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.
