EU and Energy Community on NEURC Reform: Regulator Independence is Priority #1

12.01.2026

As part of monitoring legislative initiatives on energy market regulation, Energy Club analyzed official communication between the NEURC and key international institutions. The Club has obtained letters from the Delegation of the European Union to Ukraine (dated December 18, 2025) and the Energy Community Secretariat (dated December 12, 2025).

These documents serve as a reaction to the latest legislative proposals (specifically, the main Draft Law No. 14282 and the alternative No. 14282-1) and contain crucial signals for market participants regarding the future of the Regulator.

1. Position of the European Union: Independence is the Market Foundation

In the letter, EU Ambassador to Ukraine Katarína Mathernová emphasizes that the independence, professionalism, and predictability of the national regulator constitute a “fundamental pillar of the internal energy market.”

«A well-resourced, autonomous and impartial regulator is indispensable for investor confidence, market stability, and Ukraine’s credible progress towards EU membership.»

Key points from the EU Delegation:

• Clear procedures: Safeguarding NEURC’s institutional independence requires transparent procedures for appointments and dismissals, as well as appropriate safeguards against conflicts of interest.
• EU Standards Compliance: These elements are essential to ensuring compliance with the EU acquis and best practices applied across EU Member States.
• Monitoring the situation: The EU Delegation explicitly states that it “continues to closely monitor the situation,” particularly legislative developments that may impact the Commission’s institutional capacity and autonomy.

2. Position of the Energy Community: No Assessment of Bill No. 14282 Yet

Director of the Energy Community Secretariat Artur Lorkowski made an important clarification regarding the legislative process in his letter.

• No official expertise: The Secretariat officially informed that, as of mid-December, Draft Law No. 14282 had not yet been formally assessed by the Secretariat, as no official request for such an assessment had been received from the competent authorities in Ukraine.
• Support for independence: At the same time, the Secretariat confirms that ensuring NEURC’s independence is of paramount importance for Ukraine’s continued progress toward European integration.

Conclusions for the Market

International partners are sending a clear signal: any amendments to the law on the NEURC will be scrutinized for compliance with the EU acquis. For market participants, this means that adopting Draft Law No. 14282 or alternative initiatives without real approval from the Energy Community carries significant risks.

Attempts to exert political influence on the Regulator under the guise of reform could complicate the EU accession negotiation process and access to energy system recovery funding.

Energy Club keeps its finger on the pulse of the reform

We are analyzing these risks in detail through a series of expert discussions, bringing together the views of politicians, lawyers, and business leaders.

Stage 1. Political Context
We held a debate with the authors of the bills to understand the motivation of both the government and the opposition.
Read the discussion recap and watch the recording

Stage 2. Legal Analysis (January 14, 12:00)
Together with leading lawyers, we will analyze the legal consequences of the EU letters and the risks of lawsuits.
Learn more and register

Stage 3. Business Position (January 22, 14:00)
The discussion of the series, where club member companies will form a joint vision to be presented to legislators.