The number of unfulfilled indicators in Ukraine’s Plan, which underpin the European Union’s financial support under the Ukraine Facility and, partially, the Ukraine Support Loan programs, continues to grow. Their combined “cost” has reached EUR 7.35 billion, according to the July Monitoring of the IMF and EU Aid Program by the RRR4U think tank consortium.
“Debt indicators are a rather sensitive issue: they are accumulating, and at this point, this could cost us around EUR 7.4 billion,” said Aliona Korohod, a project expert at DiXi Group, at the Monitoring presentation.
According to the presentation, eight commitments for 2025, worth a total of EUR 1.93 billion, have not yet been fulfilled, including amendments to the civil service legislation (bill no. 13478-1); conducting the next National Risk Assessment; assessing and, if necessary, amending the distinction between PSOs and non-PSOs in state-owned companies (no. 13620); lifting the suspension of the state aid law (no. 14345); improving licensing procedures for investments in renewable energy (no. 14271); appointing a nominated electricity market operator and determining the special status of the National Commission for State Regulation of Energy and Public Utilities.
Korohod specifically highlighted indicator 4.3, which concerns increasing the staffing of the High Anti-Corruption Court (HACC), as the deadline for this is already overdue by more than a year, threatening the irreversible loss of EUR 280 million in funding.
At the same time, former Deputy Prime Minister for European Integration Taras Kachka assured that this funding will be received, as this obligation is already being fulfilled, and the delay was due to objective reasons, including the inflated selection requirements agreed upon with donors.
According to a DiXi Group expert, four indicators worth a total of EUR 2.3 billion have not been met since the first quarter of 2026: the launch and use of a human resources management information system; legislation on simplified insolvency procedures for MSMEs (No. 15024); the introduction of transparent selection of prosecutors for leadership positions (No. 15343); and the Strategy for the Implementation of Circular Economy Principles and the Action Plan for its Implementation.
Korohod clarified that the human resources management information system is already operational, but it remains to be seen whether this indicator is fully met. Legislative drafts have been prepared but have yet to be adopted. Regarding the Strategy for the Implementation of Circular Economy Principles and the Action Plan for its implementation, the draft document has already undergone public consultations but has not yet been approved.
Back in the first quarter of 2026, we had an indicator of 9.3, concerning the distribution of powers between levels of government, but it was postponed.
“Moving closer to the present, the second quarter of 2026 has also ended, and here we have at least seven unmet indicators, which are currently costing us EUR 3.12 billion,” the expert continued. She noted that in addition to these, there are four other investment indicators: in education – from EUR 300 million, in healthcare from EUR 200 million, in housing for veterans from EUR 200 million, and 5% grant support for the restoration of communities, but there have been long-standing discussions about how to correctly calculate their implementation.
Oleksandra Betliy, a leading expert at the Institute for Economic Research and Policy Consulting, added that the change in government further exacerbated the situation with meeting the indicators, as all government bills that failed to pass their first readings were withdrawn as a result, even though some of them were included in the Ukraine Plan.
“In fact, if you look at the map (of indicator implementation), the situation looks very, very dire. If you recall our first monitoring reports, all the indicators were green, meaning they were completed on time. Then, slightly yellowish ones began to appear, meaning they were completed late. Now, our map is like a Christmas tree: all these colorful ornaments are just here,” Korohod stated.
Betliy emphasized that such a buildup of unfulfilled indicators is dangerous, as approximately fifty more indicators need to be met in the third and fourth quarters of this year. This number has increased due to new funding under the Ukraine Support Loan program, amounting to EUR 8 billion this year.
Korohod recalled that during the revision of Ukraine’s Plan completed in late July, 27 indicators were added, 10 of which will require legislative action, bringing the total number to 173 from 146.
“All final reforms must be completed by the third quarter of 2027, as Ukraine still must report on the implementation of reforms for the last quarter and receive funding by the end of 2027,” the DiXi Group expert noted.
However, Taras Kachka, whose appointment as Ukraine’s representative to the EU is expected soon, urged against overdramatizing the situation and expressed confidence that all commitments will be fulfilled.
“If the world had listened to experts, we would have become extinct like dinosaurs. Because your point of view is always skeptical: they missed something, something didn’t work out there, something else… Everything will be fine, because that’s how it was before,” the former deputy prime minister noted.
He emphasized that all targets had been met so far, and all EU funding had been received, because they had always been able to reach agreement and resolve contentious issues.
“And in this sense, we are no different from any other EU member state. Because they have the same logic: the funding mechanism is always money in exchange for reforms, and there is always a certain updating, a recalibration of what works and what doesn’t,” Kachka explained.
“In fact, all previous experience shows that no matter how difficult the deadlines and complex the targets, they are always met. Even if there is a slight delay, they are essentially still met,” he concluded.