The European Commission, in its annual report on Ukraine for 2026, published on 4 November, identified lifting the ban on exports of natural gas as one of the priority steps in market reform.
Recommendations on special obligations (PSO) and unbundling
The document notes that, alongside lifting the export ban, the EU expects the gradual removal of special obligations (PSO) and the proper unbundling of gas distribution system operators. The report records limited progress in the market, notably the removal of PSO for gas-fired power producers.
“Some limited progress can be reported in the gas market, where PSO for gas-fired power producers has been lifted. Reforms, including ensuring proper unbundling of gas distribution system operators, the gradual removal of PSO and the lifting of the ban on exports of natural gas, remain an important priority for Ukraine,” the European Commission report says.

Need to accelerate liberalisation and financing for vulnerable consumers
The document also stresses the need to speed up work on the gradual liberalisation of energy markets. It separately calls for the creation of a mechanism to finance the needs of vulnerable consumers.
The report notes that these measures should become part of a comprehensive reform of the gas sector alongside unbundling and the removal of PSO.

Ukraine’s steps on controlled exports
Earlier, Ukraine allowed private gas-producing companies temporary, controlled export of part of their own gas. The mechanism provides for limited delivery volumes and the possibility of halting shipments in case of risks to the domestic market.
This first step is mentioned in the report as part of preparations for broader changes to market rules.





