Bridging the Gaps: A Comparative Analysis of Ukrainian and European Experiences in Municipal Energy Development
The full-scale war and the destruction of energy infrastructure have turned the development of local energy systems into a key prerequisite for the resilience of Ukrainian communities. At the same time, European integration requires aligning national decisions with the acquis communautaire in the energy sector, which highlights the need to define the regulatory and operational compliance of Ukraine’s models of municipal energy development. The aim of the study is a comparative analysis of models of municipal energy development in the EU and Ukraine to identify points of functional alignment, key gaps, and priority areas for harmonization. The methodology is based on functional, comparative-legal, and systems analyses of EU and Ukrainian regulations, typology of models of municipal energy development, and the construction of a compliance matrix. The study systematized 12 European and 9 Ukrainian models of municipal energy development. Based on functional criteria, the models were identified as individual and collective participation, spatial integration, market coordination, and social distribution; by levels, the models were classified according to the legal status of the entity, network and organizational integration, and market monetization. A high correspondence was found between Ukrainian active consumer and aggregation models and the overall European ones; partial correspondence was seen in direct line models, small distribution systems, and flexible connection; low correspondence was found in the public energy association model. The main gaps are related to the lack of energy sharing, renewables acceleration areas, digital permitting processes, a municipal long-term contracting model, and proper protection of energy-poor consumers. The scientific novelty lies in the development of a functional typology and a correspondence matrix for models of municipal energy development. The practical value is in identifying priorities for the development of the municipal energy cycle — from spatial planning and connection to joint use, market energy sales, and social benefit distribution.