Digests • 11 December 2025

Developments in Ukraine’s Energy Sector

Andrian Prokip

Andrian Prokip

Doctor of Economics, Head of Energy Programs at the Ukrainian Institute for the Future

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Monthly Energy Digest – November 2025

By Andrian Prokip

  • A corruption scandal erupted involving the former Minister of Energy and representatives of certain energy companies. The scandal led to several dismissals and a restructuring of management at state-owned energy companies.
  • Russian attacks on non-Ukrainian energy infrastructure persisted, and outage schedules had already been applied to consumers in all regions.
  • Electricity imports rose, and exports were halted.

Energy Policy and Sector Management.

A scandal involving corruption, and a subsequent reorganization of Ukrainian state-owned energy companies and government agencies.

The NABU and the SAPO carried out a large-scale operation called MIDAS to expose corruption involving some energy companies and officials. Agencies reported it lasted for 15 months and included 1,000 hours of audio recordings. Participants in the scandal developed an extensive corruption scheme to influence key state-sector enterprises, especially JSC NNEGC Energoatom.

Published recordings included conversations with Herman Galushchenko – former Minister of Energy, now Minister of Justice, Ihor Myronyuk – former Advisor to the Minister of Energy, Dmytro Basov – Executive Director for Physical Protection and Security of Energoatom, a former employee of the Prosecutor General’s Office, Timur Mindich – a businessman, co-owner of the Kvartal 95 studio, an associate of President Volodymyr Zelensky, and head of a criminal organization, Oleksiy Chernyshov – former head of Naftogaz and former deputy prime minister, who had previously received a warrant from NABU for illegal enrichment. Additionally, Galushchenko and some other speakers discussed how other managers in the energy sector were loyal or not to Galushchenko.

  • On November 10, the NABU conducted searches at the former Minister of Energy, now Minister of Justice, Herman Galushchenko, Timur Mindich, and Energoatom. Mindich left the country a few hours before the searches were conducted.
  • On November 11, the Cabinet of Ministers prematurely ended the powers of the Supervisory Board of Energoatom. During the selection process for a new Supervisory Board, the Cabinet of Ministers will perform the functions of the company’s supervisory board in full cooperation with international partners. Yulia Svyrydenko described this as the first step toward restoring Energoatom’s management. The Prime Minister also directed the State Audit Service to conduct an urgent audit of Energoatom, including its procurement processes. The government ordered the suspension of duties for Dmytro Basov, Chief Advisor to the President of NNEGC Energoatom, who has already been notified of suspicion, as well as for employees involved in crimes currently under investigation by law enforcement agencies, such as the Director of Finance and Budgeting, the Director of Legal Support, and the Head of the Centralized Procurement Unit. On November 12, the government immediately suspended Vice President and Board Member Jakob Hartmut from his duties.
  • On November 12, the government removed Herman Halushchenko from his position as Minister of Justice. President Zelensky supported dismissing both the Minister of Justice, Herman Halushchenko, and the Minister of Energy, Svitlana Grynchuk. The same day, Minister Grynchuk signed her resignation letter. One week later, the Verkhovna Rada dismissed her from the role of Minister of Energy and Herman Halushchenko from the position of Minister of Justice. The government appointed Artem Nekrasov as the acting Minister of Energy. Previously, he served as the First Deputy Minister of Energy, a position he has held since August 1, 2025. Before working at the Ministry of Energy, he headed the State Enterprise Guaranteed Buyer. 
  • On November 12, NABU and SAPO notified former Deputy Prime Minister of Ukraine Oleksiy Chernyshov about suspicions of illicit enrichment in the high-profile MIDAS case. The former official was among those who visited the so-called laundry—a place where illegally obtained funds were legalized. The laundry was run by the leader of the criminal organization, Timur Mindich.
  • On November 13, the Ukrainian Cabinet of Ministers officially halted the competition for the head of GTS Operator of Ukraine LLC. The decision was made after the NABU investigation materials into possible abuses at Energoatom were released, where one of the finalists, Oksana Kryvenko, who currently serves as the Director for Regulatory Affairs at GTSO, is mentioned.
  • On November 14, the Cabinet of Ministers announced a comprehensive audit of state-owned companies, focusing on the energy sector. The inspections will assess management efficiency, procurement procedures, and the performance of supervisory boards. The authorities plan to restructure key state-owned enterprises in the energy sector. According to Zelenskyy, alongside a full audit of financial activities, the management of these companies should also be refreshed.
  • President Volodymyr Zelenskyy has directed the Cabinet of Ministers of Ukraine to submit an urgent draft law to the Verkhovna Rada to update the composition of the National Energy and Utilities Regulatory Commission (NEURC). He announced this after a meeting with Prime Minister Yulia Svyrydenko to discuss further steps to clean up and reboot the management of the energy sector and related institutions.
    The President also expects the management of the State Nuclear Regulatory Inspectorate and the State Energy Supervision Inspectorate to be refreshed, and he has instructed the Prime Minister to submit a proposal to the Verkhovna Rada for the appointment of the head of the State Property Fund of Ukraine.
  • On November 15, President Zelenskyy, along with Prime Minister Yulia Svyrydenko and Minister of Economy Oleksiy Sobolev, announced a restructuring of state-owned energy companies.

Reshuffling management of state-owned energy companies

The government approved a timetable for restructuring the management and/or boards of state-owned energy companies. Here are the following details.

  • Energoatom: a new composition of the supervisory board should be formed by November 24, 2025, and a new executive team for the company should be appointed within a month afterward.
  • Naftogaz: a new supervisory board composition should be established by January 20, 2026.
  • By December 31, 2025, the executive bodies of UkrGazVydobuvannya, UkrTatNafta, Ukrnafta, and Gas Distribution Networks of Ukraine should be updated.
  • UkrHydroEnergo: a representative of the state in the supervisory board should be appointed by December 10, 2025, and the selection process for the head of the executive body should be completed by February 1, 2026.
  • GTS Operator of Ukraine: representatives on the supervisory board should be reshuffled by December 10, 2025, and the competition for the head of the executive body should be completed by December 31, 2025.
  • NPC Ukrenergo: representatives on the supervisory board should be reshuffled by December 10, 2025.
  • “CentrEnergo” and JSC “ECU”: new supervisory boards should be established by December 15, 2025, and executive bodies should be updated within a month of that.
  • The Guaranteed Buyer should be converted into a corporation and a supervisory board should be formed by December 31, 2025.
  • JSC “Ukrainian Distribution Grids” (URM): supervisory board shoukd be established by December 31, 2025.
  • DSOs, accounted to URM (Khmelnytskoblenergo, Mykolaivoblenergo, Ternopiloblenergo, Kharkivoblenergo, Sumyoblenergo, “UkrESKO, Zaporizhzhiaboblenergo, Cherkasioblenergo):proposals for updating the management of the companies should be prepared by the end of 2025.
  • “Market operator” – the supervisory board should be created by December 31, 2025.
  • General changes in corporate governance: by December 31, 2025, amendments must be made to the charters and regulations of supervisory boards of all fuel and energy complex enterprises. These changes should align corporate governance with OECD standards and ensure supervisory boards cannot avoid legal liability.

The Electricity Market

The general situation in the power system

In November 2025, Ukraine’s power system faced continuous pressure from Russia’s extensive missile and drone attacks on critical infrastructure, including electricity generation, transmission, and distribution. This led to significant capacity shortages and ongoing damage, with the situation gradually worsening at the start of the month and partially stabilizing by its end. Average daily electricity consumption increased by 2–7% compared to October due to seasonal cooling and peak loads in the morning and evening, making balancing more difficult. Solar power plants’ efficiency dropped sharply because of clouds and shorter daylight hours, while hydro and thermal power plants operated with limitations due to damage.

To balance the power system, outage schedules for residential consumers (1–4 shifts per day) and capacity restrictions for industry had to be enforced. In the first half of the month, scheduled cutoffs were not implemented in all regions. However, after attacks on energy infrastructure in the western part of the country, restrictions were applied across all regions. Imports of electricity from the EU increased significantly to cover the shortages, while exports ceased completely.

During a specific period, NPP units operated at reduced capacity starting on the night of November 7 due to transmission system bottlenecks caused by damage to key substations and 750 kV power lines. By the end of the month, all but one unit had returned to full capacity.

Repeated attacks at the start, especially on November 7, and at the end of the month (November 28–29) caused extensive outages, such as over 500,000 customers in Kyiv, 100,000 in Kyiv region, and tens of thousands in other areas, along with damage to substations.

Exports and Imports

The limit for electricity imports from the EU to Ukraine and Moldova will increase to 2.3 GW.

The maximum capacity for electricity imports to Ukraine and Moldova from EU countries will increase to 2,300 MW starting December 2025, up from the current limit of 2,100 MW. However, Ukraine is not currently utilizing the full allowed capacity due to bottlenecks in transmitting electricity from west to east caused by Russian attacks. In October 2025, Ukraine and Moldova reached the import limit only during a few evening peak hours for several days.

In November, electricity imports increased, while exports were suspended.

In November, Ukraine imported 414.7 thousand MWh compared to 359,9 thousand in October. Shares of imports from Slovakia increased, while shares from Hungary and Poland dropped, as the powerline with Slovakia was put into operation at the end of October after maintenance.

Monthly electricity export and import volumes for the recent year
(The chart is based on ENTSO-E data)

October and November import comparison (based on ENTSO-E data)

Monthly import volumes of electricity by partner countries
(The chart is based on ENTSO-E data)

Daily peak electricity imports in November reached 1,855 GW early in the month. However, later on, this number rarely exceeded 1.25 GW. The primary reason was damage to power transmission systems due to Russian strikes. Therefore, even when imported, the electricity cannot be transmitted further into the country.

Meanwhile, capacity shortages caused by Russian strikes halted electricity exports. There have been no electricity exports since November 11.

Monthly electricity export volumes by partner countries
(The chart is based on ENTSO-E data)

October and November export comparison (based on ENTSO-E data)

Daily volumes of electricity exports by countries of origin, MWh
(The chart is based on ENTSO-E data)

Daily volumes of electricity imports by countries of origin, MWh
(The chart is based on ENTSO-E data)

Debts and non-payments

NEURC allowed Ukrenergo to allocate an additional UAH 1.8 billion to cover feed-in tariff payments for households’ solar power plants.

The national energy regulator has increased NPC Ukrenergo’s expenses for settlements with owners of residential solar power systems by UAH 1.8 billion (excluding VAT), while reducing the same amount in expenses for settlements with industrial renewable energy facilities. The decision took effect on December 1, 2025.

Thus, the NEURCrevised the structure of Ukrenergo’s power transmission tariff without changing its amount. At the same time, the NEURCincreased expenses for the load-reduction service provided by Ukrenergo’s industrial renewable energy generation by UAH 1.3 billion.  This was done at the expense of servicing costs of UAH 655.8 million and loan repayment costs of UAH 670.5 million.

Installed household solar power capacity has been growing rapidly. Meanwhile, the size of the Guaranteed Buyer’s balancing group has been shrinking, as many power producersmostly wind generators – have started trading directly in the market due to debts and delays in paying the feed-in tariff.

By August 2025, Ukrenergo had exhausted all the funds allocated for paying electricity to private household solar power plants for the year. This accounts for the debts that appeared in August. Over the first eight months of 2025, private household solar power plants on the green tariff accumulated electricity expenses totaling UAH 7.114 billion (excluding VAT). In comparison, Ukrenergo’s electricity transmission tariff structure allocated UAH 6.98 billion for this purpose throughout the year. As a result, Ukrenergo lacked funding sources to cover the costs of services provided by universal service providers (USPs) in 2025.

In 2024 and 2025, after blackouts caused by Russia’s strikes, companies and households increased their installation of solar power systems to partly protect themselves from potential future supply shortages. Not all households applied for feed-in tariffs, but even those who did faced financial constraints in paying the required amounts.

Level of settlements with RES producers as of early November 2025.

As of early November, Ukrenergo’s total debt to the Guaranteed Buyer for the Renewable Energy Support Service was UAH 16.10 billion, including UAH 2.1 billion for services from January to October 2025. Compared to the end of September, Ukrenergo’s debt has decreased by 1.5%.

In 2025, most months saw the Guaranteed Buyer’s payments range from 77% to 99%. Meanwhile, in 2024, the payment levels were somewhat lower, fluctuating between 61% and 98%, with an annual average of 89.3%. In 2023, nearly full settlement was achieved at 99.2%, while 2022 was the most challenging year, with monthly payments dropping to 33% to 45%, and the overall rate at just 65.7%.

The debt to Ukrenergo in the balancing market has already surpassed UAH 41 billion.

As of late November, the debt owed by balancing market participants to NPC Ukrenergo has already reached a record 41 billion UAH. Overall, since the start of 2025, the debt to Ukrenergo in the balancing market has increased by 18.6%, from 34.5 billion UAH to 41 billion UAH.

Ukrenergo’s debt to balancing market participants also grew sharply, reaching 21 billion UAH in mid-November, which is a record high. Since the start of the year, Ukrenergo’s debt has increased by 27%.

Price Caps

In November 2025, DAM prices hit price caps during 31% of all hours.

In November 2025, hourly prices on Ukraine’s day-ahead market reached the price caps in 31% of settlement periods. The peak of price cap occurrences happened daily at 5 p.m. in November, when the price hit the cap. At 4 p.m., the price reaches the cap on 26 out of 30 days. In October 2025, the hourly price cap achievement rate was only 13%.

According to the Market Operator, in November, the base-load price index in the day-ahead market rose by 6.7% from the previous month, reaching 6,387 UAH/MWh.

Market shaping

NEURC simplified licensing for distributed generation.

The NEURC shortened the list of required documents for licensing and, in some cases, removed the requirement to submit them altogether. The aim is to promote the development of distributed generation during the war and to boost the country’s energy independence.

The amendments encompass the following.

  • The list of required documents to obtain a license for thermal energy production is being shortened.
  • Production of thermal energy at cogeneration plants is allowed without a license if heat is sold to heat supply organizations at the tariff set by law (not exceeding 50% of the single-rate or variable part of the two-rate tariff for consumers). The enterprise only needs to notify the Ministry of Regional Development, NEURC, and local authorities within three working days of starting operations.
  • The process for confirming the readiness of energy facilities for operation has been simplified, including gas turbines, gas piston plants, cogeneration, and block-modular boiler houses from 1 MW. Now, a copy of the comprehensive test protocol or another document in accordance with the Cabinet of Ministers’ Resolution No. 1320 is sufficient.

The government has simplified the process for obtaining loans to install solar and wind power systems at home.

The Cabinet of Ministers has streamlined the process for individuals to receive state support when installing renewable energy-generating units in their homes. The new system offers financial aid by reimbursing 30% of the principal amount of the main loan, replacing the previous method of monthly interest rate reimbursement on that loan.

This mechanism will benefit borrowers more, as they will receive an immediate discount on loans for equipment purchase and installation. Additionally, the government and potential donors willing to provide financing will be able to determine the necessary funds to offer financial support. It is also expected that this decision will help increase the number of people able to purchase and install hybrid power supply systems, promote effective cooperation with international financial organizations and donors in raising funds, and implement a mechanism that will enhance the country’s energy security.

The Gas Market

Gas balance

Ukraine is still withdrawing small amounts from underground gas storage facilities (UGS) – 5 to 10 million m³ per day compared to the average withdrawal of 45 million m³ per day during the same month in 2023-2024 – due to temperatures 3-5 degrees Celsius above normal and imports. The total volume of gas in UGS is 13.1 billion m³, including 4.7 billion m³ of long-term storage gas (technological) and gas in temporarily uncontrolled territories, which is an 11% increase compared to last year.

Gas import and storage

Naftogaz expands LNG imports from the USA.

Naftogaz Group and Greece’s state-owned DEPA Commercial have signed a Letter of Intent to deliver American natural gas to Ukraine during the winter of 2025-2026. The gas will be transported through a pipeline across the Balkans, with deliveries starting in January.

Ahead of his visit to Greece, President Zelensky stated that Kyiv had allocated funds for gas imports from European partners and banks, backed by guarantees from the EU and Ukrainian banks, to cover nearly €2 billion ($2.3 billion) needed.

Naftogaz of Ukraine and Polish Orlen have agreed on an additional 300 million cubic meters of U.S. LNG supplies to Ukraine. A Polish export credit agency, KUKE, will provide credit support to facilitate post-payment for the delivered volumes, helping Naftogaz address its current liquidity shortfall. The contract will include the supply of three LNG tankers carrying American gas in the first quarter of 2026. The cargo will be imported by Orlen to one of the terminals, either Swinoujscie in Poland or Klaipeda in Lithuania, where the Polish company has reserved capacity. After regasification, the gas will be delivered to Ukraine through the Polish GTS. Besides, Poland is working on an agreement to import LNG from the United States for further additional supply to Ukraine and Slovakia.

The reserved capacity for gas imports via Route 1 for December doubled.

Companies have doubled the booked capacity for importing natural gas from Greece to Ukraine via the joint Route 1 for December, reaching up to 1.2 million cubic meters per day. The operators of the Trans-Balkan route offered about 2.2 million cubic meters of capacity per day for December, with companies booking 60% of it. These are the highest booking volumes in the route’s history. For example, in November, companies booked half as much—0.6 million cubic meters per day. 

According to independent estimates by ExPro consulting agency, in July-August 2025, about 18 million cubic meters of natural gas were imported into Ukraine via Route 1, and since early November, more than 14 million cubic meters.

Moldova reduced the tariff for gas transit to Ukraine by 50 percent.

The National Energy Regulatory Agency of Moldova (ANRE) approved the application for a 50% reduction in gas transportation tariffs to Ukraine. The initiative aims to strengthen regional energy security and ensure natural gas supplies to Ukraine. The approved amendments include extending the Route 1 product application period by 6 months (November 2025 – April 2026), implementing a 50% reduction in transportation tariffs for SRL Vestmoldtransgaz at the Căuşeni and Grebenyci interconnection points, and expanding the capacity product to all relevant interconnection points along the route. Additionally, a 50% reduction in transportation tariffs is also planned by the Romanian transmission system operator SA Transgaz.

Other News and Developments

Zaporizhzhia NPP Developments

Zaporizhzhia Nuclear Power Plant Power Line Updates

The Zaporizhzhia Nuclear Power Plant (ZNPP) has faced multiple disruptions to its external power supply. On November 9, the backup 330 kV “Ferrosplavna-1” line was restored after being offline for six months, following damage in May. However, on November 14, power supply from the main 750 kV “Dniprovska” line was lost due to shelling by Russian forces, leaving the plant dependent on a single line and risking an eleventh blackout. The Dniprovska line was repaired and reconnected on November 19 after four days. Ukrainian engineers have restored ZNPP power lines over 40 times since Russia’s full-scale invasion began.

Russian Attacks on Energy Infrastructure

Russia continues to target Ukraine’s energy infrastructure. The power system was the key target for Russian strikes.

  • On the night of November 4, Russian forces hit a substation in the Odessa region. Odessa has minimal power generation of its own and relies heavily on power supplied from other regions.
  • Eight DTEK mines in the Dnipropetrovsk region lost power due to shelling on November 6. 
  • On the night of November 8, Russia attacked power system infrastructure in the Kyiv, Kirovohrad, Poltava, Kharkiv, and Dnipropetrovsk regions. Thermal and hydro power plants, as well as power transmission substations, were damaged. Emergency cutoffs and extended scheduled outages followed the attack in most regions. The attack on substations threatened nuclear safety.
  • November 14, 2025: A large-scale drone and missile attack on Kyiv and other regions damages the power grid, leading to widespread power outages and casualties.
  • On the night of November 24-25, Russian forces carried out a combined missile and drone attack on energy infrastructure in several regions, including Donetsk, Kharkiv, Chernihiv, and Dnipropetrovsk. The strikes damaged power plants and substations, leaving more than 100,000 customers without power. 
  • On November 29, a large nighttime attack involved over 500 missiles and drones, including Kh-101, Iskander-M, and Kinzhal, targeting energy infrastructure in Kyiv, Odesa, and other areas. More than 500,000 customers in Kyiv and nearly 8,000 in the Kharkiv region lost power; the attack caused prolonged outages across the country.

But gas infrastructure was attacked as well.

  • November 1, 2025: Attack on a gas production facility in the Poltava region results in a fire and damage to the production facilities.
  • November 7-8, 2025: A large-scale missile and drone attack struck Naftogaz facilities, including gas production and storage sites; this was the ninth such attack since early October.
  • November 25, 2025: Drone and missile strikes on gas facilities,

Besides, throughout the month, attacks on gas stations were reported in several regions, damaging fuel infrastructure and disrupting supplies.


This publication was created by the Ukrainian Institute of the Future with the support of the Askold and Dir Foundation, administered by ISAR Unity as part of the project “Strong Civil Society in Ukraine – a Driver of Reforms and Democracy” funded by Norway and Sweden. The content of the publication is

the responsibility of the Ukrainian Institute of the Future and does not reflect the views of the governments of Norway, Sweden, or ISAR Unity.

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