Imbalance Prices After NEURC Resolution No. 621: Market Risks and Possible Temporary Solutions

Energy Club has received a proposal from ENERGY 365 LLC to bring to expert discussion the impact of new price caps and the current imbalance pricing mechanism on electricity market participants.

The reason for the appeal was the adoption of Resolution No. 621 by NEURC, which establishes new price caps for the Day-Ahead Market (DAM), Intraday Market (IDM), and the balancing market. In particular, the maximum price cap in the balancing market is set at 17,000 UAH/MWh, while the minimum is 0.01 UAH/MWh.

The company’s appeal states that the current mechanism for determining imbalance prices can create significant asymmetry: during certain hours, a positive imbalance is actually paid for at almost zero price, while a negative imbalance can be paid for at prices significantly exceeding the DAM price. According to the data provided in the letter, between January 17 and March 30, 2026, the payment price for a positive imbalance was 0.01 UAH/MWh for 351 hours, while the maximum payment price for a negative imbalance reached 16,800 UAH/MWh during 781 hours.

Energy Club considers this topic vital for professional discussion, as it affects suppliers, traders, producers, balancing groups, DSOs, consumers, and the financial stability of the market as a whole.

The purpose of the meeting is to discuss the impact of the new price caps on market participants, assess the risks of the current imbalance calculation mechanism, and determine whether there is a need to prepare a consolidated position of Energy Club member companies for NEURC, NPC Ukrenergo, JSC Market Operator, the Ministry of Energy of Ukraine, and the Cabinet of Ministers of Ukraine.

This is not about canceling responsibility for imbalances, but about searching for temporary safeguards during the period of martial law that could reduce excessive price distortions and preserve the financial stability of bona fide market participants.

Questions for Discussion

• How do NEURC Resolution No. 621 and the new price caps affect suppliers, traders, producers, balancing groups, DSOs, and consumers?
• Does the current mechanism for determining imbalance prices create an excessive asymmetry between positive and negative imbalances?
• Why is a positive imbalance actually paid at a near-zero price during certain hours, while a negative imbalance can cost significantly more than the DAM price?
• What financial risks do market participants face by increasing the upper limit of the balancing market to 17,000 UAH/MWh?
• Is it fair to place full responsibility for hourly imbalances on market participants under the conditions of war risks, emergency outages, unpredictable renewable energy generation, and limited access to part of the system information?
• Could a temporary price corridor for imbalance payments relative to the DAM be a compromise solution for the duration of martial law?
• How is the pricing problem in the balancing market related to debts, payment delays, and the risks of acquiring “Pre-default” or “Default” statuses?
• Are Energy Club member companies ready to support the preparation of a joint appeal to NEURC, NPC Ukrenergo, JSC Market Operator, the Ministry of Energy of Ukraine, and the Cabinet of Ministers of Ukraine?

Speakers

Yuriy Pidlisny

Head of Energy 365 LLC

Moderator

Iryna Dmytrotsa

Expert in energy project development and business planning, Head of Operational and Regulatory Policy at Ukrainian Distribution Grids JSC (April 2024 - November 2025)