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2025 Retrospective and 2026 Agenda: Ukraine’s Energy Priorities — Energy Freedom Summary

26.12.2025

On December 24, 2025, Energy Club held its final Energy Freedom online meeting, dedicated to the key events of the energy year, their impact on the market, and the formation of common priorities for 2026. The discussion featured heads of industry associations and business representatives, focusing on the power system’s resilience under wartime conditions, the development of distributed generation, integration with the EU, and critical regulatory bottlenecks.

Moderator:

  • Maksym Nemchynov, Vice President of Energy Club, former Deputy Minister of Energy of Ukraine.

Panelists:

  • Oleksandr Dombrovskyi (Global 100% RE Ukraine / MHP Eco Energy),
  • Yaryna Skorokhod (European Business Association),
  • Andrii Myzovets (Association “Gas Traders of Ukraine”),
  • Olga Tagiieva (“Energy Union”),
  • Andriy Konochenkov (Ukrainian Wind Energy Association),
  • Nataliia Korobenko (Elementum Energy),
  • Vladyslav Sokolovskyi (Solar Energy Association of Ukraine),
  • Artem Petrenko (Association of Gas Production Companies of Ukraine),
  • Yurii Bondarenko (NTSEU / CIGRE / “Hydro Power of Ukraine”),
  • Ivan Grygoruk (Vice President of Energy Club).

Opening the meeting, Maksym Nemchynov emphasized that summing up the results is a tool for course correction: if the market or institutions “enter a cyclical error,” it is necessary to step back and fix the causes that hinder progress. Therefore, the focus of the meeting was on:

  • Major events and decisions of 2025 and their impact on the markets;
  • 2026 priorities and the formation of a unified position for the professional community;
  • Barriers and “bottlenecks” requiring urgent institutional changes;
  • Coordination between associations, business, and state authorities.

Separately, the moderator drew attention to the decision of the Energy Community Ministerial Council regarding Ukraine’s failure to fulfill obligations, particularly regarding the implementation of decisions/rules necessary for integration with the European market, and emphasized the importance of “completing the homework” within the established timeframes.

“Ukraine has stood its ground. The energy sector is alive and adapting”

Oleksandr Dombrovskyi named the key result of 2025 as the fact that Ukraine withstood the challenges and the energy sector remained operational despite the scale of destruction, changing attack tactics, and regional blackouts. He highlighted the role of “ordinary power engineers” who restore grids and equipment in the field, and emphasized: Ukrainian energy is being rebuilt very quickly during the war, particularly through the development of solar generation, storage systems, and cogeneration.

Speaking about 2026, the speaker noted that the first months might be difficult, and the task is to protect and restore everything destroyed while simultaneously finding new opportunities. He specifically emphasized the importance of distributed generation as a practical response from businesses and communities to wartime risks.

Answering the moderator’s question about “one mistake of the year,” Dombrovskyi replied diplomatically, focusing on the principle of “government-market” interaction: “Rule one — do not interfere; rule two — help,” adding that the professional community must “lend a shoulder” to the state so that key decisions are made and implemented. He also noted a positive trend: associations have started communicating more with each other, with Energy Club serving as an integrating platform for such dialogue.

Fourth wartime winter: strikes on all links and the need to increase capacity

Yaryna Skorokhod (European Business Association) emphasized that the world has no analogous experience of long-term systemic energy warfare, and in 2025, the strikes became even more complex: the enemy hits not only generation or distribution but also local infrastructure and, separately, gas infrastructure. She highlighted the psychological dimension of the attacks — an attempt to “leave the country without light” and undermine the basic sense of security.

Among the expectations for 2026, the speaker named increasing capacity as a key task and emphasized: investors need to be stimulated not with slogans but with specific tools, and the foundation for this is regulatory predictability (completeness of payments, sufficiency of tariffs, prevention of debt accumulation).

Separately, Yaryna Skorokhod noted the development of energy storage systems as a qualitative change for the market: the technology has ceased to be a “theoretical concept” and has become a real part of the system, changing the logic of market operations.

Gas sector: termination of transit, attacks, imports, and the PSO “knot”

Andrii Myzovets named the termination of Russian gas transit, as well as strikes on gas infrastructure, including production facilities and underground storage infrastructure, among the key events of 2025. At the same time, he emphasized: the 2024/25 heating season was successfully passed, and Ukraine entered the 2025/26 season with sufficient reserves to pass the winter, provided there are no devastating attacks on production and import infrastructure.

The speaker drew attention to the development of import routes, including “unconventional” ones (mentioning the Greece-Bulgaria-Romania direction), and emphasized the importance of coordinating operators’ tariff policies and cooperation with neighbors.

In a separate block, Myzovets raised the topic of Public Service Obligations (PSO) and gas prices for the population, noting that in the spring, the issue will require difficult but necessary political decisions. The moderator, commenting on this point, supported the need to find other mechanisms — particularly monetized subsidies for those in need — to avoid the “cyclical error” of a systemic deficit.

Electricity market: legal imbalances, “active consumer,” equal rules, and readiness for market coupling

Olga Tagiieva characterized 2025 as a year of survival, flexibility, and the formation of a new market reality, as well as the “year of the people who hold the system together.” She identified legal imbalances between energy legislation and public procurement laws as a key problem, which, in her estimation, led to additional risks for businesses and consumers in 2025. Examples cited by the speaker included:

  • The situation with the possibility of price adjustment in Prozorro and different interpretations of norms;
  • The problem of the “active consumer”: while present in specialized energy legislation, there is no corresponding mechanism in Prozorro, creating legal uncertainty;
  • The need for identical rules for all players — generation, traders, suppliers, buyers, and sellers.

Tagiieva emphasized that under wartime conditions, a supplier often becomes both a forecaster and a crisis manager, and the market is “regulated by people” through their decisions and responsibility. Among positive changes, she noted the transition to partnership models with consumers, the development of practical energy solutions, and the fact that integration with the EU (REMIT, market coupling, data analytics) is no longer a slogan but a daily practice. At the same time, she stressed: what matters is not just the “roadmap” but an understanding of how to work within market coupling and the market’s readiness for new rules.

RES: capacity growth, import benefits, grid connection, and localization

Andriy Konochenkov provided wind energy statistics: total installed capacity is about 2.3 GW, with 1.3 GW located in temporarily occupied territories. He noted that in 2025, based on survey results, 324 MW of commissioned capacity was recorded (part of which is expected to be connected to the grid). He also reported a project pipeline of approximately 4.5 GW.

Separately, Konochenkov noted the rapid development of energy storage systems: according to him, over 500 MW of ESS capacity was installed in 2025, which was a “massive jump.”

Among positive regulatory decisions, he mentioned the President’s signing of amendments to the Customs Code, which, according to him, provide for customs duty exemptions for wind turbines (effective until January 1, 2029). At the same time, he identified the construction of power lines and connection procedures as key problems for project development, as they delay timelines and increase the financial burden on investors. Later, the speaker added that the association systematically communicates with authorities (mentioning the number of official appeals), noted improved dialogue with the Ministry of Energy, and emphasized the importance of production localization (particularly component production relocation and involving foreign manufacturers in transferring part of the components to Ukraine).

Vladyslav Sokolovskyi reported on the dynamics of the solar sector: according to association estimates, about 800 MW was commissioned last year, and in the first half of 2025 alone, results approached this figure; by the end of the year, he said, it is possible to reach up to 1.5 GW of installed solar capacity (including industrial, household, and self-consumption stations). He also highlighted the joint work of associations regarding decisions on VAT and duty exemptions for imported equipment (modules, batteries, wind turbines) and outlined tasks for 2026: work on legislative initiatives in the RES sphere, the issue of regulator reform, and the critical importance of recognizing guarantees of origin in the EU for competitive exports.

Producers: restoration after shelling, regulatory incentives, and “trust through fulfillment of obligations”

Nataliia Korobenko (Elementum Energy) emphasized the daily work of producers in regions with constant shelling and the practice of mutual assistance among various market participants after attacks. She noted important 2025 decisions that gave the market tools to operate:

  • Extension of the cash method for VAT calculation for participants in the PSO chain;
  • Extension of the preferential regime for energy equipment imports (VAT/excise) and the expansion of benefits to wind equipment;
  • Significant progress in the regulatory framework for energy storage systems.

Separately, Korobenko emphasized: in relations with European partners, it is important not only to ask for support but also to confirm the seriousness of intentions by fulfilling own obligations, particularly regarding reforms and integration.

Production: attacks, drilling, auctions, and preparation of the framework for cooperation with the USA

Artem Petrenko reported that 2025 was “very difficult” for gas production: according to him, over 25 mass attacks on production facilities were recorded. At the same time, he emphasized that state and private companies are making maximum efforts to stabilize production and prepare for winter, including through imports and supply diversification.

Among the indicators, he mentioned that by the end of 2025, state and private companies could reach a total mark of about 500 new gas wells started drilling during the full-scale invasion period; in 2025 alone — about 140. Petrenko also provided data on three successful auctions for special permits, totaling 1.4 billion UAH in budget revenues, and outlined expectations for 2026 as the year of practical implementation of cooperation mechanisms within the resource/mineral agreement with the USA (including the hydrocarbons sector).

Technical policy, human resources, and a realistic recovery plan

Yurii Bondarenko emphasized the role of professional associations as a source of expertise and a force often lacking in institutions. He stressed that the energy system is a physical system that lives by the laws of electrical engineering, and therefore requires a coordinated technical policy, standards (particularly for microgrids), and an update of the regulatory framework.

A separate block of the speech concerned the human resource problem in engineering education and the need for pilot projects for communities. Bondarenko also noted that the development plan/strategy until 2050, prepared by international experts, does not, in his opinion, correspond to wartime reality, and reported on the development of a pragmatic recovery plan until 2030/2035 involving specialized institutions and the expert community.

What Energy Club achieved in 2025 and plans for 2026

Summing up, Ivan Grygoruk outlined Energy Club’s 2025 results in three dimensions: education, international cooperation, and regulatory/institutional work.

Among the educational programs, he mentioned:

  • Three courses involving market practitioners, specifically “EnergyStart” (for communities — from pre-project work to commissioning of units), a course on distributed generation, and a course on communications in energy.

In the international block — holding two major forums (Rome and Vienna), expanding contacts with European partners, and exchanging experience regarding power system operations during mass shelling.

In the regulatory and advocacy direction, Grygoruk mentioned:

  • Participation in drafting decisions to simplify the movement of special heavy equipment for critical infrastructure restoration;
  • Work on public procurement issues (particularly approaches to price adjustment) and preparing proposals for specialized platforms;
  • Participation (along with partners) in work on the anti-corruption strategy regarding energy and regulator independence principles;
  • Launch of a separate Energy Club project regarding NEURC reform in the context of initiatives registered in parliament (with the intention of holding public discussions, interviews with authors, and forming market proposals).

Separately, the meeting participants repeatedly returned to the topic of debts, PSO, cross-subsidization, and the predictability of the rules of the game as basic conditions for investment and full integration with the European market.

Summary: Common priorities for 2026

Based on the discussion, participants agreed on several common priorities for 2026:

  1. Power system resilience under continued attacks: protection, rapid restoration, increased flexibility.
  2. Acceleration of distributed generation and storage systems development, creating conditions for investment.
  3. Regulatory predictability and synchronization of rules (including overcoming legal conflicts between energy regulation and public procurement).
  4. Integration with the EU: fulfillment of obligations, preparation for market coupling, development of transparency tools (specifically REMIT) and related mechanisms.
  5. A realistic recovery plan for energy and strengthening technical policy, including the human resource block and standardization.

Energy Club thanked the speakers and participants for the meaningful conversation and announced further public discussions regarding regulator reform and other energy agenda priorities for 2026.

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