New transmission system connection rules: flexible connections, cable pooling, combined energy storage and generation

Amendments to Ukraine’s Transmission System Code, approved by Resolution No. 1354 of the National Energy and Utilities Regulatory Commission dated 11 August 2026, will enter into force on 1 September 2026.

The amendments:

• establish rules for flexible connections of electrical installations with a capacity exceeding 1 megawatt (“MW”);
• clarify the arrangements for shared grid connections, i.e., cable pooling;
• allow electricity energy storage and generation to be combined.

FLEXIBLE CONNECTIONS

A flexible connection is a mechanism under which the contracted capacity of electrical installations may comprise (i) firm capacity, which remains continuously available, and (ii) non-firm capacity, which may be restricted.

An applicant seeking a connection with a capacity exceeding 1 MW may apply to the transmission system operator (“TSO”) for a flexible connection once the technical conditions for connection have taken effect and the project documentation has been prepared.

The principal features of flexible connections are as follows:

• may be used on a permanent or temporary basis;
• the requested non-firm capacity must not exceed the non-firm capacity reserve at the relevant network node;
• the requested firm and non-firm capacity must together equal the total capacity stated in the connection application and technical conditions for connection;
• it is required to install information and technical systems to prevent grid overload by regulating power intake/output or by automatically disconnecting within the limits of non-guaranteed capacity; where several users at the same network node have flexible connections, the order in which their non-firm capacity is restricted is determined by the dates on which their connection agreements were concluded, starting with the most recently concluded agreement;
• the TSO is not liable for restrictions on electricity injection or withdrawal within a user’s non-firm contracted capacity.

CABLE POOLING

The amendments regulate the connection of an applicant’s electrical installations to the technological networks used for the internal electricity supply of another user, other than a distribution system operator.

This mechanism also known as cable pooling enables the shared use of a grid connection point and network infrastructure.

The connection is established based on a tripartite agreement between the TSO, the prospective principal user and the prospective sub-user. The following installations may be connected to the principal user’s networks:

• type B, C and D power-generating modules;
• type B, C and D energy storage facilities (“BESS”);
• consumption installations with a capacity exceeding 1 MW, other than installations forming part of the housing stock.

The principal user and the sub-user must also enter into a separate agreement governing the use of the principal user’s technological networks for internal electricity supply. Among other matters, that agreement must address the allocation of contracted capacity, the coordination of electricity injection and withdrawal schedules, commercial metering and the parties’ respective liabilities.

The component of the connection fee amounting to EUR10 per kilowatt of requested connection capacity is not charged for the TSO’s service of connecting the prospective sub-user’s electrical installations to the principal user’s technological networks for internal electricity supply. Other components of the connection fee remain payable.

ENERGY STORAGE AND COMBINED GENERATION

The amendments allow generation and BESS to be combined in two ways:

• an operator of BESS may install and operate generating installations;
• an electricity producer may connect BESS to its own internal electricity networks.

Where an operator of BESS installs generating installations, the following conditions apply:

• the combined electricity injection into, or withdrawal from, the TSO’s networks must not exceed the existing authorised capacity of the operator’s installations at the connection point;
• electricity flowing into and out of the energy storage facility must be recorded through separate commercial metering.

At the same time, an electricity producer connecting BESS to its own networks must likewise ensure that the aggregate power injected or withdrawn does not exceed the contracted capacity established for its electrical installations.

Analogical changes were made to the Distribution Systems Code, the Commercial Electricity Metering Code, and the Methodology (Procedure) for Calculating Connection Fees for the Transmission and Distribution Systems.

Practical Implications for Energy Facility Owners and Investors: the amendments expand the options for connection to the transmission system by enabling the use of non-firm capacity, shared network infrastructure and combined generation and energy storage. However, implementing such projects will require an assessment of potential capacity restrictions, appropriate contractual arrangements and compliance with permitted capacity and commercial metering requirements.

ADDITIONAL NOTES

For further information on the topic please contact senior partner Glib Bondar or counsel Olena Sichkovska-Chornobyl, or by telephone +380 44 591-3355 or via e-mail.