25.09.2025
A recent crisis and an artificial price collapse in the spot electricity market have highlighted a deep-seated problem in Ukraine’s energy sector: a critical lack of transparency and access to key market data. Amid the ongoing war, market participants are forced to operate “in the dark,” lacking comprehensive data on generation, the balance of production and consumption, and clear price indicators. This situation makes forecasting impossible and threatens trust, competition, and the prospect of Ukraine’s integration into the European energy space.
The reasons why a return to transparency is a matter of survival for the market were discussed by participants of the third Energy Club discussion in a series dedicated to price volatility on the Day-Ahead Market (DAM). The event was moderated by Maksym Nemchynov, Vice President of Energy Club and former Deputy Minister of Energy of Ukraine.
Valerii Bezus: Data Transparency is the Foundation of Energy Security
According to Valerii Bezus, access to data currently balances on the edge of being an energy security issue and a matter of market development and investment. On one hand, it is crucial that the enemy does not obtain critical information about the state of the energy system. On the other hand, without basic indicators, market participants, investors, and regulators cannot build development strategies.
“Withholding data as a temporary solution is not viable and brings no benefits to Ukraine’s economy or energy sector. New approaches to information access must be developed, even under wartime conditions. Certain market segments are simply impossible to imagine without quality analytics based on open data,” he emphasized.
Bezus stressed that the lack of transparency creates artificial price indicators, alternative indexes, and destructive practices that lead to losses for market participants. He called on the National Energy and Utilities Regulatory Commission (NEURC), the Ministry of Energy, and the Market Operator to create a roadmap for data disclosure that aligns with European standards, takes into account REMIT requirements, and addresses the concerns of the Energy Community.
Oleksii Hnatenko: Insider Information Instead of Official Data
Lawyer Oleksii Hnatenko highlighted the legal and business consequences of the lack of transparency. In his view, any restriction on information, whether in the energy or banking sector, leads to negative outcomes. In the case of the energy market, it forces companies to obtain data through “their own channels,” pushing the market toward reliance on insider information.
“Businesses need to base their activities on forecasts, procurement plans, and sales strategies. When data is unavailable, companies are forced to act blindly. Information obviously leaks through media or unofficial channels, but this does not provide a complete picture. Businesses must receive official data directly from operators or the regulator,” he explained.
Hnatenko proposed creating electronic cabinets for company executives with verified access to necessary information. This would ensure both transparency and control, as it would be recorded who accessed which data. He also emphasized the role of the Antimonopoly Committee, which he believes should intervene more actively to stop the abuse of insider information in the electricity market.
Yuriy Pidlisnyy: Contract Standardization and Verified Access
Yuriy Pidlisnyy supported the idea of verified access, citing the example of the Ukrainian Energy Exchange, where a similar mechanism is already in place. He believes such procedures could also be implemented at the “Market Operator” and “Ukrenergo”. He stressed the need to standardize exchange contracts: “Today, there is an imbalance: a seller can cancel delivery volumes without sanctions, while buyers and traders face penalties. This undermines trust in trading. A single, standard contract would allow for risk hedging and ensure stability”.
Pidlisnyy also suggested introducing escrow accounts, where buyers’ funds are held by a bank and automatically transferred only after obligations are met. In his opinion, this would add confidence and predictability for market participants.
Maksym Nemchynov: Moving Towards European Standards
Moderator Maksym Nemchynov noted that the introduction of unified exchange products is a necessary step for the development of the Ukrainian electricity market and its integration into the European space. Regarding escrow accounts, he expressed doubt about their applicability in spot segments due to the specifics of market coupling. However, he agreed that such tools should be considered for other segments, as they could increase stability.
“Opening all data 100% is impossible for security reasons. But we must start working on mechanisms for responsible access now. This will give the market clear rules of the game and become the basis for further integration with the EU,” Nemchynov concluded.
Conclusion
Operating in an “information vacuum” threatens Ukraine’s energy security no less than physical attacks on its infrastructure. The lack of open data erodes trust, encourages insider trading, destroys competition, and blocks investment. The participants of the Energy Club discussion agreed on the following points:
Data disclosure is not an option but a necessary condition for the market’s survival and development, as well as for Ukraine’s integration into the European energy community.
