Ukrainian authorities have met overdue benchmarks to unlock €418 million ($485 million) under the EU’s Ukraine facility, but persistent delays in structural reforms continue to threaten billions of dollars in vital international financial assistance.
According to the August 2026 Monitoring Report published by the RRR4U coalition, Kyiv is navigating critical bottlenecks across three major donor pipelines, creating severe risks for the national budget despite recent policy breakthroughs.
The most recent €418 million ($485 million) disbursement from Brussels was authorized after Kyiv finalized the delayed appointment of judges to the High Anti-Corruption Court and designated an electricity market operator.
However, Ukraine still faces 14 unfulfilled reform indicators spanning late 2025 through mid-2026, leaving €4.8 billion ($5.57 billion) in macro-financial assistance frozen. The outstanding benchmarks require:
The six outstanding commitments (2025) include:
- Amendments to the legislation on civil service (No. 13478-1)
- Conducting the next national risk assessment
- Assessment and, if necessary, changes to distinguish PSO (Public Service Obligation) from non-PSO in state enterprises (No. 13620)
- Repeal of the suspension of the Law on State Aid (No. 14345 - withdrawn)
- Improvement of permitting procedures for investments in RES (No. 14271)
- Determination of the special status of the National Commission for State Regulation of Energy and Public Utilities (NEURC) (No. 14282)
After RRR4U published their latest monitoring, Ukraine’s Ministry of Finance published the previously unfulfilled benchmark. According to the ministry, on August 31, Ukraine’s AML/CFT Council approved its fourth National Risk Assessment report.
The three indicators without progress (Q1 2026) worth €1.3 billion ($1.51 billion) include:
- Legislation on simplified insolvency procedures for micro, small, and medium-sized enterprises (No. 15024)
- Introduction of a transparent selection procedure for prosecutors to senior positions (No. 15343)
- Strategy for implementing principles of the circular economy and action plan for its implementation
The five unfulfilled indicators (Q2 2026) worth €1.76 billion ($2.04 billion) include:
- Human rights protection strategy
- State program to combat human trafficking until 2030
- Supervisory boards of state-owned enterprises with a majority of independent members
- Roadmap for the gradual liberalization of the gas and electricity market
- Terms of reference for the external audit of NEURC
In cooperation with the International Monetary Fund (IMF), Ukraine met its June structural benchmarks on state bank strategies and third-party risk oversight of the financial sector, but missed several August deadlines.
Unfulfilled targets face varying delays: legislation on the elimination of tax-free limits on postal imports is awaiting the president’s signature, proposals on digital platform taxation are pending a second reading in parliament, and transfer pricing reforms were only recently submitted to parliament by the government.
These backlogs jeopardize the upcoming second review under the Extended Fund Facility, which controls a $692.4 million arrangement.
Meanwhile, progress remains sluggish on the World Bank’s DPO-2 program. Kyiv has yet to fulfill 12 policy commitments across private sector financing, labor market integration, and cross-border regulatory alignment, which are required to release a $1 billion loan component.