Ukraine fell short of meeting several required benchmarks under two international support programs by the end of September.
Under the four-year, $15.5 billion Extended Fund Facility (EFF) from the International Monetary Fund (IMF), Ukraine has yet to meet three of nine structural benchmarks, including reforms in the rule of law and financial oversight.
Under the EU’s Ukraine Facility program, eight indicators – covering governance, judicial staffing and digital enforcement – remained unfulfilled, according to Reconstruction and Relief for Ukraine (RR4U) at its “Monitoring the Implementation of the IMF Program and EU Assistance, Sept. 2025” report.
Unfulfilled IMF Benchmarks
The IMF is supporting Ukraine through a four-year EFF program approved in March 2023, worth about $15.6 billion.
It is the first IMF program ever granted to a country at war, made possible after the IMF changed its rules to allow lending under “exceptionally high uncertainty,” according to its March 2023 release.
By the end of September, Ukraine had completed four required benchmarks for the EFF on time.
These include “the OLX tax law,” which requires online marketplaces to report and pay taxes on certain transactions; the Budget Declaration, Ukraine’s medium-term fiscal plan; an audit of the National Anti-Corruption Bureau (NABU); and approval of the Single Project Portfolio, a centralized system to track government investment projects.
Two benchmarks were completed with delays: integrity checks of members of the National Securities and Stock Market Commission (NSSMC) and the appointment of the new head to the State Bureau of Economic Security (BEB), according to RRR4U.
The BEB is responsible for tackling financial crimes such as fraud, tax evasion, smuggling and money laundering. The resignation of its previous director in 2023, following major scandals – including allegations that BEB detectives concealed criminal activity – led to the launch of a new appointment process under revised procedures.
One IMF benchmark remains in progress: opening databases of the State Migration Service (DMS) and the State Tax Service (STS) to each other.
Two benchmarks are marked as “not completed”: introducing new approaches to reform the supervisory boards of state-owned enterprises, and repealing the “Lozovyi amendments” while allowing the Specialized Anti-Corruption Prosecutor’s Office (SAPO) to handle extradition and mutual legal assistance requests.
“Lozovy’s amendments” refers to changes to the Criminal Procedure Code of Ukraine in 2018. The changes mostly concerned the terms of pre-trial investigation deadlines and the Law of Ukraine “On Forensic Examination.”
The amendments are named after Ukrainian lawmaker Andriy Lozovy, who served as a lawmaker in 2017.
The law allows criminal investigations to be halted if pre-trial proceedings take too long. Court lawyers and anti-corruption activists say it motivates law enforcement to complete investigations promptly and prevents abuse of businesses through prolonged probes.
However, the deadlines also mean corruption cases – which generally take longer to gather evidence – can be closed before proceeding to trials.
The current IMF program has “very easy benchmarks,” yet some remain unmet, said Maria Repko, the deputy executive director at the Center for Economic Strategy (CES), during the RRR4U presentation.
However, Ukraine is still likely to start a new program with the IMF, she said.
Now, Ukraine is discussing a new IMF program as an option to help address the country’s financing needs.
The size of a new IMF loan has not been formally discussed, but early estimates put it at about $8 billion, Bloomberg reported in September.
“The new IMF program will likely be frontloaded – most of the money will be disbursed at the beginning,” Repko said. “Therefore, the Fund will have the opportunity to set stricter requirements at the start.”
Unfulfilled indicators via the EU Ukraine Facility program
Ukraine also missed eight indicators under the Ukraine Facility, which links EU funding to reforms, RRR4U reported.
The Ukraine Facility is a €50 billion ($58.3 billion) EU financial assistance program, signed in February 2024 and planned for 2024-2027, aimed at supporting the country’s recovery, reconstruction and modernization.
Four indicators slipped in the first two quarters, with four more missed in the third.
They include expanding staffing at the High Anti-Corruption Court (HACC), reforming the executive branch’s territorial structure, overhauling digital enforcement, and filling at least 20% of judicial vacancies.
The map of Ukraine Facility indicators has been updated, and almost all indicators set for next year are currently in progress, according to Vitaliy Nabok, an analyst at the Institute for Analytics and Advocacy, during the RRR4U presentation.
Nabok said two indicators might not be completed on time – namely the implementation of the Roadmap for Reforming Public Investment Management and approving Ukraine’s second Nationally Determined Contribution to the Paris Agreement.
“If these indicators are not adopted on schedule, we will face even greater financial risks and losses under the Ukraine Facility,” Nabok said.
Previously, Finance Minister Serhiy Marchenko told lawmakers that, for 2026, the identified need for external financing currently amounts to $18.1 billion, based on an estimated average annual US dollar exchange rate of Hr. 45.7.
This estimate differs from Ukraine’s central bank, which reported an “unidentified” gap of $12.7 billion for 2026. The central bank does not publish an exchange rate forecast.
Ukraine spends around 60% of its budget on its war effort against Russia and depends heavily on its Western allies to cover pensions, public sector wages and humanitarian programs.