Legal ensure of transparency of data on wholesale energy products .

Abstract

Transparency of the market of wholesale energy products is a necessary component of its stability, even under the martial
law in Ukraine. Digital technologies for processing data on the wholesale energy products market in Ukraine will accelerate
adaptation to constant threats from russia and other unfriendly states, reduce price manipulation and abuse of insider
information. The architecture of data processing in the form of a single trade repository, a taxonomy of reporting
and a single data format agreed between regulators will optimize resources for creating and administering reports
on wholesale energy products: reducing the burden on the regulators' maintenance budget, a single methodology
for training traders and investment firms, operators of trading platforms. Oversight of the market operations and competition
protection also requires an active exchange of information and simultaneous access to the save or overlapping data. Such
an exchange of data and availability of the reported informations in the compatible format will facilitate cooperation
between Ukrainian industry regulators and a competition watchdog as well as with the regulatory authorities of the Energy
Community Member States. On a different note, smart architecture of the data collection, with an open code and modular
composition make Ukraine ready for expansion of the wholesale energy products list; such a list should include, as soon
as practicable, decarbonization tools, in particular, hydrogen, "green" certificates and emission permits. Data safety
and security considerations must be accounted for through consultations with the standard setting authority for digital
economy and data encryption as well as relevant security agencies and law-enforcement authorities, including intelligence
community that can advise on the duration of the silent safety period. Subsantive measures must include physical protection
of the materials from machine copying and photographing or video recording, whereas the electronic telecommunications
channels must be encrypted and have physical surveillance per advice of the State Service of Special Communications
and Information Protection of Ukraine and the National Police Unit for Combatting Cyber Crimes (СyberPolice).
On top of said measures, the data can be released to the public later in order to mitigate the threat of the immediate release
of collected information.