The wholesale energy market participants must register before 1 February 2024 to continue operations on the market

On 15 October 2023, the Resolution approving the Procedure for Registration of Wholesale Energy Market Participants (the "Resolution") came into force. The Resolution introduces the launch of a register of wholesale energy market participants for electricity and natural gas markets. On 1 November 2023, the National Commission for State Energy and Public Utilities Regulation (the "NEURC") published such a register for the first time, but some information is not available due to the martial law.

The Resolution implements the EU Regulation No. 1227/2011 on Wholesale Energy Market Integrity and Transparency (REMIT) into national legislation, which also is implemented by the Law of Ukraine No. 3141-IX "On Amendments to Certain Laws of Ukraine on Prevention of Abuse in Wholesale Energy Markets".

The Resolution obliges wholesale energy market participants to be registered by 1 February 2024 and by 1 June 2024 provide the NEURC with an updated registration form with information on ultimate beneficial owners, related wholesale energy market participants and insider information platforms in accordance with Annex 1 to the Resolution. Full instruction on how to submit this information is available at the link. The deadline to submit this information is 1 June 2024.

Since 1 February 2024, only wholesale energy market participants that have registered in accordance with the Resolution will be able to conduct operations on the wholesale energy market.

The Resolution sets specific deadlines for wholesale energy market participants to provide the NEURC with additional information as follows.

10 – 15 November 2023

  • operators of electricity distribution systems, including small distribution systems
  • operators of gas distribution systems
  • aggregators
  • operators of energy storage facilities; and
  • traders

16 – 28 November 2023

electricity producers

29 November – 14 December 2023

suppliers of electricity to consumers

15 – 29 December 2023

natural gas suppliers


For more information, please contact Asters Partner Yaroslav Petrov and Associate Olena Sichkovska-Chornobyl.

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