Module 6Lection 2
Oleh Bakulin is a lawyer and attorney specializing in the energy and utilities sectors since 2011.
He has held positions as a legal counsel and deputy head for legal affairs at companies operating in the natural gas and electricity markets, including natural gas suppliers, electricity suppliers, a gas production company, and an electricity producer.
He holds a higher legal education and graduated from the National Academy of Internal Affairs in 1994. In 2004, he obtained a certificate to practice law.
From 2015 to 2019, he participated in the activities of public councils under the National Energy and Utilities Regulatory Commission of Ukraine (NEURC), the Ministry of Energy of Ukraine, the Ministry of Economy of Ukraine, and the Antimonopoly Committee of Ukraine. As part of working groups, he contributed to the drafting of legislative initiatives and regulatory acts of the Cabinet of Ministers of Ukraine, NEURC, and the Ministry of Energy of Ukraine.
Until 2019, he headed the NGO “Union of Gas Market Liberalization Participants.” The organization’s activities included analyzing legislative and regulatory drafts of the Cabinet of Ministers, NEURC, the Ministry of Energy, and the Ministry of Economy of Ukraine, and preparing proposals to improve them.
From 2019 to the present, he has been an analyst of regulatory draft acts for the Ministry of Energy, the National Securities and Stock Market Commission, and NEURC, preparing expert recommendations and proposals.
For over 15 years, he has practiced litigation in the energy and utilities sectors: administrative proceedings — challenging regulatory acts of the Cabinet of Ministers and NEURC; commercial proceedings — representing parties in disputes among natural gas and electricity market participants; and civil proceedings — handling cases involving market entities in natural gas, electricity, and utilities.
Since 2021, he has been a regular contributor to the information and analytical journal Energobusiness.
Introduction into legislation
The concept of EIC-code (Energy Identification Code) was enshrined in Ukrainian legislation with the adoption of the Law of Ukraine “On the Natural Gas Market” (effective from October 1, 2015).
In order to implement this law, a number of by-laws were adopted, including:
According to the GTS Code:
EIC-code (Energy Identification Code) is a unique energy identification code of a natural gas market entity or commercial metering point, which ensures unification and unambiguous identification of natural gas market participants and metering points.
Until 2015, the concept of an EIC code did not exist in the Ukrainian gas sector. The supply of natural gas was organized differently:
Who carried out the management?
How did gas transportation work?
Feature: these documents had no EIC codes.
Household consumers were displayed in a generalized figure — without individual identification.
With the adoption of the Law of Ukraine “On the Natural Gas Market” (2015) and the relevant by-laws, significant changes have occurred in the sector.
Transitional period
Purpose of assignment
Practical result
From January 1 2016:
Since 2015, the Law “On the Natural Gas Market” and subordinate legislation (GTS Code, GRM Code, Gas Supply Rules, standard contracts) have established the mandatory use of EIC codes.
Definition (from the GTS Code):
An EIC code is an energy identification code of a market entity or commercial metering point, created for unique identification in information systems.
Format: 16-digit unique code.
They were assigned EIC codes by the GTS operator (JSC “GTS Operator of Ukraine”).
Thus, the gas transmission system operator performed the key function of centrally assigning codes for all participants directly connected to the GTS.
Thus, the EIC code became the only tool for identifying consumers and metering points, without which the natural gas market does not work today.
EIS-code (Energy Identification Code) – a unique 16-digit code used to identify energy market entities and commercial metering points.
EIC-code «X» – the code of the market entity (company, legal entity or individual).
EIC-code «Z» – the code of the commercial metering point (specific connection point).
GTS operator – an entity that transports natural gas through main gas pipelines (in Ukraine – LLC «GTS Operator of Ukraine»).
GRM operator – a company that ensures the distribution of natural gas to end consumers (regional gas).
Commercial metering point – a physical location (meter, metering node) where the volume of consumed or supplied gas is recorded.
Information platform is an electronic system of the GTS Operator that provides data exchange between market participants.
Unbundling is the process of separating gas transportation from its production and supply (completed in Ukraine in 2020).