11.09.2026
On September 10, 2026, Energy Club hosted a closed online meeting dedicated to the mechanism of imbalance pricing in the electricity market and the search for solutions that would limit disproportionate financial risks for market participants without weakening balancing responsibility.
The basis for continuing the professional discussion was an appeal from the member company of Energy Club, LLC “ENERGY 365”. The company proposed to reconsider the possibility of temporarily applying an imbalance price corridor of 80/120% of the day-ahead market (DAM) price, as well as to discuss alternative and compromise mechanisms.
The speaker at the meeting was Yuriy Pidlisny, head of LLC “ENERGY 365”. The discussion was moderated by Iryna Dmytrotsa, an expert in energy project development and business planning, and head of operational and regulatory policy at JSC “Ukrainian Distribution Networks” from April 2024 to November 2025.
Yuriy Pidlisny presented an approach proposing to apply the temporary price corridor of 80/120% relative to the DAM price not to the entire volume of the imbalance, but only to the first 5% of deviation between forecast and actual consumption.
For documented cases related to military actions, damage to facilities, emergency or unpredictable outages, it is proposed to increase the limit to 10%. The current rules would apply to the remaining volume of imbalance.
According to the initiator, such a model would partially protect suppliers from the consequences of events that cannot be forecast or adjusted in time after the closure of the intraday market gates, while maintaining incentives for high-quality forecasting and the responsibility of parties responsible for balance.
According to LLC “ENERGY 365″‘s assessment, the physical level of forecasting error for many suppliers has not deteriorated significantly, but financial losses from imbalances are growing much faster. Such risks become especially tangible in the event of a sudden cessation or reduction of consumption by large enterprises due to shelling, accidents, or grid constraints.
Market participants identified the delay in publishing information on system status, balancing activations, and imbalance prices as a separate problem. According to market representatives, some of the necessary data becomes available only after several days, which limits the ability to analyze the causes of deviations promptly and improve forecasting.
Arguments against the direct linkage of imbalance prices to the DAM price were also voiced during the discussion.
Supplier representatives pointed out that the day-ahead market and the balancing market serve different functions. The price of balancing electricity must take into account the real cost of activating reserves and generation, particularly expensive gas generation.
At a certain DAM price, the 80/120% corridor might not provide generation with economically justified payment for activation in the balancing market. It is also necessary to take into account delays in settlements with balancing service providers and accumulated debt.
Participants noted that while the proposal to reduce financial pressure on suppliers is timely, a model based solely on linkage to the DAM may not receive support from NPC Ukrenergo, power generators, and the Regulator.
In this regard, it was proposed to focus on preventing further escalation of price risks as a possible short-term priority, maintaining at least the current conditions until full modeling of the consequences of the proposed changes is conducted.
One of the central topics of the meeting was the problem of debt accumulation in the balancing market.
Participants emphasized that increasing the financial burden on companies that meet their obligations on time does not address the root causes of non-payments. On the contrary, an excessive increase in the cost of imbalances could impair the solvency of compliant suppliers, reduce competition, and encourage companies to exit the market.
According to the participants, evaluating any changes requires separate analysis of:
Changes to imbalance pricing proposed by NPC Ukrenergo and NEURC (NKREKP) must also be accompanied by public justification, modeling on historical data, and an assessment of the impact on various categories of market participants.
Special attention was paid to the distribution of responsibility between the supplier and the final consumer.
Under the current model, the main financial risk of imbalances is borne by the balance responsible party. Opportunities for directly passing these costs onto the consumer remain limited, and penalty mechanisms for deviation of actual consumption from the declared schedule have not found wide application.
At the same time, imbalance costs are ultimately factored in by suppliers in their commercial offers and risk premiums. This is especially acute in long-term contracts and public procurement, where a supplier cannot predict several significant rule changes during the contract term.
The increase in unpredictable costs can lead to higher prices for consumers, reduced competition in procurement, contract termination, or supplier refusal to participate in tenders.
In the long term, the market needs to discuss a legislative model under which the risks of deviation of actual consumption from the forecast will be shared among all participants according to their ability to manage such risks.
The discussion showed that there is currently no consensus on introducing the 80/120% corridor. At the same time, participants confirmed the need for a substantive dialogue on the disproportionate growth of financial consequences of imbalances, especially under martial law and limited access to operational information.
During the meeting, it was proposed to structure further work in several areas:
Energy Club expects additional calculations and proposals from member companies, based on which a consolidated repeated appeal to NEURC (NKREKP) will be prepared.
The Club will continue to provide a platform for professional dialogue between suppliers, traders, power generators, NPC Ukrenergo, the Regulator, and other market participants with the goal of finding an economically justified and balanced model of responsibility for imbalances.
