Biomethane in Ukraine Under the 2035 Programme
In April 2026, the Ukrainian Cabinet of Ministers approved the Biomethane Production Development Programme until 2035. It targets more than 1 billion m³ per year by 2030 and approximately 2.1 billion m³ by 2035. Investors and EU buyers should separately verify grid connection, sustainability certification, Biomethane Register requirements, and the status of EU recognition of Ukrainian guarantees of origin.
The programme creates a national roadmap, but it does not replace project-specific permits, technical conditions, land and environmental due diligence, or supply-contract structuring. These issues determine whether a production or cross-border supply model is legally and commercially workable.
This material will be of interest to foreign investors, energy companies, and agricultural or processing groups considering biomethane production in Ukraine; EU buyers, traders, and utilities assessing long-term supply from Ukrainian producers; international financial institutions and project developers financing plants and grid connections; and legal, financial, and technical teams reviewing feedstock, land and environmental requirements, sustainability certification, guarantees of origin, and cross-border supply contracts.
1. Production Targets and Implementation Stages
2. Biomethane Register and Guarantees of Origin
3. Ukraine’s Role in the European Biomethane Market
4. Grid Connection for Biomethane Plants in Ukraine
5. Legal Framework for Biomethane Investments
6. Investor and EU Buyer Due Diligence
Frequently asked questions
How DLF Can Help
1. Production Targets and Implementation Stages
In April 2026, the Cabinet of Ministers adopted the Biomethane Production Development Programme until 2035 and its operational action plan. The programme is a national roadmap combining production targets, legal reform, gas-infrastructure development, and integration with EU renewable-gas markets.
| Stage | Period | Key target |
|---|---|---|
| 1 – Legal and institutional foundation | 2026-2027 | Update renewable-gas legislation, seek access to the EU renewable-gas database, and develop a national certification scheme |
| 2 – Production scale-up | 2028-2030 | Construction of new biomethane plants, connection to the national gas transmission system, implementation of financial instruments, and continued harmonisation of Ukrainian legislation with EU law |
| 3 – Market consolidation | 2031-2035 | Achievement of planned biomethane production volumes, expansion of exports to EU Member States, improvement of biomethane production processes, increased energy efficiency of biomethane production, and introduction of a national biomethane certification scheme |
The action plan separately envisages eight new plants during 2026-2028.
The programme also sets seven strategic objectives, including regulatory development for domestic and external markets, production and feedstock expansion, integration of guarantee-of-origin mechanisms with the EU, and institutional capacity building.
2. Biomethane Register and Guarantees of Origin
The Biomethane Register was launched in February 2026. Its legal basis includes the Law of Ukraine on Alternative Fuels and the government procedure governing the Register.
The Register accounts for biomethane injected into gas transmission or distribution networks and issues guarantees of origin (GoOs). One GoO corresponds to 1 MWh of biomethane. GoOs are created electronically without charge and may be transferred, split, or redeemed. A redeemed GoO cannot be reused.
Key operational parameters:
- reporting for each gas month must follow the deadlines set by the current Register procedure;
- sustainability evidence involves independent audit and certification under a recognised international scheme;
- exports require compliance with customs-declaration and Register-balance rules.
Ukrainian law allows foreign guarantees to be recognised under Ukraine’s applicable international treaties. As of July 2026, mutual recognition of Ukrainian biomethane GoOs in the EU system had not been completed. The programme treats this interoperability as a priority, but physical exports do not by themselves establish full recognition for EU renewable-energy accounting.
Ukraine exported approximately 11.2 million m³ of biomethane to the EU in 2025, demonstrating that cross-border physical supply is operational.
3. Ukraine’s Role in the European Biomethane Market
The IEA notes that the European Union aims to reach 35 billion m³ of biomethane production per year by 2030 under REPowerEU. Its projections indicate combined biogas and biomethane output of around 26 billion m³ by that date, leaving room for additional supply from strategically positioned producers.
Ukraine has approximately 33 million hectares of agricultural land and a substantial feedstock base in agricultural waste and residues. The IEA estimates the country’s theoretical biogas and biomethane potential from waste and residues at about 11.6 billion m³ equivalent per year. Existing gas-transmission links and underground storage further support cross-border supply models.
Project economics remain transaction-specific. Investors should model feedstock costs, connection expenditure, certification, financing, war-risk allocation, and the commercial treatment of GoOs rather than relying on indicative market-price estimates.
4. Grid Connection for Biomethane Plants in Ukraine
Connection requirements under current rules:
- biomethane must meet the quality specifications applicable to natural gas;
- commercial metering and quality-control equipment must comply with the operator’s technical conditions;
- the producer must apply for connection and obtain site-specific technical conditions;
- where biomethane is to reach the transmission system through a distribution network, the rules require the relevant distribution-operator capacity assessment;
- cost allocation follows the applicable code, technical conditions, and connection agreement; the producer pays the connection charge and may bear specific capacity-upgrade costs;
- ownership or use of infrastructure not transferred to the operator must be contractually regulated before commissioning.
Sustainability requirements depend on the feedstock and intended use. The project should verify land-origin restrictions, greenhouse-gas saving requirements, and the applicable certification scheme before construction or contracting.
Connection feasibility and cost are site-specific and should be confirmed directly with the relevant operator before the financial model is finalised.
5. Legal Framework for Biomethane Investments
Ukraine’s biomethane framework has four main layers:
- the Law of Ukraine on Alternative Fuels, which defines biomethane and establishes the Register and GoO regime;
- the government procedure, which governs registration, reporting, audit evidence, transfers, redemption, and export-related Register operations;
- the gas codes, which regulate technical connection and injection;
- the 2035 programme, which sets future legislative, infrastructure, certification, and EU-integration tasks.
For foreign investors, SAEE is central to the Register and GoO process, while NEURC and the relevant network operator govern connection and related charges. The project should not rely on a generic connection-cost assumption: technical conditions and the connection agreement determine the actual allocation for the selected site.
6. Investor and EU Buyer Due Diligence
For investors considering production:
- feedstock availability, long-term supply rights, and sustainability certification;
- land, environmental, construction, and grid-connection requirements;
- technical conditions, connection timetable, and allocation of upgrade costs;
- independent audit and the steps required before GoOs can be issued;
- corporate, tax, financing, and war-risk structure for the Ukrainian project.
For EU buyers and energy traders:
- current status and contractual consequences of Ukraine-EU GoO mutual recognition;
- whether the intended sustainability and mass-balance evidence meets the buyer’s regulatory needs;
- metering, customs documentation, Register accounts, and delivery-point arrangements;
- governing law, sanctions and compliance clauses, force majeure, price review, and dispute resolution.
Frequently asked questions
What is Ukraine’s Biomethane Register and who needs to use it?
The Biomethane Register is an electronic accounting and GoO issuance system launched by the State Agency on Energy Efficiency and Energy Saving in February 2026. It is operated under the Law of Ukraine on Alternative Fuels and the government-approved registry procedure. A producer seeking GoOs must be registered and complete an independent sustainability audit. One guarantee of origin equals 1 MWh of biomethane.
What are the production targets set by Ukraine’s 2035 biomethane programme?
The programme uses 52 million m³ per year as its 2025 baseline and targets more than 1 billion m³ by 2030 and approximately 2.1 billion m³ by 2035. The action plan envisages eight new plants during 2026-2028 and more than EUR 500 million in investment by 2030. Separately, the IEA reported 111 million m³ per year of installed capacity as of March 2026.
Can Ukrainian biomethane be supplied to EU buyers with EU-recognised guarantees of origin?
Ukraine exported approximately 11.2 million m³ of biomethane to the EU in 2025, demonstrating that physical supply is operational. GoOs are issued through the national Biomethane Register. However, mutual recognition of Ukrainian GoOs within the EU system had not been completed as of July 2026. Development of the relevant mechanism remains a priority under the programme.
What are the grid connection requirements for a biomethane producer in Ukraine?
Producers must apply to the relevant network operator, obtain technical conditions, install compliant commercial metering and quality-control equipment, and ensure that biomethane meets natural-gas specifications. Cost allocation is governed by the applicable code and connection agreement; the producer pays the connection charge and may also bear specific capacity-upgrade costs. Conditions depend on the selected connection point.
What sustainability requirements apply to biomethane production in Ukraine?
Sustainability rules cover feedstock origin and greenhouse-gas savings. Producers should confirm that the intended agricultural waste, manure, crop residues, or other inputs comply with Ukrainian law and the relevant certification scheme. The accepted scheme and evidence required for Register operations should be verified with SAEE before the project relies on GoO issuance.
What are the main legal risks for foreign investors entering Ukraine’s biomethane sector?
Key areas for legal review before committing to investment or supply structures:
- Grid connection availability and costs under current NEURC rules
- Sustainability certification scheme requirements
- Timeline for EU–Ukraine GoO mutual recognition
- Investment structure and asset protection under Ukrainian law
- Permanent establishment (PE) risk for foreign companies with substantial operations in Ukraine
- Contract terms for long-term biomethane supply agreements
An individual legal assessment is recommended.
How DLF Can Help
DLF attorneys-at-law supports foreign companies and investors throughout biomethane projects in Ukraine – from corporate structuring, land and regulatory due diligence to grid connection, GoO registration, financing, and cross-border supply contracts. Relevant support is provided through DLF’s renewable energy law and agribusiness practices.
Jurij Dynys, Counsel – DLF attorneys-at-law
Contacts: +380 44 384 24 54, info@dlf.ua.
This material is intended for general information purposes. The application of the approaches described depends on the circumstances of each specific situation and requires a separate legal assessment.