Ettepanek - COM(2026) 307

EN EN

EUROPEAN COMMISSION

Brussels, 17.6.2026

COM(2026) 307 final

2026/0167 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of

the Ukraine Plan

EN 1 EN

2026/0167 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of

the Ukraine Plan

THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Regulation (EU) 2024/792 of the European Parliament and of the Council of

29 February 2024 establishing the Ukraine Facility1, and in particular Article 20(2) thereof,

Having regard to the proposal from the European Commission,

Whereas:

(1) Following the submission of the Ukraine Plan (the ‘Plan’) by Ukraine on 20 March

2024, the Commission proposed its positive assessment to the Council. The Council

approved the positive assessment by Council Implementing Decision

(EU) 2024/14472.

(2) Since the Council’s approval of the Plan, and in accordance with Articles 24 and 25

of Regulation (EU) 2024/792, a sum of EUR 6 000 000 000 has been disbursed to

Ukraine as exceptional bridge financing, and a sum of EUR 1 890 000 000 has been

disbursed to Ukraine in the form of pre-financing representing an advance payment of

7 % of the loan support that Ukraine is eligible to receive under the Plan.

An additional sum of EUR 21 640 176 104 has been disbursed to Ukraine in the first

seven instalments under the Plan, pursuant to Article 26(4) of Regulation

(EU) 2024/792.

(3) On 24 February 2026, the European Parliament and the Council adopted Regulation

(EU) 2026/467 implementing enhanced cooperation on the establishment of the

Ukraine Support Loan for 2026 and 2027.

(4) In accordance with Regulation (EU) 2026/467, by virtue of Council Implementing

Decision (EU) 2026/9193 of 23 April 2026 an assistance in the amount of up to

EUR 45 000 000 000 has been made accessible to Ukraine to assist in the

implementation of the Ukrainian Financing Strategy. That assistance should cover

financing needs identified by Ukraine in the Ukrainian Financing Strategy for the

period up to 31 December 2026.

1 OJ L, 2024/792, 29.2.2024, ELI: http://data.europa.eu/eli/reg/2024/792/oj. 2 Council Implementing Decision (EU) 2024/1447 of 14 May 2024 on the approval of the assessment of

the Ukraine Plan (OJ L, 2024/1447, 24.5.2024, ELI: http://data.europa.eu/eli/dec_impl/2024/1447/oj). 3 Council Implementing Decision (EU) 2026/919 of 23 April 2026 approving assistance to Ukraine in

implementing the Ukrainian Financing Strategy (OJ L, 2026/919, 23.4.2026, ELI:

http://data.europa.eu/eli/dec_impl/2026/919/oj). 

EN 2 EN

(5) Implementing Decision (EU) 2026/919 sets an amount of up to EUR 8 350 000 000

for budget assistance in the form of a loan to be implemented pursuant to Chapter III

of Regulation (EU) 2024/792.

(6) On 12 June 2026, after consulting the Verkhovna Rada, Ukraine proposed

amendments to the Plan pursuant to Article 20(1) of Regulation (EU) 2024/792

(the ‘proposed amendments’), on the grounds that the Plan is partially no longer

achievable because of objective circumstances. The request also takes into account

additional amounts available from the Ukraine Support Loan.

(7) The proposed amendments concern 34 out of the 146 qualitative and quantitative steps

set out in Implementing Decision (EU) 2024/1447 and refer to steps due to be

implemented between Q1 2026 and Q4 2027. For 12 of those steps, Ukraine proposed

extending the initial deadline due to the implementation of these reforms taking more

time than initially anticipated and, especially for reforms requiring primary legislation,

to allow the prioritisation of more urgent reforms. The description of six reform steps

has been amended to correct clerical errors in the wording and to recalibrate the focus

of these reforms. Description or allocations for investment steps were changed in five

cases to react to changed circumstances on the ground caused by the continuation of

Russia’s war of aggression. Two steps were both split into a further two steps, each to

clarify the content and sequencing of these reforms. Two steps were removed and

replaced with new reform steps that significantly altered the scope of these reforms.

One step was deleted as it was not linked to the Union acquis and no longer

considered a priority by Ukraine. Furthermore, their removal was considered

necessary to ensure that legislative time is devoted to reforms considered a higher

priority. Finally, all the steps in Q4 2027 were moved to Q3 2027 to clarify the fact

that Ukraine needs to submit the final payment request under Ukraine Plan earlier, to

allow the disbursement from the Ukraine Facility by 31 December 2027.

(8) The proposed amendments also include the introduction of 27 new qualitative and

quantitative steps, 10 of which require amendments to primary legislation. As recalled

in recital 23 of Regulation (EU) 2026/467, the Ukraine Plan should be updated to

reflect that additional budget assistance. As the additional budget assistance covers

financing needs identified by Ukraine in the Ukrainian Financing Strategy for the

period up to 31 December 2026, the timeline for implementation of the additional

steps spans until 31 December 2026. The additional steps are intended to strengthen

the rule of law and the fight against corruption, while also advancing reforms in areas

relevant to Ukraine’s accession to the Union, including in the energy sector and

gradual market integration.

(9) Consequently, with the proposed amendments, the total number of steps in the Plan

will increase to 172 steps.

(10) In accordance with Article 18 of Regulation (EU) 2024/792, the Commission has

assessed the relevance, comprehensiveness and appropriateness of the proposed

amendments. In carrying out that assessment, the Commission acted, as much as

possible, in cooperation with Ukraine. The Commission assessed in particular whether

the proposed amendments represent a needs-based, comprehensive and adequately

balanced response to the objectives of the Ukraine Facility, whether they contribute to

and are consistent with addressing the relevant challenges identified in the context of

Ukraine’s Union accession path, whether they are consistent with the general

principles of the Ukraine Facility set out in Article 4 of Regulation (EU) 2024/792,

and whether they meet Ukraine’s recovery, reconstruction and modernisation needs.

EN 3 EN

The proposed amendments maintain the Plan’s ambition to contribute to climate

change mitigation and adaptation, to the promotion of the rule of law, to social

objectives and to gender equality and the empowerment of women and girls.

The proposed amendments do not affect the current arrangements for the protection of

the financial interests of the Union. Finally, the Commission has assessed whether the

Verkhovna Rada has been duly consulted in accordance with Ukraine’s national legal

framework, whether the proposed amendments take into consideration, where

appropriate, the inputs of stakeholders, and whether the proposed amendments ensure

that other donors are able to support the Plan’s objectives.

(11) The Commission considers that the proposed amendments do not affect the positive

assessment of the Plan set out in Implementing Decision (EU) 2024/1447 as regards

the Plan’s relevance, comprehensiveness and appropriateness. In its assessment, the

Commission took into account in particular the assessment criteria laid down in

Article 18(3), points (a) to (l), of Regulation (EU) 2024/792.

(12) Pursuant to Article 20(3) of Regulation (EU) 2024/792, the Commission considers that

the proposed amendments are justified.

(13) Following the receipt of the second additional contribution of SEK 2 000 000 000

referred to in Article 2(5) of Implementing Decision (EU) 2024/1447, the final value

in euro of that contribution was determined on the basis of the applicable exchange

rate at the time of transfer. In order to reflect the actual final value, it is appropriate to

adjust the amounts set out in the Annex to that Implementing Decision.

(14) Implementing Decision (EU) 2024/1447 should therefore be amended accordingly.

(15) In light of the situation in Ukraine and in order to ensure continuity in providing

support to Ukraine, this Decision should enter into force as a matter of urgency on the

day of its publication in the Official Journal of the European Union and should apply

from the date of its adoption,

HAS ADOPTED THIS DECISION:

Article 1

Implementing Decision (EU) 2024/1447 is amended as follows:

(1) Article 1, the first sentence is replaced by the following:

‘Article 1

Approval of the assessment of the Ukraine Plan

The Commission assessment of the Ukraine Plan, on the basis of the criteria set out in

Article 18 of Regulation (EU) 2024/792, is approved.’

(2) the Annex is replaced by the text set out in the Annex to this Decision.

EN 4 EN

Article 2

This Decision shall enter into force on the date of its publication in the Official Journal of the

European Union.

It shall apply from the date of its adoption.

Done at Brussels,

For the Council

The President

EN EN

EUROPEAN COMMISSION

Brussels, 17.6.2026

COM(2026) 307 final

ANNEX

ANNEX

to the

Proposal for a COUNCIL IMPLEMENTING DECISION

amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of

the Ukraine Plan

1

ANNEX

‘ANNEX

FINANCIAL SUPPORT UNDER THE UKRAINE PLAN

The instalments referred to in Article 19(.2), point (c) of Regulation (EU) 2024/792 shall be organised in the

following manner, considering also the indicative maximum annual amounts as provided by the Regulation:

First instalment (Q2-2024)

Total amount: EUR 4 365 691 244

Non-repayable support: EUR 1 500 000 000

Loans: EUR 2 865 691 244

Total number of steps: 9

Sequential

number

Reform/Investment Name of the step

2.2 C2.R1 Improved revenue

management

Adoption of the strategic plan for the digitalisation of

the State Customs Service

2.3 C2.R2 Improved public financial

management

Approval of the Budget Declaration for 2025-2027

2.7

C2.R4 Improved public investment

management

Adoption of the Action plan for the implementation

of the Roadmap for reforming public investment

management

4.2

C4.R1 Developing the institutional

capacity of the anti-corruption

infrastructure

Appointment of a new head of the National Agency

on Corruption Prevention

6.2

C6.R2 Improved governance and

management of state-owned

enterprises

Entry into force of the legislation on corporate

governance of state-owned enterprises

8.3 C8.R2 Reform of the Economic

Security Bureau of Ukraine

Entry into force of the law on revising the legal basis

of the Economic Security Bureau of Ukraine.

10.1 C10.R1 Integrated National Energy

and Climate Plan

Adoption of the Integrated National Energy and

Climate Plan

10.15

C10.R7 Improved energy efficiency

in public buildings and improvement

of public procurement procedures

Adoption of the Strategy for thermal modernisation

of buildings until 2050 and the Action Plan

12.8 C12.R6 Demining of land and water

areas

Adoption of the strategic document on Mine Action

for the period up to 2033

2

Second instalment (Q3 2024)

Total amount: EUR 4 248 847 926

Non-repayable support: EUR 1 500 000 000

Loans: EUR 2 748 847 926

Total number of steps: 9

Sequential

number

Reform/Investment Name of the step

4.1

C4.R1 Developing the institutional

capacity of the anti-corruption

infrastructure

Increased manpower for the Specialised Anti-

Corruption Prosecutor’s Office

4.4

C4.R2 Improving the legal

framework for a more effective fight

against corruption

Entry into force of the amended Criminal Code and

of the Criminal Procedure Code

4.6

C4.R2 Improving the legal

framework for a more effective fight

against corruption

Adoption of an Action Plan for the implementation of

the Asset Recovery Strategy for 2023-2025

7.6 C7.R6 Improved functioning of the

labour market

Adoption of the Demographic Development Strategy

for the period up to 2040

8.1 C8.R1 Improved regulatory

environment

Adoption of the Action Plan on deregulation

9.5 C9.R3 Development and

implementation of regional policy

Adoption of resolutions to amend the State Strategy

for Regional Development for 2021-2027

10.8

C10.R3 Electricity market reform Entry into force of the secondary legislation on the

Regulation on Wholesale Energy Market Integrity

and Transparency (REMIT) law

15.1

C15. R1 Prevention, reduction and

control of industrial pollution

Entry into force of the legislation on prevention,

reduction, and control of industrial pollution with

partial application of provisions

15.10

C15.R6 Environmental Impact

Assessment (EIA) and Strategic

Environmental Assessment (SEA)

Development of a concept note defining the scope of

deviations from the Environmental Impact

Assessment (EIA) and Strategic Environmental

Assessment (SEA) rules

3

Third instalment (Q4 2024)

Total amount: EUR 3 717 741 935

Non-repayable support: EUR 400 000 000

Loans: EUR 3 317 741 935

Total number of steps: 13

Sequential

number

Reform/Investment Name of the step

2.1 C2.R1 Improved revenue

management

Adoption of the strategic plan for digitalisation of

the State Tax Service

3.6 C3.R2 Reforms of insolvency and

enforcement of court decisions

Entry into force of the legislation on the

improvement of insolvency regime

6.1 C6.R1 Adopting a state ownership

policy

Adoption of the state ownership policy and of the

triage of state-owned enterprises

7.5

C7.R5 Improved social

infrastructure and de-

institutionalisation

Adoption of the Strategy for reforming

Psychoneurological, Other residential Institutions

and De-institutionalisation of Care for Persons with

Disabilities, and Older Persons and of the Strategy

for Ensuring the Right of Every Child in Ukraine to

Grow Up in a Family Environment for 2024-2028

8.7 C8.R5 Harmonisation of legislation

and standards with the EU

Adoption of the resolution for the resumption of

market surveillance measures and control of non-

food products, including product safety inspection

9.6

C9.R3 Development and

implementation of regional policy

Adoption of resolutions for development of urban

planning at the local level

10.2

C10.R2 Improved regulatory

framework for increasing renewable

energy and ensuring stable

operation of the energy system

Introduction of a market-based framework for

renewable energy

10.10

C10.R5 Ensuring independence of

National Energy and Utilities

Regulatory Commission

Entry into force of the legislation to ensure the

independence of the National Energy Utilities

Regulatory Commission

11.1 C11.R1 Comprehensive planning of

transport sector

Adoption of the revised National Transport Strategy

of Ukraine until 2030

11.2

C11.R2 Development of Ukraine’s

export logistics potential

Adoption of the Strategy for developing and

expanding the border infrastructure with EU

Member States and the Republic of Moldova until

2030

12.1

C12.R1 Aligning the institutional

framework on agriculture and rural

development with the EU policy

Adoption of the Strategy for Agriculture and Rural

Development until 2030

4

12.5 C12.R4 Improvement of the official

public electronic farm register

Entry into force of the legislation on the State

Agrarian Register

13.1

C13.R1 Strengthening strategic

planning and ensuring optimum

framework for strategic investors

Entry into force of the legislation on revising the

National Programme for the Development of the

Mineral Resource Base of Ukraine to 2030

5

Fourth instalment (Q1 2025)

Total amount: EUR 4 779 953 917

Non-repayable support: EUR 500 000 000

Loans: EUR 4 279 953 917

Total number of steps: 16

Sequential

number

Reform/Investment Name of the step

1.1 C1.R1 Civil service remuneration

reform

Entry into force of the legislative changes to the civil

service remuneration reform

4.3

C4. R1 Developing the institutional

capacity of the anti-corruption

infrastructure

Increased manpower for the High Anti-Corruption

Court

4.7

C4.R2 Improving the legal

framework for a more effective

fight against corruption.

Entry into force of the law reforming the Asset

Recovery and Management Agency

6.6

C6.R3 Separation of accounts

between public service obligations

(PSO) and non-PSO activities in

state-owned enterprises

Adoption of Roadmap on the separation of public

service obligations (PSO) and non-PSO activities

7.2 C7.R2 Improved preschool

education

Entry into force of the legislation on preschool

education

7.11 C7.R9 Improved cultural

development

Adoption of the Strategy for the Development of

Ukrainian Culture

9.1

C9.R1 Advancing decentralisation Entry into force of the legislation on reforming of

territorial organisation of the executive authorities in

Ukraine with delayed application

9.4

C9.R2 Increased involvement of

citizens to decision making process

at the local level

Entry into force of the legislation for public

consultations on public policy with delayed

application

12.3 C12.R2 Ensuring a functional land

market

Set up of an automated system for public monitoring

of land relations

12.7

C12.R5 Long-term development of

the irrigation system to increase

climate resilience of the sector

Adoption of the long-term plan on the irrigation

system

13.5 C13.R2 Improved administrative

procedures

Set up of an upgraded e-cabinet of subsoil users

14.1 C14.R1 Secure and efficient digital

infrastructure

Adoption of a revised Plan for allocation and use of

the radio spectrum in Ukraine

14.2

C14.R1 Secure and efficient digital

infrastructure

Entry into force of the legislation on strengthening

the cyber security capabilities of state information

resources and critical information infrastructure

6

14.3 C14.R2 Digitalisation of public

services

Adoption of the Action Plan for digitalisation of

public services until 2026

15.2 C15.R2 Climate policy Entry into force of the legislation on the State

Climate Policy

15.5

C15.R3 Market mechanisms of

carbon pricing

Adoption of the Action Plan for the Establishment of

a National Greenhouse Gas Emissions Trading

System

7

Fifth instalment (Q2 2025)

Total amount: EUR 2 124 423 963

Non-repayable support: EUR 300 000 000

Loans: EUR 1 824 423 963

Total number of steps: 11

Sequential

number

Reform/Investment Name of the step

3.5

C3.R1 Enhancing the

accountability, integrity and

professionalism of the judiciary

Entry into force of the legislation revising the

declarations of integrity of judges and their

verification process

3.8

C3.R2 Reforms of insolvency and

enforcement of court decisions

Entry into force of the law on the enforcement of

court decisions related to monetary and non-

monetary obligations and further digitalizing the

enforcement proceedings.

5.4 C5.R3 Improved resolution of non-

performing loans

Adoption of the strategy for resolution of non-

performing loans

7.1 C7.R1 Improved vocational

education

Entry into force of the legislation on vocational

education

7.10

C7.R8 Improved social security Adoption of the resolution on the procurement of

social services

8.4

C8.R3 Access to finance and

markets

Adoption of the Small and Medium Enterprises

(SME) Strategy and Action Plan for its

implementation

9.2

C9.R1 Advancing decentralisation Endorsement and publication on the website of the

Ministry of Communities, Territories and

Infrastructure Development of Ukraine of a study on

the necessary measures to grant legal personality to

municipalities

10.4

C10.R2 Improved regulatory

framework for increasing renewable

energy and ensuring stable

operation of the energy system

Adoption of the Roadmap of the process of

separation of the Renewable Energy Surcharge from

the Transmission Tariff

13.3 C13.R2 Improved administrative

procedures

Publication of a pipeline of investment projects for

extraction of critical raw materials

13.4 C13. R2 Improved administrative

procedures

Launch of Product Sharing Agreement (PSA)

international tenders ensuring their transparency

15.6 C15.R3 Market mechanisms of

carbon pricing

Resumption of the compulsory monitoring, reporting

and verifying (MRV) system

8

Sixth instalment (Q3 2025)

Total amount: EUR 2 655 529 954

Non-repayable support: EUR 300 000 000

Loans: EUR 2 355 529 954

Total number of steps: 10

Sequential

number

Reform/Investment Name of the step

2.8 C2.R4 Improved public investment

management

Development and implementation of the digital

management tool for the reconstruction of Ukraine

3.1 C3.R1 Enhancing the

accountability, integrity and

professionalism of the judiciary

Filling of at least 20% of judicial vacancies

3.2 C3.R1 Enhancing the

accountability, integrity and

professionalism of the judiciary

Entry into force of the law establishing a new court

to hear administrative cases

5.2 C5.R2 Reducing state ownership in

the banking sector

Entry into force of the legislation on the principles

for the sale of state-owned banks

8.8 C8.R5 Harmonisation of legislation

and standards with the EU

Adoption of harmonised standards for three groups

of industrial products

10.5 C10.R3 Electricity market reform Adoption of the Law on the transposition of the

electricity integration package

12.4 C12.R3 Improving the institutional

and administrative set up for

managing investment programmes

Entry into force of the legislation on the public

support of agriculture of Ukraine

13.2 C13.R1 Strengthening strategic

planning and ensuring optimum

framework for strategic investors

Publishing of a report on the verification of Critical

Raw Materials’ reserves of Ukraine

15.4 C.15.R2 Climate policy Adoption of the second Nationally Determined

Contribution of Ukraine to the Paris Agreement

15.9 C15.R5 Increased circular economy Adoption of the National Waste Management Plan

until 2033

9

Seventh instalment (Q4 2025)

Total amount: EUR 2 944 082 949

Non-repayable support: EUR 173 000 000

Loans: EUR 2 771 082 949

Total number of steps: 20

Sequential

number

Reform/Investment Name of the step

1.2 C1.R2 Merit-based recruitment and

selection procedure for the civil

service

Entry into force of the legislative changes to improve

the procedure for entering, passing, and terminating

civil service

2.6 C2.R3 Improved public debt

management

Adoption of the medium-term state debt

management strategy

2.9 C2.R5 Improved audit and financial

control system

Adoption of the amendments to the relevant

legislation on state financial control

3.3

C3.R1 Enhancing the

accountability, integrity and

professionalism of the judiciary

Settlement/adjudication of 20 % of old disciplinary

cases not considered as of end of 2023

3.4

C3.R1 Enhancing the

accountability, integrity and

professionalism of the judiciary

Completion of the qualification evaluation (vetting)

in respect of 50 % of judges who still had to undergo

it as of 30 September 2016

3.9 C3.R2 Reforms of insolvency and

enforcement of court decisions

A data collection system on the enforcement of court

decisions is operational

4.8 C4.R3 Anti-money laundering

measures

Conduct of the next National Risk Assessment

5.6

C5.R4 Improved capacity of the

financial supervisory authority

Entry into force of the law on the improvement of

the state regulation for capital markets and organised

commodity markets

6.7 C6.R3 Separation of accounts

between public service obligations

(PSO) and non-PSO activities in

public service obligations

Entry into force on legislation on the separation of

public service obligations (PSO) and non-PSO

activities

6.9 C6.R4 Improved state aid control

framework

Entry into force of the updated legislation on state

aid and full unsuspension of the application of state

aid control

7.8 C7.R7 Ensuring access to housing

for people in need

Entry into force of the legislation on the Basic

Principles of Housing Policy

8.2 C8.R1 Improved regulatory

environment

Entry into force of the legislation in accordance with

the Action Plan on deregulation in specific sectors

10.3 C10.R2 Improved regulatory

framework for increasing renewable

energy and ensuring stable

operation of the energy system

Entry into force of the legislation to improve

permitting procedures for renewable energy

investments

10.7 C10.R3 Electricity market reform Appointment of a new electricity market operator

10

10.11

C10.R5 Ensuring independence of

National Energy and Utilities

Regulatory Commission

Entry into force of the amendments to the Law of

Ukraine “On the National Energy and Utilities

Regulatory Commission”

10.13

C10.R6 Improved efficiency in the

district heating

Adoption of the State targeted economic programme

for the energy modernisation of heat generating

enterprises for the period up to 2030

10.14 C10.R6 Improved efficiency in the

district heating

Entry into force of the legislation to support

development of the efficient and more sustainable

district heating

11.3

C11.R3 Liberalisation in the

railways transport sector

Entry into force of the law on traffic safety and

interoperability of railway transport of Ukraine with

application within three years from its adoption

13.6

C13.R3 Use of modern Extraction

Technologies and Integration of

Ukraine into Modern Processing

Value Chains

Publication of a study on the legislation on ESG

reporting

15.3

C15.R2 Climate policy Adoption of the resolution on the Scientific and

Expert Council on Climate Change and Preservation

of the Ozone Layer

11

Eighth instalment (Q1 2026)

Total amount: EUR 2 865 920 061,86

Non-repayable support: EUR 332 049 093,86

Loans: EUR 2 533 870 968

Total number of steps: 7

Sequential

number

Reform/Investment Name of the step

1.5 C1.R3 Digitalisation of civil service

and human resources management

The Human Resources Management Information

System (HRMIS) is in operation

3.7

C3.R2 Reforms of insolvency and

enforcement of court decisions

Entry into force of the legislation for simplified

insolvency procedures for Micro, Small, and

Medium Enterprises (MSMEs)

3.12

C3.R4 Reform of the Prosecution

Service

Entry into force of the legislation enabling

transparent and merit-based selection of

management-level prosecutors

5.1 C5.R1 Assessment of the banking

sector

Published Resilience assessment in

the banking system

8.5 C8.R3 Access to finance and

markets

Entry into force of the legislation on access to

information about external engineering works

12.6

C12.R4 Improvement of the official

public electronic farm register

Publication of report on the implementation of the

state support through the public Agricultural

Register

15.8

C15.R5 Increased circular economy Adoption of the Strategy for implementing the

principles of the circular economy and its Action

Plan

12

Ninth instalment (Q2 2026)

Total amount: EUR 7 542 976 959

Non-repayable support: EUR 173 000 000

Loans: EUR 7 369 976 959

Total number of steps: 18

Sequential

number

Reform/Investment Name of the step

3.10 C3.R2 Reforms of insolvency and

enforcement of court decisions

An upgraded IT system for enforcement of court

decisions is operational

3.17 C3.R5. Enhancing the protection of

human rights

Adoption of the Presidential Decree approving the

Human Rights Protection Strategy

4.20

C4.R4. Combating

Human Trafficking

Adoption of the state programme to combat human

trafficking until 2030

5.3 C5.R2 Reducing state ownership in

the banking sector

Adoption of the strategy for gradual reduction of

state ownership in the banking sector

5.5 C5.R3 Improved resolution of non-

performing loans

Entry into force of legal acts to improve resolution

of non-performing loans

6.3

C6.R2 Improved governance and

management of state-owned

enterprises

Appointment of Supervisory boards of state-owned

enterprises with a majority of independent members

7.7 C7.R6 Improved functioning of the

labour market

Adoption of the Population Employment Strategy

7.12 C7.I1 Investments in education Investments of at least EUR 300 million in

education

7.14 C7.I2 Investments in healthcare Investments of at least EUR 200 million in

healthcare

7.18

C7 I5 Investment in providing

housing for vulnerable groups of

the population

Investments of at least EUR 200 million for

providing housing for veterans with disabilities of

the I-II groups, family members of deceased

veterans and internally displaced persons

7.20

C7.R6.

Improved functioning of the labour

market

Approval by the Cabinet of Ministers of the

Operational Plan of Measures for the

implementation in 2026–2028 of the National

Strategy for Overcoming the Gender Pay Gap for

the period up to 2030

8.12

C8.R5.

Harmonisation of legislation and

standards with the EU

Adoption of amendments to the resolution on the

designation of the single national metrology institute

9.7

C9.I1 Investments for the recovery,

reconstruction and modernisation

needs of Ukraine’s sub-national

authorities

Allocation of the equivalent of at least 5% of the

overall non-repayable financial support for meeting

recovery, reconstruction, and modernisation needs

of sub-national authorities

13

10.9

C10.R4 Liberalisation of electricity

and natural gas prices

Adoption of a Roadmap for gradual liberalisation of

gas and electricity market, to be implemented after

the expiration of the martial law

10.19

C10.R5 Ensuring independence of

National Energy and Utilities

Regulatory Commission

Preparation of the Terms of Reference for a third-

party audit of the National Energy and Utilities

Regulatory Commission regarding the integrity and

robustness of its financial and decision-making

processes

12.9 C12.I1 Investments in demining Investments of at least EUR 30 million in demining

of agriculture land

14.4

C14.R2 Digitalisation of public

services

Entry into force of the legal act on the functioning of

the Integrated Electronic Identification System, in

line with the principles of Regulation (EU)

2024/1183

15.11

C15.R4.

Restoration and conservation of

natural resources

Adoption of amendments to the Procedure for State

Water Monitoring

14

Tenth instalment (Q3 2026)

Total amount: EUR 2 951 105 991

Non-repayable support: EUR 75 000 000

Loans: EUR 2 876 105 991

Total number of steps: 10

Sequential

number

Reform/Investment Name of the step

1.4C1.R3 Digitalisation of civil service

and human resources management

Modernisation of the Unified State Web Portal of

Electronic Services

3.13

C3.R4 Reform of the Prosecution

Service

Entry into force of the legislation improving the

disciplinary system for prosecutors and increasing

the capacity of the Qualification and Disciplinary

Commission of Prosecutors

4.5

C4.R2 Improving the legal

framework for a more effective

fight against corruption

Adoption of the new Anti-Corruption Strategy for

the period 2026-2030

4.9 C4.R3 Anti-money laundering

measures

Publication in the Official Gazette of the legislation

to further reinforce the anti-money laundering

system, including for the purpose of Ukraine’s

application to join the geographical scope of Single

European Payment Area (SEPA) schemes, with an

entry into force six months after the date of

publication in the Official Gazette

4.16

C4.R3. Anti-money laundering

measures

Entry into force of legislative amendments on

information accompanying transfers of funds and

certain crypto-assets

4.18

C4.R3.

Anti-money laundering measures

Entry into force of amendments aimed at

establishing criminal liability for illegal actions with

payment cards or other payment instruments in the

interests of third parties

6.4

C6.R2 Improved governance and

management of state-owned

enterprises

Corporatisation of key state-owned enterprises

10.16

C10.R7 Improved energy efficiency

in public buildings and

improvement of public procurement

procedures

Adoption of legal acts on setting minimum energy

efficiency performance levels for buildings

10.21

C10.R8 Reform of State Nuclear

Regulatory Inspectorate

Request for an integrated regulatory review service

mission at SNRIU by the International Atomic

Energy Agency

11.9

C11.R3 Liberalisation in the

railways transport sector

Adoption of a resolution by the Cabinet of Ministers

of Ukraine approving the Action Plan for the phased

introduction of competition for freight and passenger

transport in the railway market

15

Eleventh instalment (Q4 2026)

Total amount: EUR 2 103 225 808

Non-repayable support: EUR 270 000 000

Loans: EUR 1 833 225 808

Total number of steps: 23

Sequential

number

Reform/Investment Name of the step

1.3

C1.R2 Merit-based recruitment and

selection procedure for the civil

service

Gradual restoration of merit-based recruitment in the

civil service

2.4 C2.R2 Improved public financial

management

Conduct of the spending review of the state budget

2.10

C2.R5.

Improved audit and financial control

systems

Strengthening internal control, internal audit in

Ukraine and protection of the EU’s financial interests

under the Ukraine Facility

3.14 C3.R4 Reform of the Prosecution

Service

An e-Case Management System in the criminal

justice is operational

3.15

C3.R1 Enhancing the accountability,

integrity and professionalism of the

judiciary

A new court to hear administrative cases is

operational

3.16

C3.R1 Enhancing the accountability,

integrity and professionalism of the

judiciary

Entry into force of legislation extending the

involvement of independent experts nominated by

international partners in the selection of members of

the High Qualification Commission of Judges of

Ukraine

4.11

C4.R2 Improving the legal framework

for a more effective fight against

corruption

Adoption of the new State Anti-Corruption Program

for the period 2026-2030

4.12

C4.R2 Improving the legal framework

for a more effective fight against

corruption

Entry into force of the amendments to the Criminal

Procedure Code to ensure fast and high-quality

justice

4.13

C4.R2.

Improving the legal framework for a

more effective fight against

corruption

Entry into force of a law reforming the State Bureau

of Investigation of Ukraine

4.14

C4.R2.

Improving the legal framework for a

more effective fight against corruption

Entry into force of legislation enabling single-judge

adjudication of civil and administrative cases in the

High Anti-Corruption Court

4.15

C4.R2

Improving the legal framework for a

more effective fight against

corruption

Entry into force of a law ensuring effective,

impartial and timely access to high-quality forensic

examinations by anti-corruption bodies

4.19

C4.R3 Anti-money laundering

measures

Adoption of a strategy and action plan on financial

investigations and the introduction of methodological

guidelines for conducting financial investigations

16

6.10

C6.R2 Improved governance and

management of state-owned

enterprises

Adoption of the roadmap for lifting SOE moratoria

and gradual lifting of SOE moratoria on debt

enforcement

6.11

C6.R2 Improved governance and

management of state-owned

enterprises

Entry into force of the amendments to the legislation

on state-owned enterprises, bringing operational

autonomy and internal controls of SOEs closer to

OECD standards

6.12

C6.R2 Improved governance and

management of state-owned

enterprises

Independent assessments of key corporate

governance systems for selected nondefense SOEs in

accordance with Cabinet of Ministers Ordinance No.

1223 with the involvement of external auditors

and/or consultancies.

7.21

C7.R6.

Improved functioning of the labour

market

Entry into force of the legislation on occupational

safety and health.

8.11 C8.R2 Reform of the Economic

Security Bureau of Ukraine

Entry into force of legal acts further strengthening

the Economic Security Bureau of Ukraine

10.6

C10.R3 Electricity market reform Entry into force of the legislation on changing the

conditions of taxation of participants in the

electricity market

10.18

C10.R3.

Electricity market reform

Entry into force of the secondary legislation of the

law No. 4834/IX on the transposition of the

electricity integration package, in line with the

Energy Community Treaty acquis

10.20

C10.R5.

Ensuring independence of National

Energy and Utilities Regulatory

Commission

Completion of a third-party audit of the National

Energy and Utilities Regulatory Commission

regarding the integrity and robustness of its financial

and decision-making processes.

11.8

C11 R3 Liberalisation in the railways

transport sector

Entry into force of legislation on the organisation of

socially important passenger transportation by rail

and institutional oversight with delayed application

14.5 C14.R2 Digitalisation of public

services

Enablement of EU-format Electronic Attestations in

Diia

15.7 C15.R4 Restoration and conservation

of natural resources

Entry into force of the Law on reducing deforestation

and forest degradation

17

Twelfth instalment (Q1 2027)

Total amount: EUR 248 663 594

Non-repayable support: EUR 0

Loans: EUR 248 663 594

Total number of steps: 3

Sequential

number

Reform/Investment Name of the step

9.3C9.R1 Advancing decentralisationEntry into force of the legislation to ensure a better

distribution of powers between local governments

and executive authorities

11.5 C11.R4 Improved shipping and

ports services

Entry into force of the legislation on merchant

shipping and shipping on inland waterways

12.2

C12. R1 Aligning the institutional

framework on agriculture and rural

development to the EU policy

Establishment of the Farm Sustainability Data

Network (FSDN) system

18

Thirteenth instalment (Q2 2027)

Total amount: EUR 162 442 396

Non-repayable support: EUR 0

Loans: EUR 162 442 396

Total number of steps: 7

Sequential

number

Reform/Investment Name of the step

4.10

C4.R3 Anti money-laundering

measures

The necessary software and hardware for the

registry of accounts and individual safe deposit

boxes of individuals is operational and access is

ensured to relevant authorities

4.17

C4.R3 Anti money-laundering

measures

The necessary software and hardware for the

registry of beneficial owners for trusts or other

similar legal arrangements is operational and access

is ensured to relevant authorities

7.3

C7.R3 Improved rehabilitation

system for people with disabilities

Entry into force of the legislation on rehabilitation

of persons with disabilities

7.4

C7.R4. Transition from military

service to civilian life

Implementation of a case management system

supporting veterans and demobilised personnel in

their return and transition into civilian life

7.9

C7.R7 Ensuring access to housing

for people in need

Entry into force of the legislation on the Social

Housing Fund

10.12 C10.R6 Improved efficiency in the

district heating

Cancelation of the moratorium on rising heat and hot

water tariffs

11.6

C11.R4 Improved shipping and

ports services

Review and amend the existing national legislation

in line with the principles Regulation (EU) 2017/352

of the European Parliament and of the Council of 15

February 2017 establishing a framework for the

provision of port services and common rules on the

financial transparency of ports

19

Fourteenth instalment (Q3 2027)

Total amount: EUR 162 442 396

Non-repayable support: EUR 0

Loans: EUR 162 442 396

Total number of steps: 16

Sequential

number

Reform/Investment Name of the step

3.11C3.R3 Digitalisation of the judicial

system

Set up of IT solutions in the judicial system

6.5 C6.R2 Improved governance and

management of state-owned

enterprises

Submission of a report showing that the principles

of corporate governance are duly followed

6.8

C6.R3 Separation of accounts

between public service obligations

(PSO) and non-PSO activities in

state-owned enterprises

Submission of an audit report confirming the

separation of public service obligations (PSO) and

non-PSO activities

7.13 C7.I1 Investments in education Investments of at least EUR 650 million in

education

7.15 C7.I2 Investments in healthcare Investments of at least EUR 400 million in

healthcare

7.16 C7.I3 Investments in social

infrastructure

Investments of at least EUR 350 million in social

infrastructure

7.17

C7.I4 Investments in housing

support for damaged or destroyed

housing and housing support for

internally displaced persons

Investments of at least EUR 510 million for housing

support for damaged or destroyed housing and

housing support for internally displaced persons

7.19

C7.I5 Investments in providing

housing for vulnerable groups of

the population

Investments of at least EUR 540 million for

providing housing for veterans with disabilities of

the I-II groups, family members of deceased

veterans and internally displaced persons

8.6

C8.R4 Improved public

procurement

Entry into force of the legislation on harmonising

legislation in the field of public procurement with

the EU acquis.

8.9 C8.R6 Addressing late payments Entry into force of the legislation on combating late

payments

8.10

C8.I1 Investments in financial

support for micro-enterprises and

SMEs

Investments of at least EUR 450 million for

financial support to micro-enterprises and SMEs and

small and medium processing enterprises

9.8

C9.I1 Investments for the recovery,

reconstruction and modernisation

needs of Ukraine’s sub-national

authorities

Allocation of the equivalent of at least 20% of the

overall non-repayable financial support for meeting

recovery, reconstruction, and modernisation needs

of sub-national authorities

20

10.17 C10.I1 Investments in energy

infrastructure

Investments of at least EUR 550 million in energy

infrastructure

11.4 C11.R3 Liberalisation in the

railways transport sector

Adoption of the by-laws for the implementation of

the legislation on railway transport

11.7 C11.I1 Investments in transport

infrastructure

Investments of at least EUR 350 million in transport

infrastructure

12.10 C12.I1 Investments in demining Investments of at least EUR 100 million in demining

of agriculture land

21

C.1. PUBLIC ADMINISTRATION REFORM

1. Description of Reforms and Investments

The objective of this chapter is to strengthen the capacity and efficiency of the Ukrainian public administration

and to gradually align the rules, standards, policies, and practices in the field of public administration with the

Union acquis, policies and practices. Specifically, this chapter focuses on revising the civil service

remuneration system, enhancing the merit-based recruitment and selection of the civil service, and on the

digitalisation of civil service and human resources management systems.

Reform 1. Civil Service Remuneration Reform

The objective of this reform is to introduce a transparent, fair and predictable labour remuneration system in

line with relevant OECD/SIGMA principles of public administration1.

The reform has one step. It entails the entry into force of new legislation introducing a new remuneration

system based on functional classification of positions, a clear separation of wages into fixed and variable

components, and reduction of the seniority supplement from 50 % to 30 %.

The reform is expected to be completed by Q1 2025.

Reform 2. Merit-based recruitment and selection procedure for the civil service

The objective of this reform is to introduce a meritocratic recruitment and selection procedure for civil

servants, so as to ensure public trust and attract highly professional staff to the civil service.

The reform has two steps. First, it entails the entry into force of legislation to improve the procedure for

entering, passing, and terminating civil service. Second, it entails the gradual restoration of merit-based

selection for vacant positions for civil servants of categories A, B, and C.

The reform is expected to be completed by Q4 2026.

Reform 3. Digitalisation of civil service and human resources management

This reform is aimed at digitalising the civil service human resources management functions, focusing on the

human resources management information system (HRMIS) and the Unified State Web Portal of Electronic

Services.

The reform has two steps. First, a human resources management information system (HRMIS) shall be

operational and used in all ministries and all operating /acting other central executive authorities and their

territorial bodies. Second, the Unified State Web Portal of Electronic Services will be modernised.

The reform is expected to be completed by Q2 2026.

1 OECD (2023), The Principles of Public Administration, OECD, Paris,

https://www.sigmaweb.org/publications/Principles-of-Public-Administration-2023.pdf

22

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

1.1 Reform 1.

Civil service

remuneration

reform

Entry into force of the

legislative changes to the

civil service remuneration

reform

Q1 2025 Entry into force of legislation (including the adoption of the necessary secondary legal

and normative acts), which complies with the relevant OECD SIGMA principles of

public administration. The legislation focuses on these main areas:

- introduction of remuneration based on the functional classification of positions;

- a clear separation of wages into fixed or guaranteed (not less than 70% annually) and

variable (not more than 30% annually) parts;

- reduction of seniority supplement from 50 % to 30 %.

1.2 Reform 2.

Merit-based

recruitment and

selection procedure

for the civil service

Entry into force of the

legislative changes to

improve the procedure for

entering, passing, and

terminating civil service

Q4 2025 Entry into force of legislation (including the adoption of the necessary secondary legal

and normative acts) to improve the procedure for entering, passing, and terminating

civil service. The legislation complies with the relevant OECD/SIGMA principles of

public administration related to merit-based recruitment.

The provisions relating to the resumption of merit-based selection for all civil servants’

positions in the territory controlled by Ukraine, where no hostilities are taking place,

enter into force with its application as of 1 June 2026 (in accordance with the

requirements of step 1.3).

1.3 Reform 2.

Merit-based

recruitment and

selection procedure

for the civil service

Gradual restoration of

merit-based recruitment in

the civil service

Q4 2026 Restoration of merit-based selection for vacant positions for all civil servants will be

implemented gradually in three stages:

1) for civil service positions of category “A”;

2) for civil service positions of category “B” (in the territory controlled by Ukraine

where no hostilities are taking place);

3) for civil service positions of category “C” (in the territory controlled by Ukraine

where no hostilities are taking place).

23

1.4 Reform 3.

Digitalisation of

civil service and

human resources

management

Modernisation of the

Unified State Web Portal of

Electronic Services

Q3 2026 The Unified State Web Portal of Electronic Services is modernised. Functionality for

publishing vacancies and submitting applications has been fully implemented and is

operating in full.

1.5 Reform 3.

Digitalisation of

civil service and

human resources

management

The Human Resources

Management Information

System (HRMIS) is in

operation

Q1 2026 The Human Resources Management Information System (HRMIS) is in operation and

used in all ministries and all operating/acting other central executive authorities and

their territorial bodies.

24

C.2. PUBLIC FINANCIAL MANAGEMENT

1. Description of Reforms and Investments

The objective of this chapter is to enhance Ukraine’s macro-economic and financial resilience,

ensure efficient use of public funds, align with Union standards, and promote a sustainable

growth.

Reform 1. Improved revenue management

The objective of this reform is to enhance domestic revenue mobilisation through improved

efficiency of the tax and customs administration.

The reform has two steps. First, the long-term national strategic plan for digital development,

digital transformation and digitalisation of the State Customs Service shall be adopted. Second,

the strategic plan for digital development, digital transformation and digitalisation of State Tax

Service of Ukraine shall be adopted.

The reform is expected to be completed by Q4 2024.

Reform 2. Improved public financial management

The objective of this reform is to build an efficient public finance management system and to

ensure the financial stability of the state.

The reform has two steps. First, the Budget Declaration for 2025-2027 shall be approved to

restore the medium-term budget planning and ensure the predictability of budget policy.

Second, the reform shall introduce annual spending reviews of the state budget taking into

account OECD practices in priority areas, including social protection, education, healthcare,

energy, business support.

The reform is expected to be completed by Q4 2026.

Reform 3. Improved public debt management

The objective of this reform is to increase the transparency of state debt management policy

and the efficiency of state debt management.

The reform proposes one step, namely the adoption of the medium-term state debt management

strategy for 2026-2028. The strategy shall include an analysis of current public debt structure

and trends, the establishment of targets to ensure debt sustainability, and the development of

measures for the domestic government securities market.

The reform is expected to be completed by Q4 2025.

25

Reform 4. Improved public investment management

The objective of this reform is to strengthen the institutional framework for public investment

management in Ukraine, defining roles and responsibilities for participants at all stages of the

investment project cycle, strategic priorities, transparency, and a digital project monitoring

framework.

The reform has two steps. First, an action plan to implement a roadmap towards an improved

public investment management shall be adopted. Second, the reform entails the development

and implementation of a digital management tool for the reconstruction of Ukraine.

The reform is expected to be completed by Q3 2025.

Reform 5. Improved audit systems

The objective of this reform is to strengthen the audit and financial control system, in particular

to achieve a high level of protection of the financial interests of the European Union regarding

the funds used under Pillar I of the Ukraine Facility, in line with Article 35 of Regulation (EU)

2024/792.

The reform has two steps. First, it entails the adoption and, where applicable, the entry into

force of amendments to the resolutions or other legislation on state financial control, enabling

the State Audit Service to ensure that the institution is equipped with the necessary tools to

ensure a high level of protection of the financial interest of the European Union, in particular

for the funds used under Pillar I of the Ukraine Facility. Building on this legislation, the second

step requires Ukraine to strengthen internal control and internal audit systems in Ukraine for

accountable and effective governance.

The reform is expected to be completed by Q4 2026.

26

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

2.1 Reform 1.

Improved revenue

management

Adoption of the strategic

plan for digitalisation of the

State Tax Service

Q4 2024 Adoption of the strategic plan for digital development, digital transformation

and digitalisation of State Tax Service of Ukraine, in line with the

recommendations of the National Revenue Strategy for 2024-2030.

2.2 Reform 1.

Improved revenue

management

Adoption of the plan for the

digitalisation of the State

Customs Service

Q2 2024 Adoption of the long-term national strategic plan for digital development, digital

transformation and digitalisation of the State Customs Service.

2.3 Reform 2.

Improved public

financial

management

Approval of the Budget

Declaration for 2025-2027

Q2 2024 The Budget Declaration for 2025-2027 is approved and submitted to the

Parliament. The Declaration focuses on these main areas:

- key macroeconomic projections of economic and social development of the

country;

- key budget indicators (revenues, expenditures, budget deficit, public debt);

- public policy priorities by spheres and expenditure ceilings for each key

spending unit;

- relations between the state budget and local budgets, including necessary

guidance for preparing medium-term forecasts of local budgets;

- fiscal risks assessment.

2.4 Reform 2.

Improved public

financial

management

Conduct of the spending

review of the state budget

Q4 2026 Spending reviews of the state budget are conducted annually based on the

Government decision and the methodology taking into account best OECD

practices in particular in the priority areas, such as social protection, education,

healthcare, energy, business support.

2.6 Reform 3.

Improved public

debt management

Adoption of the medium-

term state debt management

strategy

Q4 2025 Adoption of the medium-term state debt management strategy (MTDS) for

2026-2028. The MTDS focuses on these main areas:

- analysis of current public debt structure and trends;

- targets to ensure debt sustainability;

- measures for the development of domestic government securities market.

27

2.7 Reform 4.

Improved public

investment

management

Adoption of the Action plan

for the implementation of

the Roadmap for reforming

public investment

management

Q2 2024 Adoption of the Action plan for the implementation of the Roadmap for

reforming public investment management. The action plan focuses on these

main areas and includes the sequencing and timeframe:

- introduction of strategic planning for public investment in close connection with

budget planning;

- definition of the roles of all participants at all stages of the investment project

cycle;

- establishment of unified approaches to the selection, evaluation and monitoring of

investment projects, regardless of the sources of funding (budget revenues,

international donors, state (local) guarantees, concessions, public-private

partnerships) to enable the preparation of single project pipeline;

- definition of prioritisation criteria that capture defined needs, maturity of

projects, and alignment with sectoral and/or regional strategies in the context of

the public investment management;

- introduction of an independent assessment of large public investment projects.

2.8 Reform 4.

Improved public

investment

management

Development and

implementation of the

digital management tool for

the reconstruction of

Ukraine

Q3 2025 Development and implementation of the digital management tool for the

reconstruction of Ukraine, which provides public access to data on

reconstruction projects at all stages, including planning, financing, procurement,

construction and commissioning, to enable a public and transparent monitoring

of project implementation and better coordination of reconstruction efforts

between sectors.

2.9 Reform 5.

Improved audit and

financial control

systems

Adoption of the

amendments to the relevant

legislation on state financial

control

Q4 2025 Adoption of amendments to the resolutions of the Cabinet of Ministers and, if

needed, entry into force of other relevant legislation on state financial control.

These changes focus on these main areas:

- provision of support to State Audit Services to ensure that the institution is

equipped with the necessary tools to protect the financial interests of the Union,

in particular for the funds used under Pillar I of the Ukraine Facility, in line with

the principles of the international audit standards;

- strengthening measures for monitoring the procurement procedures.

28

2.10 Reform 5.

Improved audit and

financial control

systems

Strengthening internal

control, internal audit in

Ukraine and protection of

the EU’s financial

interests under the Ukraine

Facility

Q4 2026 Building on legislation adopted under Step 2.9, strengthening Ukraine’s internal

control and internal audit systems and the mechanisms for protecting the

financial interests of Ukraine and the European Union under the Ukraine

Facility, through the adoption of a national Action Plan to “strengthen internal

control and internal audit systems in Ukraine for accountable and

effective governance”, by the Cabinet of Ministers of Ukraine. The Action Plan

is to cover the following aspects:

- improving the State Audit Service of Ukraine’s effective access to the

information and data necessary to carry out state financial control measures

under the Ukraine Facility, including relevant registers, databases and

information systems;

- amending the Audit Strategy for the Implementation of the Ukraine Plan to

clarify the respective roles and cooperation arrangements between the Ministry

of Finance, the State Audit Service and the internal audit units of state bodies

with spending units;

- improving the methodological framework for risk-based system audits for

Ukraine Facility spending and ensuring their effective uptake by Q2 2027,

including the assessment of risks of fraud, corruption, conflicts of interest and

double funding;

- strengthening risk management and the role of internal control and internal

audit in the preparation of management declarations, in particular by providing

practical guidance and support to state bodies responsible for the implementation

of the Ukraine Plan.

29

C.3. JUDICIAL SYSTEM AND HUMAN RIGHTS

1. Description of Reforms and Investments

The objective of this chapter is increasing the capacity, accountability, integrity, efficiency and

transparency of the judicial system which is crucial for ensuring the rule of law and the

protection of human rights in Ukraine as well as for a swift recovery, economic growth and

attraction of investment.

Reform 1. Enhancing the accountability, integrity, and professionalism of the judiciary

The objective of this reform is consolidating the results of the judicial reform and building

public trust in the judiciary by resuming the transparent and meritocratic selection of judges,

boosting the qualification evaluation of sitting judges, strengthening the disciplinary

responsibility system, reinforcing existing judicial integrity tools, and establishing a new court

to hear administrative cases involving state agencies.

The reform has seven steps. First, 20 % of judicial vacancies are filled based on amended

legislation, which includes streamlined stages of selection and shortened mandatory judicial

training periods, consistent application of clear assessment criteria and scoring methodology,

and the involvement of the Public Integrity Council in assessing the integrity of judicial

candidates. Second, a new Specialised District Administrative Court and a new Specialised

Administrative Court of Appeal are legally established and a transparent selection of judges in

line with the adopted legislation is launched. Third, 20 % of pending disciplinary cases are

resolved with the involvement of the Disciplinary Inspectors Service on the basis of the High

Council of Justice’s methodology of prioritisation. Fourth, the qualification evaluation

(vetting) is completed in respect of 50 % of outstanding cases. Fifth, laws and bylaws

concerning revising and verification of the declarations of integrity enter into force. Sixth, a

new Specialised District Administrative Court and a new Specialised Administrative Court of

Appeal are operational. Seventh, a law extending the involvement of independent experts

nominated by international partners in the selection commission for the High Qualification

Commission of Judges (HQCJ) has entered into force.

The reform is expected to be completed by Q4 2026.

Reform 2. Reforms of insolvency and enforcement of court decisions

The objective of this reform is the improvement of insolvency and enforcement procedures by

aligning the relevant legislation with the EU acquis and building institutional and other

capacities to properly apply it.

The reform has five steps. First, legislation on improving the insolvency regime, introducing

insolvency prevention system and the early warning tool for legal entities and entrepreneurs in

line with the Union acquis enters into force. Second, legislation for introducing simplified

insolvency procedures for Micro, Small, And Medium Enterprises (MSMEs) in line with EU

acquis enters into force. Third, the law on the enforcement of court decisions related to

30

monetary and non-monetary obligations and further digitalisation of the enforcement

proceedings enters into force. Fourth, an upgraded IT system for facilitating the enforcement

process, debtor asset tracking, bank account freezing, and debt recovery becomes operational.

Fifth, a data collection system on the enforcement of court decisions becomes operational.

The reform is expected to be completed by Q2 2026.

Reform 3. Digitalisation of the judicial system

The objective of this reform is to enhance access to justice, increase the transparency,

efficiency, and effectiveness in the operation of courts, save operational costs, and enable an

evidence-based policy making in the judiciary.

The reform has one step. It entails the introduction of the subsystem of the Electronic Document

Management of the Unified Judicial Information and Telecommunication System (UJITS) in

15 pilot courts of general, commercial and administrative jurisdiction at the level of first and

appellate instances.

The reform is expected to be completed by Q3 2027.

Reform 4. Reform of the Prosecution Service

The objective of this reform is to reinforce integrity, meritocracy and professionalism within

the prosecutorial ranks and prevent corruption in the criminal justice chain.

The reform has three steps. First, legislation establishing a transparent and merit-based

selection process of management-level prosecutors enters into force. Second, legislation

improving the disciplinary system for prosecutors and increasing the capacity of the

Qualification and Disciplinary Commission of Prosecutors enters into force. Third, three

modules of an e-Case management system in the criminal justice chain are put in place to

enable the digital processing of criminal cases.

The reform is expected to be completed by Q4 2026.

Reform 5. Enhancing the protection of human rights

The objective of this reform is to enhance the protection of human rights, including the rights

of persons residing in the territory of Ukraine temporarily occupied by the Russian

Federation, and enhance access to services for vulnerable persons.

The reform has one step. It entails the adoption of the Presidential Decree approving the

Human Rights Protection Strategy.

The reform is expected to be completed by Q2 2026.

31

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

3.1 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Filling of at least 20% of

judicial vacancies are filled.

Q3 2025 At least 20% of judicial vacancies available as of 16. October 2023 (a total number of

2205 positions) is filled on the basis of amended legislation, which includes the

following elements:

- streamlined stages of selection and shortened mandatory judicial training periods;

- consistent application of clear and duly published assessment criteria and scoring

methodology for assessing professional competence and integrity of judicial candidates;

- involvement of the Public Integrity Council in assessing the integrity of judicial

candidates whenever the law requires it.

3.2 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Entry into force of the law

establishing a new court to

hear administrative cases

Q3 2025

The law on the establishment of the Specialised District Administrative Court and the

Specialised Administrative Court of Appeal entered into force and a transparent

selection of judges in line with the adopted legislation is launched.

3.3 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Settlement/adjudication of

20% of old disciplinary

cases not considered as of

end of 2023

Q4 2025 20% of old disciplinary proceedings (complaints) not considered as of 31 December

2023 are settled/ adjudicated with the involvement of the Disciplinary Inspectors

Service and on the basis of the criteria for prioritisation of disciplinary complaints

consideration, provided for in clause 13.7 of the Rules of Procedure of the High

Council of Justice (as amended on 21 November 2023, No. 1068/0/15-23) that are

published on the official website of the High Council of Justice.

3.4 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Completion of the

qualification evaluation

(vetting) in respect of 50%

of judges who still had to

undergo it as of 30

September 2016

Q4 2025 Qualification evaluation (vetting) is completed in respect of 50% of judges who still

had to undergo it as of 30 September 2016 in line with the established procedures and

with the involvement of the Public Integrity Council.

32

3.5 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Entry into force of the

legislation revising the

declarations of integrity of

judges and their verification

process

Q2 2025 Entry into force of the laws and the bylaws of the High Qualification Commission of

Judges of Ukraine revising the declarations of integrity of judges and their verification

process. The acts focus on these main areas:

- clarification of the content of the integrity declarations and the grounds for initiating

the verification;

- expansion of the time period covered by the verification;

- improvement of the verification procedure by specifying the verification mechanisms

and deadlines, defining the rights and obligations of the persons and entities involved in

the verification process, clarifying the legal consequences of the verification.

3.6 Reform 2.

Reforms of

insolvency and

enforcement of

court decisions

Entry into force of the

legislation on the

improvement of insolvency

regime

Q4 2024 Entry into force of the law on the improvement of insolvency regime and the relevant

secondary legislation, introducing insolvency prevention system and the early warning

tool for legal entities and entrepreneurs in line with the principles of Directive (EU)

2019/1023 of the European Parliament and of the Council of 20 June 2019 on

preventive restructuring frameworks, on discharge of debt and disqualifications, and on

measures to increase the efficiency of procedures concerning restructuring, insolvency

and discharge of debt, and amending Directive (EU) 2017/1132. The new legislation

focuses on these main areas:

- prevention of bankruptcy and restoration of solvency of debtors

- early detection of signs of crisis in the company

- identification of additional opportunities for restoring solvency of companies

- availability of information for the companies about the mechanisms for preventing

insolvency and early warning.

3.7 Reform 2. Reforms

of insolvency and

enforcement of

court decisions

Entry into force of the

legislation for simplified

insolvency procedures for

Micro, Small, and Medium

Enterprises (MSMEs)

Q1 2026 Entry into force of the legislation for simplified insolvency procedures for Micro,

Small, and Medium Enterprises (MSMEs) in line with the principles of the Directive

(EU) 2019/1023 of the European Parliament and of the Council of 20 June 2019 on

preventive restructuring frameworks, on discharge of debt and disqualifications, and on

measures to increase the efficiency of procedures concerning restructuring, insolvency

and discharge of debt, and amending Directive (EU) 2017/1132. The legislation is

drafted based on a regulatory impact assessment with the involvement of EU experts.

The legislation focuses on these main areas:

33

- simplified out-of-court and bankruptcy procedures for MSMEs (including individual

entrepreneurs);

- availability of insolvency tools and services of insolvency practitioners for MSMEs;

- prevention of abuse of insolvency procedures by MSMEs.

3.8 Reform 2.

Reforms of

insolvency and

enforcement of

court decisions

Entry into force of the

legislation on improving the

enforcement of court

decisions related to

monetary and non-monetary

obligations and digitalisation

Q2 2025 Entry into force of the law on the enforcement of court decisions related to monetary

and non-monetary obligations and further digitalisation of the enforcement proceedings.

3.9 Reform 2.

Reforms of

insolvency and

enforcement of

court decisions

A data collection system on

the enforcement of court

decisions is operational

Q4 2025 A data collection system on the enforcement of court decisions is operational.

3.10 Reform 2.

Reforms of

insolvency and

enforcement of

court decisions

An upgraded IT system for

enforcement of court

decisions is operational

Q2 2026 The upgraded IT system for enforcement facilitating enforcement process, debtor asset

tracking, bank account freezing and debt recovery is operational.

3.11 Reform 3.

Digitalisation of the

judicial system

Set up of IT solutions in the

judicial system

Q3 2027 The introduction of the subsystem of the Electronic Document Management of the

Unified Judicial Information and Communication System in 15 pilot courts of general,

commercial and administrative jurisdiction at the level of first and appellate instances.

3.12 Reform 4.

Reform of the

Prosecution Service

Entry into force of the

legislation enabling

transparent and merit-based

selection of management-

level prosecutors

Q1 2026 Entry into force of the legislation enabling transparent and merit-based selection of

management-level prosecutors. This legislation focuses on these main areas:

- clear assessment criteria, including professional competence and integrity/ethics;

- transparent, competitive and meritocratic selection procedure that includes a credible

professionalism and integrity check;

- strengthening the institutional capacity and the powers of the Prosecutor's Office and

the self government bodies, in particular the Council of Prosecutors, in terms of

selecting prosecutors for senior positions.

34

3.13 Reform 4.

Reform of the

Prosecution Service

Entry into force of the

legislation improving the

disciplinary system for

prosecutors and increasing

the capacity of the

Qualification and

Disciplinary Commission of

Prosecutors

Q3 2026 Entry into force of the legislation improving the disciplinary system for prosecutors and

strengthening the institutional capacity of the Qualification and Disciplinary

Commission of Prosecutors (QDCP). The improved legal and institutional framework

aimed at implementing GRECO recommendations focuses on these main areas:

- specification of disciplinary offences related to the conduct of prosecutors and their

compliance with ethical standards, and expansion of the list of available disciplinary

sanctions to increase their proportionality and effectiveness;

- amending the provisions on the composition of the QDCP to ensure that the majority

of seats are held by prosecutors elected by their colleagues and conducting an

independent and objective procedure for the pre-selection of all candidates for members

of the QDCP, which includes verification of their integrity;

- increasing the efficiency of disciplinary proceedings by extending the statute of

limitations.

3.14 Reform 4.

Reform of the

Prosecution Service

An e-Case Management

System in the criminal

justice is operational

Q4 2026 The criminal justice e-Case Management System’s system-forming module, electronic

criminal proceedings module, and case analysis module are operational, enabling digital

processing of criminal cases and gradually replacing/significantly upgrading the

outdated Unified Register of Pre-Trial Investigations.

3.15 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

A new court to hear

administrative cases is

operational

Q4 2026 The Specialised District Administrative Court and the Specialised Administrative Court

of Appeal become operational.

3.16 Reform 1.

Enhancing the

accountability,

integrity and

professionalism of

the judiciary

Entry into force of

legislation extending the

involvement of independent

experts nominated by

international partners in the

selection of members of the

High Qualification

Commission of Judges of

Ukraine

Q4 2026 Entry into force of a law extending, in close cooperation with the European

Commission as regards the modalities, the involvement of independent experts

nominated by international partners in the selection commission for the High

Qualification Commission of Judges (HQCJ).

35

3.17 Reform 5.

Enhancing the

protection of

human rights

The adoption of the

Presidential Decree

approving the Human Rights

Protection Strategy

Q2 2026 Adoption of the Presidential Decree approving the Human Rights Protection Strategy.

The strategy focuses on these main areas:

- human rights in the context of the martial law regime and Ukraine’s post-war recovery

- rights of persons residing in the territory of Ukraine temporarily occupied by the

Russian Federation, near frontlines and internally displaced persons

- legal protection to persons who have suffered from gender-based violence

- rights of children in armed conflicts

- access to services for vulnerable persons.

36

C.4. FIGHT AGAINST CORRUPTION AND MONEY LAUNDERING

1. Description of Reforms and Investment

The objective of this chapter is to reinforce the key anti-corruption agencies and to update the legal framework

to increase the overall effectiveness of the anti-corruption framework and the implementation of the state’s

anti-corruption policy, which is essential for a favourable business and investment climate and sustainable

recovery and economic growth. The chapter also addresses the shortcomings related to asset recovery and

management at institutional and procedural levels and on alignment of Ukrainian legislation with Union

acquis and FATF standards in the field of anti-money laundering enabling to better tackle economic crime

and to improve the overall business climate in Ukraine.

Reform 1. Developing the institutional capacity of the anti-corruption framework.

The objective of this reform is to increase the overall capacity of the anti-corruption infrastructure to fight

corruption, including at the high level, via active and efficient investigation.

The reform has three steps. First, the Specialised Anti-Corruption Prosecutor’s Office (SAPO) is given the

opportunity to increase its manpower from 10 % to 15 %. Second, a new head of the National Agency on

Corruption Prevention (NACP) is appointed. Third, the number of judges and of the apparatus at the High

Anti-Corruption Court (HACC) is increased by 60 % and by 40 % respectively.

The reform is expected to be completed by Q1 2025.

Reform 2. Improving the legal framework for a more effective fight against corruption

The overall objective of the reform is to strengthen the key anti-corruption institutions and to streamline

criminal procedure to increase their efficiency, including in high-level corruption cases, while preventing

instances of procedural abuse and undue interferences. The reform also addresses the shortcomings related to

asset recovery and management at institutional and procedural levels.

The reform has nine steps. First, the amended Criminal Code and of the Criminal Procedure Code enters into

force. The amended legislation improves the provisions regulating plea bargaining; cancels the pre-trial

investigation period from the time of the registration of the criminal proceedings until the notification of the

suspicion and allow the adjudication of certain cases by a single judge of the High Anti-Corruption Court.

Second, the law reforming the Asset Recovery and Management Agency (ARMA) enters into force. Third, an

action plan for the implementation of the Asset Recovery Strategy for 2023-2025 is adopted. Fourth, a new

Anti-Corruption Strategy for the period 2026-2030 is adopted. Fifth, a State Anti-Corruption Program for

implementation of the Anti-Corruption Strategy covering the period 2026-2030 is adopted. Sixth, the amended

Criminal Procedure Code to ensure fast and high-quality justice enters into force. Seventh, the law reforming

the State Bureau of Investigation of Ukraine enters into force. Eight, a law ensuring effective, impartial and

timely access to high-quality forensic examinations by anti-corruption bodies enters into force. Ninth, the law

enabling single-judge adjudication of civil and administrative cases in the High Anti-Corruption Court enters

into force.

The reform is expected to be completed by Q4 2026.

37

Reform 3. Anti-money laundering measures

The objective of this reform is to further align Ukraine’s legal framework with the Union acquis and FATF

standards and to create an effective anti-money laundering system in Ukraine to better tackle economic crime

and improve the overall business climate in Ukraine.

The reform has seven steps. First, the next National Risk Assessment is conducted. Second, the legislation to

further reinforce the anti-money laundering system, including for the purpose of Ukraine’s application to join

the geographical scope of Single European Payment Area (SEPA) enters into force six months after

publication in the Official Gazette. Third, the legislation on information accompanying transfers of funds and

certain crypto-assets, including for the purpose of Ukraine’s application to join the geographical scope of

SEPA enters into force. Fourth, the amendments aimed at establishing criminal liability for illegal actions with

payment cards or other payment instruments in the interests of third parties enter into force. Fifth, the strategy

and action plan on financial investigations are adopted and the methodological guidelines for conducting

financial investigations are introduced. Sixth, the necessary software and hardware for the registry of accounts

and individual safe deposit boxes of individuals is operational. Seventh, the necessary software and hardware

for the registry of beneficial owners for trusts or other similar legal arrangements is operational.

The reform is expected to be completed by Q2 2027.

Reform 4. Combating Human Trafficking

The objective of this reform is to improve the legal framework on combating human trafficking and align it

with the relevant Union acquis.

The reform has one step. It entails the adoption of the State Program for Combating Human Trafficking until

2030 in line with the Union acquis and the Union Strategy on combating trafficking in human beings.

The reform is expected to be completed by Q2 2026.

38

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

4.1Reform 1.

Developing the

institutional capacity

of the anti-corruption

framework

Increased manpower for

the Specialised Anti-

Corruption Prosecutor’s

Office

Q3

2024The Specialised Anti-Corruption Prosecutor's Office is given the opportunity to

increase its manpower from 10 % to 15 % of the manpower of the National Anti-

Corruption Bureau.

4.2Reform 1.

Developing the

institutional capacity

of the anti-corruption

framework

Appointment of a new

head of the National

Agency on Corruption

Prevention

Q22024A new head of the National Agency on Corruption Prevention is appointed following a

selection procedure in line with the Law on the Prevention of Corruption

4.3Reform 1.

Developing the

institutional capacity

of the anti-corruption

framework

Increased manpower for

the High Anti-Corruption

Court

Q12025The personnel number of High Anti-Corruption Court (HACC) judges is increased by

60 %, and the HACC apparatus number is increased by 40 %.

4.4 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Entry into force of the

amended Criminal Code

and of the Criminal

Procedure Code

Q3 2024 Entry into force of the Laws of Ukraineon amending the Criminal Code of Ukraine and

the Criminal Procedure Code of Ukraine. The laws focus on these main areas:

- improvement of the provisions regulating plea bargain;

- cancellation of the pre-trial investigation period from the time of the registration of the

criminal proceedings until the notification of the suspicion;

- allowing to adjudicate certain cases by a single-judge of the High Anti-Corruption

Court.

4.5 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Adoption of the new Anti-

Corruption Strategy for

the period 2026-2030

Q3 2026 Adoption and publication by the Parliament of an Anti-Corruption Strategy covering

the period 2026-2030.

4.6 Reform 2. Adoption of an Action

Plan for the

implementation of the

Q3

2024 Adoption and publication on the website of the Cabinet of Ministers of an Action Plan

for the implementation of the Asset Recovery Strategy for 2023-2025.

39

Improving the legal

framework for a

more effective fight

against corruption.

Asset Recovery Strategy

for 2023-2025

4.7 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption.

Entry into force of the law

reforming the Asset

Recovery and

Management Agency

Q1

2025 Entry into force of the Law reforming the Asset Recovery and Management Agency.

The law focuses on these main areas:

- a transparent and merit-based selection procedure for the head of the agency,

including a credible integrity and professionalism check;

- an independent external performance assessment system;

- transparent procedure for the management and sale of seized assets under the agency’s

control.

4.8 Reform 3.

Anti-money

laundering measures

Conduct of the next

National Risk Assessment

Q4 2025 Preparation and implementation of the next National Risk Assessment in accordance

with the updated Methodology for the National Assessment of money laundering and

terrorist financing risks in Ukraine

4.9 Reform 3. Anti-

money laundering

measures

Publication in the Official

Gazette of the legislation

to further reinforce the

anti-money laundering

system, including for the

purpose of Ukraine’s

application to join the

geographical scope of

Single European Payment

Area (SEPA) schemes,

with an entry into force

six months after the date

of publication in the

Official Gazette

Q3 2026 Entry into force six months after publication in the Official Gazette of legislation to

further reinforce the anti-money laundering system, including for the purpose of

Ukraine’s application to join the geographical scope of Single European Payment Area

(SEPA) schemes.

The legislation focuses on:

- rules on anti-money laundering and countering financing of terrorism, including, inter

alia, on registry of bank accounts for individuals and personal bank deposit boxes, and

the register of beneficial owners for trusts or other similar legal arrangements in line

with the principles of:

- Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May

2015 on the prevention of the use of the financial system for the purposes of money

laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the

European Parliament and of the Council, and repealing Directive 2005/60/EC of the

European Parliament and of the Council and Commission Directive 2006/70/EC;

- Directive (EU) 2019/1153 of the European Parliament and of the Council of 20 June

2019 laying down rules facilitating the use of financial and other information for the

40

prevention, detection, investigation or prosecution of certain criminal offences, and

repealing Council Decision 2000/642/JHA.

4.10. Reform 3. Anti

money-laundering

measures.

The necessary software

and hardware for the

registry of accounts and

individual safe deposit

boxes of individuals and

is operational and access

is ensured to relevant

authorities

Q2 2027 The necessary software and hardware for the registry of accounts and individual safe

deposit boxes of individuals is operational and access is ensured to relevant authorities.

4.11 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Adoption of the new State

Anti-Corruption Program

for the period 2026-2030

Q4 2026 A State Anti-Corruption Programme for implementation of the Anti-Corruption

Strategy covering the period 2026-2030 is adopted by the Government and published.

4.12 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Entry into force of the

amendments to the

Criminal Procedure Code

to ensure fast and high-

quality justice

Q4 2026 Entry into force of the amendments to the Criminal Procedure Code to ensure fast and

high-quality justice. These amendments focus on:

- removing the automatic closure of criminal cases due to the expiry of pre-trial

investigation time limits and reviewing the current time limits;

- addressing procedural impediments in criminal proceedings, particularly in high-level

corruption cases;

- ensuring that statute of limitations and grounds for their interruption / suspension are

strengthened, in line with European standards;

- expanding the jurisdiction of NABU to cover the high-risk positions based on the

available independent assessment.

4.13 Reform 2.

Improving the legal

framework for a

Entry into force of a law

reforming the State

Bureau of Investigation of

Ukraine

Q4 2026 Entry into force of the law reforming the State Bureau of Investigation, taking into

account the independent comprehensive review of the SBI, as available, including the

following elements:

41

more effective fight

against corruption

- meaningful involvement of international experts, in particular for the transparent and

merit-based selection procedure for the head of the bureau;

- a mechanism for attestation of managerial level staff;

- an independent external performance assessment conducted by independent experts

nominated by international partners.

4.14 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Enabling single-judge

adjudication of civil and

administrative cases in the

High Anti-Corruption

Court

Q4 2026 Entry into force of the amendments to Civil Procedure Code and to the Code of

Administrative Procedure of Ukraine, enabling single-judge adjudication of civil and

administrative cases in the High Anti-Corruption Court (HACC).

4.15 Reform 2.

Improving the legal

framework for a

more effective fight

against corruption

Entry into force of a law

ensuring effective,

impartial and timely

access to high-quality

forensic examinations by

anti-corruption bodies

Q4 2026 Entry into force of legislation that:

- ensures the institutional and operational independence of the Scientific Research

Centre of Independent Forensic Expertise (SRCIF) by taking measures necessary for

the proper functioning of the supervisory body with participation of members,

appointed in accordance with the procedure established by legislation, and that will be

responsible, inter alia, for the selection of the Head of the SRCIF, submitting proposals

for his dismissal, evaluating his performance, and that shall also be empowered to

participate in inspections of the SRCIF and in disciplinary proceedings concerning

SRCIF personnel;

- ensures timely access by NABU to SRCIF-provided forensic services, as a rule within

2 months, as well as an increase of the SRCIF’s overall operational capacity;

- expands opportunities to use private forensic expertise by limiting the exclusive

competence of state expert institutions to a more narrow, legally defined list of

examinations.

4.16 Reform 3. Anti-

money laundering

measures

Entry into force of

legislative amendments

on information

accompanying transfers of

funds and certain crypto-

assets

Q3 2026 Entry into force of legislative amendments on information accompanying transfers of

funds and certain crypto-assets in line with the principles of Regulation (EU)

2023/1113 of the European Parliament and of the Council of 31 May 2023 on

information accompanying transfers of funds and certain crypto-assets and amending

Directive (EU) 2015/849.

42

4.17 Reform 3. Anti

money-laundering

measures.

The necessary software

and hardware for the

registry of beneficial

owners for trusts or other

similar legal arrangements

is operational and access

is ensured to relevant

authorities

Q2 2027 The necessary software and hardware for the registry of beneficial owners for trusts or

other similar legal arrangements is operational and access is ensured to relevant

authorities.

4.18 Reform 3.

Anti-money

laundering measures

Entry into force of

amendments aimed at

establishing criminal

liability for illegal actions

with payment cards or

other payment

instruments in the

interests of third parties

Q3 2026 Entry into force of amendments aimed at establishing criminal liability for illegal

actions with payment cards or other payment instruments in the interests of third

parties, in line with the principles of Directive (EU) 2019/713.

4.19 Reform 3.

Anti-money

laundering measures

Adoption of a strategy

and action plan on

financial investigations

and the introduction of

methodological guidelines

for conducting financial

investigations

Q4 2026 The adoption of a strategy and action plan on financial investigations, taking into

account recommendations from EU and technical assistance, and the introduction of

methodological guidelines for conducting financial investigations in the secondary

legislation, including on money laundering, aiming to increase in the number of stand-

alone money laundering cases/convictions. The action plan should include key elements

from the strategy as well as the auditing of ongoing cases for retro-active opening of

financial investigations. The methodological guidelines should focus particularly on

criteria for opening of financial investigations, methods and resources to be used,

mechanisms for data exchange (including with foreign jurisdictions), use of Joint

Investigation Teams, methods to build evidentiary basis, effectiveness monitoring and

review.

4.20 Reform 4.

Combatting

Human Trafficking

Adoption of the State

Program for Combatting

Human Trafficking until

2030 in line with the EU

acquis and the EU

Strategy on combatting

Q2 2026 Developing and approving the State Programme for Combatting Human Trafficking

until 2030 in line with the principles of Directive 2011/36/EU of the European

Parliament and of the Council of 5 April 2011, as amended by Directive 2024/1712 of

the European Parliament and of the Council of 13 June 2024, the EU Strategy on

combatting trafficking in human beings, and the recommendations of the Council of

Europe Group of Experts on Action against Trafficking in Human Beings (GRETA).

43

trafficking in human

beings

44

C.5. FINANCIAL MARKETS

1. Description of Reforms and Investments

The objective of this Chapter is to leverage the potential of Ukraine’s financial sector to drive

economic growth and support recovery, by monitoring the health of the banking sector to

maintain financial stability, strengthening regulatory framework in aligning with Union

standards, addressing non-performing loans, and improving the regulation of capital markets.

Reform 1. Assessment of the banking sector

The objective of this reform is to return to the regular assessment process, identify potential

vulnerabilities within major banks, and ensure the resilience of the banking system in Ukraine.

The reform has one step. The National Bank of Ukraine shall carry out a resilience assessment

of the largest banks that includes stress testing under the adverse scenario as well as an

independent Asset Quality Review.

The reform is expected to be completed by Q1 2026.

Reform 2. Reducing state ownership in the banking sector

The objective of this reform is to lay down the principles for the sale of state-owned banks and

the strategy for gradually reducing state ownership in the banking sector.

The reform has two steps. First, an updated legislation shall establish guiding principles for the

sale of varying ownership stakes in SOBs, while also providing the flexibility for complete

acquisition. Second, a strategy shall be adopted, preparing for a gradual reduction of state-

ownership in SOBs.

The reform is expected to be completed by Q2 2026.

Reform 3. Improved resolution of non-performing loans

The objective of this reform is to improve the resolution of non-performing loans (NPLs).

The reform has two steps. First, Ukraine shall adopt a strategy for the resolution of NPLs,

focusing on prudential requirements and improving the framework for NPL restructuring and

resolution. Second, the subsequent legislative amendments to the relevant laws shall be

adopted, addressing the recommendations of the strategy.

The reform is expected to be completed by Q2 2026.

45

Reform 4. Improved capacity of the financial supervisory authority

The objective of this reform is to improve the state regulation for capital markets and organised

commodity markets.

The reform has one step. It entails the entry into force of the law on the improvement of state

regulation for capital markets and organised commodity markets, aligned with International

Organization of Securities Commissions (IOSCO) standards.

The reform is expected to be completed by Q4 2025.

46

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

5.1 Reform 1.

Assessment of the

banking sector

Published Resilience

assessment in the banking

system

Q1 2026 The National Bank of Ukraine (NBU) publishes the Resilience Assessment of the

largest banks in the banking system (in terms of assets) that includes stress testing under

the adverse scenario, and the results of an independent Asset Quality Review if

conditions allow it to be carried out.

5.2 Reform 2.

Reducing state

ownership in the

banking sector

Entry into force of the

legislation on the principles

for the sale of state-owned

banks

Q3 2025 Entry into force of the updated legislation on the sale of state-owned banks, namely, the

Law of Ukraine “On Divesting State-Owned Shareholdings in the Charter Capital of

Banks that Have Undergone Recapitalisation by the State" No. 4524-VI dated 2012.

The revised legislation should facilitate the sale of varying ownership stakes in State-

owned banks (SOBs), while also providing the flexibility for complete acquisition. The

fundamental principles guiding the sale of SOBs will be developed through

collaborative discussions and in consensus with the international donors.

5.3 Reform 2.

Reducing state

ownership in the

banking sector

Adoption of the strategy for

gradual reduction of state

ownership in the banking

sector

Q2 2026 Adoption of the resolution of the Government or other legal act of the Government

adopting the reform strategy for the SOBs, which sets out a gradual reduction in state

ownership in the banking sector. The strategy focuses on these main areas:

- financial health and stability;

- management of non-performing loans;

- mitigation of fiscal risks;

- enhancement of bank governance and operational efficiency;

- bank value enhancement, long-term viability, and steps towards privatisation (when

relevant).

5.4 Reform 3.

Improved

resolution of non-

performing loans

Adoption of the strategy for

resolution of non-

performing loans

Q2 2025 Adoption of the strategy for resolution of non-performing loans in line with the relevant

Union practices. The strategy focuses on these main areas:

- strengthening of the prudential requirements for the NPL recognition and resolution;

- exchange of data on the NPLs and other relevant market data between the financial

institutions and state agencies to improve NPL resolution;

- review of potential obstacles and development of measures to improve the framework

for NPL restructuring and resolution.

47

5.5 Reform 3.

Improved

resolution of non-

performing loans

Entry into force of legal acts

to improve resolution of

non-performing loans

Q2 2026 Entry into force of the legal acts implementing the recommendations of the strategy for

resolution of non-performing loans improving the system of NPLs resolution. In

particular, these legal acts aim to:

- improve the definition of NPL and implement requirements on preventive

restructuring, in line with the principles of the EU acquis;

- reinstating the requirement for banks to update and submit plans and strategies for

dealing with NPLs;

- improve the procedure for selecting a bankruptcy trustee and supervising their

activities and for conducting auctions to sell the bankrupt’s property;

- improve the procedure and access to bankruptcy and restructuring procedures for

individuals, micro and small enterprises;

- introduce safeguards in the Code of Ukraine on Bankruptcy Procedures to prevent

fraudulent actions of participants and limit the influence of related parties of the debtor

on bankruptcy proceedings;

- improve the legislation on debt collection and debt treatment

- introduce in Ukraine regulatory conditions favouring the NPL market’s development

and operation, and to attract foreign investment to this market.

5.6 Reform 4.

Improved capacity

of the financial

supervisory

authority

Entry into force of the law

on the improvement of the

state regulation for capital

markets and organised

commodity markets

Q4 2025 Entry into force of the Law on the improvement of state regulation for capital markets

and organised commodity markets, aligning it with IOSCO standards. This refers to the

ability of the National Commission on Securities and Stock Market (NSSMC) to

operate free from external influence, particularly from political or industry pressures,

make decisions based on the law and the best interests of market integrity and investor

protection, rather than external interests, and have strong enforcement mechanisms and

international cooperation.

48

C.6. MANAGEMENT OF PUBLIC ASSETS

1. Description of Reforms and Investments

The objective of this chapter is to improve the state ownership policy, corporate governance

and management of Ukraine’s state-owned enterprises (SOEs) as well as to harmonise the State

Aid framework with the Union acquis. This serves to improve transparency and efficiency and

supports strengthening the level playing field with the private sector.

Reform 1. Adopting a state ownership policy

The objective of this reform is to adopt a state ownership policy that would reflect long-term

and whole-of-government priorities of SOEs ownership. The triage of SOEs shall be renewed

according to the principles laid out in the state ownership policy. The triage of SOEs shall result

in a list of SOEs that will remain in state ownership as strategic, a list of SOEs that will be

proposed for privatisation, also indicating all SOEs which are temporarily banned for

privatisation during the martial law in a dedicated subsection, and a list of SOEs which will be

liquidated.

The reform has one step. It entails entry into force of legislation introducing the state ownership

policy, and the publication of the triage of SOEs.

The reform is expected to be completed by Q4 2024.

Reform 2. Improved governance and management of state-owned enterprises

The objective of this reform is to facilitate the transition from the state unitary enterprise legal

form into more commercially oriented forms, to foster a more efficient and transparent

governance framework for state-owned enterprises (SOEs) via enhancing corporate

governance standards and implementation in top SOEs.

The reform has seven steps. First, a new law enters into force that improves corporate

governance of SOEs taking into account OECD guidelines2, including by defining the powers

of SOEs’ supervisory boards. Second, supervisory boards with a majority of independent

members in at least 15 top key SOEs are appointed. Third, Ukraine corporatises at least 15 top

key SOEs as either joint-stock companies or limited liability companies. Fourth, a roadmap is

adopted, providing for the lifting of SOE moratoria and gradual lifting of SOE moratoria on

debt enforcement. Fifth, amendments to the legislation on SOEs enter into force, bringing

operational autonomy and internal controls of SOEs closer to OECD standards. Sixth,

independent external evaluations are performed for top SOEs. Seventh, authorities submit the

first annual report showing that the principles of corporate governance are duly followed.

2 OECD (2015), OECD Guidelines on Corporate Governance of State-Owned Enterprises, OECD, Paris,

https://www.oecd.org/en/publications/oecd-guidelines-on-corporate-governance-of-state-owned-enterprises-

2024_18a24f43-en.html

49

The reform is expected to be completed by Q3 2027.

Reform 3. Separation of accounts between public service obligations (PSO) and non-PSO

activities in state-owned enterprises

The objective of this reform is to strengthen the level playing field with the private sector, as

well as further convergence with the EU acquis via a separation of accounts between activities

connected to Public Service Obligations (PSOs) from non-PSOs activities.

The reform has three steps. First, Ukraine shall adopt and publish a Roadmap defining the

necessary steps for mandatory structural separation of accounts between PSO and non-PSO

activities for all SOEs engaged in PSOs. Second, entry into force of the legislation to align with

the Directive 2006/111 of the European Commission, which will ensure that mandatory

structural separation of accounts between PSO and non-PSO activities is defined and

implemented. Third, Ukraine shall publish an independent audit report on top SOEs engaged

in the PSOs, including on the implementation of accounts separation and market compliance

on cross-subsidisation.

The reform is expected to be completed by Q3 2027.

Reform 4. Improved state aid control framework

The objective of this reform is to lift the suspension of application of State aid control and align

the State aid control framework with that of the Union, which would result in more

transparency over the state funding to SOEs.

The reform has one step. It entails the updating of legislation on state aid, including provisions

in relation to services of general economic interest, together with the full lifting of suspension

of application of state aid control by the Antimonopoly Committee of Ukraine.

The reform is expected to be completed by Q4 2025.

50

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

6.1 Reform 1.

Adopting a

state ownership

policy

Adoption of the state

ownership policy and

of the triage of state-

owned enterprises

Q4 2024 Adoption and publication of the Resolution of the Cabinet of Ministers of Ukraine on Approving

the General State Ownership Policy and the ‘triage’ of SOEs. The State Ownership Policy

focuses on these main areas:

- listing the public policy objectives that SOEs are required to achieve;

- describing the state’s role in the governance of SOEs; how the state will implement its

ownership policy; and the respective roles and responsibilities of those government authorities

involved in its implementation;

- defining the overall rationales for keeping SOEs under state ownership and subjects these

rationales to regular reviews;

- setting long-term and whole-of-government priorities of SOEs ownership;

- defining dividend policy, remuneration policy for members of supervisory boards and

managers.

The ownership policy allows for the implementation of OECD Corporate governance reforms in

DSO companies to improve competition in natural gas markets.

The triage of SOEs leads to the following outcomes:

- a list of SOEs that will remain in state ownership as strategic;

- a list of SOEs that will be proposed for privatisation, also indicating all SOEs which are

temporarily banned for privatisation during the martial law in a dedicated subsection;

- a list of SOEs which will be liquidated.

6.2 Reform 2.

Improved

governance and

management of

state-owned

enterprises

Entry into force of the

legislation on corporate

governance of state-

owned enterprises

Q2 2024 Entry into force of the new law on corporate governance of SOEs taking into account OECD

guidelines on corporate governance. The law focuses on these main areas:

- defining the powers of SOEs’ supervisory boards to appoint and dismiss CEOs;

- defining the powers of SOEs’ supervisory boards to approve the strategic, investment and

financial plans documents of SOEs;

- establishing an annual evaluation procedure for the supervisory boards of SOEs.

6.3 Reform 2. Appointment of

Supervisory boards of

Q2 2026 Supervisory boards with a majority of independent members are appointed for at least 15 SOEs

from the list of top key SOEs approved by the Cabinet of Ministers protocol decision. The

51

Improved

governance and

management of

state-owned

enterprises

state-owned enterprises

with a majority of

independent members

nomination of the Supervisory board members is conducted via competitive selection process,

on the basis of procedures agreed and in place at the time of the start of the selection.

6.4 Reform 2.

Improved

governance and

management of

state-owned

enterprises

Corporatisation of key

state-owned enterprises

Q3 2026 At least 15 SOEs from the list of top key SOEs approved by a Cabinet of Ministers protocol

decision are corporatised as either joint-stock companies or limited liability companies.

6.5 Reform 2.

Improved

governance and

management of

state-owned

enterprises

Submission of a report

showing that the

principles of corporate

governance are duly

followed

Q3 2027 The first annual report with the financial and operational results showing that the principles of

corporate governance are duly followed is shared with the European Commission. The report

also assesses the independence of Supervisory boards’ decision-making, in particular in at least

15 SOEs from the list of top key SOEs, including whether decisions on strategic matters and

managerial appointments require a de facto consent from the government.

Before the audit, the following key principles of corporate governance are put in place and

enforced:

- the roles of the Cabinet of Ministers, Ministry of Finance, the Ministry of Economy are clearly

defined, and the Parliament oversight is enforced;

- the mandate and scope of the consolidated SOE management entities are clearly defined fully

in line with the State Ownership Policy;

- public finance management considerations are embedded in top SOEs’ charters (and, if needed

in those of the consolidated SOE management entities);

- top SOEs charters, when needed, are amended in line with the corporate governance reform

principles, including to ensure the independence of supervisory boards in decision making.

6.6 Reform 3.

Separation of

accounts

between public

service

Adoption of Roadmap

on the separation of

public service

obligations (PSO) and

non-PSO activities

Q1 2025 Adoption and publication of the Roadmap defining the steps for mandatory structural separation

of PSO and non-PSO activities for all SOEs engaged in PSOs. The Roadmap is based on the

identified current level of adoption of required accounting approaches and include operational

steps for the separation of accounts for companies on different stages of implementation of

required changes. The Roadmap describes how the account separation between PSO and non-

52

obligations

(PSO) and non-

PSO activities

in state-owned

enterprises

PSO activities will be performed in all top key SOEs approved by the Cabinet of Ministers

protocol decision.

6.7 Reform 3.

Separation of

accounts

between public

service

obligations

(PSO) and non-

PSO activities

in state-owned

enterprises

Entry into force on

legislation on the

separation of public

service obligations

(PSO) and non-PSO

activities

Q4 2025 Entry into force of the legislation identified in the Roadmap adopted under step 6.6 to align with

the Directive 2006/111 of the European Commission, which will ensure that mandatory

structural separation of accounts between PSO and non-PSO activities is defined and

implemented in all top key SOEs approved by the Cabinet of Ministers protocol decision which

are engaged in PSOs.

6.8 Reform 3.

Separation of

accounts

between public

service

obligations

(PSO) and non-

PSO activities

in state-owned

enterprises

Submission of an audit

report confirming the

separation of public

service obligations

(PSO) and non-PSO

activities

Q3 2027 Submission of an independent audit report conducted by an audit company that is part of the

international auditing network and, according to national legislation, has the right to conduct a

mandatory audit of the financial statements of enterprises of public interest. Such a report

contains a detailed assessment on the following areas for the top key SOEs approved by the

Cabinet of Ministers protocol decision, engaged in PSO:

- implementation of accounts separation;

- market compliance on cross-subsidisation;

- definition of public service obligations for each SOE;

- costs, financial flows and liabilities stemming from the Public Service obligations.

6.9 Reform 4.

Improved state

aid control

framework

Entry into force of the

updated legislation on

state aid and full

unsuspension of the

application of state aid

control

Q4 2025 Entry into force of the updated legislation on state aid, including provisions in relation to

services of general economic interest, together with the full unsuspension of the application of

state aid control by the Antimonopoly Committee of Ukraine, with the exception of the

recapitalization by the State of systemically important banks holding state secrecy clearance for

financing of the defence industry for the duration of martial law. The law will also allow

for specific appropriate aid schemes for support to SMEs provided under martial law.

6.10 Reform 2.

Improved

governance and

Adoption of the

roadmap for lifting

SOE moratoria and

Q4 2026 Adoption of the roadmap for lifting SOE moratoria and gradual lifting of SOE moratoria on debt

enforcement.

53

management of

state-owned

enterprises

gradual lifting of SOE

moratoria on debt

enforcement

6.11 Reform 2.

Improved

governance and

management of

state-owned

enterprises

Entry into force of the

amendments to the

legislation on state-

owned enterprises,

bringing operational

autonomy and internal

controls of SOEs closer

to OECD standards

Q4 2026 Amend relevant laws, bringing operational autonomy and internal controls of SOEs closer to

OECD standards, including:

- to increase the autonomy and the role of the supervisory boards by (i) ensuring that the CEO

reports exclusively to the board, (ii) strengthening the board’s role in

core governance matters, including the development and adoption of the corporate governance

code, (iii) making more effective its decision-making by relying more on simple majority

decisions as opposite to qualified majority decisions and (iv) ensuring appropriate access to the

board of all companies’ information,

-to strengthen the composition of the board and its accountability by (i) linking the extension of

board members’ mandate to objective and performance-based criteria, and (ii) extending the

independent external evaluation of the board to all SOEs that are required to have a supervisory

board,

- to foster sound internal governance practices by (i) introducing size- and risk-based

thresholds identifying large SOEs to be equipped with independent risk-management and

compliance functions, and (ii) ensuring the internal auditors have access to all

relevant information;

- to foster the integrity of SOEs by strengthening the framework for related-party and

significant transactions in line with EU acquis.

6.12 Reform 2.

Improved

governance and

management of

state-owned

enterprises

Independent

assessments of key

corporate governance

systems for selected

nondefense SOEs in

accordance with

Cabinet of Ministers

Ordinance No. 1223

with the involvement

of external auditors

and/or consultancies.

Q4 2026 Completion and publication of independent comprehensive governance assessments of key

corporate governance systems, including internal control, risk management, public procurement,

corporate integrity and anti-corruption frameworks, for selected non-defense SOEs in

accordance with Cabinet of Ministers Ordinance No. 1223, as amended, conducted with the

involvement of external auditors and/or consultancies in line with internationally recognized

standards and methodologies.

54

C.7. HUMAN CAPITAL

1. Description of Reforms and Investments

The objective of this chapter is to present reforms considered necessary to halt recent years’ erosion of human

capital, while simultaneously laying a foundation for a sustainable recovery, reconstruction and modernisation

process.

Reform 1. Improved vocational education

The objective of this reform is to ensure that education meets the needs of the labour market and the country’s

recovery via expanding the institutional capacity of educational entities to provide formal and non-formal

vocational education, and regulating the relations between vocational education institutions, national/local and

international stakeholders for the sustainable development of human capital in Ukraine.

The reform has one step. It entails the entry into force of the law on vocational education.

The reform is expected to be completed by Q2 2025.

Reform 2. Improved preschool education

The objective of this reform is to ensure access to quality preschool education with the aim to increase the

involvement of women with preschool children into the labour market.

The reform has one step. It entails the entry into force of the law on preschool education.

The reform is expected to be completed by Q1 2025.

Reform 3. Improved rehabilitation system for people with disabilities

The objective of this reform is to improve the rehabilitation system and to allow for a broader assessment of

people’s needs through a new electronic system.

The reform has one step. It entails the entry into force of legislation for aligning with international standards

for measuring functioning, disability and health, and introducing an electronic system containing information

about the needs of the individual and automatically offering services in accordance with the identified needs.

The reform is expected to be completed by Q2 2027.

Reform 4. Transition from military service to civilian life

The objective of this reform is to facilitate the transition from military service to civilian life, including active

participation in social and economic life.

The reform has one step, namely the implementation of a case management system supporting veterans and

demobilised personnel in their return and transition into civilian life.

The reform is expected to be completed by Q2 2027.

55

Reform 5. Improved social infrastructure and de-institutionalisation

The objective of this reform is to improve the well-being of children, persons with disabilities, and the

elderly in the public care system.

The reform has one step. It entails the adoption of two strategies for reforming psychoneurological and other

residential institutions and de-institutionalisation of care for children, persons with disabilities and the elderly.

The reform is expected to be completed by Q4 2024.

Reform 6. Improved functioning of the labour market

The objective of this reform is to contribute to the improved functioning of the labour market.

The reform has four steps. First, a strategy shall be adopted aiming to improve the demographic situation of

Ukraine up to 2040, including reducing premature mortality, and overcoming negative migration trends.

Second, a population employment strategy shall be adopted that proposes measures to update the conditions

of Ukraine’s labour market, such as simplified access to the labour market, and a reformed state employment

service. Third, the Operational Plan of Measures for the implementation in 2026–2028 of the National Strategy

for Overcoming the Gender Pay Gap for the period up to 2030 is approved. Fourth, the legislation on

Occupational Safety and Health enters into force.

The reform is expected to be completed by Q4 2026.

Reform 7. Ensuring access to housing for people in need

The objective of this reform is to develop the framework for a social housing system.

The reform has two steps. First, legislation shall enter into force that that establishes key priorities for

Ukraine’s housing policy, such as the need for transparency, accessibility for most vulnerable groups, or the

creation of support schemes. Second, legislation establishing a social housing shall enter into force.

The reform is expected to be completed by Q2 2027.

Reform 8. Improved social security

The objective of this reform is to improve the provision of public social services, through the introduction of

mechanisms for procuring certain social services from registered providers.

The reform has one step. It entails the adoption of a resolution that reforms the social procurement system for

social services, changes the financing model to a result-oriented purchasing model of social services, and

incentivises the provision of social services usually not financed by the community.

The reform is expected to be completed by Q2 2025.

Reform 9. Improved cultural development

56

The objective of this reform is to promote Ukraine’s cultural heritage.

The reform has one step. It entails the adoption of a strategy that establishes priority goals such as improving

the quality and accessibility of Ukraine’s cultural offer, as well as capacity building for Ukraine’s cultural

institutions.

The reform is expected to be completed by Q1 2025.

Investment 1. Investments in education

The objective of this investment is to improve access to safe and quality public education.

The investment has two steps. First, it entails the budgeting of at least EUR 300 million in current prices (in

UAH equivalent) for improving access to safe and quality education for the years 2024 and 2025. Second, it

entails the budgeting of at least EUR 650 million in (UAH equivalent) for improving the access to safe and

quality education for the years 2024, 2025, 2026, and 2027.

The investment is expected to be completed by Q3 2027.

Investment 2. Investments in healthcare

The objective of this investment is to improve Ukraine’s public healthcare system.

The investment has two steps. First, it entails budgeting at least EUR 200 million in current prices (in UAH

equivalent) for strengthening of the healthcare infrastructure and facilities, digitalisation of healthcare

services, and the provision of equipment for medical analysis, surgery, and patient care for the years 2024 and

2025. Second, it entails budgeting at least EUR 400 million (in UAH equivalent) for strengthening the

healthcare infrastructure and facilities, digitalisation of healthcare services, and the provision of equipment

for medical analysis, surgery, and patient care for the years 2024, 2025, 2026 and 2027.

The investment is expected to be completed by Q3 2027.

Investment 3. Investments in social infrastructure

The objective of this investment is to strengthen Ukraine’s social infrastructure.

The investment has one step. It entails the budgeting of at least EUR 350 million in current prices (in UAH

equivalent) for the restoration, construction (new construction, reconstruction, overhaul, restoration) of

damaged/destroyed social infrastructure.

The investment is expected to be completed by Q3 2027.

Investment 4. Investments in housing support for damaged or destroyed housing and for internally displaced

persons

57

The objective of this investment is to improve access to affordable housing and improve the quality and

accessibility of housing.

The investment has one step. It entails the budgeting of at least EUR 510 million in current prices (in UAH

equivalent) for the housing support measures for persons whose housing was damaged or destroyed as a result

of Russia’s war of aggression as well as those lost as a result of displacement from territories temporarily

occupied by Russian Federation.

The investment is expected to be completed by Q3 2027.

Investment 5. Investments in housing provision for vulnerable groups of the population

The objective of this investment is to improve access to affordable housing and improve the quality and

accessibility of housing with particular focus on veterans, with disabilities, their family members and

internally displaced persons (IDPs).

The investment has two steps. First, it entails the budgeting of at least EUR 200 million in current prices (in

UAH equivalent) for the provision of housing for persons with disabilities of group I-II for the years 2024 and

2025. Second, it entails the budgeting of at least EUR 540 million (in UAH equivalent) for the provision of

housing for persons with disabilities of group I-II for the years 2024, 2025, 2026 and 2027.

The investment is expected to be completed by Q3 2027.

58

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

7.1 Reform 1.

Improved

vocational

education

Entry into force of the legislation on

vocational education

Q2 2025 Entry into force of the Law of Ukraine “On Vocational Education.” The law

focuses on these main areas:

- fair rules for the functioning of educational entities in the market of

educational services in the field of vocational education are defined;

- the institutional capacity of educational entities to provide formal and non-

formal vocational education is expanded;

- relations between vocational education institutions, national/local and

international stakeholders for the sustainable development of human capital in

Ukraine are clearly defined.

7.2 Reform 2.

Improved

preschool

education

Entry into force of the legislation on

preschool education

Q1 2025 Entry into force of the Law of Ukraine “On Preschool Education” in alignment

with the Council Recommendation of 22 May 2019 on High-Quality Early

Childhood Education. The law focuses on these main areas:

- guarantees of access to preschool education for children of early and preschool

age;

- fair rules for the functioning of educational entities in the market of

educational services in the field of preschool education;

- decent working conditions for employees in the field of preschool education;

- the rules for the functioning of a flexible and efficient network of preschool

education providers.

7.3 Reform 3.

Improved

rehabilitation

system for people

with disabilities

Entry into force of the legislation on

rehabilitation of persons with

disabilities

Q2 2027 Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine

“On Rehabilitation of Persons with Disabilities in Ukraine”.

The law focuses on these main areas:

- use of the International Classification of Functioning Disability and Health;

- introduction of an electronic system that contains information about the needs

of the individual and automatically offers services in accordance with the

identified needs (social, medical, and other).

59

7.4 Reform 4.

Transition from

military service

to civilian life

Implementation of a case

management system supporting

veterans and demobilised personnel

in their return and transition into

civilian life

Q2 2027 Implementation of a case management system, complementary to and

interoperable with other case management systems of the Government of

Ukraine, supporting veterans and demobilised personnel in their return and

transition into civilian life, that ensures the streamlining of public services related

to physical and mental rehabilitation, social services, economic reintegration and

housing support for veterans and demobilised personnel. The system should

provide information for performance-based monitoring, such as:

- number of veterans and demobilised personnel referred to and number that

received physical and mental rehabilitation programmes;

- number of veterans and demobilised personnel that requested and received

support with employment including education/skills development;

- number of veterans and demobilised personnel in a need of and that received

housing support;

- geographic distribution of demand for veteran reintegration support services.

7.5 Reform 5.

Improved social

infrastructure and

de-

institutionalisatio

n

Adoption of the Strategy for

reforming Psychoneurological, Other

residential Institutions and De-

institutionalisation of Care for

Persons with Disabilities, and Older

Persons and of the Strategy for

Ensuring the Right of Every Child in

Ukraine to Grow Up in a Family

Environment for 2024-2028

Q4 2024 Adoption of the Order of the Cabinet of Ministers ‘On Approval of the Strategy

for Reforming Psychoneurological, Other Residential Institutions and De-

institutionalisation of Care for Persons with Disabilities and Older Persons’ and

of the Order of the Cabinet of Ministers ‘On Approval of the Strategy for

ensuring the right of every child in Ukraine to grow up in a family environment

for 2024-2028’. The strategies focus on these main areas:

- development of social services to support families with children, people with

disabilities and older persons to live independently in the community and prevent

institutionalisation;

- development of assisted living services for people with disabilities and older

people who need additional support;

-providing family-based forms of upbringing (e.g. foster care, guardianship, and

adoption) for children left without parental care.

7.6 Reform 6.

Improved

functioning of

the labour market

Adoption of the Demographic

Development Strategy for the period

up to 2040

Q3 2024 Adoption of the Order of the Cabinet of Ministers of Ukraine “On Approval of

the Demographic Strategy of Ukraine for the Period up to 2040”. The Strategy

focuses on these main areas:

- improving the situation in the field of fertility;

- reducing premature mortality, especially among men of working age;

60

- overcoming negative migration trends, through the return of forced migrants,

attracting representatives of the foreign diaspora to Ukraine, etc.;

- promoting active longevity;

- creating infrastructure and security preconditions for improving the

demographic situation.

7.7 Reform 6.

Improved

functioning of

the labour market

Adoption of the Population

Employment Strategy

Q2 2026 Adoption of the Order of the Cabinet of Ministers of Ukraine on approving the

Population Employment Strategy. The strategy focuses on these main areas:

- creation of favourable conditions for employment, including through

entrepreneurship and with a particular focus on women;

- simplification of access to the labour market;

- retraining and re-qualification;

- reform the state employment service;

- reform the labour market forecasting;

- incentives to attract foreign talent to the Ukrainian labour market foreign

entrepreneurs, highly skilled and working personnel and students.

7.8 Reform 7.

Ensuring access

to housing for

people in need

Entry into force of the legislation on

the Basic Principles of Housing

Policy

Q4 2025 Entry into force of the Law of Ukraine "On Basic Principles of Housing Policy".

The Law focuses on these main areas:

- accessibility of housing for the most vulnerable categories of citizens should

become the main principle in the provision of housing;

- creation of various support mechanisms for citizens with different financial

capacities and determination of criteria for access to them;

- regulating the legal basis for the introduction of lease of communal housing,

lease of communal housing with the right to buy;

- creating a transparent system for registering the housing needs of citizens to

ensure prompt response at the local level;

- creating a transparent framework for monitoring by the public, civil society

and the international community.

7.9 Reform 7. Entry into force of the legislation on

the Social Housing Fund

Q2 2027 Entry into force the Law of Ukraine on Amendments to the Law of Ukraine "On

Social Housing Fund" (or the new version of this Law). The Law focuses on

these main areas:

61

Ensuring access

to housing for

people in need

- establishing an institutional framework to ensure a sufficient supply of social

housing projects;

- establishing a transparent system for monitoring the needs of citizens to ensure

prompt response at the local level;

- establishing a transparent framework for monitoring by the public, civil society

and the international community;

- improving the capacity of the institutional framework to ensure a sufficient

supply of social housing projects;

- improving the rules for the establishment and operation of social housing,

including ensuring compliance with energy efficiency, safety, and other

standards.

7.10 Reform 8.

Improved social

security

Adoption of the resolution on the

procurement of social services

Q2 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on

purchasing social services at the expense of the state budget. The Resolution is

fiscally neutral and does not impact in any way the debt sustainability of

Ukraine and focuses on these main areas:

- transition from financing institutions to a result-oriented purchasing model of

social services;

- introducing a mechanism for purchasing certain social services from registered

public and private social service providers based on established social service

standards and criteria for providers.

7.11 Reform 9.

Improved

cultural

development

Adoption of the Strategy for the

Development of Ukrainian Culture

Q1 2025 Adoption of an Order by the Cabinet of Ministers approving the Strategy for the

Development of Ukrainian Culture. The strategy focuses on these main areas:

- preservation, safeguarding and promotion of cultural heritage and properties of

Ukrainian people as an integral part of common European cultural area,

preservation of national remembrance;

- rendering of high-quality and accessible cultural services and opportunities for

creative self-realisation of people;

- capacity building of Ukrainian cultural institutions to enhance accessibility,

share the best practices of cultural participation, and strengthen international

cultural relations;

62

- support to creative industries sector as a driver of social innovation and

employment, enhancement of institutional capacities of creative industries.

7.12 Investment 1.

Investments in

education

Investments of at least EUR 300

million in education

Q2 2026 Interim report of the government (or State Treasury report) showing that in the

State Budgets for 2024 and 2025 the general government budgeted in particular,

to the regional and local levels (as part of step 9.7), at least EUR 300 million (in

UAH equivalent) for improving the access to safe and quality education,

including preschool education in line with the new legislation on preschool

education, among others for the following:

- shelters and safe conditions in educational establishments;

- school buses;

- modern teaching method, including through digitalisation;

- materials and equipment for educational establishments;

- quality nutrition;

- establishment of workshops and laboratories in educational institutions;

- improvement of the energy efficiency of educational buildings.

7.13 Investment 1.

Investments in

education

Investments of at least EUR 650

million in education

Q3 2027 Final report of the government (or State Treasury report) showing that in the

State Budgets for 2024, 2025, 2026, and 2027, the general government budgeted

in particular, to the regional and local levels (as part of the step 9.8) at least

EUR 650 million (in UAH equivalent) for improving the access to safe and

quality education, including preschool education in line with the new legislation

on preschool education, among others for the following:

- shelters and safe conditions in educational establishments;

- school buses;

- modern teaching method, including through digitalisation;

- materials and equipment for educational establishments;

- quality nutrition;

- establishment of workshops and laboratories in educational institutions;

- improvement of the energy efficiency of educational buildings.

63

7.14 Investment 2.

Investments in

healthcare

Investments of at least EUR 200

million in healthcare

Q2 2026 Interim report of the government (or Treasury report) showing that in the State

Budgets for 2024 and 2025 the general government budgeted, part of which will

be budgeted to the regional level (as a part of step 9.7), at least EUR 200 million

(in UAH equivalent) for strengthening healthcare, among others for the

following:

- laboratory equipment for micro-biological, chemical, and physical analysis;

- shelters and safety measures for healthcare facilities;

- hospital equipment for medical analysis, surgery, and patient care;

- healthcare infrastructure and facilities;

- IT systems s to improve efficiency and effectiveness of healthcare services.

7.15 Investment 2.

Investments in

healthcare

Investments of at least EUR 400

million in healthcare

Q3 2027 Final report of the government (or Treasury report) showing that in the State

Budgets for 2024, 2025, 2026, and 2027, the general government budgeted, part

of which will be budgeted to the regional level (as part of step 9.8), at least EUR

400 million (in UAH equivalent) for strengthening healthcare, among others for

the following:

- laboratory equipment for micro-biological, chemical, and physical analysis;

- shelters and safety measures for healthcare facilities;

- hospital equipment for medical analysis, surgery, and patient care;

- healthcare infrastructure and facilities;

- IT systems to improve efficiency and effectiveness of healthcare services.

7.16 Investment 3.

Investments in

social

infrastructure

Investments of at least EUR 350

million in social infrastructure

Q3 2027 Final report of the government (or State Treasury report) showing that in the

State Budgets for 2026 and 2027 the general government budgeted at least EUR

350 million (in UAH equivalent) for the restoration, construction (new

construction, reconstruction, overhaul, restoration) of damaged/destroyed social

infrastructure, part of which will be budgeted to the regional level (as a part of

step 9.8), to eliminate the social, economic and environmental consequences

caused by the armed aggression of the Russian Federation against Ukraine, in

particular to the regional level.

7.17 Investment 4. Investments of at least EUR 510

million in housing support for

Q3 2027 Final report of the government (or State Treasury report) showing that in the

State Budgets for 2026, and 2027, the general government budgeted at least

64

Investments in

housing support

for damaged or

destroyed

housing and

housing support

for internally

displaced persons

damaged or destroyed housing and

housing support for internally

displaced persons

EUR 510 million (in UAH equivalent) for housing support measures for persons

whose housing was damaged or destroyed as a result of hostilities, terrorist acts,

sabotage caused by the military aggression of the Russian Federation, as well as

those lost as a result of displacement from territories temporarily occupied by

the Russian Federation, including compensation payments, housing certificates,

vouchers, and provision of social rental housing for internally displaced persons,

based on verified data from the State Register of Damaged and Destroyed

Property and other relevant state databases.

7.18 Investment 5.

Investments in

providing

housing for

vulnerable

groups of

population

Investments of at least EUR 200

million for providing housing to

veterans with disabilities of the I-II

groups, family members of deceased

veterans and internally displaced

persons

Q2 2026 Interim report of the government (or State Treasury report) showing that in the

State Budgets for 2024 and 2025 the general Government budgeted at least EUR

200 million (in UAH equivalent) for providing housing for:

- persons with disabilities of I-II groups who defended the independence,

sovereignty and territorial integrity of Ukraine;

- family members of the deceased defenders;

- internally displaced persons who defended the independence, sovereignty and

territorial integrity of Ukraine and their family members.

7.19 Investment 5.

Investments in

providing

housing for

vulnerable

groups of the

population

Investments of at least EUR 540

million for providing housing to

veterans with disabilities of the I-II

groups, family members of deceased

veterans and internally displaced

persons

Q3 2027 Final report of the government (or State Treasury report) showing that in the

State Budgets for 2024, 2025, 2026, and 2027, the general Government

budgeted at least EUR 540 million (in UAH equivalent) for providing housing

for:

- persons with disabilities of I-II groups who defended the independence,

sovereignty and territorial integrity of Ukraine;

- family members of the deceased defenders;

- Internally displaced persons who defended the independence, sovereignty and

territorial integrity of Ukraine and their family members.

7.20 Reform 6.

Improved

functioning of

the labour market

Adoption of the Operational Plan of

Measures for the implementation in

2026–2028 of the National Strategy

for Overcoming the Gender Pay Gap

for the period up to 2030

Q2 2026 Adoption and publication on the website of the Cabinet of Ministers of the

Operational Plan of Measures for the implementation in 2026–2028 of the

National Strategy for Overcoming the Gender Pay Gap for the period up to

2030.

65

7.21 Reform 6.

Improved

functioning of

the labour market

Entry into force of the legislation on

occupational safety and health

Q4 2026 Entry into force of the legislation on occupational safety and health in line with

the principles of OSH Framework Directive 89/391/EEC following meaningful

consultation of social partners. The legislation focuses on these main areas:

- increasing the level of protection of workers’ lives and health;

- increasing employers’ responsibility for creating proper working conditions

and a safe working environment;

- simplifying legislation in the field of workers’ safety and health, and reducing

the administrative and regulatory burden on employers;

- introducing mechanisms to improve workers’ safety conditions and relevant

economic incentives;

- strengthening fair competition, expanding Ukrainian enterprises’ access to

international markets, and increasing their competitiveness in those markets.

66

C.8. BUSINESS ENVIRONMENT

1. Description of Reforms and Investments

The objective of this chapter is to improve the business environment in Ukraine, recognising the role of the

private sector in a sustainable recovery of the country. The reforms within this chapter are targeted towards

reducing costs of doing business, inter alia, by cutting red tape, increasing digitalisation, and facilitating access

to finance.

Reform 1. Improved Regulatory Environment

The objective of this reform is to improve the regulatory environment by abolishing overlapping regulations,

and by simplifying and digitising administrative procedures.

The reform has two steps. First, an Action Plan on the optimisation and digitalisation of regulation of economic

activities in various sectors shall be adopted. Second, legislation on deregulation and simplification of business

conditions shall enter into force.

The reform is expected to be completed by Q4 2025.

Reform 2. Reform of the Economic Security Bureau

The objective of this reform is to relaunch and reinvigorate the Economic Security Bureau through the

provision of a clearer mandate and an open, transparent and competitive process for selection of management

and staff.

The reform has two steps. The first step entails entry into force of new legislation to establish an open,

transparent and competitive (merit-based) process for selection of management and staff, strengthened

requirements for the selection commission, a contract system for employees, a clear scope and mandate

definition, and a mechanism of attestation of staff. The second step requires the strengthening of the Economic

Security Bureau by expanding its territorial presence, ensuring electronic access to critical databases and

strengthening the capacity of ESBU through specialized training.

The reform is expected to be completed by Q4 2026.

Reform 3. Access to finance and markets

The objective of this reform is to help the private sector via different tools.

The reform has two steps. First, Ukraine shall adopt the Small and Medium Enterprises (SME) Strategy and

Action Plan for its implementation to improve access to markets, finance and other resources and access to

knowledge for SMEs. Second, legislative amendments on the simplification of access to utility networks shall

enter into force.

The reform is expected to be completed by Q1 2026.

67

Reform 4. Improved public procurement

The objective of this reform is to strengthen Ukraine’s public procurement system via a legislative framework

aligned with the EU acquis.

The reform has one step. It entails the alignment of public procurement legislation with the EU acquis,

focussing primarily on classic and utilities public procurement directives, on concessions and Public-Private

Partnerships, the application of requirements for energy labelling and eco-design as mandatory minimum

criteria during public procurement, and the enhancement of the e-procurement system.

The reform is expected to be completed by Q3 2027.

Reform 5. Harmonisation of legislation and standards with the Union

The objective of this reform is to resume market surveillance measures and facilitate the adoption of Union

norms and standards in Ukraine, particularly in the areas of industrial products.

The reform has three steps. First, legislation on the resumption of market surveillance measures and control

for non-food products shall be adopted. Second, harmonised standards for three groups of industrial products

(machines, electromagnetic compatibility of equipment, low-voltage electrical equipment) shall be translated

into national standards. Third, the amendments to the resolution on the single national metrology institute shall

be adopted.

The reform is expected to be completed by Q2 2026.

Reform 6. Addressing late payments

The objective of this reform is to ensure that late payments do not impede business activity.

The reform has one step. It entails the alignment of relevant legislation with Directive 2011/7/EU (also known

as the EU’s “Late Payment Directive”).

The reform is expected to be completed by Q3 2027.

Investment 1. Investments in financial support for micro-enterprises and SMEs

The objective of this investment is to ensure entrepreneurs have access to finance.

The investment has one step. It entails budgeting of at least EUR 450 million in current prices (in UAH

equivalent) for improving access to financial support for microenterprises, SMEs, small and medium farmers,

and especially small to medium processing enterprises for the years 2024,2025, 2026, 2027 that can include

both corporate lending and grants that will be allocated based on transparent criteria.

The investment is expected to be completed by Q3 2027.

68

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

8.1 Reform 1.

Improved

regulatory

environment

Adoption of the Action

Plan on deregulation

Q3 2024 Adoption of the Order of the Cabinet of Ministers of Ukraine regarding the approval of the

Action Plan on deregulation. The Action Plan focuses on these main areas:

- reduction and digitisation of market access regulations;

- changing the punitive and repressive model of state supervision (control) to a preventive one

(risk-oriented approach);

- reducing the number of supervisory and control functions.

8.2 Reform 1.

Improved

regulatory

environment

Entry into force of the

legislation in accordance

with the Action Plan on

deregulation in specific

sectors

Q4 2025 Entry into force of the legislation on deregulation and simplification of business conditions. The

legislation focuses on these main areas:

- digitisation of permit and license procedures through the implementation of an experimental

project on the introduction of the Unified State Electronic System of Permit Documents;

- reduction of business inspections by introducing voluntary insurance and audit;

- settlement of the issue of legal succession of permit documents and licenses in case of change

in the organisational and legal form of a business entity.

8.3 Reform 2.

Reform of the

Economic

Security Bureau

of Ukraine

Entry into force of the

law on revising the legal

basis of the Economic

Security Bureau of

Ukraine

Q2 2024 Entry into force of the law on revising the legal basis of the activity of the Economic Security

Bureau of Ukraine. The new legislation focuses on these main areas:

- developing an open, transparent and competitive process for selection of management and staff,

selection of the new head on merit-based procedure defined by law

- strengthening requirements for the selection commission;

- introducing a contract system for employees;

- defining a clearer scope and a mandate;

- developing a mechanism of attestation of staff.

8.4 Reform 3.

Access to finance

and markets.

Adoption of the Small

and Medium Enterprises

(SME) Strategy and

Action Plan for its

implementation

Q2 2025 Adoption of the resolution of the Cabinet of Ministers of Ukraine on approving the SME

Strategy and Action Plan for its implementation. The strategy focuses on these main areas:

- access to markets;

- access to finance and other resources;

- access to knowledge.

69

8.5 Reform 3.

Access to finance

and markets.

Entry into force of the

legislation on access to

information about

external engineering

works

Q1 2026 Entry into force of the Law of Ukraine “On Amendments to Certain Laws of Ukraine in the

Fields of Energy and Heat Supply Regarding the Improvement of Certain Provisions Related to

Economic Activity and Martial Law in Ukraine”, along with amendments to the Laws of

Ukraine “On Drinking Water and Drinking Water Supply,” “On Heat Supply,” “On the Natural

Gas Market,” “On the Electricity Market,” and “On Regulation of Urban Development,” as

well as relevant sectoral secondary legislation.. The legislative changes focus on these main

areas:

- open access to information about external engineering networks through public electronic

registers, if the security situation allows, which will be determined in the relevant provisions of

the amendments to the legal act(s), as well as a simplified procedure(s) for connecting to external

engineering networks;

- inclusion of information about external engineering networks in public electronic registers of

state ownership, if the security situation allows, which will be determined in the relevant

provisions of the amendment to the legal act(s);

- inclusion of information on protection zones of external engineering networks in public

electronic registers of state property.

8.6 Reform 4.

Improved public

procurement

Entry into force of the

legislation on

harmonising legislation

in the field of public

procurement with the EU

acquis.

Q3 2027 Entry into force of the Laws of Ukraine aligning legislation in the field of public procurement,

with:

- Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on

public procurement and repealing Directive 2004/18/EC;

- Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on

procurement by entities operating in the water, energy, transport and postal services sectors and

repealing Directive 2004/17/EC;

- Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on

the award of concession contracts;

- Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the

coordination of procedures for the award of certain works contracts, supply contracts and

service contracts by contracting authorities or entities in the fields of defence and security, and

amending Directives 2004/17/EC and 2004/18/EC;

70

- Council Directive 89/665/EEC of 21 December 1989 on the coordination of the laws,

regulations and administrative provisions relating to the application of review procedures to the

award of public supply and public works contracts;

- Council Directive 92/13/EEC of 25 February 1992 coordinating the laws, regulations and

administrative provisions relating to the application of Community rules on the procurement

procedures of entities operating in the water, energy, transport and telecommunications sectors;

- Directive 2007/66/EC of the European Parliament and of the Council of 11 December 2007

amending Council Directives 89/665/EEC and 92/13/EEC with regard to improving the

effectiveness of review procedures concerning the award of public contracts;

- Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on

electronic invoicing in public procurement

These laws focus on these main areas:

- further alignment of national legislation with the classic and utilities public procurement

directives, especially with respect to the material scope of the Public Procurement Law and

exemptions thereof, delimitation of procurement regulation that is not directly related to military

needs carried out by customers in the sphere of security and defence;

- further alignment of national legislation on concessions and PPPs with the EU acquis;

- application of the requirements for energy labelling and eco-design as mandatory minimum

criteria during public procurement;

- enhancement of the e-procurement system, that includes development of e-contracting in the

Prozorro system, and operational interoperability with DREAM system and other state IT

systems if applicable.

8.7 Reform 5.

Harmonisation of

legislation and

standards with

the EU

Adoption of the

resolution for the

resumption of market

surveillance measures

and control of non-food

products, including

product safety inspection

Q4 2024 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on Amendments to the

Resolution of 13 March 2022 no. 303 "On the Termination of Measures of State Surveillance

(Control) and State Market Surveillance under the Conditions of Martial Law" with regard to

the exclusion of state market surveillance from its scope and to repeal Resolution of 3 May

2022 no. 550 "On the Termination of the Carrying Out of State Control of Non-Food Products

under the Conditions of Martial Law" in order to resume market surveillance measures and

control of non-food products, including product safety inspections

71

8.8 Reform 5.

Harmonisation of

legislation and

standards with

the EU

Adoption of harmonised

standards for three

groups of industrial

products

Q3 2025 Harmonised standards for 3 groups of industrial products (machinery, electromagnetic

compatibility of equipment, low-voltage electrical equipment) are adopted as national ones by

translation method

8.9 Reform 6.

Addressing late

payments

Entry into force of the

legislation on combating

late payments

Q3 2027 Entry into force of the amendments to the legislation in line with the principles of the Directive

2011/7/EU of the European Parliament and of the Council of 16 February 2011 on combating

late payment in commercial transactions (recast)

8.10 Investment 1.

Investments in

financial support

for micro-

enterprises and

SMEs

Investment of at least

EUR 450 million for

financial support to

microenterprises, SMEs

and small and medium

processing enterprises

Q3 2027 Report of the government (or State Treasury report) showing that in the State Budgets for

2024, 2025, 2026, 2027 the general government budgeted at least EUR 450 million (in UAH

equivalent) for financial support for microenterprises, SMEs, small and medium farmers, and

especially small and medium processing enterprises, also in line with the new SME Strategy

and Action Plan when adopted and where relevant, that can include both corporate lending and

grants that will be allocated based on transparent criteria. The corporate lending is channelled

through financial intermediaries. The grants are channelled through dedicated entities with

appropriate resources and capacity and through financial intermediaries.

8.11 Reform 2.

Reform of the

Economic

Security Bureau

of Ukraine

Entry into force of a

legal acts further

strengthening the

Economic Security

Bureau of Ukraine

Q4 2026 Entry into force of legal acts to further strengthen the Economic Security Bureau of Ukraine

(ESBU) in effectively combating economic crimes, particularly by:

- ESBU will establish territorial offices;

- ensuring ESBU’s access to essential information systems and data as well as other relevant

registers and databases via electronic exchange;

- strengthening the capacity, including human resources, of the ESBU through a gender-

sensitive approach by facilitating the participation of Bureau staff in specialized training on

best practices for detecting, preventing, and investigating criminal offenses that threaten the

state economy, including with the involvement of international partners.

8.12 Reform 5.

Harmonisation of

legislation and

standards with

the EU

Adoption of

amendments to the

resolution on the single

national metrology

institute

Q2 2026 Adoption of amendments to the resolution of the Cabinet of Ministers No. 330 of 27 May 2015

on the designation of a single national metrology institute - State Enterprise “All-Ukrainian

State Scientific and Production Centre for Standardisation, Metrology, Certification and

Consumer Protection” (SE “Ukrmetrteststandard”, Kyiv).

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C.9. DECENTRALISATION AND REGIONAL POLICY

1. Description of Reforms and Investments

The objective of this chapter is to advance the process of decentralisation on institutional and

legislative level and to strengthen the development of regional policy. This contributes to a

higher level of participation in the decision-making process at the local level and empowers

regional and local government entities to participate in the recovery and reconstruction process.

The reform also strengthens the capacity of entities, structures and systems that will be used

for identification, implementation and evaluation of recovery and reconstruction projects.

Reform 1. Advancing decentralisation

The objective of this reform is to put into place a framework for transforming local state

administration into prefecture-type authorities and to ensure a better distribution of powers

between local governments and executive authorities.

The reform has three steps. First, the legislation on transforming local state administration into

prefecture-type authorities enters into force and is applied within 12 months from the date of

termination or abolition of martial law in Ukraine. Second, a study on the necessary measures

to grant legal personality to municipalities is endorsed and published. Third, the legislation to

ensure a better distribution of powers between local governments and executive authorities

enters into force with an application in 12 months after the end of the martial law and from the

start of the new budget period.

The reform is expected to be completed by Q1 2027.

Reform 2. Increased involvement of citizens to decision making process at the local level

The objective of this reform is to increase citizen involvement and active participation into

local decision-making processes.

The reform has one step. The law for public consultations on public policy enters into force

and is applied within 12 months from the date of termination or abolition of martial law in

Ukraine. The legislation launches a legal mechanism for public consultations during the

formation and implementation of public policy, addressing issues of local importance.

The reform is expected to be completed by Q1 2025.

Reform 3. Development and implementation of regional policy

The objective of this reform is to align regional policy with recovery and reconstruction efforts,

by amending the strategy for regional development and development of urban planning at the

local level.

73

The reform has two steps. First, adoption of resolutions to amend the State Strategy for

Regional Development for 2021-2027. Second, the resolution for development of urban

planning at the local level to foster the digitalisation of urban planning documentation is

adopted.

The reform is expected to be completed by Q4 2024.

Investment 1. Investments for the recovery, reconstruction and modernisation needs of

Ukraine’s sub-national authorities

The objective of the investment is to support the recovery, reconstruction and modernisation

needs of Ukraine’s sub-national authorities, in particular local self-government.

The investment has two steps. First, it entails providing an interim report showing that the

equivalent of at least 5% of the non-repayable financing support under Pillar I of the Ukraine

Facility have been allocated to the recovery, reconstruction, and modernisation needs of

Ukraine’s sub-national authorities, in particular local self-government for the years 2024 and

2025. Second, it entails providing a report showing that the equivalent of at least 20% of the

non-repayable financing support under Pillar I of the Ukraine Facility have been allocated to

the recovery, reconstruction, and modernisation needs of Ukraine’s sub-national authorities, in

particular local self-government for the years 2024, 2025, 2026, and 2027.

This investment is expected to be completed by Q3 2027.

74

2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

9.1 Reform 1.

Advancing

decentralisation

Entry into force of the

legislation on reforming of

territorial organisation of

the executive authorities in

Ukraine with delayed

application

Q1 2025 Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine ‘On

Local State Administrations’ and Some Other Legislative Acts of Ukraine as Regards the

Reforming of Territorial Organisation of the Executive Authorities in Ukraine” with its

application within 12 months from the date of termination or abolition of martial law in

Ukraine. Subordinate legal acts for the implementation of the law shall be adopted after it

enters into force.

The law focuses on these main areas:

- transforming local state administrations into prefecture-type authorities in order to

create a balanced system of ensuring a legal nature of activities undertaken by local self-

government bodies;

- ensuring coordination of the territorial bodies of the central executive authorities when

implementing the state policy at the regional and local levels.

9.2 Reform 1.

Advancing

decentralisation

Endorsement and

publication on the website

of the Ministry of

Communities, Territories

and Infrastructure

Development of Ukraine of

a study on the necessary

measures to grant legal

personality to municipalities

Q2 2025 Publication of the results of the study on the possibility of granting territorial

communities the status of a legal entity on the official web portal of the Ministry of

Communities, Territories and Infrastructure Development of Ukraine

9.3 Reform 1.

Advancing

decentralisation

Entry into force of the

legislation to ensure a better

distribution of powers

between local governments

and executive authorities

Q1 2027 Entry into force of the amendments to the Law of Ukraine “On Local Self-Government

in Ukraine” and sector-specific laws with an application in 12 months after the end of the

martial law but not earlier than the start of the new budget period. These legislative

amendments are expected to focus on these main areas:

- lead to an improved distribution of powers between local governments and executive

authorities based on the principles of subsidiarity and decentralisation;

75

- help to eliminate conflicts of competence between different tiers of central, regional,

district and local authorities, as well as within bodies of local self-government;

- encourage a proper quality of public services at the local level and an efficient use of

budget funds.

9.4. Reform 2.

Increased

involvement of

citizens to decision

making process at

the local level

Entry into force of the

legislation for public

consultations on public

policy with delayed

application

Q1 2025 Entry into force of the Law of Ukraine “On Public Consultations” with its application

within 12 months from the date of termination or abolition of martial law in Ukraine. The

Law will launch legal mechanism for public consultations during the formation and

implementation of public policy, addressing issues of local importance, which will

establish preconditions for coherent, effective and efficient policy- and decision-making.

9.5 Reform 3.

Development and

implementation of

regional policy

Adoption of resolutions to

amend the State Strategy for

Regional Development for

2021-2027

Q3 2024 Adoption of the Resolution of the Cabinet of Ministers of Ukraine "On Amendments to

the State Strategy for Regional Development for 2021-2027, approved by the Resolution

of the Cabinet of Ministers of Ukraine No. 695 dated 5 August 2020". The resolution

focuses on these main areas:

- development of multi-level governance, approximation of the regional development

management system to EU procedures and best practices;

- promoting partnerships, inter-municipal, interregional and cross-border cooperation;

- developing the institutional capacity of territorial communities and regions in terms of

project management, digitalisation, anti-corruption and strategic planning.

9.6 Reform 3.

Development and

implementation of

regional policy

Adoption of resolutions for

development of urban

planning at the local level

Q4 2024 Adoption of the Resolutions by the Cabinet of Ministers of Ukraine approving the

Procedure for maintaining the state-level urban planning cadastre, the Unified State

Address Register, the Unified State Register of Buildings and Structures, the Unified

State Register of Administrative Units, amending resolutions of the Cabinet of Ministers

of Ukraine regulating the development of urban planning documentation in the form of

electronic documents, maintaining the Unified State Electronic System in the field of

construction, integration and information interaction of registers and cadastres of the

state.

9.7 Investment 1.

Investments for the

recovery,

Allocation of at least 5% of

the overall non-repayable

financial support for

Q2 2026 Interim report showing that the equivalent of at least 5% of the non-repayable financial

support has been allocated to the recovery, reconstruction and modernisation needs of

Ukraine’s sub-national authorities, in particular local self-government.

76

reconstruction and

modernisation

needs of Ukraine’s

sub-national

authorities

meeting recovery,

reconstruction, and

modernisation needs of sub-

national authorities

9.8 Investment 1.

Investments for the

recovery,

reconstruction and

modernisation

needs of Ukraine’s

sub-national

authorities

Allocation of at least 20%

of the overall non-repayable

financial support for

meeting recovery,

reconstruction, and

modernisation needs of sub-

national authorities

Q3 2027 Final report proving that the equivalent of at least 20% of the non-repayable financing

support has been allocated to the recovery, reconstruction and modernisation needs of

Ukraine’s sub-national authorities, in particular local self-government.

77

C.10. ENERGY SECTOR

1. Description of Reforms and Investments

The objective of this chapter is to strengthen the resilience and security of the energy sector in Ukraine, with

a particular view to facilitate a clean energy transition, including via focusing on the energy efficiency

measures, supporting private sector investments in renewable energy, advancing structural reforms, and easing

integration of the energy system of Ukraine with that of the Union.

Reform 1. Integrated National Energy and Climate Plan

The objective of this reform is to approve the Integrated National Energy and Climate Plan (INECP) which

will set out national climate neutrality objectives, with an overarching goal to reduce greenhouse gas

emissions.

The reform has one step. It entails the adoption of the Integrated National Energy and Climate Plan.

The reform is expected to be completed by Q2 2024.

Reform 2. Improved regulatory framework for increasing renewable energy and ensuring stable operation of

the energy system.

The objective of this reform is to increase the share of renewable energy in the energy mix of Ukraine. This

will be done via improving the conditions for the development of renewable energy on a market basis.

The reform has three steps. First, it entails the introduction of a market-based renewable energy framework in

line with Union rules, defining necessary procedures and documents for competitive auctions. Second,

legislation on streamlining and shortening the permitting procedures for renewable energy investments in line

with Union rules enters into force. Third, it entails the development and approval of a Roadmap for the

separation of the Renewable Energy Surcharge from the Transmission Tariff.

The reform is expected to be completed by Q4 2025.

Reform 3. Electricity market reform

The objective of this reform is to improve the regulatory framework for the energy sector in Ukraine, including

to support integration of the Ukrainian and European markets.

The reform has five steps. First, legislation enters into force that transposes the electricity integration package.

Second, legislation changing the regime of indirect taxation of participants in the electricity market enters into

force facilitating the market coupling of day-ahead and intraday markets of neighbouring states and export

and import of electric energy. Third, a new electricity market operator designated by the regulator is appointed.

Fourth, the secondary legislation on the wholesale energy market integrity and transparency (REMIT) law

enters into force. Fifth, the secondary legislation of law No. 4834/IX on the transposition of the electricity

integration package shall enter into force.

The reform is expected to be completed by Q4 2026.

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Reform 4. Liberalisation of electricity and natural gas prices

The objective of this reform is to set the grounds for a gradual liberalisation of prices once conditions allow,

ensuring sufficient measures to protect vulnerable households.

The reform has one step. It entails the adoption of a Roadmap for gradual liberalisation of gas and electricity

markets, which shall include a set of specific steps to take and the timeline to be implemented after the martial

law is lifted.

The reform is expected to be completed by Q2 2026.

Reform 5. Ensuring independence of National Energy and Utilities Regulatory Commission

The objective of this reform is to strengthen the independence of the energy regulator and ensure the effective

functioning and development of markets in the energy and utilities sectors.

The reform has four steps. First, the legislative amendments exempting the decisions of the energy regulator

from the state registration procedure, according to the requirements of the relevant EU directives, will enter

into force. Second, legislative amendments to provide for the specification of special status of the regulator,

as per the relevant EU directives, enter into force. Third, Ukraine shall launch a selection procedure for the

identification of an auditor to be tasked for carrying out a third-party audit of the energy regulator regarding

its financial and decision-making processes. Fourth, the third-party audit of the energy regulator shall be

completed.

The reform is expected to be completed by Q4 2026.

Reform 6. Improved efficiency in the district heating

The objective of this reform is to improve the district heating sector and aim to strengthen the resilience of the

integrated energy system, including by improving the regulatory framework, and supporting modernisation of

the heating companies.

The reform has three steps. First, the State targeted economic programme for the modernisation of heat

generating enterprises for the period up to 2030 will be adopted to improve heat supply services, support the

green transition of the energy sector, and strengthen governance. Second, entry into force of legislation to

support the development of efficient and sustainable district heating via clear rules for network connection

and disconnection, and on improving procedures for individual heat substations installation in multi-apartment

buildings. Third, Ukraine will cancel the moratorium on rising heat and hot water tariffs.

The reform is expected to be completed by Q4 2026.

Reform 7. Improved energy efficiency in public buildings and improvement of public procurement procedures

The objective of this reform is to improve energy sustainability and support the reduction of energy

consumption by rolling out energy efficiency measures.

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The reform has two steps. First, Ukraine shall adopt a Strategy for Thermal Modernisation of Buildings until

2050 and an accompanying Action plan aimed at improved the energy efficiency of the buildings. Second,

Ukraine shall adopt legal acts on setting minimum energy efficiency performance levels for buildings and also

for products covered by the EU energy labelling legislation, and on setting classes of energy efficiency

performance levels for products covered by the EU energy labelling legislation.

The reform is expected to be completed by Q3 2026.

Investment 1. Investments in energy infrastructure, energy efficiency interventions and the restoration of war-

damaged buildings

The objective of this investment is to finance critical energy infrastructure to ensure energy security as well

as to support energy efficiency interventions and the restoration of war-damaged buildings with a strong focus

on energy efficiency and development of renewable sources.

The investment has one step. It entails budgeting of at least EUR 550 million in current prices (in UAH

equivalent) for energy investments in 2026 and 2027, for strengthening the energy infrastructure of Ukraine

and promote energy efficiency, including at the regional level, with a focus on improving energy efficiency

in district heating, public buildings, and the residential sector, physical protection of Ukraine’s infrastructure,

and development of renewable energy sources. It also entails supporting the reparation of war-damaged

buildings.

The investment is expected to be completed by Q3 2027.

Reform 8. Integrated Regulatory Review Service at the State Nuclear Regulatory Inspectorate

The objective of the reform is to launch the process of an independent international peer review of the

effectiveness, independence, governance and regulatory functions of the national nuclear and radiation safety

regulatory framework against IAEA safety standards.

The reform has one step. The State Nuclear Regulatory Inspectorate (SNRIU) shall request an Integrated

Regulatory Review Service mission by the International Atomic Energy Agency.

The reform is expected to be completed by Q3 2026.

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2. List of steps and timetable for implementation

No. Reform / Investment Name of the step Timeline Step description

10.1 Reform 1.

Integrated National Energy and

Climate Plan

Adoption of the Integrated National

Energy and Climate Plan

Q2 2024 Adoption of the Ordinance of the Cabinet of Ministers of

Ukraine on approving the Integrated National Energy and

Climate Plan to establish national climate neutrality objectives

and ensure appropriate planning after duly taking into account

the recommendations from the Energy Community. The plan

defines targets to be achieved by 2030 on:

- GHG reductions, including through market-based carbon

pricing mechanisms;

- the share of renewable sources in gross final consumption of

energy;

- the energy saving in final energy consumption.

10.2 Reform 2.

Improved regulatory framework

for increasing renewable energy

and ensuring stable operation of

the energy system

Introduction of a market-based

framework for renewable energy

Q4 2024 Entry into force of market-based legislative and regulatory

framework for investments in renewable energy sources in line

with EU rules, namely necessary procedures and documents for

competitive auctions. The following legislative act is

introduced/amended: The Resolution of the Cabinet of Ministers

‘On Amendments to the Resolution of the Cabinet of Ministers

dated 29 December 2019 № 1175 on Improving the Procedure

for Holding Auctions for the Distribution of Support Quotas’

10.3 Reform 2.

Improved regulatory framework

for increasing renewable energy

and ensuring stable operation of

the energy system

Entry into force of the legislation to

improve permitting procedures for

renewable energy investments

Q4 2025 Entry into force of the legislation on shortening the permitting

procedures for renewable investments in line with Union rules

transposed in the Energy Community as Ministerial Council

Recommendation 2024/1/MC-EnC of 11 December 2024 on

accelerating the deployment of renewable energy projects and

implementing the energy efficiency first principle

(“Recommendation 2024/1/MC-EnC”).

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10.4 Reform 2.

Improved regulatory framework

for increasing renewable energy

and ensuring stable operation of

the energy system

Adoption of the Roadmap of the

process of separation of the Renewable

Energy Surcharge from the

Transmission Tariff

Q2 2025 Adoption of the Roadmap of the process of separation of the

Renewable Energy Surcharge from the Transmission Tariff with

identifying legislative needed acts and terms of implementation.

10.5 Reform 3.

Electricity market reform

Entry into force of the Law on the

transposition of the electricity

integration package

Q3 2025 Entry into force of the Law on the transposition of the electricity

integration package, aligning Ukrainian national legislation with

the electricity integration package, as incorporated in the Energy

Community acquis in December 2022. The electricity

integration package approximates legislation in line with the

following acts and network codes and guidelines:

- Directive (EU) 2019/944 of the European Parliament and of

the Council of 5 June 2019 on common rules for the internal

market for electricity and amending Directive 2012/27/EU

(recast)

- Regulation (EU) 2019/943 of the European Parliament and of

the Council of 5 June 2019 on the internal market for electricity

(recast);

- Regulation (EU) 2019/941 of the European Parliament and of

the Council of 5 June 2019 on risk-preparedness in the

electricity sector and repealing Directive 2005/89/EC;

- Regulation (EU) 2019/942 of the European Parliament and of

the Council of 5 June 2019 establishing a European Union

Agency for the Cooperation of Energy Regulators (recast).

- the five Network Codes and Guidelines establish detailed rules

related to different market segments and system operation:

- Commission Regulation (EU) 2016/1719 of 26 September

2016 establishing a guideline on forward capacity allocation;

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- Commission Regulation (EU) 2015/1222 of 24 July 2015

establishing a guideline on capacity allocation and congestion

management;

- Commission Regulation (EU) 2017/2195 of 23 November

2017 establishing a guideline on electricity balancing;

- Commission Regulation (EU) 2017/1485 of 2 August 2017

establishing a guideline on electricity transmission system

operation;

- Commission Regulation (EU) 2017/2196 of 24 November

2017 establishing a network code on electricity emergency and

restoration.

10.6 Reform 3.

Electricity market reform

Entry into force of the legislation on

changing the conditions of taxation of

participants in the electricity market

Q4 2026 Entry into force of the legislation changing the regime of

indirect taxation of participants in the electricity market, in order

to facilitate the market coupling of day-ahead and intraday

markets with day-ahead markets and intraday markets of

neighbouring states and operations related to exports and import

of electric energy within the framework of the implementation

of the legislation of the Energy Community introduced by the

decision of the Council of Ministers of the EU dated 15.12.2022

№ D/2022/03/MC–EnС, namely to amend the Tax Code of

Ukraine and to amend the Customs Code of Ukraine to enable

market integration and market coupling. The list of specific laws

will be finalised after the adoption of the basic law on the

transposition of the Electricity Integration Package.

10.7 Reform 3.

Electricity market reform

Appointment of a new electricity

market operator

Q4 2025 Appointment of a nominated electricity market operator

designated by National Energy and Utilities Regulatory

Commission (NEURC).

10.8 Reform 3.

Electricity market reform

Entry into force of the secondary

legislation on the Regulation on

Q3 2024 Entry into force of the secondary legislation on REMIT law.

The NEURC approves these procedures and requirements:

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Wholesale Energy Market Integrity and

Transparency (REMIT) law

- the procedure for acquiring, suspending and terminating the

status of a data transfer administrator;

- the procedure for the functioning of insider information

platforms;

- requirements for ensuring integrity and transparency in the

wholesale energy market;

- procedure for Submission of Information on Economic and

Trade Transactions with Wholesale Energy Products

Preparation of the Terms of Reference for the development of an

information system defining the following functions of the

NEURC:

- the system will be integrated with the systems of market

operators, insider information platforms, data transfer

administrators and will detect information indicating the

presence of abuse.

10.9 Reform 4.

Liberalisation of electricity and

natural gas prices

Adoption of a Roadmap for gradual

liberalisation of gas and electricity

market, to be implemented after the

expiration of the martial law

Q2 2026 Adoption of a Roadmap for gradual liberalisation of gas and

electricity market by the Cabinet of Ministers of Ukraine with

steps to take and the associated timeline, to be implemented

after the expiration of the martial law. The Roadmap is based

on the technical analysis to understand the financial condition

of the sector. The Roadmap focuses on these main areas:

- steps needed to reform the PSOs in order to gradually

liberalise the market prices, once the martial law is lifted;

- steps to take to ensure vulnerable consumers are adequately

protected once the prices for households are liberalised,

including the new design of the subsidy system for vulnerable

consumers which improve the targeting and ensures adequate

levels of protection, as well as preparatory steps to be

implemented before the end of the martial law, such as

identification of vulnerable population and the associated digital

solution.

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10.10 Reform 5.

Ensuring independence of

National Energy and Utilities

Regulatory Commission

Entry into force of the legislation to

ensure the independence of the National

Energy Utilities Regulatory

Commission

Q4 2024 Entry into force of the amendments Law dated 24 August 2023

№ 3354–IX ‘On law-making activity’, which exempt the

decisions of the National Energy and Utilities Regulatory

Commission, which are regulatory legal acts, from the state

registration procedure provided for by law. These amendments

focus on these main areas:

- ensuring the independence of the Regulator as provided for by

Directive (EU) 2019/944 of the European Parliament and of the

Council of 5 June 2019 on common rules for the internal market

for electricity and amending Directive 2012/27/EU (recast)and

Directive 2009/73/EC of the European Parliament and of the

Council of 13 July 2009 concerning common rules for the

internal market in natural gas and repealing Directive

2003/55/EC;

- implementation of Article 5 of the Law of Ukraine ‘On the

National Energy and Utilities Regulatory Commission’ on the

prohibition of state bodies to interfere in the activities of the

Regulator.

10.11

Reform 5.

Ensuring independence of

National Energy and Utilities

Regulatory Commission

Entry into force of the amendments to

the Law of Ukraine "On the National

Energy and Utilities Regulatory

Commission"

Q4 2025 Entry into force of the amendments to the Law of Ukraine "On

the National Energy and Utilities Regulatory Commission" and

other acts, which provide for the specification of the special

status for ensuring the independence of the Regulator as

provided for by Directive (EU) 2019/944 of the European

Parliament and of the Council of 5 June 2019 on common rules

for the internal market for electricity and amending Directive

2012/27/EU and Directive 2009/73/EC of the European

Parliament and of the Council of 13 July 2009 concerning

common rules for the internal market in natural gas and

repealing Directive 2003/55/EC.

10.12 Reform 6.

Improved efficiency in the

district heating

Cancelation of the moratorium on rising

heat and hot water tariffs

Q2 2027 Cancelation of the moratorium introduced by Law No. 2479-IX

"On the peculiarities of regulating relations in the natural gas

market and in the field of heat supply during martial law and the

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subsequent restoration of their functioning" followed by an

increase in heat tariffs in order to reach cost-reflectiveness of

heat and hot water tariffs.

10.13 Reform 6.

Improved efficiency in the

district heating

Adoption of the State targeted

economic programme for the energy

modernisation of heat generating

enterprises for the period up to 2030

Q4 2025 Adoption of the State targeted economic program for the energy

modernisation of heat generating enterprises for the period up to

2030 by the Cabinet of Ministers. The Strategy focuses on these

main areas:

- identifying measures to improve resilience, quality and

availability of heat supply services;

- identifying measures to support decarbonisation, reduction of

greenhouse gas emissions and expansion of renewable energy

sources;

- providing measures to strengthen governance and management

skills for local authorities in district heating sector.

10.14 Reform 6.

Improved efficiency in the

district heating

Entry into force of the legislation to

support development of the efficient

and more sustainable district heating’

Q4 2025 Entry into force of the Law of Ukraine ‘On amendments to

some Laws of Ukraine to support development of the efficient

and more sustainable district heating’. The law focuses on these

main areas:

- setting clear rules for network connection/ disconnection,

zones of priority development of district heating systems;

- improvement of procedures for individual heat substations

(IHS) installation in multi-apartment buildings to ensure proper

remote control and demand management.

10.15 Reform 7.

Improved energy efficiency in

public buildings and

improvement of public

procurement procedures

Adoption of the Strategy for thermal

modernisation of buildings until 2050

and the Action Plan

Q2 2024 Adoption of the act "On Approval of the Strategy for Thermal

Modernisation of Buildings until 2050” and Action plan for the

Strategy by the Cabinet of Ministers of Ukraine, aimed at

introducing market-based financial instruments and incentives,

containing a roadmap with policy measures, including those

aimed to support the introduction of nearly-zero energy

building.

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10.16 Reform 7.

Improved energy efficiency in

public buildings and

improvement of public

procurement procedures

Adoption of legal acts on setting

minimum energy efficiency

performance levels for buildings

Q3 2026 Adoption by the Cabinet of Ministers of Ukraine of legal acts on

setting minimum energy efficiency performance levels for

buildings and also for products covered by the EU eco-design

legislation and the Ministry for Communities, Territories and

Infrastructure Development adopted acts on setting classes of

energy efficiency performance levels for products covered by

the Union energy labelling legislation.

10.17 Investment 1.

Investments in energy

infrastructure, energy efficiency

interventions and the restoration

of war-damaged buildings.

Investments of at least EUR 550 million

in energy infrastructure

Q3 2027 Report of the Government (or State Treasury report) showing

that in the State Budgets for 2026 and 2027 the general

Government budgeted at least EUR 550 million (in UAH

equivalent) for strengthening the energy infrastructure of

Ukraine, supporting energy efficiency and the restoration of

war-damaged buildings, including at the regional level (as part

of step 9.8), among others for the following:

- improving energy efficiency and restoration in district heating;

- financial contribution to the Energy Efficiency Fund to support

its statutory activities, including the implementation of

programmes and the functioning of the Fund

- improving energy efficiency in public buildings, in line with

the Strategy for Thermal Modernisation of Buildings until 2050;

- protection and restoration of critical energy infrastructure;

- promotion of electricity generation from renewable energy

sources and the development of distributed generation and

energy storage equipment.

10.18 Reform 3.

Electricity market reform

Entry into force of the secondary

legislation of law No. 4834/IX on the

transposition of the electricity

integration package, in line with the

Energy Community Treaty Acquis

Q4 2026 Entry into force of the secondary legislation of law No. 4834/IX

on the transposition of the electricity integration package, in line

with the Energy Community Treaty acquis. The secondary

legislation approximate legislation in line with the 5 network

codes and guidelines for electricity:

- Commission Regulation (EU) 2016/1719 of 26 September

2016 establishing a guideline on forward capacity allocation;

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- Commission Regulation (EU) 2015/1222 of 24 July 2015

establishing a guideline on capacity allocation and congestion

management - Commission Regulation (EU) 2017/2195 of 23 November

2017 establishing a guideline on electricity balancing;

- Commission Regulation (EU) 2017/1485 of 2 August 2017

establishing a guideline on electricity transmission system

operation:

- Commission Regulation (EU) 2017/2196 of 24 November

2017 establishing a network code on electricity emergency

restoration.

10.19 Reform 5.

Ensuring independence of

National Energy and Utilities

Regulatory Commission

Preparation of the Terms of Reference

for a third-party audit of the National

Energy and Utilities Regulatory

Commission regarding the integrity and

robustness of its financial and decision-

making processes

Q2 2026 Preparation of the Terms of Reference for a third-party audit of

the National Energy and Utilities Regulatory Commission

regarding the integrity and robustness of its financial, governance

and decision-making processes, including in light of recent

integrity concerns and developments in the energy sector. The

Terms of Reference should focus on:

- assessment of the Decision-Making Process, including internal

approval procedures, traceability, documentation standards and

safeguards ensuring integrity and transparency of regulatory

decisions

- assessment of the Ethical Practices, including conflict-of-

interest prevention, declarations of interests, recusal procedures

and accountability mechanisms applicable to Commissioners,

management and staff

- assessment of the Anti-Corruption Program and internal

compliance mechanisms, including identification of institutional

vulnerabilities and integrity risks.

- assessment of financial decision-making processes, allocation

and management of financial resources, and related internal

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control mechanisms, including transparency, traceability,

accountability and safeguards against misuse or undue influence

- assessment of the Communication Policy, including interaction

with EU/EnC regulators, market participants and other Ukrainian

public authorities and mechanisms to ensure transparency,

consistency and equal treatment

- assessment of the Financial Component, including Budgeting,

procurement, internal controls and Reporting procedures

The terms of reference shall determine the detailed modalities,

timing and cost of such audit. Draft terms of reference shall have

been shared with a list of potential service providers.

The audit shall be institutional and systems-oriented in nature and

shall not duplicate or interfere with ongoing investigations or

competencies of law-enforcement authorities.

10.20 Reform 5.

Ensuring independence of

National Energy and Utilities

Regulatory Commission

Completion of a third-party audit of the

National Energy and Utilities

Regulatory Commission regarding the

integrity and robustness of its financial

and decision-making processes

Q4 2026 Completion of a third-party audit of the National Energy and

Utilities Regulatory Commission regarding the integrity and

robustness of its financial and decision-making processes,

covering:

- assessment of the Decision-Making Process, including internal

approval procedures, traceability, documentation standards and

safeguards ensuring integrity and transparency of regulatory

decisions

- assessment of the Ethical Practices, including conflict-of-

interest prevention, declarations of interests, recusal procedures

and accountability mechanisms applicable to Commissioners,

management and staff

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- assessment of the Anti-Corruption Program and internal

compliance mechanisms, including identification of institutional

vulnerabilities and integrity risks.

- assessment of the Communication Policy including interaction

with EU/EnC regulators, market participants and other

Ukrainian public authorities and mechanisms to ensure

transparency, consistency and equal treatment

- assessment of the Financial Component, including Budgeting,

procurement, internal controls and Reporting procedures.

The audit shall be institutional and systems-oriented in nature

and shall not duplicate or interfere with ongoing investigations

or competencies of law-enforcement authorities.

10.21 Reform 8. Integrated Regulatory

Review Service at State Nuclear

Regulatory Inspectorate

Request for an integrated regulatory

review service mission at SNRIU by the

International Atomic Energy Agency

Q3 2026 State Nuclear Regulatory Inspectorate has submitted a request

for an integrated regulatory review service mission by the

International Atomic Energy Agency to start in the first half of

2027.

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C.11. TRANSPORT

1. Description of Reforms and Investments

The objective of this chapter is to modernise and reform Ukraine’s transport sector. It aims to enhance

connectivity with the Union and the Republic of Moldova and support development of a competitive and

efficient transport system in line with Union policies and standards.

Reform 1. Comprehensive planning of transport sector

The objective of this reform is to revise the key strategic document for the transport sector.

The reform has one step. It entails the adoption of the revised National Transport Strategy of Ukraine until

2030.

The reform is expected to be completed by Q4 2024.

Reform 2. Development of Ukraine’s export logistics potential

The objective of this reform is to support modernisation and increase capacity of the existing network of

Border Crossing Points to facilitate the needs for transportation across the border of Ukraine with the Union

and the Republic of Moldova.

The reform has one step. It entails the adoption of the Strategy for developing and expanding the border

infrastructure with EU Member States and the Republic of Moldova until 2030.

The reform is expected to be completed by Q4 2024.

Reform 3. Liberalisation in the railways transport sector

The objective of this reform is the creation of a competitive rail market in line with Union standards.

The reform has four steps. First, the law on traffic safety and interoperability of railway transport of Ukraine

enters into force, with application within three years from its adoption. Second, the Cabinet of Ministers of

Ukraine adopts an Action Plan for the phased opening of the railway market. Third, the legislation on the

organisation of socially important passenger transportation by rail and its institutional oversight enters into

force with application of its provisions two years after adoption. Fourth, the main by-laws for the

implementation of the law on traffic safety and interoperability and the procedure for the organisation of

socially important passenger transportation (PSO) shall be adopted.

The reform is expected to be completed by Q3 2027.

Reform 4. Improved shipping and port services

The objective of this reform is to ensure improvements in Ukraine's performance of its obligations under

international treaties in the field of merchant shipping as well as enhance competition in port services.

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The reform has two steps. First, legislation on merchant shipping and shipping on inland waterways shall enter

into force. Second, the existing national legislation to ensure full compliance with the provisions of EU

Regulation 2017/352 on Port Service Regulation shall be amended.

The reform is expected to be completed by Q2 2027.

Investment 1. Investments in transport infrastructure

The objective of this investment is to restore the damaged and destroyed transport infrastructure.

The investment has one step. It entails budgeting of at least EUR 350 million in current prices (in UAH

equivalent) in 2026-2027 for the construction, reconstruction, restoration, modernisation and upgrade of

transport infrastructure facilities amongst others in the following sectors, railways, maritime and inland

shipping, roads, aviation and border crossing points.

The investment is expected to be completed by Q3 2027.

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2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

11.1 Reform 1.

Comprehensive

planning of

transport sector

Adoption of the revised

National Transport Strategy

of Ukraine until 2030

Q4 2024 Adoption of an Order of the Cabinet of Ministers on updating the National Transport

Strategy of Ukraine for the period up to 2030.

The Strategy focuses on these main areas:

- reconstruction and development of a competitive and efficient transport system in line

with Union policies and standards in particular relating to trans-European transport

networks and the decarbonisation targets of the transport sector set out at international

and European level (including through the development of railway, road and inland

waterway routes, included in indicative maps of the TEN-T network, digitisation of

transport system management, etc.);

- high-quality passenger transportation and unimpeded mobility;

- safe for people and the environment, sustainable, energy-efficient transport.

11.2 Reform 2.

Development of

Ukraine’s export

logistics potential

Adoption of the Strategy for

developing and expanding

the border infrastructure

with EU Member States and

the Republic of Moldova

until 2030

Q4 2024 Adoption of the Strategy for Developing and Expanding the Border Infrastructure with

EU Member States and the Republic of Moldova until 2030. The Strategy focuses on

these main areas:

- reconstruction of border crossing points on the border with Poland, Slovakia, Hungary,

and Romania;

- creation of a network of service areas;

- simplification of border crossing procedures (digitalisation and introduction of joint

control) in line with Union standards.

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11.3 Reform 3.

Liberalisation in the

railways transport

sector

Entry into force of the law

on traffic safety and

interoperability of railway

transport of Ukraine with

application within three

years from its adoption

Q4 2025

Entry into force of the Law of Ukraine "On Traffic Safety and Interoperability of

Railway Transport of Ukraine" with application within three years from its adoption. The

law ensures technical integration of railway transport in line with the principles of

Directives 2016/798, 2016/797, and Regulation 2016/796 and focuses on these main

areas:

- establishing a national rail safety authority and vesting it with the powers and functions

assigned to it by Union legislation;

- introducing a legal framework for the safety certification of railway undertakings and

the safety authorisation of infrastructure managers;

- establishing a national investigating body and introducing the technical investigation of

railway accidents;

- establishing the legal framework for vehicle and infrastructure authorization based on

technical specifications for interoperability;

- establishing a legal framework for train driver certification, based on the Union model.

11.4 Reform 3.

Liberalisation in the

railways transport

sector

Adoption of the by-laws for

the implementation of the

legislation on railway

transport

Q3 2027 Adoption of the main legislative acts (by-laws) for the implementation of the Law of

Ukraine ‘On Traffic Safety and Interoperability of Railway Transport of Ukraine’ and

the new legislation ‘on the organisation of socially important passenger transportation by

rail and institutional oversight’. The by-laws introduce mechanisms for the functioning of

the rail transportation market and, in particular, focus on: licensing of railway operators,

safety management systems, the procedure for the organisation of socially important

passenger transportation (PSO).

11.5 Reform 4.

Improved shipping

and ports services

Entry into force of the

legislation on merchant

shipping and shipping on

inland waterways

Q1 2027 Entry into force of the Law of Ukraine "On Amendments to Certain Legislative Acts of

Ukraine Concerning Merchant Shipping and Shipping on Inland Waterways". The Law

focuses on these main areas:

- defining and regulating the principles of ensuring the safety of navigation in the

territorial sea, inland sea waters, seaports, and inland waterways;

- improvement of the mechanism for implementing the international regime for the

protection of ships and seaports;

- defining a detailed mechanism for controlling ships in a seaport;

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- review of the functions of the central executive body implementing state policy in the

areas of maritime and inland waterway transport and shipping in the Merchant Shipping

Code, the Laws of Ukraine "On Transport", "On Inland Waterway Transport" and "On

Seaports of Ukraine" in order to eliminate duplication of legislative norms and clarify the

division of competence, in particular with the central executive body that ensures the

formation and implementation of state policy in the areas of maritime and inland

waterway transport;

- simplification of administrative procedures, a clear list of powers of state bodies,

elimination of administrative barriers.

11.6 Reform 4.

Improved shipping

and ports services

Review and amend the

existing national legislation

in line with the principles

Regulation (EU) 2017/352

of the European Parliament

and of the Council of 15

February 2017 establishing

a framework for the

provision of port services

and common rules on the

financial transparency of

ports

Q2 2027 Review and amend the existing national legislation (including relevant subordinate legal

acts) in line with the principles of Regulation (EU) 2017/352 of the European Parliament

and of the Council of 15 February 2017 establishing a framework for the provision of

port services and common rules on the financial transparency of ports.

11.7 Investment 1.

Investments in

transport

infrastructure

Investments of at least EUR

350 million in transport

infrastructure

Q3 2027 Report of the government (or State Treasury report) showing that in the State Budgets for

2026 and 2027 the general government budgeted at least EUR 350 million (in UAH

equivalent) for the reconstruction, restoration, modernisation and upgrade of damaged

and destroyed transport infrastructure facilities, in line with the National Transport

Strategy of Ukraine until 2030, including some of the funds to be directed to the regional

level (as part of step 9.8), among others in the following sectors:

- railways (in line with the new legislation on railway transport of Ukraine);

- maritime and inland shipping (in line with the new legislation on merchant shipping and

shipping on inland waterways);

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- roads;

- aviation;

- and border crossing points (in line with the Strategy for developing and expanding the

border infrastructure with EU Member States and the Republic of Moldova until 2030).

11.8 Reform 3.

Liberalisation in the

railways transport

sector

Entry into force of

legislation on the

organisation of socially

important passenger

transportation by rail and

institutional oversight with

delayed application

Q4 2026 Entry into force of legislation on the organisation of socially important passenger

transportation by rail and institutional oversight thereof, with an application of its

provisions within two years after its adoption. The legislation will implement the key

elements of EU legislation on the provision of public passenger transport services by rail

(PSO) in line with the principles of Regulation (EC) No 1370/2007 of the European

Parliament and of the Council of 23 October 2007 on public passenger transport services

by rail and by road and repealing Council Regulations (EEC) Nos 1191/69 and 1107/70

read in conjunction with its 2023 Interpretative Guidelines. The legislation focuses,

among others, on these main areas:

- providing for the functional and accounting separation between infrastructure manager

and transport operations within the incumbent railway undertaking;

- ensuring oversight of account separation by a structurally separate and autonomous

authority with full enforcement powers to monitor account separation;

- to control contract performance and to prevent overcompensation for the provision of

public services.

11.9 Reform 3.

Liberalisation in the

railways transport

sector

Adoption of a resolution by

the Cabinet of Ministers of

Ukraine approving the

Action Plan for the phased

introduction of competition

for freight and passenger

transport in the railway

market

Q3 2026 Adoption of a resolution by the Cabinet of Ministers of Ukraine approving the Action

Plan for the phased introduction of competition for freight and passenger transport in the

railway market. The Action Plan sets out a timetable for the phased introduction of

competition for freight and passenger transport, providing for the gradual introduction of

non-discriminatory access to the 1,435 mm gauge network, and defining mandatory

stages for the 1,520 mm gauge network. The Action Plan is aligned with the revised

National Programme for the Adaptation of Ukrainian Legislation to European Union

Law (EU acquis) (NPAA).

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C.12 AGRI-FOOD SECTOR

1. Description of Reforms and Investments

The objective of this chapter is to support strengthening of the Ukraine’s agri-food sector in parallel with

further aligning its regulatory framework with the Union acquis.

Reform 1. Aligning the institutional framework on agriculture and rural development with the EU

The objective of this reform is to develop strategic national priorities including to further alignment with EU

practices, norms and rules.

The reform has two steps. First, Ukraine shall adopt the Strategy for Agriculture and Rural Development until

2030. Second, a Farm Accountancy Data Network System shall be put in place in selected pilot regions to

allow tracking the situation in the agricultural sector.

The reform is expected to be completed by Q1 2027.

Reform 2. Ensuring a functional land market

The objective of this reform is to improve the functional land market.

The reform has one step. An automated system for public monitoring of land relations and a geoinformation

system for mass land assessment shall be put in place.

The reform is expected to be completed by Q1 2025.

Reform 3. Improving the institutional and administrative set up for managing investment programmes

The objective of this reform is to improve the set up for managing public financial support schemes to the

agri-food sector.

The reform has one step. It entails the entry into force of legislation that focuses on the design of public support

measures, including for small scale farms, future financial instruments, as well as digitalisation of the system

via electronic document management systems, and ensures that state support can only be channelled to

beneficiaries registered in the State Agrarian Register (SAR).

The reform is expected to be completed by Q3 2025.

Reform 4. Improvement of the official public electronic farm register

The objective of this reform is to formalise and improve the official public electronic farm register (i.e. State

Agrarian Register).

The reform has two steps. First, a law that recognises the State Agrarian Register (SAR) as an official public

electronic register in the field of agrarian policy and food security enters into force. Second, a report is

published detailing the implementation of state support by central government institutions through the SAR.

The reform is expected to be completed by Q1 2026.

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Reform 5. Long-term development of the irrigation system to increase climate resilience of the sector

The objective of this reform is to ensure long-term planning of irrigation infrastructure in a sustainable way,

in order to foster resilience of the agri-food sector in the context of climate change.

The reform has one step. It entails the adoption of a long-term plan setting out the key areas and principles for

developing Ukraine’s water irrigation systems.

The reform is expected to be completed by Q1 2025.

Reform 6. Demining of land and water areas

The objective of this reform is to develop a national strategy to outlining key components of Ukraine’s de-

mining efforts.

The reform has one step. It entails the adoption of the Strategy on Mine Action.

The reform is expected to be completed by Q2 2024.

Investment 1. Investments in demining

The objective of this investment is to support owners or users of agricultural land undertaking de-mining

efforts.

The investment has two steps. First, it entails budgeting of at least EUR 30 million in current prices (in UAH

equivalent) for the demining of agricultural land in 2024-2025. Second, it entails budgeting of at least EUR

100 million in current prices (in UAH equivalent) for the demining of agricultural land in 2024-2027.

The investment is expected to be completed by Q3 2027.

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2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

12.1 Reform 1.

Aligning the

institutional

framework on

agriculture and

rural development

to the EU policy

Adoption of the Strategy

for Agriculture and Rural

Development until 2030

Q4 2024 Adoption of the Strategy for Agriculture and Rural Development until 2030. The strategy

focuses on these main areas:

- adapting Ukrainian Agriculture and Rural Development policies to the EU pre-accession

context and areas of special Ukrainian concern, such as land reform, irrigation, war recovery

and development support;

- institutional strengthening and capacity building to develop necessary systems;

- acceleration of the process to approximate legal acts and capacities for agri-food

agriculture and sanitary and phytosanitary measures (SPS) to EU standards;

- promoting the development to small producers and rural communities;

- defining of environmental and climate action baselines and targets, building up evidence-

based programming and sound financial management and control capacities.

12.2 Reform 1.

Aligning the

institutional

framework on

agriculture and

rural development

to the EU policy

Establishment of the

Farm Sustainability Data

Network (FSDN) system

Q1 2027 The Farm Sustainability Data Network (FSDN) system with data from selected pilot

regions, to be created under the Ministry of Agrarian Policy, is established and is

operational in line with the principles of the EU acquis in this area. The system allows

tracking the situation in the agricultural sector and making informed decisions regarding the

allocation of state support to agricultural producers

12.3 Reform 2.

Ensuring a

functional land

market

Set up of an automated

system for public

monitoring of land

relations

Q1 2025 An automated system for public monitoring of land relations has been put into operation,

functioning within the framework of maintaining the State Land Cadastre. A geoinformation

system for mass land assessment has been put into operation as part of the software of the

State Land Cadastre.

12.4 Reform 3.

Improving the

institutional and

administrative set

up for managing

Entry into force of the

legislation on the public

support of agriculture of

Ukraine

Q3 2025 Entry into force of the Law on Amendments to the Law of Ukraine “On State Support of

Agriculture of Ukraine”. The Law focuses on these main areas:

- design future public support measures in line with the principles of the EU acquis in this

area. The selection of future public support measures will include an analysis of Strengths,

Weaknesses, Opportunities, and Threats (SWOT);

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investment

programmes

- design measures to support agricultural production for small scale farms to undertake

private investments (physical assets of agricultural holdings producers, for processing and

marketing);

- design of future financial instruments (including credit guarantee facilities) for all farm

categories in collaboration with International Financial Institutions;

- digitalisation through electronic document management systems;

- state support exclusively channelled to beneficiaries enlisted in the State Agrarian

Register.

12.5 Reform 4.

Improvement of

the official public

electronic farm

register

Entry into force of the

legislation on the State

Agrarian Register (SAR)

Q4 2024 Entry into force of the Law of Ukraine “On the State Agrarian Register”. The law focuses

on these main areas:

- the State Agrarian Register (SAR) is recognised as an official public electronic register in

the field of agrarian policy and food security with the regulation of its mandatory elements,

such as the procedure for its administration, the definition of its data, access by the third

parties;

- SAR coverage is expanded to register and include information on stakeholders throughout

the entire agricultural value chains such as agricultural producers, food processors, water

users;

- SAR functionality is expanded, serving as a pre-condition for financial assistance and

enabling targeted channelling of technical assistance, other administrative services, the

introduction of analytical information;

- registration in SAR is a precondition for receiving any type of public support in agri-food

sector;

- mandatory publication of the register of beneficiaries of any state support programmes in

the sector implemented through SAR.

12.6 Reform 4.

Improvement of

the official public

electronic farm

register

Publication of report on

the implementation of the

state support through the

public Agricultural

Register

Q1 2026 Submission of the report on the implementation of state support through SAR showing that

minimum 80 percent of public support in the agricultural sector provided in 2025 by central

government institutions was provided through the State Agricultural Register (SAR).

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12.7 Reform 5.

Long-term

development of

the irrigation

system to increase

climate resilience

of the sector

Adoption of the long-

term plan on the

irrigation system

Q1 2025 Adoption of the “Long-term plan for the development of the irrigation system”. The plan

focuses on these main areas:

- priorities in the irrigation sector based on an analysis of full economic benefits;

- alignment with the water sector strategy and the water basin-based water management

principles;

- indication of needed public and other investments and the need for further privatisation;

- governance/management dimension of the sector;

- environmental assessment to be carried out for any rehabilitation or construction project in

line with EU recommendation on environmental impact assessment, environmental strategic

assessment and Ukraine legislation in this area.

12.8 Reform 6.

Demining of land

and water areas

Adoption of the strategic

document on Mine

Action for the period up

to 2033

Q2 2024 Adoption of the legislative act on the approval of the strategic document on Mine Action for

the period up to 2033 (the Act of the Cabinet of Ministers of Ukraine or the President of

Ukraine). The legislative act focuses on these main areas:

- management in the field of Mine Action;

- support of the efficiency of Mine Action operators;

- prevention of accidents;

- comprehensive assistance to victims;

- innovations;

- gender balance and representation;

- development of the private market;

- effective and transparent coordination with donors;

- forming the system of prioritisation of tasks in mine action.

12.9 Investment 1.

Investments in

demining

Investments of at least

EUR 30 million in

demining of agriculture

land

Q2 2026 Interim report of the Government (or State Treasury report) showing that in the State

Budgets for 2024 and 2025 the general Government budgeted at least EUR 30 million (in

UAH equivalent) for the demining of agricultural land.

12.10 Investment 1.

Investments in

demining

Investments of at least

EUR 100 million in

demining of agriculture

land

Q3 2027 Final report of the Government (or State Treasury report) showing that in the State Budgets

for 2024, 2025, 2026, 2027 the general Government budgeted at least EUR 100 million (in

UAH equivalent) for the demining of agricultural land.

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C.13. MANAGEMENT OF CRITICAL RAW MATERIALS

1. Description of Reforms and Investments

The objective of this chapter is to support further development of the critical raw materials sector in Ukraine

in line with both economic and sustainability objectives. It will focus on improving strategic planning and

administrative procedures.

Reform 1. Strengthening strategic planning and ensuring optimum framework for strategic investors.

The objective of this reform is to attract investments in the extraction and processing of critical raw materials.

The reform has two steps. First, a law on amendments to the National Programme for the Development of the

Mineral Resource Base of Ukraine for the Period up to 2030 shall enter into force, introducing the State

Compensatory Fund for geological area and setting strategic directions for the sector. Second, a report on the

verification of critical raw materials reserves of Ukraine using international classification shall be published

and made available to investors.

The reform is expected to be completed by Q3 2025.

Reform 2. Improved administrative procedures.

The objective of this reform is to optimise the procedure and reduce the administrative burden for potential

investors. The main goal is to improve transparency, speed, and cost efficiency for new investment decisions.

The reform has three steps. First, a pipeline of investment projects for extraction of critical raw materials shall

be published. Second, Product Sharing Agreement (PSA) international tenders using the model agreement

terms as agreed by the Government and made public shall be launched. Third, the development and launch of

an e-cabinet of subsoil users with additional functionalities.

The reform is expected to be completed by Q2 2025.

Reform 3. Use of Modern Extraction Technologies and Integration of Ukraine into Modern Processing Value

Chains

The objective of this reform is to enhance transparency as regards environmental, social and corporate

governance practices in the critical raw materials sector.

The reform has one step. It entails the publication of a study assessing current legislation on Environmental,

Social and Governance reporting (ESG) in the mining and extractive sector.

The reform is expected to be completed by Q4 2025.

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2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

13.1 Reform 1.

Strengthening

strategic planning

and ensuring

optimum framework

for strategic

investors

Entry into force of the

legislation on revising the

National Programme for

the Development of the

Mineral Resource Base of

Ukraine to 2030

Q4 2024 Entry into force of the Law of Ukraine on Amendments to the National Program for the

Development of the Mineral Resource Base of Ukraine for the Period up to 2030. The law

focuses on these main areas:

- introduction of State Compensatory Fund for geological area;

- prioritisation of the goals of extraction area in line with the EU Strategies;

- definition of the terms of strategic and critical raw materials, the need for regular

methodological risk assessment of the level of security of their supply, and the definition

of a group of partner countries.

13.2 Reform 1.

Strengthening

strategic planning

and ensuring

optimum framework

for strategic

investors

Publishing of a report on

the verification of Critical

Raw Materials’ reserves

of Ukraine

Q3 2025 Publication of a report on the verification of Critical Raw Materials reserves of Ukraine

using international classification system and results are made available to investors.

13.3 Reform 2.

Improved

administrative

procedures

Publication of a pipeline

of investment projects for

extraction of critical raw

materials

Q2 2025 Publication of the pipeline of investment projects for extraction of critical raw materials.

13.4 Reform 2.

Improved

administrative

procedures

Launching of Product

Sharing Agreement (PSA)

international tenders

ensuring their

transparency

Q2 2025 Launch and publication of the Product Sharing Agreement (PSA) international tenders,

using the model agreement terms as agreed by the Government. Transparency of PSA

tenders and Agreements ensured through the open access to its terms.

13.5 Reform 2. Set up of an upgraded e-

cabinet of subsoil users

Q1 2025 An upgraded e-cabinet of subsoil users with additional functionalities of access to state

register of special permits for subsoil use allowing requesting and obtaining e-licences

(extract from the Register) and providing access to digital geological data is operational.

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Improved

administrative

procedures

13.6 Reform 3.

Use of Modern

Extraction

Technologies and

Integration of

Ukraine into Modern

Processing Value

Chains

Publication of a study on

the legislation on ESG

reporting

Q4 2025 Endorsement and publication of study assessing the current legislation on Environmental,

Social and Governance (ESG) reporting in the mining and extractive sector, proposing

recommendations on what legislative gaps need to be covered.

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C.14. DIGITAL TRANSFORMATION

1. Description of Reforms and Investments

The objective of this chapter is to bolster the digital transformation of Ukraine. It will also focus on

strengthening cybersecurity.

Reform 1. Secure and efficient digital infrastructure

The objective of this reform is to strengthen cybersecurity in the process of digital transformation.

The reform has two steps. First, a resolution that defines the radio technologies that are allowed for use in

Ukraine shall be adopted. Second, a number of cybersecurity legislative acts shall enter into force to align

with the NIS and NIS2 framework, also paving the way towards the implementation of the Union’s 5G

Security Toolbox.

The reform is expected to be completed by Q1 2025.

Reform 2. Digitalisation of public services

The objective of this reform is to simplify the interaction between the state and citizens via digitalisation.

The reform has three steps. First, an Action Plan until 2026 for digitalisation of most common public services

in a number of areas shall be adopted. Second, a legal act on the functioning of the Integrated Electronic

Identification System in line with the principles of Regulation (EU) 2024/1183 of the European Parliament

and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the

European Digital Identity Framework shall enter into force. Third, the technical specifications of the Diia

mobile application shall enable the use of electronic attestations of attributes for Ukrainian nationals in

accordance with the data format specified for the EU Digital Identity Wallet.

The reform is expected to be completed by Q4 2026.

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2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

14.1 Reform 1.

Secure and

efficient digital

infrastructure

Adoption of a revised

Plan for allocation and

use of the radio spectrum

in Ukraine

Q1 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on amending the Resolution

of the Cabinet of Ministers of Ukraine “On Approving the Plan for Allocation and Use of the

Radio Spectrum in Ukraine”. The Resolution defines the radio technologies that are allowed for

use in Ukraine, with the definition of the radio frequency bands and radio services to which they

correspond, as well as the terms of termination of their development and use, as well as the list

of promising radio technologies for implementation in Ukraine with the definition of the radio

frequency bands and radio services to which they correspond, as well as the terms of their

implementation in line with the Union acquis.

14.2 Reform 1.

Secure and

efficient digital

infrastructure

Entry into force of the

legislation on

strengthening the cyber

security capabilities of

state information

resources and critical

information

infrastructure

Q1 2025 Entry into force of the respective legislative acts to align with the NIS and NIS2 framework

(namely the Directive (EU) 2022/2555 of the European Parliament and of the Council of 14

December 2022 on measures for a high common level of cybersecurity across the Union,

amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and repealing Directive

(EU) 2016/1148). The acts focus on these main areas:

- regulate the mandatory implementation of measures aimed at creating an appropriate legal

framework for the implementation of measures to prevent, detect and suppress acts of aggression

in cyberspace in the context of the Russian Federation’s war against Ukraine;

- increase the level of protection of state information resources and critical information

infrastructure against cyberattacks;

- improve the regulatory framework in the field of cybersecurity and information protection to

strengthen the capabilities of the national cybersecurity system to counter cyber threats.

14.3 Reform 2.

Digitalisation of

public services

Adoption of the Action

Plan for digitalisation of

public services until

2026

Q1 2025 Adoption of the Ordinance of the Cabinet of Ministers of Ukraine on approving the action plan

for digitalisation of public services until 2026. The action plan focuses on these main areas:

- recovery;

- education;

- health care;

- services for veterans;

- military serviceman;

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- customs;

- e-social sphere.

14.4 Reform 2.

Digitalisation of

public services

Entry into force of the

legal act on the

functioning of the

Integrated Electronic

Identification System, in

line with the principles

of Regulation (EU)

2024/1183

Q2 2026 Entry into force of a legal act on the functioning of the Integrated Electronic Identification

System in Ukraine as a key component of the national electronic identity infrastructure, in line

with the principles of Regulation (EU) 2024/1183. The legal act focuses on these main areas: :

- establishment of a modern electronic identification system in Ukraine and ensuring its

sustainable development;

- ensuring interoperability (technological compatibility) of electronic identification means,

intermediate electronic identification nodes (hubs) and electronic identification schemes;

- protection of information resources processed in the system.

14.5 Reform 2.

Digitalisation of

public services

Enablement of EU-

format Electronic

Attestations in Diia

Q4 2026 The technical specifications of the mobile application of Diia Portal enables usage of electronic

attestation of attributes for the nationals of Ukraine in the data format specified for EU Digital

Identity Wallet.

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C.15. GREEN TRANSITION AND ENVIRONMENTAL PROTECTION

1. Description of Reforms and Investments

The objective of this chapter is to foster Ukraine’s green transition, by supporting decarbonisation and

strengthening environmental and climate resilience.

Reform 1. Prevention, reduction and control of industrial pollution

The objective of this reform is to address environmental pollution, ensuring the constitutional right of citizens

to a safe environment.

The reform has one step. It entails the entry into force of the legislation aimed at preventing, reducing and

controlling industrial pollution, with a partial application of provisions. The step introduces integrated

approaches to permitting and control of industrial pollution based on the application of best available

technologies and management methods in accordance with relevant EU legislation.

The reform is expected to be completed by Q3 2024.

Reform 2. Climate policy

The objective of this reform is to create an architecture for climate governance as well as an appropriate

mechanism for the development and implementation of state policy in the field of climate change in Ukraine.

The reform has three steps. First, new legislation shall enter into force that establishes basic principles of

Ukraine’s state climate policy. Second, resolution on the scientific and expert council on the preservation of

the ozone layer shall be adopted. Third, the second Nationally Determined Contribution of Ukraine to the

Paris Climate Agreement shall be adopted.

The reform is expected to be completed by Q4 2025.

Reform 3. Market mechanisms of carbon pricing

The objective of this reform is to foster the development of market mechanisms of carbon pricing.

The reform has two steps. First, an action plan for the development of a National Greenhouse Gas Emissions

Trading Systemshall be adopted. Second, Ukraine shall resume its mandatory monitoring, reporting, and

verification (MRV) system, with certain exceptions.

The reform is expected to be completed by Q2 2025.

Reform 4. Restoration and conservation of natural resources

The objective of this reform is to reduce deforestation and forest degradation.

The reform has two steps. First, the amendments to the Resolution of 19 September 2018 no. 758 on the

Procedure for State Water Monitoring are adopted. Second, legislation that will regulate the issue of

confirming the sustainability of the origin of wood and other goods that may lead to deforestation and forest

degradation enters into force.

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The reform is expected to be completed by Q4 2026.

Reform 5. Increased circular economy

The objective of this reform is to implement the principles of circular economy and waste management.

The reform has two steps. First, a national waste management plan shall be adopted. Second, Ukraine shall

adopt a strategy for implementing the principles of the circular economy and an action plan for its

implementation.

The reform is expected to be completed by Q1 2026.

Reform 6. Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA)

The objective of this reform is to foster environmental protection by enhancing clarity on the Environmental

Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) rules.

The reform has one step. It entails the publication of a concept note that shall define the scope of derogations

from the EIA and SEA rules.

The reform is expected to be completed by Q3 2024.

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2. List of steps and timetable for implementation

No. Reform /

Investment Name of the step Timeline Step description

15.1 Reform 1

Prevention,

reduction and

control of

industrial pollution

Entry into force of the legislation

on prevention, reduction, and

control of industrial pollution with

partial application of provisions

Q3 2024 Entry into force of the Law of Ukraine on Ensuring the Constitutional Rights of

citizens to a safe environment for life and health with a partial application of the

provisions. Bylaws are to be adopted within 12 months and some provisions on

applying of the findings of the best available technologies and management

methods within 4 years after termination of the martial law, except for the

installations that are put into operation for the first time.

The law is aimed at preventing, reducing and controlling industrial pollution and

introduces integrated approaches to permitting and control of industrial pollution

based on the application of the best available technologies and management

methods in accordance with Directive 2010/75/EU of the European Parliament

and of the Council of 24 November 2010 on industrial emissions (integrated

pollution prevention and control)

15.2 Reform 2.

Climate policy

Entry into force of the legislation

on the State Climate Policy

Q1 2025 Entry into force of the Law of Ukraine "On the Basic Principles of State Climate

Policy". The law focuses on these main areas:

- goals and basic principles of the state climate policy;

- governing bodies in the field of climate change;

- strategic planning in the field of climate change;

- mechanisms and tools for achieving climate goals;

- national framework for tracking the implementation of policies and measures

and forecasting in the field of climate change;

- scientific and expert council on climate change and preservation of the ozone

layer;

- national system of inventory of anthropogenic emissions by sources and

absorption by sinks of greenhouse gases;

- international cooperation in the field of climate change.

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15.3 Reform 2.

Climate policy

Adoption of the resolution on the

Scientific and Expert Council on

Climate Change and Preservation

of the Ozone Layer

Q4 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine "On Approval

of the Regulation on the Scientific and Expert Council on Climate Change and

Preservation of the Ozone Layer". The Regulation focuses on these main areas:

- consideration of scientific conclusions of the Intergovernmental Panel on

Climate Change (IPCC) reports and scientific climate data and information, in

particular, concerning Ukraine;

- providing scientific and expert support and proposals, including preparation of

reports, on climate goals, policies and measures, monitoring their implementation

and forecasting in the field of climate change, as well as compliance of goals,

policies and measures with Ukraine's international obligations;

- promoting the exchange of scientific achievements in the field of modelling,

monitoring, advanced research and innovation aimed at reducing greenhouse gas

emissions and increasing absorption by sinks;

- scientific substantiation of ways and means to achieve climate goals;

- informing, raising awareness and educating on climate change and its

consequences, as well as developing dialogue and cooperation between scientific

institutions on climate change issues;

- guarantees of independence for said Council in all its proceedings;

- diverse, scientifically relevant composition of said Council.

15.4 Reform 2.

Climate policy

Adoption of the second Nationally

Determined Contribution of

Ukraine to the Paris Agreement

Q3 2025 Adoption of the Order of the Cabinet of Ministers of Ukraine "On Approval of the

Second Nationally Determined Contribution (NDC) of Ukraine to the Paris

Agreement". The NDC focuses on these main areas:

- higher emission reduction target than in the current NDC of Ukraine;

- establishing a base year for calculating emissions from sources and sinks of

greenhouse gases;

- duration of implementation and/or time periods of the proposed measures;

- scope and coverage of economic sectors and greenhouse gases;

- process planning, assumptions and methodological approaches used, including

for estimation and accounting of anthropogenic emissions by sources and

removals by sinks of greenhouse gases;

111

- justification of the equity and ambition of the NDC in the light of national

circumstances;

- contribution to the achievement of the objective of the UN Framework

Convention on Climate Change and to limit greenhouse gas emissions/enhance

sinks, in accordance with the objective set out in Article 2 of the UN Framework

Convention on Climate Change.

The Second NDC of Ukraine to the Paris Agreement will be more ambitious than

the current Updated NDC.

15.5 Reform 3.

Market

mechanisms of

carbon pricing

Adoption of the Action Plan for

the Establishment of a National

Greenhouse Gas Emissions

Trading System

Q1

2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine "On Approval

of the Action Plan for the Establishment of a National Greenhouse Gas

Emissions Trading System. Adoption of the Action Plan will ensure the

definition of:

- stages of the ETS implementation;

- timeframes of the stages;

- the necessary infrastructure;

- organisational measures.

15.6 Reform 3.

Market

mechanisms of

carbon pricing

Resumption of the compulsory

monitoring, reporting and

verifying (MRV) system

Q2 2025 The resumption of a mandatory monitoring, reporting and verification (MRV)

system for facilities covered by the scope of the existing legislation, except for

those that are not controlled, destroyed or located in the temporarily occupied

territory, or have officially announced the suspension of operations in terms of

production.

15.7 Reform 4.

Restoration and

conservation of

natural resources

Entry into force of the Law on

reducing deforestation and forest

degradation

Q4 2026 Entry into force of the Law of Ukraine that will regulate the issue of confirming

the sustainability of the origin of wood and other goods that may lead to

deforestation and forest degradation. The Law focuses on these main areas:

- expanding the use of electronic timber accounting, which will ensure the

tracking of timber movement and confirmation of the legitimacy of the origin of

timber and timber products;

- ensuring that the certification system for wood products was introduced and the

existing certification system for manufactured wood was extended to cover all

wood trading operations;

112

- establishing requirements for confirming the origin of wood, including wood

products in trade.

15.8 Reform 5.

Increased circular

economy

Adoption of the Strategy for

implementing the principles of the

circular economy and its Action

Plan

Q1 2026 Adoption of the strategy for implementing the principles of the circular economy

and of an action plan for its implementation by the Cabinet of Ministers of

Ukraine. The strategy identifies potential opportunities and impacts of the

transition to a circular economy in Ukraine for 5-10 pre-selected priority sectors

and value chains, such as waste, textiles, plastics, batteries, electronics,

agriculture, construction and repair, and metals and minerals.

15.9 Reform 5.

Increased circular

economy

Adoption of the National Waste

Management Plan until 2033

Q3 2025 Adoption of the Order of the Cabinet of Ministers of Ukraine "On Approval of

the National Waste Management Plan until 2033". The National Waste

Management Plan focuses on these main areas:

- household waste management;

- hazardous waste management;

- infrastructure needs;

- economic and financial sustainability analyses of the action plan;

- implementation of economic instruments to improve waste management;

- monitoring and control of waste management;

- strategic planning of waste management in Ukraine;

- implementation of waste management at the regional level.

15.10 Reform 6.

Environmental

Impact Assessment

(EIA) and Strategic

Environmental

Assessment (SEA)

Development of a concept note

defining the scope of deviations

from the Environmental Impact

Assessment (EIA) and Strategic

Environmental Assessment (SEA)

rules

Q3 2024 Preparation and publication on the official website of the Ministry of

Environmental Protection and Natural Resources of aa concept note following

public consultations with stakeholders defining the scope of derogations from the

EIA and SEA rules.

The concept note includes the following information:

- on the body that determines the scope of derogations from EIA and SEA

obligations;

- description of the objects and explanation of why they are included in the scope

of derogation in each specific case;

- justification of the scope of derogations;

- time limits for the derogations granted.’.

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15.11 Reform 4.

Restoration and

conservation of

natural resources

Adoption of amendments to the

Procedure for State Water

Monitoring

Q2 2026 Adoption of amendments to the Resolution of 19 September 2018 no. 758 on the

Procedure for State Water Monitoring in line with the principles of Directive

2000/60/EC of the European Parliament and of the Council of 23 October 2000

establishing a framework for Community action in the field of water policy and

Directive 2008/105/EC of the European Parliament and of the Council of 16

December 2008 on environmental quality standards in the field of water policy,

amending and subsequently repealing Council Directives 82/176/EEC,

83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and amending Directive

2000/60/EC of the European Parliament and of the Council.