Failure to meet nine indicators in Q4 2025 under the Ukraine Facility program could result in a loss of €2.3 billion under the program, according to a presentation by the #RRR4U Consortium on the implementation of program indicators.
According to the published presentation, for October-December 2025, the list of unfulfilled indicators includes amendments to the legislation on civil service, the repeal of the suspension of the law on state aid, the entry into force of the law “On the Basic Principles of Housing Policy,” deregulation in certain sectors, and improvement of licensing procedures for investments in renewable energy sources (RES).
This list also includes the appointment of a nominated electricity market operator, the determination of the special status of the National Commission for State Regulation in Energy and Utilities (NKREKP), support for the development of efficient and more sustainable centralized heat supply, and the entry into force of the law on traffic safety and interoperability of rail transport.
In addition, indicators from previous periods of 2025 remain unfulfilled: from the first quarter – an increase in the staff of the High Anti-Corruption Court (HACC) (the estimated cost of the unfulfilled indicator is EUR 0.3 billion), in the second quarter – changes regarding the review of judges’ integrity declarations and their verification, and the reform of the digitization of enforcement proceedings (EUR 0.7 billion), in the third quarter – the adoption of legislation for the electricity integration package (EUR 0.3 billion).
According to the information in the presentation, Ukraine’s failure to meet the indicators cost it EUR 3.6 billion for the whole year.
Ukraine Facility is a EUR 50 billion EU financial support program for Ukraine aimed at macroeconomic stability, modernization, reconstruction, and acceleration of Ukraine’s European integration in 2024-2027. Funding is provided in tranches after Ukraine confirms that it has met the agreed structural indicators. After August this year, Ukraine’s Plan was updated compared to its initial version two years ago.
The total amount of assistance to Ukraine under the Ukraine Facility, which has been allocated since March 2024, is EUR 26.8 billion, which corresponds to almost 70% of the funds available under the first component of the Ukraine Facility. The last tranche from the European Commission was received on December 22 in the amount of EUR 2.3 billion.
The Council of the European Union has approved the fourth tranche of the Ukraine Facility program in the amount of more than EUR3.2bn, while its size was previously determined at around EUR3.05bn.
“The objective is to support Ukraine’s macro-financial stability as well as its recovery, reconstruction and modernization,” the EU Council said in a statement.
As reported, the size of the tranche was reduced from the planned EUR4.5bn due to delays in the implementation of 3 out of 16 indicators that Kiev had to fulfill according to the Ukraine Facility’s Ukraine Plan: the laws on the territorial organization of executive power (the so-called “decentralization reform”) and on the ARMA reform, as well as the selection of 25 judges for the Supreme Anti-Corruption Court in a competition in which only 2 candidates reached the finish line.
At the same time, the head of the Economy Ministry, Oleksiy Sobolev, noted that Ukraine will fulfill two of the three indicators (laws) before September, which will make it possible to receive EUR1.1bn tentatively in early November
As the Ministry of Finance of Ukraine reminded, in general, the state budget has already received EUR19.6bn within the framework of the Ukraine Facility program, the total amount of which is EUR50bn. In 2025 alone, about EUR12.5bn of financial support for Ukraine is envisaged, of which EUR3.5bn has already been attracted.
The European Union remains the largest donor of budget support for Ukraine – EUR53.5bn over more than three years, the Finance Ministry also noted.
