NEURC Updates Grid Connection and Self-Generation Rules: What Changes for RES, Energy Storage and Businesses

The amendments further develop the provisions of the Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine Regarding the Improvement of the Functioning of Energy Markets, Competitive Conditions for Electricity Generation from Alternative Energy Sources and Strengthening Energy Resilience” dated 10 February 2026 No. 4777-IX.

For businesses, this creates broader opportunities both for the development of new renewable energy and energy storage projects and for the deployment of on-site generation at industrial and commercial facilities.

New Opportunities for Grid Connection

One of the key innovations is flexible connection. It allows the permitted capacity to be subject to certain limitations and provides for technical means to control such limitations. At the same time, part of the permitted capacity may be guaranteed, meaning that it is available for use at any time.

Law No. 4777-IX also provides for a specific case where an applicant may propose a flexible connection to the transmission system operator or distribution system operator as an alternative to the reconstruction or construction of external electricity supply networks. Where the statutory requirements are met, the system operator may not refuse such flexible connection. The connection point must be equipped with technical means enabling the automatic disconnection of electrical installations or reduction of their load.

NEURC expressly links the introduction of this mechanism to the possibility of connecting new generation and energy storage facilities even where network capacity is limited, provided that the technical parameters established by the system operator are complied with.

For investors, this means that a grid connection should no longer be assessed merely by confirming the existence of a connection agreement and technical specifications. It is important to understand the actual amount of available capacity, potential restrictions, required network works, the timetable for their completion and the operational regime of the facility following connection.

These parameters directly affect capital expenditure, project timelines and the economics of a new RES or energy storage project.

Shared Connection Point for Generation, Storage and Consumption

The regulatory update also broadens the possibilities for using a single connection point for different types of energy installations. NEURC specifically identifies the expansion of shared connection arrangements as one of the areas implementing Law No. 4777-IX.

Generation, energy storage and consumption facilities may be connected at a single connection point, and their aggregate installed capacity may exceed the permitted capacity. However, the actual capacity injected into and withdrawn from the grid may not exceed the respective permitted injection and withdrawal capacity at the connection point.

Where installations owned by different parties are used within such a configuration, separate commercial metering must be ensured. For licensing purposes, the aggregate installed capacity of the relevant installations located within the same metering site is also relevant, irrespective of their ownership.

Particular attention should be paid to restrictions on withdrawal and injection capacity, the commercial metering model, the legal status of each installation and the implications of combining equipment owned by different parties within the same metering site. For RES facilities benefiting from state support mechanisms, the addition of new generation may also be subject to specific statutory restrictions.

For investors, this creates more flexibility for combined “generation + energy storage + consumption” projects, while at the same time increasing the importance of legal and technical due diligence of the connection arrangements.

More Opportunities for Energy Storage Facilities

Operators of energy storage facilities may use generating units at the location where energy storage activities are carried out. NEURC also identifies this possibility as one of the key innovations introduced in implementation of Law No. 4777-IX.

However, this right is subject to compliance with statutory conditions. In particular, the withdrawal and injection capacity at the connection point must not exceed the respective permitted capacity limits, while electricity flows to and from the energy storage facility must be separately metered.

For developers and investors, this makes it particularly important to structure the technical and legal configuration of the facility properly before construction begins or the project is acquired.

Self-Generation Becomes More Convenient for Businesses

The second important set of amendments concerns active consumers.

The amendments adopted by NEURC provide for the possibility of settlements without netting under the self-generation mechanism. Where this is provided for in the electricity purchase agreement under the self-generation mechanism, electricity consumed by a business from the grid is paid for under the relevant supply agreement, while electricity injected into the grid is paid for separately.

The use of the non-netting settlement model must be expressly provided for in the electricity purchase agreement under the self-generation mechanism. The new rules also expressly allow this mechanism to be used by businesses applying the simplified taxation, accounting and reporting regime. Already during the regulatory process, NEURC separately referred to the introduction of this possibility for active consumers using the simplified taxation system.

The adopted amendments provide that an electricity supplier or universal service supplier will pay for electricity injected into the grid by an active consumer by the 15th day of the month following the settlement month.

The amendments also allow electricity generated by third-party generation facilities connected to the active consumer’s networks or electrical installations to be included in the volume of electricity injected into the grid by that active consumer, provided that such electricity has not been used for the consumer’s own needs.

In our view, this particular change may be especially relevant for industrial businesses. It creates a stronger regulatory basis for models under which generation equipment located at the consumer’s premises is owned or operated by a third party, while the consumer receives electricity or a broader energy service without having to finance the acquisition of all equipment itself.

At the same time, each such model requires a separate review of the contractual structure, commercial metering arrangements, imbalance responsibility, licensing requirements and tax implications.

What This Means for Investors and Energy Project Owners

For RES and energy storage projects that are under development or being prepared for acquisition, it is worth reassessing:

• the technical specifications and actual parameters of the permitted capacity;
• potential restrictions under a flexible connection arrangement;
• the calculation of the connection fee;
• the deadlines and stages for performance of the system operator’s obligations;
• the status of construction of external networks;
• the possibility of shared use of the connection point;
• the commercial metering model;
• the implications of adding an energy storage facility or additional generation to an existing project;
• the need to amend the connection agreement and technical specifications.

This is particularly relevant for acquisitions of projects marketed as ready-to-build. The mere existence of a connection agreement and technical specifications is not sufficient to assess the actual status of the grid connection element of a project. It is necessary to verify whether the connection can in fact be implemented under the current regulatory framework.

For industrial consumers, the changes provide a reason to reassess the economics of on-site solar generation and energy storage and to compare direct ownership of equipment with models under which the generation assets are owned by a third party.

GOLAW’s View

In our view, the new regulatory framework better reflects the modern structure of energy projects, where consumption, generation and energy storage may be combined within a single site.

At the same time, greater flexibility means that when assessing a project, the substance of the grid connection rights is becoming increasingly important, rather than their mere formal existence: available capacity, applicable restrictions, timing, required network works and the ability to use the connection point for the planned configuration of equipment.

GOLAW advises on the development and acquisition of energy projects, conducts legal due diligence of grid connection arrangements and other key project rights, structures on-site generation and energy storage models, and assesses project readiness for project financing.

If you are developing, financing or planning to acquire a RES or energy storage project, or considering on-site generation at your business premises, the new rules should be taken into account already at the project structuring stage.