I have some experience working with optimization schemes in the management of Energoatom and the structures of individual nuclear power plants (NPPs). Therefore, I will try to explain why the Supervisory Board is stalling, why independent members left it, and what needs to be done to fix the situation. At first glance, Energoatom is a successful and balanced organization with significant potential. But that is only at first glance. Beneath the surface lie years of simplified decisions, wrong appointments, and worn-out equipment. And all of this is happening against the backdrop of a full-scale war.
Section I. The Legal Trap: When the Statute Becomes a Problem
The current Statute of JSC Energoatom was approved by the Cabinet of Ministers of Ukraine (CMU) on August 15, 2025. It defines a two-tier management system: a supervisory board and a management board—both collegial bodies of seven people each in peacetime. This model functions in many countries. However, it has a fundamental vulnerability: within the management board, personal responsibility for nuclear and radiation safety is diluted. When everyone is responsible together, no one is responsible.
The Statute does not clearly separate powers, nor does it distinguish between the structure that defines rules and limitations and the structure that acts as the operational executor within those defined limits. Furthermore, the Statute contains a direct conflict of interest between the powers of the Supervisory Board and the Management Board. The Supervisory Board decides on the creation and liquidation of separate units (branches), but it is the Management Board that approves the general organizational structure. This is not a technical inaccuracy. This is an institutional trap that paralyzes managerial decisions and generates legally void actions that frustrate nuclear professionals.
There is another striking detail. The Statute stipulates that during martial law, the Management Board is reduced from seven to five members. The logic behind this decision is unclear. Does this mean that the workload on the body decreases? On the contrary: the company operates under constant shelling, ruined power grids, and critical responsibility to the country's energy system. Yet, managerial resources are reduced.
Although the Supervisory Board is tasked with developing structures and appointing specialists in the field of anti-corruption activities, it does not have the right to appoint or dismiss Energoatom employees, even those against whom there are grounds for conducting official investigations—this is the exclusive competence of the Management Board. When the Supervisory Board still tries to interfere in these matters, it violates the Statute. That is why the Management Board does not execute protocol decisions.
Section II. The Letter of Expectations: The CMU Has Disconnected from Reality
The Owner's Letter of Expectations is a document by which the CMU, as a shareholder, formulates the requirements for the company's activities. It was approved on October 1, 2025. And already at the level of this document, it is evident that there is a lack of professional goal-setting for the reporting period, considering the actual state of affairs.
The letter sets financial indicators that are impossible to evaluate. At the same time, key non-financial indicators—electricity generation, supply, and the capacity factor—are completely missing. Instead, there is a requirement: 100% electricity supply. One hundred percent of what? Where is the forecasted supply in megawatt-hours, tied to the real state of the power grids and to the consumption schedules of an energy system that has been living under constant strikes since 2022? There is nothing of the sort in the document.
The word "war" appears in the letter of expectations only in the context of justifying the low percentage of investment program execution and 100% provision of measures stipulated by safety passports and facility protection plans, which implement exclusively passive defense. In other words, the state as an owner realizes that the war affects the operation of NPPs, but does not consider it necessary to account for it when planning electricity production and supply. This is not just inconsistency. It is a detachment from reality that carries direct risks.
The General Meeting (CMU) formally fulfills its role as a shareholder: it defines profitability ratios, liquidity, and profit distribution to the state. Part of the requirements regarding corporate governance is formulated reasonably well. But when financial indicators are disconnected from operational realities, this entire construct turns into paper reporting devoid of managerial substance.
Section III. Roadmap: What Must Be Done Immediately
The crisis in Energoatom is not developing in a vacuum. The 2026–2027 winter heating season lies ahead. Interaction between government agencies and Energoatom is already unstable. The situation is worsened by the fact that the Acting Chairman of the Management Board and the Management Board themselves have taken an adversarial stance against the Supervisory Board. In wartime conditions, this translates into a paralysis of management.
There are things that need to be done urgently:
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Dismiss the current Acting Chairman of the Management Board and appoint all missing acting members of the Management Board from among specialists capable of obtaining the necessary licenses from the State Nuclear Regulatory Inspectorate of Ukraine (SNRIU) in a short timeframe.
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Provide the Supervisory Board with real advisory support. The current composition lacks sufficient competence in the existing regulatory framework, which is one of the main reasons why the board is stalling.
Parallel to this, systemic regulatory work is required. The current Statute must be rewritten: duplication of powers must be eliminated, the competencies of the Supervisory Board and the Management Board must be clearly separated, and the personal responsibility of each Management Board member must be specified, as is done in the vast majority of nuclear companies worldwide. Separately, the Regulations on the Management Board and the Regulations on Energoatom must be developed and approved.
Regarding the structure of the Management Board, logic suggests the following configuration: a chairman and six heads of functional areas (effectively, executive directors). These areas correspond to the main processes of the company's activities: administrative management, production processes, safety, human resources, material resources, economics, and finance. The first three leaders—those responsible for safety—must hold an SNRIU license. It was under this exact structure that Energoatom passed ISO certification.
Finally, new members of the Supervisory Board must be elected and appointed, as it is impossible to appoint permanent members of the Management Board (which requires a three-quarters majority vote) until new Supervisory Board members are elected. Afterward, a transparent competition for the election of the company's Management Board must be conducted and completed. This is the minimum necessary step to stabilize the situation.
Ukraine's nuclear energy sector is not an area where one can afford to wait. Temporary staffing decisions, the Statute, regulations—all of this must be resolved in a short timeframe, preferably before the start of the autumn-winter heating period. Otherwise, the price of managerial irresponsibility may extend far beyond a corporate conflict.
