04.02.2026
The Ministry of Energy of Ukraine officially responded to the Energy Club’s appeal dated November 20, 2025 regarding problematic issues in the application of legislation in the field of electricity procurement.
In its letter, the department confirmed the objectivity of the reasons for the price increase and reported on the preparation of important legislative changes that should resolve the systemic collision between market realities and bureaucratic procedures.
Key theses of the Ministry of Energy’s response:
1. The Ministry has developed a draft law “On Amendments to Certain Legislative Acts of Ukraine to Improve Certain Provisions Related to Conducting Economic Activities in the Energy Sector.” It proposes not to apply the Law “On Public Procurement” if customers purchase goods and services on:
The draft law has already been sent to interested parties in accordance with the Regulations of the Cabinet of Ministers of Ukraine.
2. The Ministry confirmed the position of the Energy Club, noting that the increase in prices and high volatility in 2022–2025 are due to objective factors: market changes and the consequences of the Russian Federation’s military aggression.
3. The Ministry of Energy recalled that according to Resolution No. 1178 (clause 19, subparagraph 7), the indicator for price changes in contracts is the weighted average prices on the DAM. At the same time, stock indices or prices of bilateral contracts for reviewing prices under this resolution are not currently used.
The response of the Ministry of Energy indicates that the relevant ministry is aware that regulating the purchase of exchange-traded goods by the static norms of the Law “On Public Procurement” is ineffective. The initiative to remove purchases on the DAM and VDR from the scope of this law is exactly the systemic step that the market insisted on. Energy Club will closely monitor the passage of this bill and promote its early adoption.
