Board independence and separate gas-to-power assets by end-2026, in line with EU unbundling and corporate governance standards. 

The Secretariat will continue to support Ukraine in implementing EU-aligned reforms, with the next Ukraine Energy Market Observatory Report, due in early 2026, expected to assess the first outcomes of long-term cross-border auctions and progress in key energy reforms