On 18 August 2026, Ukraine’s National Energy and Utilities Regulatory Commission (NEURC) adopted Resolution No. 1390 “On the Appointment of Joint Stock Company “Market Operator” as a Nominated Electricity Market Operator”, appointing JSC “Market Operator” as a nominated electricity market operator (NEMO) for Ukraine’s participation in the Single Day-Ahead Coupling (SDAC) and Single Intraday Coupling (SIDC).
Market Operator was selected after submitting its application on 15 July 2026 and meeting all nine NEMO criteria set out in the Electricity Market Law.
The appointment marks the first designated Ukrainian NEMO, an institutional prerequisite for Ukraine’s participation in the European market coupling arrangements. A CMS overview of the NEMO designation procedure is available at this link.
Key takeaways
The designation does the following:
- establishes the first Ukrainian NEMO responsible for facilitating Ukraine’s participation in SDAC and SIDC;
- lasts for an initial term of four years. On expiry of that term, the designation may be granted for an indefinite period;
- allows Market Operator to formally participate in the European market coupling framework;
requires Market Operator to establish contractual arrangements with other NEMOs, TSOs, central counterparties and trading agents; - requires further technical integration of the Market Operator’s trading systems with the European coupling arrangements; and
- brings Ukraine one step closer to the practical launch of cross-border day-ahead and intraday electricity trading.
Background
Under the market coupling framework introduced by Ukraine in April 2026, NEMOs are the entities responsible for organising trading within the coupled day-ahead and intraday markets.
Market Operator has organised trading on Ukraine’s day-ahead and intraday markets since 2019 under a market operator licence and already performs central counterparty (CCP) functions on those markets. The NEURC found that it has the organisational, technical, financial, legal and information resources and processes required for those markets.
Since 2022, Market Operator has taken part as an observer in European institutional cooperation on SDAC and SIDC. It is also party to the November 2024 Memorandum of Understanding establishing the Local Implementation Project, under which the TSOs and market operators of Ukraine, Moldova, Poland, Slovakia, Hungary and Romania are preparing Ukrainian and Moldovan integration into SDAC and SIDC.
Future steps
The Market Operator will need to complete the following steps following its designation before coupled trading can begin:
- enter into the agreements necessary for financial settlement and cooperation with other NEMOs, TSOs and trading agents;
- complete technical integration by modernising its trading platform to meet the technical and functional requirements of European market coupling; and
- expand its existing market information publication framework to cover information on cross-border trading and the operation of SDAC and SIDC.
Practical implications for market participants
Once the remaining technical, contractual and regulatory arrangements are completed, the NEMO framework will allow Ukraine to participate in SDAC and SIDC. For market participants, this is expected to have the following implications:
- for traders: market coupling should enable participation in cross-border day-ahead and intraday trading through coordinated European market mechanisms. It should increase trading opportunities and improve price discovery, subject to available cross-border capacity and market conditions.
- for generators (and renewable generators): additional cross-border trading opportunities. The ability to sell electricity into neighbouring markets may improve portfolio optimisation and provide additional export opportunities during periods of surplus domestic generation.
- for consumers and the market: market coupling is expected to improve liquidity, transparency and the efficiency of cross-border capacity allocation. It should also strengthen the integration of Ukraine’s electricity market with the EU internal electricity market and help align Ukrainian market processes with European market rules.
Conclusion
The designation of Market Operator as Ukraine’s first NEMO marks a significant transition from legislative preparation to practical implementation of electricity market coupling.
Market Operator already performs many of the functions relevant to the NEMO role, possesses market surveillance and settlement infrastructure, participates in European market coupling initiatives and is upgrading its IT systems for SDAC/SIDC integration.
For market participants, the key point is that Ukraine is moving closer to actual cross-border coupled trading, but NEMO designation is not the launch of market coupling. The next critical junctures will be the conclusion of the NEMO-TSO cooperation framework, completion of technical integration and implementation of the remaining operational arrangements.
For more information, contact your CMS client partner or the CMS experts who contributed to this article.
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