Fast Facts
| Wholesale trading licence | None required at border points, VTP, storage or CWS if gas is not supplied to end-consumers |
| Gas supply licence | NEURC-issued for end-consumer supply; decision within 10 business days; indefinite term; residents only |
| Minimum financial resources | No statutory minimum; financial security to GTSOU required for daily imbalances |
| One-time licence fee | Approximately EUR 70 |
| Regulatory fee | Regulatory fee is paid only by license holders. 0.053% of prior-quarter net energy income (rate set quarterly by NEURC); statutory cap 0.15% of net income from the regulated activity |
| Storage base | Approximatelly 30 BCM of underground storage facilities, CWS can exempt 20% import VAT for up to 1,095 days. |
Ukraine Gas Market Fundamentals
Ukraine's 2015 Law On the Natural Gas Market transposed the EU Third Energy Package. Commercial and public consumers may buy from any trader, while regulated prices remain only for households and district heating.
The wholesale market is non-centralised: most trade is bilateral and OTC, with UEEX as the leading exchange. The VTP covers all entry and exit points and requires only a sale agreement and a trade notification on the Information Platform.
Ukraine holds Europe's third-largest gas reserves, up to 719 bcm.
Ukraine has one of Europe's largest transmission systems, operated by state-owned GTSOU and unbundled from Naftogaz. Storage is run by Ukrtransgaz. No LNG terminals exist in Ukraine.
Since 24 February 2022, wartime measures apply on top of the liberalised framework, including heavier regulation and a ban on exporting gas of Ukrainian origin.
When Is a Licence Required in Ukraine's Gas Market?
NEURC is Ukraine's energy regulator and National Regulatory Authority. It licenses, sets tariffs and supervises market participants.
For resident traders, no licence is needed to trade at the border points, VTP, storage or CWS, provided gas is not supplied to end-consumers. Non-resident access is narrower (see below).
A gas supply licence for end-consumer supply is issued by NEURC to Ukrainian residents only. It is granted for an indefinite period, with a decision within 10 business days.
Participants must register with NEURC as wholesale energy market participants under REMIT before any transactions.
Network and storage access require a Transportation Agreement with GTSOU and, where needed, a Storage Agreement with Ukrtransgaz.
GTSOU is the certified, 100% state-owned TSO. Ukrtransgaz is the Storage System Operator (SSO).
What Are Ukraine's Gas Market Licence Requirements for EU and Non-EU Entities?
Non-resident traders:
Trade only at the Ukrainian border point (EU side), only under the Customs Warehouse Scheme (CWS).
Under CWS: may import, store and trade non-Ukrainian-origin gas without a licence.
Required: Transportation Agreement with GTSOU, Storage Agreement with Ukrtransgaz, REMIT registration in CWS.
Cannot hold a supply licence directly; reaching end-consumers requires a local subsidiary.
Resident traders:
No licence needed for wholesale trading (border, VTP, storage, CWS), provided gas is not supplied to end-consumers.
Supply licence required for end-consumers; available to residents only. This is the route foreign groups must take: set up a local subsidiary to qualify as resident.
Both:
Customs may require financial security on import where volume exceeds the trader's prior 365-day volume.
Balancing in the Ukraine Gas Market
GTSOU is Ukraine's TSO and is responsible for balancing the national transmission system.
UEEX short-term product prices set the marginal price used to settle daily imbalances.
Single Balancing Zone: the whole GTS, including distribution, forms one balancing zone, with GTSOU providing balancing services under the Transportation Agreement and the GTS Code.
There is no designated balancing market. Balancing groups are allowed under the GTS Code but rarely used.
For each gas day, GTSOU nets gas delivered to the GTS against gas offtaken. A positive imbalance counts as sold to the TSO, and a negative imbalance as bought from it.
Imbalances settle at a marginal price taken from UEEX short-term product prices, with a 5% flexibility band and a 10% correction above it.
Customers post financial security to GTSOU for imbalances, either as a bank guarantee or cash.
CWS transactions create no imbalances.
Ukraine gas transmission system operator
UEEX marginal price referenceTransmission Capacity in the Ukraine Gas Market
Each trader signs a Transportation Agreement with GTSOU on the NEURC-approved template, accepted as is, with access through the TSO Information Platform.
Annual, quarterly, monthly, day-ahead and intraday capacity is available, each as firm, interruptible or reverse capacity.
Domestic points and storage are allocated first-come, first-served basis.
Cross-border points are allocated by auction on the RBP and GSA platforms.
Short-haul is a discounted, transit-only service at the western borders with Poland, Hungary and Slovakia, usable with CWS and requiring no financial security.
Ukraine Gas Market Exchange(s)
The Ukrainian Energy Exchange, UEEX, is a private exchange founded in 2010 and active in gas since 2016. It is Ukraine's most liquid gas venue.
UEEX is licensed by the National Commission on Securities and Stock Market (NSSMC) and is a member of the Association of European Energy Exchanges.
UEEX has over 1,500 members overall, more than 500 of them accredited to trade natural gas.
Products include short-term within-day and day-ahead contracts and longer-term contracts across VTP, storage and CWS. A dedicated import and customs warehouse section for non-residents has run since April 2024, priced in euros.
Applicants sign standard agreements and submit a registration form. The Exchange Committee decides within 10 business days, and brokers must be accredited.
Participants post a minimum deposit of 3% of planned transaction value to register for trading.
Before execution, buyers must fund 100% of the trade value into escrow.
5 Market Entry Steps for Ukraine Gas Market
- 01Choose the trading mode: cross-border/CWS or licensed subsidiary for supply only.
- 02Obtain an EIC code and register on the GTSOU and Ukrtransgaz platforms.
- 03Sign the Transportation Agreement and Storage Agreement for CWS.
- 04Register with NEURC as a wholesale energy market participant under REMIT.
- 05Book capacity and provide financial security.
- Post-Market Entry Reporting Obligations.
CorreggioNET, Ukraine Gas Market Access Report
Market Access Reports: CorreggioNET offers Pre-Market Entry Reports (PMER) as part of the PMER Library, providing firms with an A-to-Z guide for market entry.
CorreggioNET Alert Service: Helps you never miss a reporting obligation. Note that Ukraine has multiple gas market reporting obligations, across NEURC, GTSOU, Ukrtransgaz and the customs and tax authorities, with a complex and evolving regulatory landscape. The Alert Service ensures you never miss a deadline.
CorreggioNET Hotline: For your time-sensitive queries, the Regulatory Hotline Service provides direct support through an online interaction with a qualified regulatory specialist.
Consulting Solutions: For those firms which require additional assistance, Correggio Consulting is on hand to assist with all your licensing needs:
- Market entry & registration in Ukraine;
- NEURC gas supply licence & REMIT registration;
- GTSOU onboarding;
- UEEX exchange onboarding;
- Ukrtransgaz onboarding for CWS;
- Corporate structuring;
- EFET contract negotiation;
- Yearly compliance audits.
Market Info
Stay Compliant After Market Entry
Entering a new market is only the beginning.
Once trading activity starts, the real challenge is staying compliant with ongoing regulatory updates and reporting obligations. CorreggioNET supports this post-market entry stage through its regulatory platform and monitoring services.
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