For years, Ukraine has received financial assistance from the International Monetary Fund (IMF), provided under agreements between the Fund and Ukraine. Disbursements are made based on the fulfillment of structural benchmarks set out in the Memorandum — reforms and changes intended to strengthen Ukraine.Under the current program (which is effectively no longer operational), there were as many as eight (!) reviews. This was explained both by the fact that “we desperately needed the money” and by the IMF’s increased flexibility, as it postponed many structural benchmarks that Ukraine failed to complete on time.Since the program no longer met current needs, discussions about a new program began in autumn 2025. A staff-level agreement was reached at the end of November 2025.The key point: the IMF Executive Board must approve the program, but only after Ukraine implements prior actions. This time, those include:
- submitting a draft law introducing VAT for simplified taxation entrepreneurs,
- adopting legislation on taxation of digital platforms,
- abolishing tax exemptions for small parcels.
The Ukrainian authorities agreed to these conditions, but implementation delays have emerged again — and as a result, the new program is being postponed.Moreover, monitoring shows that Ukraine is also failing to meet existing structural benchmarks (which is important because they will not disappear — they will carry over into the new program).
Ukraine Facility
Another key document defining Ukraine’s commitments since 2024 is the Ukraine Plan, adopted by the Cabinet of Ministers. It includes numerous reforms, policy changes, and structural measures needed for Ukraine’s resilience and development.The reforms and changes defined in the Ukraine Plan serve as indicators under the EU’s support mechanism known as the Ukraine Facility, whose first pillar — budget support — amounts to €38 billion.Ukraine receives funds under this mechanism quarterly, but only upon meeting the agreed indicators. And this is where problems arise.Since early 2025, together with colleagues from RRR4U, we have regularly recorded delays in fulfilling various indicators. These indicators vary widely in complexity, significance, and responsible institutions.As of the end of January 2026, unfulfilled indicators have already cost the state nearly €3.9 billion — funds urgently needed to finance budget expenditures.Since the first quarter of 2025, one unresolved issue has been the increase in the number of judges at the High Anti-Corruption Court. This has not yet been completed, although the process continues.It is critical to complete this by the end of Q1 2026; otherwise, Ukraine will permanently lose approximately €300 million (arrears must be cleared within one year).In the next two quarters of 2025, three additional indicators worth €1.2 billion were also not fulfilled:
- 3.5. Amendments regarding integrity declarations of judges and their verification.
- 3.8. Reform of digitalization of enforcement proceedings.
- 10.5. Adoption of legislation for the electricity integration package.
The situation worsened further in Q4 2025, when numerous indicators — most of them legislative acts — were not fulfilled. Importantly, the requirement is not just submitting draft laws to parliament but ensuring their entry into force.This means:
- the government must submit them on time (which does not always happen),
- parliament must review and adopt them in two readings (which is far from guaranteed),
- and the president must promptly sign them (delays also occur).
So what remains pending?
- 1.2. Amendments to civil service legislation.
- 6.7. Assessment and, if necessary, revision of special public service obligations (PSOs) in state-owned enterprises.
- 6.9. Repeal of the suspension of the state aid law.
- 7.8. Entry into force of the Law “On the Basic Principles of Housing Policy” (adopted and sent for presidential signature on January 19; according to the Presidential Office it has been signed, but as of February 6 this is not reflected on parliament’s website).
- 8.2. Deregulation in certain sectors.
- 10.3. Improvement of permitting procedures for renewable energy investments.
- 10.7. Appointment of the nominated electricity market operator.
- 10.11. Determination of the special status of the National Energy and Utilities Regulatory Commission (NEURC).
- 10.14. Support for the development of efficient and more resilient district heating.
- 11.3. Entry into force of the law on railway safety and interoperability.
It is also evident that several indicators for Q1 2026 are unlikely to be fulfilled on time.
Why This Matters Now
Poor implementation of indicators also directly affects Ukraine’s EU integration prospects.Most EU member states are closely monitoring our reform implementation. A lack of progress strengthens the position of skeptics regarding Ukraine’s accession “What kind of EU integration are we talking about if Ukraine cannot even implement these reforms on time?”
That is why it is crucial for all branches of government to finally understand: timely fulfillment of commitments is essential not only for Ukraine’s macroeconomic stability but also for our EU membership.
Read the full article on the “European Pravda” website.
