10.04.2026
Energy Club continues to systematically protect the interests of energy market participants. We have received official clarifications from the relevant authorities regarding the legal situation in the field of public electricity procurement. Energy Club’s appeal, dated February 10, 2026, concerned systemic risks to Ukraine’s investment security and issues of law enforcement.
In letter No. 6387/0/2-26, the Ministry clarified the specifics of changing the cost of goods in government contracts.
Key points of the response:
Price Adjustment: Legislation allows for changes in the unit price of goods in proportion to market price fluctuations. Crucially, the restriction on price reviews (no more than once every 90 days) does not apply to the procurement of electricity and natural gas.
Legislative Harmonization: Preparation is currently underway for the second reading of Draft Law No. 11520, dated August 23, 2024. This document aims to bring Ukrainian procurement rules into full compliance with European Union Directives.
In response to Energy Club’s request, the Ministry of Justice emphasized the importance of adhering to the rule of law when resolving disputes in the sector:
Judicial Precedent: Conclusions regarding the application of legal norms as set out in Supreme Court rulings must be taken into account when resolving similar cases.
Expert Support: The Ministry of Justice expressed its readiness to conduct expert examinations of new draft laws and regulations if they are submitted to address problematic issues in the energy sector.
