After several months of discussions, the Cabinet of Ministers finally decided to allow partial exports of natural gas to the European Union—for the first time since the start of the full-scale war. The government adopted the relevant decision on October 7.
Once the document takes effect, private operators will be able to sell up to 15% of the natural gas they produced and delivered to the gas transmission system during the previous month.
The main goal of this decision is to give companies an additional incentive to increase production and invest in the restoration of war-damaged facilities.
Is this decision justified on the eve of an extremely difficult winter, and who will be able to sell their gas abroad?
How Exports Will Work
The monthly limit for each company will be no more than 15% of the actual volume of gas that the producer delivered to the gas transmission system (GTS) in the previous month. For example, if a company delivered 100 million cubic meters of gas to the system in October, it will be able to export no more than 15 million cubic meters in November.
Any unused portion of the monthly limit will not be carried over. In other words, a company will not be able to accumulate its permitted export volume and export it at a later date.
Gas sales for export will take place through specialized auctions on the “Ukrainian Energy Exchange,” in which non-residents wishing to import Ukrainian gas will participate.
This mechanism will not apply to gas produced under production-sharing agreements, nor to market participants that have special obligations to supply gas to the domestic market. That is, it will not apply to the so-called “PSO entities,” which include the state-owned companies “Naftogaz,” “Ukrgazvydobuvannya,” as well as “Ukrnafta” and “Ukrnaftoburinnya”—control over which Ihor Kolomoyskyi and his partners lost after the start of the full-scale war.
Instead, the right to export gas will be granted to Rinat Akhmetov’s DTEK “Naftogaz”—the country’s largest private producer—Burisma, owned by the family of Mykola Zlochevsky, the former Minister of Ecology during the Yanukovych era; Viktor Pinchuk’s “Geo-Alliance”; “Zakhidnadraservice” owned by Zinoviy Kozytskyi, the Poltava Gas and Oil Company, which is owned by the British firm JKX Oil & Gas, Oleksandr Katsuba’s “Nadra-Geoinvest,” and others.
Why Did the Government Allow Exports?
The Ministry of Energy explains this decision by the need to stimulate domestic gas production, which has declined significantly in recent years.
As noted in the government resolution, a copy of which was obtained by EP, production by private gas companies has fallen from about 5 billion cubic meters in 2021 to 3.7 billion cubic meters in 2025.
The situation has been influenced by both the war and Russian attacks on gas production infrastructure, as well as the market’s own economic conditions. Producers are operating in an environment where the domestic price of gas is significantly lower than the European price.
According to the industry publication ExPro, as of mid-September, Ukrainian gas cost approximately 2.5 times less domestically than on the European market. For example, on October 7, 1,000 cubic meters of gas cost $888 on the European market, while in Ukraine, industrial consumers purchased it for 16,037 UAH excluding VAT (equivalent to $356).
In the event of severe cold snaps, consumption will rise, and new Russian attacks could significantly reduce domestic production or even make it impossible to withdraw fuel from storage facilities. Therefore, even with sufficient gas reserves in storage, Ukraine may still require additional imports during certain periods.
In this context, the Ministry of Finance and the Ministry of Energy emphasize in a government resolution the need to account for the risks associated with the 2026/27 heating season and the need for sufficient gas volumes for the domestic market, particularly during peak periods.
Exports Can Be Halted
That is precisely why the government has put a safeguard in place in case the gas situation worsens.
If a threat to energy security arises, exports can be halted promptly. The decision will be made by a crisis committee under the Ministry of Energy at the initiative of the ministry itself, Naftogaz, or the Gas Transmission System Operator.
After that, new auctions for the sale of gas for export will be suspended. At the same time, gas that companies have already sold on the exchange prior to the suspension may still be delivered abroad.
Now the main question is how effectively this mechanism will work in practice. If exports truly help producers restore damaged capacity and increase production, the decision makes sense.
But if, as a result, Ukraine simply sells part of its gas abroad and is then forced to buy it at a higher price in the winter, the logic behind such a move will raise far more questions.