On 1 April 2026, the Cabinet of Ministers of Ukraine (CMU) adopted Resolution No. 438 approving the National Programme for the Alignment of Ukrainian Legislation with EU Law (Programme). This Programme is a key instrument of Ukraine's EU accession process and establishes an institutional and legal framework for the systematic implementation of reforms and the alignment of Ukrainian legislation with the EU’s acquis communautaire.
The Programme, which is based on screening reports and benchmarks established by the European Commission and structured in accordance with Clusters and Chapters, can be accessed on the official CMU’s webpage.
The Programme’s key points
The picture below illustrates the key aspects of the Programme.
Monitoring and coordination
The Programme will be monitored and evaluated through the dedicated digital information system “Pulse of Accession”, designed to ensure transparency, regular progress tracking and effective coordination among the relevant authorities. The Programme will be subject to periodic updates in line with the progress of the negotiation process and assessments by the European Commission.
Under the Programme, ministries and other central executive authorities of Ukraine must ensure the following:
- submission to the CMU of draft laws provided for by the Programme no later than six months prior to their scheduled adoption by the Ukrainian Parliament;
- engagement with relevant parliamentary committees and members of the Parliament during the development of the draft laws, including the presentation and discussion of draft-law concepts;
- reporting, monitoring and evaluation of the implementation of the Programme’s measures.
Overall coordination and monitoring is entrusted to the Government Office for Coordination of European and Euro-Atlantic Integration.
Relevance for the energy sector: TEN-E action points
The Programme includes a number of action points directly relevant to the energy sector (Chapter 15 of the Programme), including obligations arising from the Trans-European Energy Infrastructure Regulation (TEN-E). See below for a summary of the key TEN-E-related action points, together with applicable deadlines and responsible state bodies.
Table. Key Action Points under the Programme for Alignment with EU Law: Energy and Infrastructure Sector
| No | Area | Action | Deadline for adoption | Responsible state authorities |
| 1 | Energy efficiency / buildings | Adopt a framework law amending Ukrainian energy-efficiency legislation: “energy efficiency first”, stronger public-sector exemplar role, procurement criteria, higher energy-savings obligation, rules on audits and energy management, heat-sector decarbonisation, updated building-performance rules, certification, renovation passports, zero-emission buildings, solar in buildings, automation/control systems, stronger enforcement. | Dec 2027 | Ministry of Development of Communities and Territories of Ukraine (MinDevelopment), Ministry of Energy of Ukraine (Ministry of Energy), State Agency on Energy Efficiency, National Energy and Utilities Regulatory Commission (NEURC), Parliament |
| 2 | Renewables | Adopt Renewable Energy Sources (RES) implementation law and then secondary legislation covering RES terminology, statistical transfers, joint projects/support schemes, renewable energy communities, permitting and RES acceleration areas, sustainability criteria for biofuels/bioliquids/biomass fuels, professional certification, calculation of gross final RES consumption and procedures for joint projects / transfers. | Law: Dec 2026 | Ministry of Energy, MinDevelopment, Ministry of Economy, Environmental and Agriculture of Ukraine (Ministry of Economy) State Agency on Energy Efficiency, NEURC |
| Secondary legislation: Dec 2027 | ||||
| 3 | Ecodesign | Approve a technical regulation establishing the ecodesign framework for sustainable products. | Dec 2027 | State Agency on Energy Efficiency, Ministry of Economy, MinDevelopment |
| 4 | Ecodesign | Approve technical regulation on ecodesign requirements for smartphones, non-smart mobile phones, cordless phones and tablets. | Draft: Dec 2026 | State Agency on Energy Efficiency, MinDevelopment |
| Adoption: Jun 2027 | ||||
| 5 | Ecodesign | Approve technical regulation on ecodesign requirements for fans driven by motors from 125 W to 500 kW. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 6 | Ecodesign | Approve technical regulation on ecodesign requirements for local space heaters and related controls. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 7 | Ecodesign | Approve technical regulation on ecodesign requirements for household tumble dryers. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 8 | Ecodesign | Approve technical regulation on off-mode, standby and networked-standby energy use of electrical / electronic household and office equipment. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 9 | Energy labelling | Approve technical regulation on energy labelling of smartphones and tablets. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 10 | Energy labelling | Approve technical regulation on energy labelling of household tumble dryers. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 11 | Ecodesign framework | Amend Ukraine’s generic ecodesign technical regulation for energy-related products. | Draft: Mar 2027 | State Agency on Energy Efficiency, MinDevelopment |
| Adoption: Dec 2027 | ||||
| 12 | Ecodesign updates | Update ecodesign rules for servers / data storage, motors and variable-speed drives, refrigerators, light sources and controls, electronic displays, dishwashers, washing machines / washer-dryers, and direct-sales refrigeration. | Draft: Mar 2027 | State Agency on Energy Efficiency, MinDevelopment |
| Adoption: Dec 2027 | ||||
| 13 | Energy labelling framework | Replace / update the technical regulation on energy labelling of energy-related products. | Draft: Mar 2027 | State Agency on Energy Efficiency, MinDevelopment |
| Adoption: Dec 2027 | ||||
| 14 | Energy labelling updates | Update labelling rules for electronic displays, washers / washer-dryers, light sources, refrigerators, dishwashers and direct-sales refrigeration. | Draft: Mar 2027 | State Agency on Energy Efficiency, MinDevelopment |
| Adoption: Dec 2027 | ||||
| 15 | Energy labelling / transport products | Approve technical regulation for tire labelling on fuel efficiency and other parameters. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment |
| 16 | Biofuels / sustainability | Approve rules for verifying sustainability criteria, GHG-emission savings and low- indirect land use change (ILUC)-risk criteria. | Jun 2027 | State Agency on Energy Efficiency, Ministry of Energy |
| 17 | Renewable fuels | Approve methodology for determining the share of co-processed biofuels and biogas for transport. | Jun 2027 | State Agency on Energy Efficiency |
| 18 | Biofuels / land-use criteria | Approve criteria for high-ILUC-risk feedstocks and certification rules for low-ILUC-risk biofuels / bioliquids / biomass fuels. | Jun 2027 | State Agency on Energy Efficiency, MinDevelopment, Ministry of Economy, Ministry of Energy |
| 19 | Biomass | Approve rules on demonstrating sustainability compliance for forest biomass. | Dec 2027 | Ministry of Economy, State Agency of Forest Resources of Ukraine (State Forest Agency) |
| 20 | Biofuels / biodiversity | Approve methodology for identifying biodiversity-rich grasslands and justifying their possible use for feedstock collection. | Jun 2027 | Ministry of Economy, Ministry of Education and Science, Ministry of Energy |
| 21 | Renewable gases / Renewable fuels of non-biological origin (RFNBO) | Approve methodology for production of renewable transport fuels of non-biological origin. | Jun 2027 | Ministry of Energy, NEURC, National Power Company "Ukrenergo" (Ukrenergo) |
| 22 | Renewable gases / recycled-carbon fuels | Approve methodology for assessing Greenhouse Gas (GHG) savings from RFNBO fuels and recycled-carbon fuels. | Jun 2027 | Ministry of Energy, Ministry of Economy, State Agency on Energy Efficiency |
| 23 | Gas storage / security of supply | Amend legislation to fully implement EU gas-storage/security rules, including storage-filling targets; approve preventive action and emergency plans; create strategic gas reserves or another reserve mechanism if needed. | Dec 2026 / Dec 2027 | Ministry of Energy, National Joint Stock Company "Naftogaz of Ukraine" (Naftogaz), NEURC, Private Joint Stock Company "Ukrtransgaz" (Ukrtransgaz), Gas Transmission System Operator of Ukraine LLC (OGTSU), Parliament |
| 24 | Oil / petroleum products | Approve methodology for calculating minimum crude-oil / petroleum-product stocks, including stock volumes, product nomenclature and market prices. | Dec 2026 | Ministry of Energy, tax/customs/statistics bodies, Public Joint Stock Company "Ukrnafta" (Ukrnafta), Joint Stock Company "Ukrtransnafta" (Ukrtransnafta) |
| 25 | Offshore oil & gas | Create interagency working group and action plan; then amend legislation for full implementation of EU offshore oil and gas safety rules and reporting formats. | Working group: Apr 2026 | Ministry of Energy, Joint Stock Company "Ukrgasvydobuvannya" (Ukrgasvydobuvannya), State Labour Service of Ukraine (State Labour Service), Parliament, State Emergency Service of Ukraine ("SES"), Naftogaz, Ukrnafta |
| Legislation: Dec 2027 | ||||
| 26 | Electricity security / emergency | Adopt electricity-crisis legislation defining competent authority, crisis concepts, plans and coordination; approve crisis-preparedness procedure and risk-preparedness plan; amend grid code and market rules for emergency and restoration compliance. | Apr 2026 / Jan 2027 / Mar 2027 / Jun 2027 | Ministry of Energy, NEURC, Ukrenergo, Parliament |
| 27 | Electricity / cybersecurity | Approve sectoral cyber rules for cross-border electricity flows. | Dec 2027 | Ministry of Energy, State Service of Special Communications and Information Protection of Ukraine (State Special Communications Service), Security Service of Ukraine (Security Service) |
| 28 | Wholesale energy market / REMIT | Amend the NEURC law to strengthen investigative powers (including on-site inspections and access to records); then update the investigation procedure for market abuse / other wholesale-market breaches. | Oct 2026 / Dec 2026 | NEURC, Parliament, Ministry of Energy |
| 29 | REMIT reform 2024 | Fully transpose the amended REMIT framework (with delayed application of some provisions), then update NEURC secondary acts. | Dec 2027 / Jun 2028 | NEURC, Parliament, Ministry of Energy |
| 30 | REMIT implementation | Build and launch a REMIT information system linked to market-operator systems, insider-information platforms and data-reporting interfaces to detect abusive conduct. | Dec 2027 | NEURC, Ministry of Energy |
| 31 | ACER / regulator cooperation | Amend legislation to define ACER powers on Ukraine’s electricity market. | Apr 2026 | Ministry of Energy, Parliament, NEURC |
| 32 | Electricity grid connection codes | Amend the Transmission System Code to align with EU connection codes for generators, demand customers and High-voltage direct current (HVDC) systems, including tests, demand response, offshore modules and HVDC requirements. | Jun 2027 | NEURC, Ukrenergo, Ministry of Energy |
| 33 | Electricity internal market / balancing / coupling | Broad electricity-market integration package: adopt primary-law changes; assess and set date for 15-minute imbalance settlement; develop and approve required national / regional / pan-European rules and methodologies; translate and publish EU-wide rules; amend NEURC acts for system operation guidelines implementation; seek observer status on EU balancing platforms; adapt IT systems and communications for market coupling; approve roadmap for full balancing-platform participation; conclude Regional Coordination Centres (RCC) / coupling agreements; complete commodities and global markets (CGM) integration and regional outage coordination. | Main steps Apr-Dec 2027 | Ministry of Energy, NEURC, Ukrenergo, Parliament |
| Final CGM integration by Dec 2029 | ||||
| 34 | Electricity market design reform | Amend legislation to transpose the 2024 EU electricity-market-design reform (Directive + Regulation), with some provisions deferred. | Dec 2027 | Ministry of Energy, NEURC, Ukrenergo, Parliament |
| 35 | Methane emissions | Amend gas / oil-and-gas / coal-methane legislation to transpose methane rules: designate authority, monitoring and reporting, third-party verification, coal-mine methane reporting, etc. | Dec 2027 | Ministry of Energy, NEURC, Ministry of Economy, Parliament |
| 36 | Renewable gas / natural gas / hydrogen | Transpose the new gas-hydrogen directive: amend legislation, adopt secondary acts, start a gas-consumption information database, align price-intervention mechanisms with EU rules, and ensure gas meters for all end-users (subject to exceptions). | Mar 2027 / Dec 2027 / within 12 months after martial law ends / within 7 years after martial law ends | Ministry of Energy, NEURC, Ministry of Economy, Ministry of Finance, Naftogaz, OGTSU, Parliament |
| 37 | Renewable gas / natural gas / hydrogen | Transpose the new gas-hydrogen regulation through legislative amendments and follow-up secondary legislation. | Mar 2027 / Dec 2027 | Ministry of Energy, NEURC, Ministry of Economy, Ministry of Finance, Naftogaz, OGTSU, Parliament |
| 38 | Gas network codes | Ensure bundled-capacity allocation at Ukraine-EU interconnection points under the EU Capacity Allocation Mechanism (CAM) code (except full ban on unbundled sales, to apply after EU accession). | Aug 2026 | OGTSU, NEURC, Ministry of Energy |
| 39 | Gas balancing | Gradually remove tolerances and improve system / imbalance-data requirements; abolish special public-service obligations imposed in 2022; consult on methodology for non-daily-metered offtakes. | Within 6 / 12 / 18 months after martial law ends | NEURC, Ministry of Energy, OGTSU |
| 40 | Euratom / emergency response | Amend hygiene standards for permitted Cs and Sr radionuclide levels in food and drinking water after a nuclear / radiological emergency. | Dec 2026 | Ministry of Health |
| 41 | Euratom safeguards | Launch negotiations with the EU on adapting Ukraine’s nuclear-material accountancy and control system to Euratom safeguards rules. | Jan 2028 | State Nuclear Regulatory Inspectorate of Ukraine ("State Nuclear Regulatory Inspectorate"), Ministry of Energy |
| 42 | Nuclear safety | Issue safety regulations for research reactors, dry spent-fuel storage and certain nuclear installations; study EU practice on waste repositories and other nuclear-safety provisions to identify needed legislative upgrades. | Dec 2026 / Dec 2027 | State Nuclear Regulatory Inspectorate, Parliament |
| 43 | Energy governance | Amend legislation to improve corporate governance in the energy sector in connection with certification of the electricity TSO and gas TSO, including separation of enterprise-management and policy functions. | Jun 2026 | Ministry of Energy, Ministry of Economy, Parliament |
| 44 | Energy regulator | Adopt legislative amendments to strengthen the independence and transparency of NEURC.
| Apr 2026 | Ministry of Energy, Parliament |
Impact of the Programme and next steps
The adoption of the Programme represents a significant step in Ukraine's EU integration process and indicates an acceleration of regulatory reforms across all sectors, including energy and infrastructure. Clients operating in regulated sectors are advised to closely monitor upcoming legislative developments under the Programme and assess how the required EU-alignment measures may affect their existing project structures, licences and contractual arrangements.
For more information, contact your CMS client partner or the CMS experts: Vitaliy Radchenko, Maryna Ilchuk.
