Early Warning System

Countries

Ukraine

Geographic location where the impacts of the investment may be experienced.

Financial Institutions

European Bank for Reconstruction and Development (EBRD)

International, regional and national development finance institutions. Many of these banks have a public interest mission, such as poverty reduction.

Project Status

Approved

Stage of the project cycle. Stages vary by development bank and can include: pending, approval, implementation, and closed or completed.

Bank Risk Rating

Environmental and social categorization assessed by the development bank as a measure of the planned project’s environmental and social impacts. A higher risk rating may require more due diligence to limit or avoid harm to people and the environment. For example, "A" or "B" are risk categories where "A" represents the highest amount of risk. Results will include projects that specifically recorded a rating, all other projects are marked ‘U’ for "Undisclosed."

Voting Date

Jul 23, 2025

Date when project documentation and funding is reviewed by the Board for consideration and approval. Some development banks will state a "board date" or "decision date." When funding approval is obtained, the legal documents are accepted and signed, the implementation phase begins.

Borrower

Naftogaz of Ukraine PJSC

A public entity (government or state-owned) provided with funds or financial support to manage and/or implement a project.

Sectors

Energy
Law and Government

The service or industry focus of the investment. A project can have several sectors.

Investment Type(s)

Loan

The categories of the bank investment: loan, grant, guarantee, technical assistance, advisory services, equity and fund.

Investment Amount (USD)

$ 588.67 million

Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Currency conversion note:
Bank reported 500
Converted using 2025-07-23 exchange rate.

Project Cost (USD)

$ 683.51 million

Primary Source

Original disclosure @ EBRD website

Updated in EWS Nov 26, 2025

Disclosed by Bank Nov 26, 2025

Contribute Information
Can you contribute information about this project?
Contact the EWS Team

Project Description

If provided by the financial institution, the Early Warning System Team writes a short summary describing the purported development objective of the project and project components. Review the complete project documentation for a detailed description.

According to the Bank’s website, the project consists of an up to EUR 500 million revolving credit facility to National Joint Stock Company "Naftogaz of Ukraine" ("NAK"). The proposed transaction supports Ukraine's energy security through financing of emergency gas purchases over the next two heating seasons. The loan benefits from partial EU guarantee under the Ukraine Investment Framework. The Bank's financing is complemented by up to EUR 80.6m Norway grant through the EBRD Crisis Response Special Fund.

The strategic importance of the transaction is driven by the energy security objective to ensure uninterrupted gas supply in Ukraine and safeguard vital access to energy for people and communities due to challenges imposed by the war on Ukraine.

Early Warning System Project Analysis

For a project with severe or irreversible impacts to local community and natural resources, the Early Warning System Team may conduct a thorough analysis regarding its potential impacts to human and environmental rights.

Categorised C (2024). The use of proceeds funds emergency gas purchase and therefore the Project definition is limited to the trading activity only. While the purchase of gas does not trigger direct impacts, its transportation and storage may be associated with potential impacts related to routine and accidental gas leaks due to the technical integrity status of the gas pipelines and underground gas storage facilities.

Given the emergency need for this loan, project appraisal relied on results of the previous project's ESDD, which concluded that the Company has the capability of operating it in line with the Bank's ESRs. No ESAP or further ESDD is required.

Investment Description

Here you can find a list of individual development financial institutions that finance the project.

European Bank for Reconstruction and Development (EBRD)

An up to EUR 500 million revolving credit facility.

Private Actors Description

A Private Actor is a non-governmental body or entity that is the borrower or client of a development project, which can include corporations, private equity and banks. This describes the private actors and their roles in relation to the project, when private actor information is disclosed or has been further researched.

NAFTOGAZ OF UKRAINE PJSC - NAK, 100% state-owned vertically integrated oil and gas holding in Ukraine, is the country's largest natural gas producer, importer, wholesale trader and supplier of last resort for the population, district heating utilities, electricity generation and public sector.

Private Actor 1	Private Actor 1 Role	Private Actor 1 Sector	Relation	Private Actor 2	Private Actor 2 Role	Private Actor 2 Sector
-	-	-	-	Naftogaz	Client	-

Contact Information

This section aims to support the local communities and local CSO to get to know which stakeholders are involved in a project with their roles and responsibilities. If available, there may be a complaint office for the respective bank which operates independently to receive and determine violations in policy and practice. Independent Accountability Mechanisms receive and respond to complaints. Most Independent Accountability Mechanisms offer two functions for addressing complaints: dispute resolution and compliance review.

Yaroslav Turianskyi
ngu@naftogaz.com
+380 (44) 5863841
www.naftogaz.com
Bohdana Khmelnitskogo Str. 6 B, Kyiv, Ukraine, 01601

ACCESS TO INFORMATION

You can request information by emailing: accessinfo@ebrd.com or by using this electronic form: https://www.ebrd.com/eform/information-request

ACCOUNTABILITY MECHANISM OF EBRD

The Project Complaint Mechanism (PCM) is the independent complaint mechanism and fact-finding body for people who have been or are likely to be adversely affected by an European Bank for Reconstruction and Development (EBRD)-financed project. If you submit a complaint to the PCM, it may assess compliance with EBRD's own policies and procedures to prevent harm to the environment or communities or it may assist you in resolving the problem that led to the complaint through a dialogue with those implementing the project. Additionally, the PCM has the authority to recommend a project be suspended in the event that harm is imminent.

You can contact the PCM at: pcm@ebrd.com or you can submit a complaint online using an online form at: http://www.ebrd.com/eform/pcm/complaint_form?language=en

You can learn more about the PCM and how to file a complaint at: http://www.ebrd.com/work-with-us/project-finance/project-complaint-mechanism.html