21.05.2026
On May 14, Energy Club held a closed expert meeting on the topic “Imbalance prices after the NEURC resolution No. 621: risks for the market and possible temporary solutions”. The focus of the discussion was on the consequences of new maximum prices for electricity market participants, the risks of the current imbalance calculation mechanism, and the possibility of preparing a consolidated position of Energy Club member companies to the National Commission for the Regulation of Energy and the Economy of Ukraine, Ukrenergo NPC, Market Operator JSC, the Ministry of Energy of Ukraine, and the Cabinet of Ministers of Ukraine.
The meeting participants emphasized that this is not about abolishing liability for imbalances, but about finding temporary safeguards for the period of martial law. Such decisions should reduce excessive price distortions, preserve the liquidity of bona fide market participants, and prevent further accumulation of debts.
The meeting was moderated by Iryna Dmytrotsa, advisor to the President of Energy Club, expert in the development of energy projects and business planning, head of operational and regulatory policy of JSC “Ukrainian Distribution Networks” in 2024–2025.
Opening the discussion, she noted that the issue of pricing in the electricity market today is one of the most sensitive for market participants.
“Today’s discussion is devoted to one of the most sensitive and at the same time strategic issues of the energy market — pricing, namely the latest resolution No. 621. This is not the first resolution that changes price caps, but it is very painful. Energy The sector is operating under unprecedented challenges: martial law, lack of predictability, high market volatility. The purpose of our meeting is not to repeal the resolution, but to discuss the problems it creates and find balanced solutions,” noted Iryna Dmytrotsa.
The head of Energy 365 LLC Yuriy Pidlisny presented an analysis of the impact of increased limit prices on the balancing market. According to him, the NEURC Resolution No. 621 of April 23 introduced new limit prices on the RDM, VDR and the balancing market. Similar approaches were already temporarily in effect from January 17 to March 31, 2026.
The company analyzed the periods from January 17 to March 30, 2026, when the increased price caps were in effect, and from April 1 to 20, when the previous maximum prices were in effect. According to Yuriy Pidlisny, statistics showed a significant increase in the financial burden on suppliers, traders, producers and other participants who faithfully fulfill their obligations to NPC Ukrenergo.
According to the calculations presented during the meeting:
According to Yuriy Pidlisny, in May the market may see a similar picture: large price distortions and an increase in the financial burden on balancing market participants.
“These calculations fell on the shoulders of conscientious market participants who fulfilled their obligations to Ukrenergo. Those who failed received appropriate sanctions – pre-default or default. There are few such companies, but most likely they tried to fulfill their obligations on time, they simply could not withstand the financial burden,” Yuriy noted. Pidlisny.
Separately, he drew attention to the debt situation in the balancing market. According to public data, as of April 30, the debt of market participants to NEC Ukrenergo amounted to about UAH 46.5 billion, and the company’s own counter-debt to market participants amounted to about UAH 25.8 billion.
According to Yuriy Pidlisny, a mechanical increase in the financial obligations of market participants will not solve the debt problem, but may only worsen the situation.
“Changing the very amount of market participants’ obligations to Ukrenergo will not solve this situation. From my point of view, it will worsen it. The debt will not disappear, but competition in the market will disappear, because some participants will not be able to financially pull this story out,” he emphasized.
LLC “Energy365” proposed to temporarily, for the period of martial law, establish price corridors for imbalances tied to the DAM price of the relevant settlement period.
The proposal provides for:
“In our opinion, this will make it possible to stabilize settlements, maintain a competitive market, not increase debt and generally balance the climate in the market,” Yuriy Pidlisny noted.
He also emphasized that this is not about making permanent changes to the Market Rules, but about temporary norms within the framework of the NEURC Resolution No. 332, which is valid for the period of martial law.
One of the meeting participants drew attention to the fact that the problem is not limited to current imbalances and settlements. According to him, new approaches are being discussed in the market to the formation of imbalance prices and prices for balancing electricity, which can further increase the burden on bona fide participants.
“Ukrenergo’s position is unchanged: to collect even more funds for imbalances from those who are still working to cover the difference between the total cost of funds received and accrued. For a long time, the uplift was positive, but no one offered to return this positive uplift to market participants. When it became negative, proposals immediately appeared to collect more funds from participants,” noted a participant in the meeting.
It was also noted during the meeting that the introduction of two balancing market prices could lead to a situation where surpluses would actually be given away almost for free, and purchases would be made at the maximum price during certain hours.
During the discussion, examples of the impact of war on imbalances were also heard: damage to substations, generation, and network infrastructure due to drone attacks can instantly change actual production or consumption, which automatically creates imbalances and financial losses for market participants.
“Yesterday, several generation facilities temporarily stopped supplying electricity and became imbalanced precisely as a result of being hit by enemy drones. This immediately led to financial losses. Any such unforeseen load washes away funds from market participants that could be used to restore infrastructure, develop generation, and support consumers,” the meeting participant noted.
At the same time, the discussion participants emphasized that liability for imbalances is a necessary component of the market, but its rigidity must correspond to the conditions in which the system operates.
“I fully support the position that imbalances should be compensated with money. But this applies to a market that operates in stable conditions. In the current conditions, when there are unpredictable disconnections of consumers and generation, it is impossible to apply maximum liability without fuses,” the meeting participant emphasized.
A separate topic was the practice of offsetting homogeneous counterclaims between NPC Ukrenergo and market participants. During the meeting, it was noted that such a mechanism had been operating since 2024 and allowed to reduce mutual debt. However, now participants are faced with situations where the offsetting is not carried out in full.
“In our example: Ukrenergo’s debt to us is UAH 140 million, our obligation was UAH 81 million. Instead of counting this as debt coverage, we ended up with a situation where Ukrenergo owes us about UAH 80 million, and we still have to pay UAH 24 million in cash. This is nonsense,” said a participant in the meeting.
The participants in the meeting emphasized that such a practice worsens the liquidity of companies that already operate in conditions of high volatility, military risks, and limited predictability.
One of the participants in the meeting drew attention to another important aspect — the gap between the price on the DAM and the actual balance in the system.
According to him, situations where the price on the DAM remains sufficiently high are particularly painful for traders and generation aggregators.is quite high, but the system is in surplus at the same time, and the price for positive imbalances actually drops to 1 kopeck.
“We see situations when the price for the DAM can be 7–8–9 thousand UAH, and at the same time there is a huge surplus in the system, and the price for positive imbalances is 1 kopeck. This means that the DAM and the real balance of the system often live in different parallel realities,” Ilya noted.
In his opinion, prices for imbalances should either be tied to the DAM, or the DAM itself should be closer to the real balance of the system. At the same time, he emphasized that approaches to forming price caps on the balancing market should be transparent, clear and regulated.
“The calculation should be at least transparent and clear. Currently, we are simply receiving a set of prices — 24 values for the past period, which are often completely disconnected from reality,” he emphasized.
The meeting participants agreed that in order to develop balanced solutions, a broader professional discussion is needed with the involvement of the National Commission for the Regulation of Energy and Power Generation of Ukraine, NEC “Ukrenergo”, JSC “Market Operator”, representatives of suppliers, traders, manufacturers, aggregators, consumers and other market participants.
The meeting participants also emphasized that market companies need to participate more actively in developing changes to regulatory legal acts at the stage of their discussion.
“When changes have already been implemented, it is very difficult to overcome them. But at the stage of development and discussion, you can still influence, and very effectively. The regulator hears arguments when they are there. If there are reasonable proposals, a reasoned position, this has a good effect on the adoption of more balanced decisions,” noted one of the participants in the meeting.
Summing up the discussion, Iryna Dmytrotsa emphasized that the key issue for the market today is to find a balance between tough market signals and the need for temporary financial stabilization in wartime.
“The most important thing we need to determine today is what the Ukrainian energy market needs now: the toughest market signals or temporary financial stabilization during the war. Based on the results of the meeting, we will jointly prepare an appeal to the National Commission for the Regulation of Energy and Power Generation, NPC Ukrenergo, the Market Operator and other bodies to include them in this discussion,” she noted.
Following the results of the meeting, Energy Club invited member companies to provide their data, calculations and proposals to form a common position on temporary fuses in the balancing market.
Among the issues that may be submitted for a joint appeal:
Energy Club will continue consultations with member companies and prepare a consolidated position for further submission to relevant state bodies and market participants.
