13.08.2026
During Energy Club’s expert online discussion “CBAM and Electricity Trade between Ukraine and the EU: Risks, Practical Challenges and the Market Position”, energy markets expert Artem Kompan emphasized that Ukraine should not rely solely on a possible deferral of CBAM due to martial law.
In his view, the country must work in parallel on internal changes necessary for the full implementation of the CBAM model and for adapting the Ukrainian market to European rules.
“I would not rely on the idea that we will somehow get through this situation and that it will not affect us because of martial law. We have clearly chosen our path toward the European Union, and therefore we must prepare for the implementation of a full CBAM model for Ukraine,” Artem Kompan said.
He proposed dividing further work into two separate tracks. The first is communication with the European Union regarding a possible deferral, mitigation or special approach for Ukraine. The second is Ukraine’s internal “homework,” which must be carried out regardless of whether a deferral is granted.
According to Artem Kompan, this homework includes preparing legislation, defining verification mechanisms, launching a full-fledged system for confirming the origin and carbon intensity of electricity, and creating a civilized market for certificate trading.
“It is necessary to clearly separate two tracks: communication with the EU on a deferral and internal homework. We must carry out this work regardless of whether CBAM conditions are deferred for us or not,” the expert stressed.
Artem Kompan paid special attention to the need to formulate the state’s position on Ukraine’s energy mix. According to him, it is fundamentally important for Ukraine to ensure that nuclear, hydro and renewable generation are taken into account, as these sources form a significant part of the low-carbon profile of Ukrainian electricity.
At the same time, he emphasized that without a clear verification system and agreed mechanisms for confirming the origin of electricity, this potential cannot be fully used in trade with the EU.
“The state must take a clear position on the energy mix and the inclusion of nuclear, hydro and renewable generation. Negotiations on verifiers need to start now,” Artem Kompan noted.
According to him, Ukraine already has certain mechanisms related to certificates of origin, but there is still no full-fledged system that would create demand for these certificates and allow them to be effectively used in the context of CBAM.
Artem Kompan stressed that demand for such instruments will come both from exporters of goods and from electricity traders who will be interested in purchasing electricity with confirmed origin and relevant certificates.
“We need to create a civilized exchange-based market for certificate trading. At the moment, the mechanism exists, but there is no verifier and no demand for these certificates,” he emphasized.
He also noted that CBAM is not only an issue for electricity traders or the state. It will directly affect producers, exporters and companies from various sectors of the economy, including metallurgy, chemicals and other industries that may lose competitiveness on the EU market due to the additional carbon burden.
In Artem Kompan’s view, businesses still do not fully understand the scale of CBAM’s future impact. That is why further professional discussions, explanations and the involvement of companies in the formation of a practical position are necessary.
“Business needs to be involved in this discussion so that it understands what CBAM is and how it will affect not only the state or electricity traders, but also producers,” the expert said.
Artem Kompan also suggested that such discussions should result in a consolidated document with proposals. According to him, the professional community can develop a vision of which legislative acts need to be finalized, which changes must be implemented and which decisions should be adopted in an accelerated mode.
“Such discussions should end with a consolidated document containing proposals. From our side, we can provide our vision of which documents need to be developed and implemented,” Artem Kompan said.
Summing up, he emphasized that Ukraine must simultaneously conduct negotiations with the European Commission, carry out internal legislative work, create a verification system, develop the certificate market and involve business more broadly in the CBAM discussion.
In his view, only a combination of external dialogue with the EU and internal preparation will allow Ukraine to reduce risks for exports, the electricity sector and industry.
