Net billing for business: how Ukraine's self-production mechanism works in 2026
Author: Sviatoslav Yurdyk, quality engineer at LK Energy Group.
Factory acceptance of equipment and site supervision of electrical installation works, including industrial solar plants and storage systems.
Short answer
Net billing — the self-production mechanism under Ukrainian law — is the sale of the surplus electricity your plant exports to the grid, under a sale-and-purchase contract that is an annex to your existing supply contract [Law of Ukraine «On the Electricity Market» No. 2019-VIII, Art. 58-1, para. 1(3)]. Settlement is an hourly netting of the value of exported and consumed electricity, not of kilowatt-hours [Procedure approved by NEURC Resolution No. 2651 of 29.12.2023, cl. 4.1]. For a business this is a mechanism that offsets the bill, not a separate source of income: the price changes every hour.
As of 6 September 2026 the framework rests on three acts: the Law as amended on 26.07.2026, the Distribution System Code (NEURC Resolution No. 310) as amended on 01.09.2026, and the Procedure for the sale and metering of electricity of active consumers (NEURC Resolution No. 2651) as amended on 13.08.2026. The last two amendments date from August, so most online overviews still describe rules that are no longer in force.
What has changed compared with what you read online
- «The 50 % limit is set by cl. 4.12.1 of the Code» is no longer true. The figure was removed from cl. 4.12.1 [as amended by NEURC Resolution No. 1355 of 11.08.2026]: it now says that the value is set «at the level determined by applicable law», and the exact figure is stated by the distribution system operator (DSO) in the connection point passport [cl. 4.12.1, para. 9]. The 50 % itself remains in cl. 4.13.1 [para. 13] and is addressed to an active consumer under the self-production mechanism, other than household and small non-household consumers. This is a collision between two chapters, not a lifting of the limit: plan on 50 %.
- There is no rule that «above 1 MW you lose active consumer status» — it disappeared with the amendments of 14.01.2025 (Law No. 4213-IX), yet secondary sources keep repeating it.
- The mechanism has no expiry date: Art. 58-1 sets neither an end date nor a termination condition.
Who is eligible and what the capacity limits are
The limits are in Art. 58-1, para. 2 of the Law:
| Category | Maximum installed capacity of the generating unit |
|---|---|
| Private households | within the permitted (contracted) capacity, but no more than 30 kW |
| Small non-household consumers | within the permitted (contracted) capacity, but no more than 50 kW |
| Non-household consumers (businesses) | within the permitted (contracted) capacity; the law sets no separate ceiling in kilowatts |
Two rules from the same paragraph that are often missed:
- capacity is measured by the rated capacity of the inverter equipment operating in parallel with the power system;
- the total capacity of generating units and of storage units — each separately — may not exceed the capacity permitted for consumption under the connection contract.
🔑 What this means in practice. The constraint is not an abstract ceiling in kilowatts but your own contracted capacity and the rating of your inverters. That is why sizing a plant starts with the connection contract, not with the roof area.
How much you may export
- Households and small non-household consumers — within the full permitted (contracted) capacity [Code, cl. 4.12.1, para. 11].
- Non-household consumers — plan on 50 % of the permitted (contracted) capacity [cl. 4.13.1, para. 13]; the figure was removed from cl. 4.12.1 [NEURC Resolution No. 1355 of 11.08.2026], and the exact value is stated by the DSO in the connection point passport after the procedure of chapter 4.12 [cl. 4.12.1, para. 9].
- Third-party units count together with yours — the same value covers generating and storage units of third parties connected to the active consumer's networks [Code, cl. 4.13.1, para. 13].
- To raise the limit you must meet the technical requirements stated by the DSO in the connection technical conditions and obtain the connection service [cl. 4.12.1, para. 10].
Exceeding the permitted export capacity is sanctioned under the Retail Electricity Market Rules (NEURC Resolution No. 312).
At what price the surplus is credited
The most common mistake in overviews is «you will sell at the day-ahead price» — that is true only for some.
The universal service provider buys the surplus at the day-ahead market price of the settlement period (hour). An electricity supplier that is not a universal service provider buys at free (negotiated) prices [Procedure No. 2651, cl. 3.3]: for most businesses this means the buy-back price is contractual and has to be agreed with the supplier.
The export volume also includes electricity from generating units of third parties connected to the active consumer's networks, provided that the active consumer buys all of that volume.
When you get the money
Netting is hourly and by value, based on the metering system installed at the site [cl. 4.1]. The month is then settled [cl. 4.2]:
- if consumption is worth more than exports, the consumer pays the difference;
- if exports are worth more, the difference is credited to the personal account and is payable by the supplier by the 15th day of the month following the settlement month (paragraph added by NEURC Resolution No. 1360 of 11.08.2026);
- by mutual agreement the parties may settle without netting.
Licence and storage
No licence is required up to 5 MW of installed capacity at a single metering site: this counts as generation «for own needs» [Art. 58-1, para. 9]. The same threshold applies to storage.
An energy storage unit operates without a storage licence if its capacity does not exceed the consumer's permitted capacity [para. 5]. Transmission and distribution charges for the owner of a storage unit are calculated separately: on the consumption volume and on the modulus of the monthly difference between the unit's withdrawal and export [para. 10].
🔴 A trap worth knowing before design. A storage unit is connected inside your own internal networks without obtaining a connection service [Code, cl. 4.13.1], but the right applies only if at any point in time the consumption capacity — including electricity drawn by the storage unit — stays within the contracted capacity. In other words, charging the battery counts as your consumption, and the charging window has to be built into the calculation. The installation is accompanied by an application under Annex 12 through the DSO's portal [cl. 4.13.3], technical requirements [cl. 4.13.2], sealing of the equipment [cl. 4.13.4] and the connection point passport [cl. 4.13.5].
What a company needs to start
- Contract: a sale-and-purchase contract under the self-production mechanism as an annex to the supply contract; the buyer is the universal service provider or another electricity supplier [Art. 58-1, paras. 1(3) and 3].
- Capacity: check the installed capacity of the plant (by inverters) and of the storage unit against the capacity permitted by the connection contract.
- Metering: bidirectional commercial metering with hourly data — netting is hourly.
- Export limit: plan on 50 % of the permitted (contracted) capacity [cl. 4.13.1, para. 13] and ask the DSO for the exact figure from the connection point passport [cl. 4.12.1, para. 9].
- Load profile: record the hourly load curve — it determines how much energy you use on site and how much you export at a variable price.
Frequently asked questions
How does net billing differ from the feed-in («green») tariff?
They are different mechanisms: a different buyer, a different price and different rules. Under the self-production mechanism the surplus is sold under an annex to the supply contract, and settlement is hourly netting of value [Art. 58-1; Procedure No. 2651, cl. 4.1].
How many kilowatts may a business install?
The law sets no separate ceiling in kilowatts for non-household consumers: the only limit is that the installed capacity stays within the permitted (contracted) capacity, measured by the inverter rating [Art. 58-1, para. 2]. The 30 kW and 50 kW thresholds apply to households and small non-household consumers. How much of that capacity may be exported is a separate question, governed by the 50 % limit [cl. 4.13.1, para. 13].
How much may be exported to the grid?
Plan on 50 % of the permitted (contracted) capacity [cl. 4.13.1, para. 13]: the rule is addressed to an active consumer under the self-production mechanism other than household and small non-household consumers, and third-party units count towards the same value. The figure was removed from cl. 4.12.1 [Resolution No. 1355 of 11.08.2026], so the exact value is stated by the DSO in the connection point passport [cl. 4.12.1, para. 9]. Households and small non-household consumers export within their full permitted capacity [cl. 4.12.1, para. 11].
At what price is the surplus credited and when is it paid?
The universal service provider pays the day-ahead price of the relevant hour; any other supplier pays free (negotiated) prices [Procedure No. 2651, cl. 3.3]. If exports are worth more than consumption over the month, the difference is credited to the personal account and paid by the 15th day of the following month [cl. 4.2].
Is a licence required?
No, provided the installed capacity at a single metering site does not exceed 5 MW — this is generation «for own needs» [Art. 58-1, para. 9]. The same threshold applies to energy storage.
What we do
We design and build solar plants and storage systems, manufacture switchgear at our own factory in Odesa and deliver projects turnkey. We size the plant against your hourly load profile, prepare the document set for the DSO and provide bidirectional metering.
- Industrial solar plants from 500 kW
- 30 kW solar plant for business
- Containerised storage systems (BESS)
This material is for information only and is neither an offer nor legal advice. The rules are stated as of 6 September 2026 with references to clauses of the versions in force; NEURC amends these acts frequently — always check the official text at the source.
See also
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