This paper analyses the issues of regulatory reform in the energy industry of post- Soviet countries. We identify the characteristics of the transformation that these countries go through: it is the introduction of a) a new legal culture and b) a capitalist rationality of production in societies embedded in a post-Soviet institutional context. We identify existing models to which these countries' regulations could adhere. Though the industries claim to adopt an Anglo-Saxon approach, one observes in reality the emergence of a specific, post-Soviet regulatory model, characterized by the legalisation of the quasi-proprietorial rights factually enjoyed by new political and economic elites. We review some specific aspects of regulatory reform in the energy sector in Russia, Ukraine, Kazakstan and Azerbaijan. We conclude that foreign investors, politicians and advisors have to adjust to the post-Soviet reality if they want to have a lasting impact.