Gap Between Battery Storage Law and Grid Operator Practice Complicates Ukrainian BESS Projects

Ukrainian legislation explicitly prohibits double network charges for energy storage systems, yet industry research by AIN found that some distribution system operators still apply grid-connection requirements designed for conventional power plants — creating a persistent gap between the legal framework and day-to-day practice.

Laws №2046-IX and №4777-IX established the legal status of storage installations and introduced a netting principle: transmission, distribution and dispatch tariffs are calculated on the monthly balance of energy drawn from and returned to the grid. If a battery draws 100 MWh from the grid and returns 80 MWh, tariffs are charged only on the net difference of 20 MWh — provided metering is properly configured to track both flows separately.

The AIN study identified three recurring obstacles in practice:

• Metering and billing: not all DSOs have set up net-settlement procedures, and the monthly calculation cycle does not align with daily charge-discharge patterns.
• Grid connection: storage projects face requirements designed for large generation facilities, including mandatory reservation of excess capacity.
• Ambiguous legal status: a storage operator may simultaneously qualify as a consumer, generator or ancillary-service provider, complicating investment payback projections.

Lawyers cited in the research advise negotiating and documenting connection and billing terms with the local DSO before any equipment is installed. An alternative approach is integrating the battery with on-site solar generation: consuming stored energy locally, without exporting to the external grid, removes the risk of disputed tariff charges.

Resolving these inconsistencies will require NEURC — Ukraine’s energy and utilities regulator — to harmonise its secondary legislation, including metering rules, tariff methodologies and the Distribution System Code.

Source: AIN.UA