EN EN

EUROPEAN COMMISSION

Brussels, 21.10.2026 COM(2026) 583 final

2026/0331 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

establishing the satisfactory fulfilment of the conditions for the partial payment of the

ninth instalment under the Ukraine Plan of the Ukraine Facility

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2026/0331 (NLE)

Proposal for a

COUNCIL IMPLEMENTING DECISION

establishing the satisfactory fulfilment of the conditions for the partial payment of the

ninth instalment under the Ukraine Plan of the Ukraine Facility

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 26(4) thereof,

Having regard to the proposal from the European Commission,

Whereas:

(1) Pillar I of the Ukraine Facility (‘the Facility’), established by Regulation

(EU) 2024/792, makes financial support of up to EUR 46 873 049 093,86 as set out in

Council Implementing Decision (EU) 2026/19232 and the equivalent in EUR of

NOK 1 000 000 000 as set out in Council Implementing Decision (EU) 2026/22293

available to Ukraine for the period 2024-2027.

(2) The financial support takes the form of non-repayable support and loans.

(3) Financial support under Pillar I of the Facility is allocated largely on the basis of the

Ukraine Plan (‘the Plan’)4, approved by the Council Implementing Decision (EU)

2024/14475. The Plan sets out the steps that Ukraine must fulfil in order to receive the

quarterly instalments.

(4) To date, EUR 32 455 384 486,86 has been disbursed to Ukraine under Pillar I of the

Facility. Of that amount, EUR 4 431 301 973,86 has been disbursed in the form of

non-repayable financial support and EUR 20 134 082 513 in the form of loans under

the first eight instalments of the Plan. In addition, Ukraine received EUR

1 OJ L, 2024/792, 29.2.2024, ELI: http://data.europa.eu/eli/reg/2024/792/oj. 2 Council Implementing Decision (EU) 2026/1923 of 30 July 2026 amending Implementing Decision

(EU) 2024/1447 on the approval of the assessment of the Ukraine Plan (OJ L, 2026/1923, 7.8.2026,

ELI: http://data.europa.eu/eli/dec_impl/2026/1923/oj). 3 Council Implementing Decision (EU) 2026/2229 of 24 September 2026 amending Implementing

Decision (EU) 2024/1447 as regards the additional financial contribution from Norway. In accordance

with that Decision, Norway will provide NOK 1 000 000 000 as an additional financial contribution to

Pillar I of the Facility in the form of non-repayable financial support, following the entry into force of

a transfer agreement between Norway and the Commission and the transfer of the related financial

contribution (OJ L, 2026/2229, 2.10.2026, ELI: http://data.europa.eu/eli/dec_impl/2026/2229/oj). 4 Financial support under Pillar I of the Facility includes exceptional bridge financing as set out in Article

25 of Regulation (EU) 2024/792 in addition to the support available under the Ukraine Plan. 5 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).

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6 000 000 000 as exceptional bridge financing and EUR 1 890 000 000 as pre-

financing, pursuant to Articles 24 and 25 of Regulation (EU) 2024/792.

(5) In accordance with the loan agreement concluded between the Union and Ukraine

pursuant to Article 22 of Regulation (EU) 2024/792, an amount of EUR 1 455 253 522

from those first eight instalments was used to clear the pre-financing of the Ukraine

Facility loan.

(6) On 30 September 2026, Ukraine submitted a request for the payment of part of the

fourth, seventh, eighth and ninth instalments under the Plan, amounting to

EUR 8 305 265 116. The request also covered one step in the tenth instalment.

(7) In particular, the request was accompanied by documents presented as evidence that

Ukraine had fulfilled one step in the fourth instalment, three steps in the seventh

instalment, one step in the eight instalment, seventeen steps in the ninth instalment and

one step in the tenth instalment. Ukraine also submitted documents required under the

agreements concluded pursuant to Articles 9, 10 and 22, of Regulation

(EU) 2024/7926.

(8) The steps underpinning Ukraine’s latest payment request relate to various reforms and

investments set out in the Plan which broadly fall under the chapters on: judicial

system; fight against corruption and money laundering; financial markets;

management of public assets; human capital; business environment; decentralisation

and regional policy; energy sector; transport; agri-food sector; digital transformation;

and green transition and environmental protection.

(9) As set out in the Annex to this Decision, the Commission has assessed Ukraine’s

request in detail in accordance with Article 26 (3) of Regulation (EU) 2024/792. It has

concluded that Ukraine has satisfactorily fulfilled step 4.3 under the fourth instalment

under the Plan, steps 4.8, 6.7 and 10.3 under the seventh instalment, step 15.8 under

the eighth instalment, and steps 3.10, 3.17, 4.20, 5.3, 5.5, 7.7, 7.12, 7.14, 7.18, 7.20,

8.12, 9.7, 10.19, 12.9, 14.4 and 15.11 under the ninth instalment.

(10) The Commission has assessed that Ukraine partially fulfilled step 6.3 under the ninth

instalment. In addition, the Commission has assessed that Ukraine has satisfactorily

fulfilled step 10.21 under the tenth instalment. Therefore, in line with the methodology

for handling partial fulfilment of steps in the Plan set out in the Communication from

the Commission of 17 April 20267 (the ‘methodology’), the Commission proposes to

take this into account as a mitigating factor.

(11) The Commission has further assessed that Ukraine continues to fulfil the pre-condition

for Union support set out in Article 5 of Regulation (EU) 2024/792. In particular,

Ukraine continues to uphold and respect effective democratic mechanisms, including

a multi-party parliamentary system and the rule of law, and to guarantee respect for

human rights, including the rights of persons belonging to minorities.

(12) In its payment request, Ukraine confirmed that it had not reversed any measure related

to the steps which it had previously satisfactorily fulfilled.

6 The respective agreements include: the framework agreement concluded pursuant to Article 9 of

Regulation (EU) 2024/792, the financing agreement concluded pursuant to Article 10 of Regulation

(EU) 2024/792, and the loan agreement concluded pursuant to Article 22 of Regulation (EU) 2024/792. 7 Communication from the Commission amending the methodology for handling the partial fulfilment of

steps in the Ukraine Plan under the Ukraine Facility Regulation and replacing Communication C(2025)

1725 (OJ C, 2026/2328, 17.4.2026, ELI: http://data.europa.eu/eli/C/2026/2328/oj).

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(13) This Decision should therefore establish that Ukraine has satisfactorily fulfilled the

relevant conditions for the payment of the fourth instalment in respect of one

outstanding step under the Plan, of the seventh instalment in respect of three

outstanding steps, of the eighth instalment in respect of one outstanding step and of the

ninth instalment in respect of sixteen steps.

(14) Considering Ukraine’s urgent financing needs, it is of the utmost importance to

disburse the funds as soon as possible. With a view to expediting the process, this

Decision should enter into force on the date 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

(1) In accordance with the Commission’s assessment provided in accordance with

Article 26 of Regulation (EU) 2024/792 set out in the Annex to this Decision, the

Council establishes that Ukraine has satisfactorily fulfilled the relevant conditions for

the partial payment pursuant to Implementing Decision (EU) 2024/1447 of the

fourth, seventh, eighth and ninth instalments of financial assistance under the

Ukraine Plan. Such assistance shall amount to EUR 8 040 665 425 before clearing

the pre-financing, of which EUR 298 747 120 corresponds to the fourth instalment,

EUR 368 010 368 corresponds to the seventh instalment, EUR 95 530 669

corresponds to the eighth instalment, and EUR 7 278 377 268 corresponds to the

ninth instalment.

(2) Taking into account the satisfactory fulfilment of one step under the tenth instalment

and the partial fulfilment of one step under the ninth instalment, the importance of

the steps that have not been fulfilled, the reasons for their non-fulfilment, and the

importance of the step that has been fulfilled early, a mitigating factor amounting to

EUR 529 397 883 is applied, thereby reducing the suspension value corresponding to

the unfulfilled steps under the ninth instalment.

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

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EUROPEAN COMMISSION

Brussels, 21.10.2026 COM(2026) 583 final

ANNEX

ANNEX

to the

Proposal for a Council Implementing Decision

establishing the satisfactory fulfilment of the conditions for the partial payment of the

ninth instalment under the Ukraine Plan of the Ukraine Facility

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ANNEX

EXECUTIVE SUMMARY

On 30 September 2026, Ukraine submitted a request for payment of part of the fourth,

seventh, eighth and ninth instalments of the Ukraine Plan, in accordance with Article 26 of

Regulation (EU) 2024/792 of 29 February 2024 establishing the Ukraine Facility1. To support

the payment request, Ukraine provided justification for the satisfactory fulfilment of one step

in the fourth instalment, three steps in the seventh instalment, one step in the eighth

instalment and 17 steps in the ninth instalment, set out in the Annex to Council Implementing

Decision (EU) 2024/1447 of 14 May 2024 on the approval of the assessment of the Ukraine

Plan2, as subsequently amended (‘the CID Annex’). Ukraine also provided evidence for one

step in the 10th instalment.

On the basis of the information provided by Ukraine, 16 steps of the ninth instalment are

considered to have been satisfactorily fulfilled.

• Step 3.10, concerning the upgraded IT system for enforcement of court decisions is

operational.

• Step 3.17, concerning the adoption of the Presidential Decree approving the Human

Rights Protection Strategy.

• Step 4.20, concerning the adoption of the State Programme to combat human

trafficking until 2030.

• Step 5.3, concerning the adoption of the strategy for gradual reduction of state

ownership in the banking sector.

• Step 5.5, concerning the entry into force of legal acts to improve resolution of non-

performing loans.

• Step 7.7, concerning the adoption of the Population Employment Strategy.

• Step 7.12, concerning investments of at least EUR 300 million in education.

• Step 7.14, concerning investments of at least EUR 200 million in healthcare.

• Step 7.18, concerning 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.

• Step 7.20, concerning the 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.

1 Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024

establishing the Ukraine Facility (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).

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• Step 8.12, concerning the adoption of amendments to the resolution on the

designation of the single national metrology institute.

• Step 9.7, concerning the 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.

• Step 10.19, concerning the preparation of the Terms of Reference for a third-party of

the National Energy and Utilities Regulatory Commission regarding the integrity

and robustness of its financial and decision-making processes.

• Step 12.9, concerning investments of at least EUR 30 million in demining of

agricultural land.

• Step 14.4, concerning the entry into force of the functioning of the Integrated

Electronic Identification System, in line with the principles of Regulation (EU)

2024/1183.

• Step 15.11, concerning the adoption of amendments to the Procedure for State Water

Monitoring.

The Commission has assessed that the evidence provided for two of the steps required for the

ninth instalment is not sufficient to conclude that they are satisfactorily fulfilled (Step 6.3

concerning the appointment of supervisory boards of state-owned enterprises with a majority

of independent members and Step 10.9 concerning the adoption of a roadmap for the gradual

liberalisation of gas and electricity markets to be implemented after the expiration of martial

law).

In accordance with the methodology for handling the partial fulfilment of steps under the

Ukraine Plan (‘the methodology’), the progress made in the implementation of the

quantitative Step 6.3 was proposed as a mitigating factor:

• Step 6.3, concerning the appointment of supervisory boards of state-owned

enterprises with a majority of independent members.

In addition, and in accordance with the methodology, the following step scheduled for the

10th instalment was declared by Ukraine as fulfilled and was also proposed as a potential

mitigating factor:

• Step 10.21, concerning the request for an integrated regulatory review service

mission at SNRIU by the International Atomic Energy Agency.

Furthermore, the information provided by Ukraine, shows that one step from the fourth

instalment, three steps from the seventh instalment and one step from the eighth instalment

have been satisfactorily fulfilled.

• Step 4.3, concerning increased manpower for the High Anti-Corruption Court.

• Step 4.8, concerning the preparation and implementation of the next National Risk

Assessment.

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• Step 6.7, concerning the entry into force of legislation on the separation of public

service obligations (PSO) and non-PSO activities.

• Step 10.3, concerning the entry into force of the legislation to improve permitting

procedures for renewable energy investments.

• Step 15.8, concerning the adoption of the Strategy for implementing the principles of

the circular economy and its Action Plan.

As part of Chapter 3 on the judicial system, an upgraded IT system for enforcement of court

decisions became operational; and the Presidential Decree approving the Human Rights

Protection Strategy was adopted.

As part of Chapter 4 on the fight against corruption and money laundering, the manpower

for the High Anti-Corruption Court was increased, the next National Risk Assessment was

conducted and the State Programme to combat human trafficking until 2030 was adopted.

As part of Chapter 5 on financial markets, the strategy for gradual reduction of state

ownership in the banking sector was adopted; and the legislation to improve the resolution of

non-performing loans entered into force.

As part of Chapter 6 on management of public assets, the legislation on the separation of

public service obligations (PSO) and non-PSO activities entered into force.

As part of Chapter 7 on human capital, the Population Employment Strategy was adopted,

there have been investments of at least EUR 300 million in education and 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. At the same time, 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 was approved.

As part of Chapter 8 on the business environment, amendments to the resolution on the

designation of the single national metrology institute were adopted.

As part of Chapter 9 on the decentralisation and regional policy, the 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 entities was reached.

As part of Chapter 10 on the energy sector, the legislation on shortening the permitting

procedures for renewable energy investments entered into force; 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 were prepared and the

request for an integrated regulatory review service mission at SNRIU by the International

Atomic Energy Agency was submitted.

As part of Chapter 14, on digital transformation, the legislation on the functioning of the

Integrated Electronic Identification System, in line with Regulation (EU) 2024/1183, was

adopted and entered into force.

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As part of Chapter 15 on green transition and environmental protection,the Strategy for

implementing the principles of circular economy and its Action Plan and the legislation

amending the Procedure for State Water Monitoring were adopted.

For the assessment of investment Steps 7.12, 7.14, 7.18, 9.7 and 12.9, expenses reported in

Ukrainian hryvnia (UAH) were converted into euro (EUR) using the average of the monthly

UAH/EUR exchange rates for the relevant budget year. For expenditure reported in 2026, the

average monthly exchange rate was calculated with the latest available data as of October

2026.

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Step 3.10

Name of the step: An upgraded IT system for enforcement of court decisions is operational

Related reform/investment: Reform 2. Reforms of insolvency and enforcement of court

decisions

Financed from: loan

Context

The requirement for Step 3.10 described in the CID Annex is:

‘The upgraded IT system for enforcement facilitating enforcement process, debtor asset

tracking, bank account freezing and debt recovery is operational.’

Step 3.10 is one of the five steps under Reform 2 of Chapter 3 (judicial system and human

rights). It is the last step in Reform 2 apart from Step 3.7 due by Q1 2026 that remains

unfulfilled from the eight payment.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) The Strategic Action Plan of the State Enterprise on National Information Systems for

2024 – 2027;

3) A detailed description provided by the Ministry of Justice of the upgrades introduced

to the Automated System of Enforcement Proceedings;

4) Copies of Orders of the Ministry of Justice No 9 of 19.1.2024, No 35 of 28.2.2024, No

77 of 27.5.2024, No 94 of 28.6.2024, No 234 of 25.12.2024, No 177 of 1.9.2025, No.

162 of 12.9.2025 and No. 132 of 24.6.2026 to the State Enterprise on National

Information Systems on the modernisation of software;

5) Letter dated 10 June 2025 from the State Enterprise on National Information Systems

to the Ministry of Justice on the implementation of the upgrades to the Automated

System of Enforcement Proceedings;

6) Copies of the minutes of meetings of the Technological Committee of the State

Enterprise on National Information Systems.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover the

constitutive elements of Step 3.10.

The objective of Reform 2 is to improve insolvency and enforcement procedures by aligning

the relevant legislation with the EU acquis and building institutional and other capacities to

properly apply it. To this end, Ukraine has upgraded several functionalities of the Automated

System of Enforcement Proceedings (ASEP).

To facilitate the enforcement process, the option of sending documents linked to enforcement

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proceedings through ASEP to parties registered in the Unified Judicial Information and

Communication System (UJICS) was launched on 15 May 2024. Following this upgrade,

individuals and legal entities that have electronic cabinets in the UJICS will receive

documents of enforcement proceedings (decrees, acts, etc.) directly in their electronic cabinet.

ASEP contains updated document templates for a number of typical procedural actions, such

as reports on search warrants sent to the National Police. Furthermore, in 2025 a series of

improvements were implemented aimed at the digitalisation of record-keeping for public and

private bailiffs.

The upgrades also improve asset tracking by displaying and storing information about

debtors’ assets. On 8 January 2024 the system was revised to facilitate enforcement officers’

work with debtors’ assets. Following the upgrades, all information received during

enforcement proceedings is stored centrally. The upgraded system improves enforcement

officers’ ability to track information on a debtor’s property, such as cars or apartments. An

information exchange with the Ministry of Social Policy, Family and Unity of Ukraine

introduced in 2025 will increase the accessibility of information on natural persons.

Furthermore, ASEP has been upgraded to include the centralised display of data on the

debtors’ bank accounts, providing executors faster and easier access to the information on

debtors’ accounts.

To facilitate the freezing of bank accounts, in total 30 payment service providers have joined

the system as of 2024, allowing for automatic information exchange in the procedure for the

seizure of funds, contributing to debt recovery.

To facilitate debt recovery, ASEP also allows executive documents to be sent in electronic

format. The automated sending of decisions on administrative fines and additional materials

in the form of electronic documents was extended to new actors in 2024, in particular to Kyiv

City Council and Lutsk City Council. From 2026 onwards the system has allowed orders to

recover a debtor’s income to be delivered to the debtor’s employer(s), increasing the

effectiveness of debt recovery.

Commission assessment: satisfactorily fulfilled

Step 3.17

Name of the step: The adoption of the Presidential Decree approving the Human Rights

Protection Strategy

Related reform/investment: Reform 5. Enhancing the protection of human rights

Financed from: loan

Context

The requirement for Step 3.17 described in the CID Annex is:

‘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

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

- rights of children in armed conflicts

- access to services for vulnerable persons.’

Step 3.17 is the only step in the implementation of Reform 5 in Chapter 3 (judicial system and

human rights).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of the Decree of the President of Ukraine No 1038/2026 ‘Issues of the National

Human Rights Strategy’ of 12 October 2026.

Analysis

The justification and evidence provided by the Ukrainian authorities cover all constitutive

elements of Step 3.17.

The objective of Reform 5 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 to enhance access to services for vulnerable people. To this end, the National Human

Rights Strategy for the period up to 2035 was adopted by the Decree of the President of

Ukraine No. 1038/2026 ‘Issues of the National Human Rights Strategy’ on 12 October 2026.

According to the General Provisions, the National Human Rights Strategy (‘the Strategy’) is a

long-term framework policy document on human rights setting out the strategic objectives,

priorities and principles for ensuring and protecting human rights and freedoms in Ukraine

until 2035. The Strategy is intended to complement Ukraine’s existing commitments in the

context of European integration. Its implementation will be supported by action plans to be

developed every three years.

The Strategy takes into account the specific challenges to the protection of human rights

arising from martial law, such as restrictions on access to documents and on the freedom of

peaceful assembly. It recognises challenges that are particularly relevant to Ukraine’s post-

war recovery, such as the availability of specialised medical, psychological and social

rehabilitation programmes for war veterans and the reintegration and return of and services

for internally displaced persons. It includes an objective to improve electoral legislation and

ensure the exercise of electoral rights in the post-war period.

Special attention is paid to the rights of persons living in territories of Ukraine temporarily

occupied by the Russian Federation, in areas near the frontline and of internally displaced

persons. The Strategy sets out the objective of developing and implementing state policy on

the disoccupation and reintegration of the temporarily occupied territory of Ukraine, as well

as mechanisms for restoring the rights and freedoms of persons in the temporarily occupied

areas. It also includes a commitment to document human rights violations in the temporarily

occupied territory of Ukraine for the purposes of international justice, accountability and the

protection of victims’ rights.

The Strategy recognises the need for legal protection for persons who have suffered from

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gender-based violence. It includes the objective of aligning of Ukrainian legislation with

international obligations and EU legal acts in the field of the prevention of violence against

women and domestic violence. It also commits to ensuring the accessibility of assistance to

persons who have suffered from domestic violence and/or gender-based violence or sexual

violence related to the armed aggression of the Russian Federation against Ukraine, in

particular through the development and monitoring of the functioning of the national support

system for survivors in accordance with European standards.

A particular focus is placed on the rights of children in armed conflicts, including ensuring

legal protection regarding the return to Ukraine of children who were temporarily displaced

(evacuated) outside Ukraine as a result of the armed aggression of the Russian Federation and

regarding their reintegration. It sets out an objective to ensure systematic documentation of

violations of children’s rights during their deportation and forced displacement, as well as

facts of deportation and forced displacement as a result of the armed aggression of the

Russian Federation against Ukraine.

The Strategy aims to improve access to services for vulnerable persons, such as children,

elderly persons and persons with disabilities. It sets out concrete objectives to improve the

access of these groups to medical services, housing, legal aid as well as educational and

cultural services.

Commission assessment: satisfactorily fulfilled

Step 4.3

Name of the step: Increased manpower for the High Anti-Corruption Court

Related reform/investment: Reform 1. Developing the institutional capacity of the anti-

corruption framework

Financed from: non-repayable support

Context

The requirement for Step 4.3 described in the CID Annex is:

‘The personnel number of High Anti-Corruption Court (HACC) judges is increased by 60 %,

and the HACC apparatus number is increased by 40 %.’

Step 4.3 is the third of the three steps under Reform 1 of Chapter 4 (fight against corruption

and money laundering). It was preceded by Step 4.2 on the appointment of a new head of the

National Agency on Corruption Prevention and Step 4.1 on increasing the manpower for the

Specialised Anti-Corruption Prosecutor’s Office.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of the Decision of the High Council of Judges No. 930/0/15-23 of 26 September

2023 ‘on determining the number of judges in the High Anti-Corruption Court;

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3) Copy of the list of judges appointed to the High Anti-Corruption Court;

4) Copy of the list of personnel selected for the High Anti-Corruption Court;

5) Copy of the Law of Ukraine ‘on the State Budget for 2025’ and its annexes;

6) Copy of the Law of Ukraine ‘on the State Budget for 2026’ and its annexes;

7) Copy of draft annexes of the Law of Ukraine ‘on the State Budget for 2027’.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover the

constitutive elements of Step 4.3.

The objective of Reform 1 of Chapter 4 (fight against corruption and money laundering) is to

increase the overall capacity of the anti-corruption infrastructure to fight corruption, including

at a high level, through active and efficient investigation. The step aims to help the

operationalisation of the High Anti-Corruption Court (HACC) by increasing the number of

judges by 60% and the number of staff by 40%. The baseline used to calculate the nominal

increase was 38 judges and 270 auxiliary personnel, resulting in an additional 22 judges and

108 auxiliary staff.

The High Council of Justice (HCJ) and the High Qualification Commission of Judges of

Ukraine (HQCJ) are the judicial self-governing bodies for the selection of judges, including

for the HACC. The HQCJ is supported by a temporary subsidiary body known as the Public

Council of International Experts (PCIE) consisting of international legal experts who assist

the HQCJ in assessing whether candidates meet integrity and competence requirements. The

HQCJ announces and organises competitions and determines, with the support of the PCIE,

the successful candidates from those competitions. The HCJ reviews the HQCJ’s

recommendations and submits the candidates to the President for appointment on the basis of

those recommendations. The President formally appoints the judges submitted by the HCJ. In

accordance with the constitution, HACC judges are appointed by the President upon

submission of the HCJ.

On 26 September 2023, the HCJ adopted Decision No 930/0/15-23, which sets out that the

HACC should be composed of 63 judges, 21 of whom are judges of the Appeals Chamber

(court of second instance). The increase in the number of judges was justified by the need to

handle the higher number and complexity of the criminal proceedings in the HACC.

To this end, on 23 November 2023, the HQCJ announced a competition for 25 vacancies for

judges of the HACC: 15 vacancies for the court of first instance and 10 vacancies for the court

of second instance. However, on 31 March 2025, the HQCJ announced that only two

candidates had successfully passed all stages of the competitive selection and recommended

their appointment. On 20 May 2025, the HCJ recommended those two judges to the President

for appointment. On 3 May 2025, the President officially appointed those two candidates as

judges of the HACC.

To address the remaining staffing needs, on 3 June 2025, the HQCJ announced a competition

for 13 vacancies for the court of first instance and 10 vacancies for the court of second

instance. At the same time, Ukraine took steps to further improve the judicial selection

framework (detailed below).

As a result of the fact that the selection procedure did not yield the required number of new

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judges, Step 4.3 was assessed negatively as part of the fourth payment request on 30 June

2025. On 2 July 2025, the Commission notified Ukraine of its decision, stating that Ukraine

had 12 months from the notification of the initial negative assessment to take the necessary

measures to ensure satisfactory fulfilment of the outstanding step. On 17 July 2026, following

the expiry of this 12-month period on 2 July 2026, the Commission invited Ukraine to submit

its observations within two months.

Following the competition, announced on 3 June 2025, on 22 June 2026, before the end of 12-

month period, the HQCJ recommended a total of 17 judges for appointment. Between 2 July

and 13 August 2026, the HCJ recommended those 17 judges to the President for appointment.

On 21 August 2026, the President appointed the 17 judges, including 12 candidates as judges

of the HACC and five candidates as judges of the appeal chamber of the HACC. In addition,

between 7 April 2025 and 1 July 2026, the HACC increased the number of administrative

staff by 56 posts before the end of 12-month period and by a further 56 posts between 7 July

2026 and 10 September 2026. This reflected the fact that the recruitment of administrative

staff depended on the appointment of the judges, as the former were intended to support the

latter.

Overall, the Ukrainian authorities increased the number of judges by 19 compared to the

target of 22 and the number of administrative staff by 112, of which 108 posts are required for

fulfilment of the step. This corresponds to a total increase of 131 posts against a target of 130

posts. Furthermore, the shortfall in judicial appointments compared to the target is explained

by the limited number of candidates meeting the required standards, including general legal

competence, anti-corruption specialisation and cognitive abilities.

The Law of Ukraine on the State Budget for 2025 and the Law of Ukraine on the State Budget

for 2026 have allocated funding to support an increase in the number of judges and personnel

of the HACC. This budgetary support reflects the authorities’ recognition of the need to

strengthen the institutional and operational capacity of the HACC. In the same vein, the draft

annexes to the Law of Ukraine on the State Budget for 2027 are expected to confirm the

allocation of additional funding for the increase in the number of judges and staff of the

HACC.

The responsible Ukrainian authorities, including the HQCJ, the HCJ, the President of Ukraine

and the HACC, took the measures needed to ensure the fulfilment of this step in spite of

objective circumstances that caused delays. These efforts can be taken into account in the

assessment of this step and in particular to justify the discrepancy between the number of

judges appointed and the baseline target. In particular, following the high failure rate observed

in the 2023 competition, the HQCJ shortly thereafter launched a new competition to address

the remaining staffing needs. In addition, on 14 May 2025, the Verkhovna Rada adopted Law

of Ukraine “On amendments to the Law of Ukraine ‘on the judiciary and the status of judges’

to clarify the procedures for competition for the post of a judge and secondment of a judge”

with a view to improve certain procedures governing the competitive selection of judges. The

changes made by these amendments directly addressed some of the shortcomings of the

previous competition and will improve future competitions beyond the requirements of this

step. The changes include in particular addressing overly rigid thresholds for some of the

early tests in the procedure, a unified application track for both the first-instance court and the

Appeals Chamber to reduce duplication and a streamlining of the process to reduce the time

required to complete the competition. At the same time, high professional and ethical

standards have been maintained. Comparable efforts were also made by the HACC itself,

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which selected a number of administrative staff exceeding the target established under this

step.

Ukrainian authorities also took the necessary measures within the 12-month period ending on

2 July 2026 to ensure the fulfilment of the step. In particular, before the expiry of that period,

the HQCJ had completed the competition and, on 22 June 2026, recommended 17 judges for

appointment, including the assessment of whether candidates met integrity and competence

requirements. The HACC had also increased the number of administrative staff by 56 posts by

1 July 2026. These measures constituted the essential actions required from the Ukrainian

authorities to advance the increase in the number of judges and staff of the HACC. The

subsequent decisions of the HCJ, the presidential appointments and the further increase in

administrative staff after 2 July 2026 followed directly from the measures taken within the

relevant period and confirmed their concrete results.

Finally, in line with recitals 10 and 13 of Council Implementing Decision (EU) 2024/1447 of

14 May 2024 on the approval of the assessment of the Ukraine Plan and recital 35 of

Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February

2024 establishing the Ukraine Facility, the positive outcomes of the implementation of this

step go beyond the selection of judges and administrative staff of the HACC. Indeed, the

implementation of this step significantly contributes to strengthening the rule of law in

Ukraine and, more specifically, to improving the institutional capacity and legal framework

for the fight against corruption by ensuring that one of its key institutions, the High Anti-

Corruption Court, is able to function with an appropriate level of staff and that future

recruitment competitions are streamlined.

Based on the evidence provided by Ukraine during the observation period, as well as the

considerations set out above regarding the measures taken by the Ukrainian authorities, the

objective circumstances that led to the delayed fulfilment of this step and the discrepancy

between the number of judges appointed and the baseline target, and the objectives of the

Ukraine Facility with regard to the rule of law, the Commission therefore concludes that the

measures taken by the Ukrainian authorities ensured the satisfactory fulfilment of the step.

Commission assessment: satisfactorily fulfilled

Step 4.8

Name of the step: Conduct of the next National Risk Assessment

Related reform/investment: Reform 3. Anti-money laundering measures

Financed from: loan

Context

The requirement for Step 4.8 described in the CID Annex is:

‘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’

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Step 4.8 is the first of the seven steps in the implementation of Reform 3 of Chapter 4 (fight

against corruption and money laundering). It is followed by Step 4.9 on the 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 the Single European Payment Area scheme, Step 4.16 on the entry into

force of the legislative amendments on information accompanying transfers of funds and

certain crypto-assets; and Step 4.18 on the 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 (all steps due by Q3 2026).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of the Minutes of the Council on Prevention and Counteraction to Legalisation

(Laundering) of Proceeds of Crime, Terrorist Financing and Financing of the

Proliferation of Weapons of Mass Destruction No 2 of 31 August 2026 on the ‘2025

National Risk Assessment Report on Money Laundering, Terrorist Financing and

Financing of the Proliferation of Weapons of Mass Destruction in Ukraine’;

3) Copy of the ‘2025 National Risk Assessment Report on Money Laundering, Terrorist

Financing and Financing of the Proliferation of Weapons of Mass Destruction in

Ukraine’ dated 31 August 2026;

4) Copy of the ‘Methodology for conducting a National Risk Assessment Report on

Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons

of Mass Destruction in Ukraine’ dated 26 December 2024.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover the

constitutive elements of Step 4.8.

The objective of Reform 3 of Chapter 4 (fight against corruption and money laundering) is to

further align Ukraine’s legal framework with the EU 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. To this end, the Council on Prevention and

Counteraction to Legalisation (Laundering) of Proceeds of Crime, Terrorist Financing and

Financing of the Proliferation of Weapons of Mass Destruction approved the 2025 National

Risk Assessment Report on Money Laundering, Terrorist Financing and Financing of the

Proliferation of Weapons of Mass Destruction in Ukraine (hereinafter ‘the 2025 NRA

Report’) on 31 August 2026.

The 2025 NRA Report was compiled on the basis of the Methodology for conducting a

National Risk Assessment of money laundering, terrorist financing and financing of the

proliferation of weapons of mass destruction in Ukraine (updated in 2024).

The document sets out a comprehensive and structured identification of risks across the

relevant sectors and threat areas, with 30 risks identified in total. The distribution of these

risks by level 7 high, 21 medium and 2 low indicates that the exercise was conducted on the

basis of a differentiated, risk-based methodology. This breakdown suggests a sufficient degree

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of granularity to distinguish the most significant threats from those that, while still relevant,

appear comparatively more manageable, thereby providing a credible basis for prioritisation

and for the design of targeted mitigation measures.

Despite some methodological shortcomings in terms of data collection and interpretation, as

well as the heterogeneous level of analytical depth across the risk factors, the 2025 NRA

Report suggests that the assessment constitutes a methodologically robust exercise capable of

supporting effective policy and supervisory and operational follow-up. The identification and

grading of risks provide a basis for setting priorities, allocating resources and strengthening

preventive measures in the areas of greatest concern, while ensuring continued attention to

medium- and lower-level risks. Taken together, the assessment reflects a well-developed

understanding of the risk environment and provides a solid foundation for proportionate,

targeted and evidence-based action.

Commission assessment: satisfactorily fulfilled

Step 4.20

Name of the step: Adoption of the state programme to combat human trafficking until 2030

Related reform/investment: Reform 4. Combating Human Trafficking

Financed from: loan

Context

The requirement for Step 4.20 described in the CID Annex is:

‘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).’

Step 4.20 is the only step in the implementation of Reform 4 of Chapter 4 (fight against

corruption and money laundering).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of the publication of the programme in Official Gazette No. 199 of 23

September 2026;

3) Copy of Order No. 875-r of the Cabinet of Ministers of 3 September 2026 ‘on

Approval of the State Target Social Programme for Combating Trafficking in Human

Beings for the period up to 2030’;

4) Copy of the ‘State Target Social Programme for Combating Trafficking in Human

Beings for the period up to 2030’ as an attachment to Order 875-r of 3 September

2026.

Analysis

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The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 4.20.

The objective of Reform 4 of Chapter 4 (fight against corruption and money laundering) is to

ensure the strategic approach to combating trafficking in human beings, improve

organisational settings and strengthen Ukraine’s capacity in this area in line with the EU

principles. To this end, the Cabinet of Ministers adopted Order No. 875-r of 3 September

2026 ‘on Approval of the State Target Social Programme for Combating Trafficking in

Human Beings for the period up to 2030’ (hereinafter ‘the programme’). The programme is

attached to the approved Order No. 875-r.

The programme establishes a comprehensive policy framework for addressing trafficking in

human beings in Ukraine for the period up to 2030. It covers the main areas of action,

including prevention, protection and assistance for victims, investigation and prosecution of

perpetrators and interinstitutional coordination, within a single and coherent strategic

framework. The approach is broadly aligned with the relevant international standards and with

the EU acquis, as required by the step description.

The programme pays particular attention to persons in situations of vulnerability, including

children, internally displaced persons, refugees, persons with disabilities and persons affected

by the consequences of the Russian Federation’s armed aggression against Ukraine. It refers

to trauma-informed support, non-discrimination, access to assistance and the prevention of

secondary victimisation, thereby reflecting a rights-based and victim-centred approach.

The programme also includes a number of operational components. It sets out tasks,

indicators, implementation timelines for the 2026–2030 period, responsible authorities and

expected results, including measures related to public awareness raising, victim identification

and assistance, investigations and institutional capacity building. It further refers to the use of

digital tools, professional training, cross-border cooperation and legislative approximation.

Overall, the programme provides a structured basis for policy action in the area of trafficking

in human beings and indicates the authorities’ intention to address the issue through a

coordinated and comprehensive approach over the period covered.

Commission assessment: satisfactorily fulfilled

Step 5.3

Name of the step: Adoption of the strategy for gradual reduction of state ownership in the

banking sector

Related reform/investment: Reform 2. Adoption of the strategy for gradual reduction of

state ownership in the banking sector

Financed from: loan

Context

The requirement for Step 5.3 described in the CID Annex is:

‘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;

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- mitigation of fiscal risks;

- enhancement of bank governance and operational efficiency;

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

relevant).’

Step 5.3 is one of the two steps of Reform 2 in Chapter 5 (financial markets). It was preceded

by Step 5.2 on the entry into force of the updated legislation on the sale of state-owned banks.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of the main (strategic) areas of activities of public-sector banks;

3) Copy of Order of the Cabinet of Ministers of Ukraine of 30 June, 2026, ‘on the

approval of the main (strategic) activities of public-sector banks’;

4) Copy of the publication of the strategy in Official Gazette No 147 of 15 July 2026.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 5.3.

The objective of Reform 2 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 strategy focuses on increasing banks’ profitability, managing non-performing assets,

minimising fiscal risks, improving corporate governance and gradually reducing the state’s

share in the banking sector. The strategic objectives include ensuring state-owned banks’

support for priority sectors of the economy such as critical infrastructure, the defence

industry, energy resilience and the development of frontline regions, as well as participation

in state programmes as part of banks’ business models. It is envisaged that state-owned banks

should develop or update their own strategies by the end of 2026, as well as ensure the proper

functioning of supervisory boards and conduct annual assessments of their activities.

Particular attention is paid to reducing the level of non-performing assets to not more than

15%, including through the sale of non-core assets and work with the largest non-performing

loans. The strategy also provides for a gradual reduction in the state’s share through the sale

of shareholdings in certain banks to strategic investors, taking into account martial law and

market conditions.

Commission assessment: satisfactorily fulfilled

Step 5.5

Name of the step: Entry into force of legal acts to improve resolution of non-performing

loans

Related reform/investment: Reform 3. Improved resolution of non-performing loans

Financed from: non-repayable support

Context

The requirement for Step 5.5 described in the CID Annex is:

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‘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.’

Step 5.5 is one of the two steps of Reform 3 in Chapter 5 (financial markets).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of Law of Ukraine No. 4833 - IX of 7 April 2026 on Amendments to Certain

Legislative Acts of Ukraine on Improving the Procedure for Enforcement of Court

Decisions, Decisions of Other Bodies and Digitalization of Certain Stages of

Enforcement Proceedings;

3) Copy of Law of Ukraine No. 3985 – IX of 19 September 2024 on Amendments to the

Code of Ukraine on Bankruptcy Procedures and Certain Other Legislative Acts of

Ukraine on the Implementation of Directive (EU) 2019/1023 of the European

Parliament and of the Council and the Introduction of Preventive Restructuring

Procedures;

4) Copy of the Resolution No 1566 of the Cabinet of Ministers of Ukraine of 3 December

2025 on Amendments to the Procedure for Organising and Conducting Auctions for

the Sale of Debtors’ Property in Bankruptcy Cases (Insolvency);

5) Copy of Law of Ukraine No. 4863-IX of 29 April 2026 on Amendments to the Civil

Code of Ukraine regarding Regulation of Relations in the Sphere of Factoring;

6) Copy of Resolution of the Board of the National Bank of Ukraine No 12 of 7 February

2025 on Approval of Amendments to the Regulations on the Organisation of the

Process of Management of Problem Assets in Banks of Ukraine;

7) Copy of Resolution of the Board of the National Bank of Ukraine No 351 of 30 June

2016 on Approval of the Regulations on Determination by Banks of Ukraine of the

Size of Credit Risk for Active Banking Transactions;

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8) Copy of Law of Ukraine No. 4466 - IX of 3 June 2025 on Factoring;

9) Copy of Law of Ukraine No. 2923 - IX of 23 February 2023on Compensation for

Damage to and Destruction of Certain Categories of Real Estate as a Result of

Hostilities;

10) Copy of Law of Ukraine No. 4340-IX of 27 March 2025 on Amendments to the Final

and Transitional Provisions of the Civil Code of Ukraine Regarding the Specifics of

Lending and Financial Leasing During the Period of Martial Law.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all the

constitutive elements of Step 5.5.

The objective of Reform 3 is to improve the resolution of non-performing loans. Ukrainian

authorities have brought into force the legal acts implementing the recommendations of the

strategy for resolution of non-performing loans improving the system of NPL resolution, as

described below.

The improvement of the definition of NPLs in line with the principles of the EU acquis was

implemented through amendments to the NBU regulatory framework. In particular, NBU

Resolution No. 12 of 7 February 2025 amended the ‘Regulation on the Organisation of the

Process of Management of Problem Assets in Banks of Ukraine’, while the applicable credit-

risk framework builds on the requirements established under NBU Resolution No. 351 of 30

June 2016. The category of non-performing assets has been expanded to include assets that

are not in default but are impaired in accordance with International Financial Reporting

Standards (IFRS), including assets that were impaired at initial recognition (Purchased or

Originated Credit-Impaired - POCI). The requirements for ceasing to classify assets as non-

performing have been clarified. Specifically, the period for monitoring non-performing assets

prior to a change in status has been extended and the requirements for asset quality control

have been tightened. The introduction of this provision strengthens the framework for

monitoring and resolving non-performing assets.

The reinstatement of the requirement for banks to update and submit plans and strategies for

dealing with NPLs and providing recommendations based on the results of their analysis was

implemented through amendments to the NBU Regulation ‘on the Organisation of the

Process of Management of Problem Assets in Banks of Ukraine’, approved by NBU

Resolution No 97 of 18 July 2019. The relevant amendments were adopted byNBU

Resolution No 12 of 7 February 2025 and entered into force on 1 January 2026. Under the

amended Regulation, banks must update their strategies for non-performing loans and their

sale plans and then update them annually.

Law No 3985-IX introduced the relevant amendments to the Code of Ukraine on Bankruptcy

Procedures, including the framework for preventive restructuring and related bankruptcy-

procedure reforms. The changes are reflected in articles covering the requirements for the

arbitration manager, the rights and liabilities of the arbitration manager, the control over the

activities of arbitration managers, the disciplinary penalties, the appointment and removal of

the arbitration manager and the temporary suspension of the right to carry out the activities of

the arbitration manager. These changes strengthen the responsibility of the arbitration

manager for the performance of their duties, impose additional requirements on arbitration

managers and regulate their rights and enforcement measures in the event of violations. The

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detailed electronic auction procedures were subsequently aligned with the amended Code

through CMU Resolution No 1566 of 3 December 2025, which entered into force on 10

December 2025.

The measures identified in the NPL Strategy concerning the improvement of the procedure for

and access to bankruptcy and restructuring procedures for individuals, micro and small

enterprises were implemented through Law No. 3985-IX of 19 September 2024 and the

subsequent implementing amendments to the electronic auction framework introduced by

CMU Resolution No. 1566 of 3 December 2025. These changes introduce more flexible and

predictable rules for the sale of assets in bankruptcy proceedings. They clarify the conduct

and outcome of auctions, including the treatment of guarantee fees, the obligations of the

winning bidder, and the procedure to be followed where the winner refuses to complete the

purchase. In such cases, the electronic trading system automatically identifies the bidder

offering the next-highest price, while failed auctions are subject to a defined procedure for

determining their outcome. The amendments also provide that seizures or other restrictions on

bankrupt property, where properly disclosed in the auction announcement, do not prevent the

auction or the completion of the sale.

In addition, CMU Resolution No 865 of 2 October 2019, ‘Issues of the Functioning of the

Electronic Trading System for the Sale of Debtors’ Property in Bankruptcy Proceedings’, has

been brought into compliance with the updated Code of Ukraine on Bankruptcy Procedures.

The respective amendments were introduced by CMU Resolution No. 1566 of 3 December

2025. More specifically, they brought the electronic auction procedure under CMU

Resolution No. 865 into line with the updated Code of Ukraine on Bankruptcy Procedures by

extending its application to preventive restructuring proceedings and introducing the

corresponding role of the preventive restructuring administrator. The rules governing

guarantee fees, the consequences of a winner’s refusal to purchase and the transfer of winning

status to the participant offering the next-highest price were aligned with the revised

provisions of the Code, including the automatic generation of a new auction-results protocol.

The amendments also updated procedural requirements for auction announcements,

participation applications, signing and publication of auction-results protocols and the sale of

seized or encumbered property.

Additionally, safeguards have been introduced 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. This was done by amending Articles 45 and

47 of the Code of Ukraine on Bankruptcy Procedures introduced by Law No. 3985-IX of 19

September 2024. These amendments strengthen safeguards against conflicts of interest in

bankruptcy proceedings by requiring creditors to disclose any interest in or relationship with

the debtor when submitting claims against the debtor. It also provides that creditors with an

interest in the debtor’s property do not have a deciding vote at meetings of creditors or the

creditors’ committee, thereby limiting their influence over decisions in the proceedings.

The legislation on debt collection and debt treatment was also improved. Namely, Law of

Ukraine No 2923-IX ‘on Compensation for Damage to and Destruction of Certain Categories

of Real Estate as a Result of Hostilities’ of 23 February 2023, which entered into force on 22

May 2023, provides a framework for compensation in respect of certain damaged or

destroyed real estate and thereby supports the treatment of war-affected collateral and related

debt exposures. Law of Ukraine No 4340-IX ‘on Amendments to the Final and Transitional

Provisions of the Civil Code of Ukraine Regarding the Specifics of Lending and Financial

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Leasing During the Period of Martial Law’ of 27 March 2025, which entered into force on 10

August 2025, establishes a temporary moratorium mechanism for qualifying borrowers

affected by Russia's war of aggression against Ukraine, including certain businesses whose

assets and activity are affected. Law of Ukraine No. 4833 - IX ‘on Amendments to Certain

Legislative Acts of Ukraine on Improving the Procedure for Enforcement of Court Decisions,

Decisions of Other Bodies and Digitalisation of Certain Stages of Enforcement Proceedings’

was adopted in the Verkhovna Rada on 7 April 2026 with certain provisions entering into

force earlier, on 24 April 2026 and 23 May 2026. It will be fully in force from 23 October

2026. Together, these measures strengthen the framework for debt treatment and recovery by

addressing the consequences of war-related destruction and loss of productive assets, while

providing clearer rules for borrowers and creditors affected by such circumstances. Taken

together, the measures address the debt collection and treatment elements identified in the

NPL strategy.

Lastly, regulatory conditions favouring the NPL market’s development and operation were

introduced. This was implemented through Law of Ukraine No 4466 - IX of 3 June 2025 ‘on

Factoring’, which entered into force on 30 July 2025 and was put into effect from 30 July

2026, following the entry into force of Law of Ukraine No 4863 of 29 April 2026 ‘on

Amending the Civil Code of Ukraine’s Provisions on Relations in the Factoring Business’.

The first law establishes a new legal framework for factoring and clarifies the legal

framework for the assignment and enforcement of monetary claims, while its amendments to

banking and consumer credit legislation establish rules governing the transfer of certain credit

claims to eligible new creditors. The second law aligns the relevant Civil Code provisions

with this new framework, creating greater legal clarity and predictability for market

participants. These measures are intended to facilitate the development and operation of the

factoring market and create a clearer legal framework for market participants.

As part of Council Implementing Decision (EU) 2026/2230 of 24 September 2026

establishing the satisfactory fulfilment of the conditions for the partial payment of the eighth

instalment under the Ukraine Plan of the Ukraine Facility, this step was taken into account as

a mitigating factor, in accordance with the methodology for assessing the partial fulfilment of

steps under the Ukraine Plan, solely for the purposes of the application of that Decision. The

assessment of this step has not changed since the adoption of that Decision.

Commission assessment: satisfactorily fulfilled

Step 6.7

Name of the step: Entry into force on legislation on the separation of public service

obligations (PSO) and non-PSO activities

Related reform/investment: Reform 3. Separation of accounts between public service

obligations (PSO) and non-PSO activities in public service obligations

Financed from: loan

Context

The requirement for Step 6.7 described in the CID Annex is:

‘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

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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.’

Step 6.7 is the second of the three steps in the implementation of Reform 3 of Chapter 6

(management of public assets). It was preceded by Step 6.6 on the adoption of a roadmap

on the separation of public service obligations (PSO) and non-PSO activities. It is followed

by Step 6.8 (due by Q3 2027), which entails the submission of an audit report confirming

the separation of public service obligations (PSO) and non-PSO activities.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Law of Ukraine No 4961-IX of 2 September 2026 on Amendments to

Certain Legislative Acts of Ukraine on Improving the Functioning of Industrial

Parks.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 6.7.

The objective of Reform 3 of Chapter 6 (management of public assets) is to strengthen the

level playing field with the private sector, as well as further convergence with the EU

acquis by a separating account between activities connected to Public Service Obligations

(PSOs) and non-PSO activities.

Step 6.7 is the second element of Reform 3 and builds on Step 6.6 by implementing

legislation identified in the roadmap defining the steps for mandatory structural separation

of PSO and non-PSO activities for all SOEs engaged in PSOs, which was adopted and

published under Step 6.6.

The adopted legislation has entered into force and provides the legal basis for the

implementation of accounts separation in all SOEs engaged in PSOs but pays particular

attention to those outlined in the Cabinet of Ministers’ protocol decision as top key SOEs. It

thus allows strategic SOEs – in sectors such as, but not limited to, energy and transport – to

continue honouring commitments to public service provision, while also engaging in

commercial activities transparently and on a level playing field with other market

participants.

The law defines, among other things, PSOs, special rights and exclusive rights, and

establishes mandatory separate accounting for relevant financial and economic transactions.

It also requires the disclosure of financial relations with public authorities, reporting on the

provision and actual use of public funds and the retention of supporting documentation,

thereby strengthening financial transparency and helping prevent cross-subsidisation

between public service and commercial activities.

That Law, in particular, contains provisions that:

- define the terms ‘special obligation’, ‘exclusive rights’ and ‘special rights’ with

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respect to business entities;

- introduce a requirement for separate accounting for business entities assigned

special obligations or performing other specific duties based on exclusive or special

rights;

- establish requirements for the disclosure of financial information, particularly

regarding the sources of funding for special obligations.

These provisions establish the legal basis for the mandatory structural separation of

accounts between PSO and non-PSO activities, in line with the requirements of

Commission Directive 2006/111/EC.

Commission assessment: satisfactorily fulfilled

Step 7.7

Name of the step: Adoption of the Population Employment Strategy

Related reform/investment: Reform 6. Improved functioning of the labour market

Financed from: loan

Context

The requirement for Step 7.7 described in the CID Annex is:

‘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.’

Step 7.7 is the second step in the implementation of Reform 6 of Chapter 7 (human capital).

Step 7.6 on the adoption of the Demographic Development Strategy for the period up to 2040

was positively assessed as part of the second instalment (Q3 2024). It will be followed by

Step 7.20 on the 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 (due by Q2 2026) and Step 7.21 on entry into force of the legislation on occupational

health and safety (due by Q4 2026).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

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with the requirements set out in the CID Annex;

2) Copy of the publication of the strategy in Official Gazette No 40 of 18 February 2026;

3) Copy of Order No. 92-r of the Cabinet of Ministers of 7 January 2026 ‘on the approval

of the Population Employment Strategy of Ukraine for the period up to 2030 and the

approval of the operational action plan for its implementation in 2026-2028'6;

4) Copy of the ‘Population Employment Strategy of Ukraine for the period up to

2030’ as an attachment to the Order 92-r of 7 January 2026.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 7.7.

The objective of Reform 6 of Chapter 7 (human capital) is to contribute to the functioning of

the labour market. To this end, the Cabinet of Ministers of Ukraine adopted Order No 92-r of

7 January 2026 ‘oOn the approval of the Population Employment Strategy of Ukraine for the

period up to 2030 and the approval of the operational action plan for its implementation in

2026-2028' (hereinafter the ‘the strategy’). The strategy is attached to the approved Order No

92-r and is accompanied by the operational plan for 2026-2028.

The strategy aims to simplify access to the labour market while reskilling and upskilling key

segments of the population. To achieve this, it introduces an integrated reform package

designed to: minimise information gaps between jobseekers and employers; expedite job

matching; and make employment pathways clearer, faster and more inclusive. A central

component of this approach is the rollout of Obrii, a Unified Information and Analytical

System serving as a single digital gateway for citizens and businesses. This platform will

consolidate job vacancies and CVs, enable competency-based matching and provide e-

recruitment services.

Additionally, the strategy seeks to promote entrepreneurship as a key route to employment,

with a particular focus on supporting women in business. Both the overarching strategy and

its operational plan aim to bolster women’s entrepreneurship through measures such as:

reducing administrative and regulatory hurdles to starting and running a business, particularly

for women-led enterprises; expanding financial support and access to capital to foster the

growth of small and medium-sized enterprises (SMEs); evaluating the impact of government

policies on women’s entrepreneurship and providing recommendations to enhance targeted

support and dismantle systemic barriers.

The strategy also includes the development of a dedicated Roadmap for the State Employment

Service (2026–2030), outlining a phased approach to institutional reforms and service

modernisation. Key initiatives include: adopting a competency-based framework for human

resource management across employment agencies to enhance performance tracking and

ensure that teams meet service effectiveness targets; updating training programmes to

systematically upskill managers and staff in line with evolving labour market needs;

strengthening cross-agency cooperation, led by the State Employment Centre, to improve

coordination with other government bodies and frontline professionals.

To future-proof the labour market, the strategy proposes reforms in labour demand forecasting

and attracting international talent, including foreign entrepreneurs, skilled workers and

students. This involves: establishing a robust system for analysing and forecasting labour

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demand, using standardised data collection, analytics and indicators – broken down by age,

gender and locality; introducing an economic forecasting model with a 5-10 year outlook,

accounting for macroeconomic trends, demographic shifts and sectoral changes.

Finally, the strategy will deploy a mix of promotional, regulatory and digital

tools, including: targeted awareness campaigns; international promotion of Ukrainian

education and research to attract foreign students and academics; analytical studies and a

roadmap on managed labour migration, alongside regular reviews of the list of professions

and qualifications eligible for immigration – including pathways to permanent residency.

As part of Council Implementing Decision (EU) 2026/1204 of 28 May 2026 establishing the

satisfactory fulfilment of the conditions for the partial payment of the seventh instalment

under the Ukraine Plan of the Ukraine Facility and amending Implementing Decision (EU)

2024/1447, this step was taken into account as a mitigating factor, in accordance with the

methodology for assessing the partial fulfilment of steps under the Ukraine Plan, solely for the

purposes of the application of that Decision. The assessment of this step has not changed

since the adoption of that Decision.

Commission assessment: satisfactorily fulfilled

Step 7.12

Name of the step: Investments of at least EUR 300 million in education

Related reform/investment: Investment 1. Investments in education

Financed from: loan

Context

The requirement for Step 7.12 described in the CID Annex is:

‘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.’

Step 7.12 is the first of two steps in the implementation of Investment 1 of Chapter 7 (human

capital). It is followed by Step 7.13 (due on Q3 2027) on investments of at least EUR 650

million in education.

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Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Law of Ukraine No 3460-IX of 9 November 2023 ‘on the State Budget of

Ukraine for 2024’ and its annexes;

3) Copy of Law of Ukraine No 4059-IX of 19 November 2024‘on the State Budget of

Ukraine for 2025’ and its annexes;

4) Copy of Resolution No 925 of the Cabinet of Ministers of Ukraine of 30 November

2016 for BP 2211210 VEC in 2024 and BP 2211800 VEC in 2025;

5) Copy of Resolution No 419 of the Cabinet of Ministers of Ukraine of 28 April 2023

for BP 2211310 Shelters in 2024 and BP 2211810 Shelters in 2025;

6) Copy of Resolution No 418 of the Cabinet of Ministers of Ukraine of 28 April 2023

for BP 2211320 Buses in 2024 and BP 2211830 Buses in 2025;

7) Copy of Resolution No 120 of the Cabinet of Ministers of Ukraine of 16 February

2022 for BP 2211330 Canteens in 2025;

8) Copy of Resolution No 237 of the Cabinet of Ministers of Ukraine of 4 April 2018 for

BP 2211230 NUS;

9) Copy of Resolution No 1554 of the Cabinet of Ministers of Ukraine of 31 December

2024 for BP 2211850 NUS in 2025;

10) Copy of Resolution No 1530 of the Cabinet of Ministers of Ukraine of 30 December

2024 for BP 2211840 Fire protection;

11) Copy of Resolution No 1477 of the Cabinet of Ministers of Ukraine of 30 December

2022 for BP 3511280 Shelters and Buses and Resolution No 1392 of the Cabinet of

Ministers of Ukraine of 29 October 2025, which entered into force with Order No

1308 of the Ministry of Education and Science of Ukraine of 11 September 2024 and

Order No 1310 of the Ministry of Education and Science of Ukraine of 11 September

2024;

12) Copy of the Reporting form on Subsection II.1 ‘Expenditure by the Programme

Classification of State Budget Expenditure and Lending’ of Section II ‘Expenditure’ of

the Report on the Execution of the State Budget of Ukraine’, for 2024 and 2025 of the

Report on the Execution of the State Budget of Ukraine, approved by Order No 41 of

the Ministry of Finance of Ukraine of 30 January 2018;

13) Copy of the Reporting form on ‘Information on the Implementation of

Intergovernmental Transfer Indicators (Other Grants and Subventions) from the State

Budget of Ukraine to Local Budgets’ for 2024 and 2025 of the Report on the

Execution of the State Budget of Ukraine, approved by Order of the Ministry of

Finance of Ukraine No 41 of 30 January 2018;

14) Copy of the technical simplified calculations;

15) Copy of the list of Orders of the Ministry of Education and Science of Ukraine or

other decisions defining the list of projects to be financed under the respective budget

programme;

16) Copy of the list of all projects implemented under the respective budget programme.

17) Copy of the list of projects implemented under the respective budget programme and

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the related procurements.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all the

constitutive elements of Step 7.12.

The objective of Investment 1 of Chapter 7 (human capital) is to improve access to safe and

quality public education.

To this end, the State Budgets of Ukraine for 2024 and 2025 earmarked and implemented a

set of dedicated budget programmes specifically targeting investments in safe, accessible and

quality education at regional and local level. These programmes covered, inter alia, the

development of shelters and fire protection measures in educational institutions, the purchase

of school buses, the modernisation of canteens, the provision of teaching and learning

materials and equipment under the ‘New Ukrainian School’ reform and the upgrading of

workshops and laboratories in vocational education institutions, including measures related to

energy efficiency, safety and inclusiveness.

Overall, the total volume of expenditure reported under these dedicated budget programmes

amounted to UAH 4.64 billion (EUR 107 million) in 2024 and UAH 11.42 billion (EUR 244

million) in 2025, corresponding to a combined investment of approximately UAH 16.06

billion (EUR 351 million) over the two years exceeding the minimum target of EUR 300

million set out under Step 7.12. It should be noted, that as Ukraine reported only verified

expenditure and the verification is still ongoing, this amount may increase to approximately

UAH 17.38 billion (EUR 380 million).

Commission assessment: satisfactorily fulfilled

Step 7.14

Name of the step: Investments of at least EUR 200 million in healthcare

Related reform/investment: Investment 2. Investments in healthcare

Financed from: loan

Context

The requirement for Step 7.14 described in the CID Annex is:

‘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.’

Step 7.14 is the first step in the implementation of Investment 2 under Chapter 7 (human

capital). It will be followed by Step 7.15 (due on Q3 2027) on investments of at least EUR

EN 26 EN

400 million in healthcare.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Law of Ukraine No 3460-IX of 9 November 2023 ‘on the State Budget of

Ukraine for 2024 and its annexes;

3) Copy of Law of Ukraine No 4059-IX of 19 November 2024‘on the State Budget of

Ukraine for 2025 and its annexes;

4) Copy of Law of Ukraine No 4695-IX of 3 December 2025 ‘on the State Budget of

Ukraine for 2026’and its annex;

5) Copy of Resolution No 1886 of the Cabinet of Ministers of Ukraine of 24 December

2019 for BP 2308060;

6) Copy of Resolution No 298 of the Cabinet of Ministers of Ukraine of 17 March

2011 for BP 2301400;

7) Copy of Resolution No 374 of the Cabinet of Ministers of Ukraine of 2 April 2024

for BP 2311590;

8) Copy of Resolution No 73 of the Cabinet of Ministers of Ukraine of 23 January

2024 for BP 2311500;

9) Copy of Resolution No 289 of the Cabinet of Ministers of Ukraine of 15 March

2024 for BP 2301060;

10) Copy of Resolution No 1121 of the Cabinet of Ministers of Ukraine of 27 November

2019 for BP 2301040;

11) Copy of Resolution No 271 of the Cabinet of Ministers of Ukraine of 7 March 2025

for BP 2301800;

12) Copy of Resolution No 312 of the Cabinet of Ministers of Ukraine of 18 March

2025 for BP 2311800;

13) Copy of Resolution No 312 of the Cabinet of Ministers of Ukraine of 18 March

2025 (as amended);

14) Copy of Order No 2195 of the Ministry of Health of Ukraine of 30 December 2024

for BP 2301170 and its annex;

15) Copy of Order No 2192 of the Ministry of Health of Ukraine of 30 December 2024

for BP 230110 and its annex;

16) Copy of Passport No 39 of the National Academy of Science of Ukraine of 22 May

2024 for BP 6561190 and its annex;

17) Copy of Order No 464 of the Ministry of Health of 6 April 2026 for BP 2301800;

18) Copy of the Reporting form on Subsection II.1 ‘Expenditure by the Programme

Classification of State Budget Expenditure and Lending’ of Section II ‘Expenditure’

of the Report on the Execution of the State Budget of Ukraine’ for 2024 and 2025 of

the Report on the Execution of the State Budget of Ukraine, approved by Order No

41 of the Ministry of Finance of Ukraine of 30 January 2018;

19) Copy of the Reporting form on ‘Information on the Implementation of

Intergovernmental Transfer Indicators (Other Grants and Subventions) from the

EN 27 EN

State Budget of Ukraine to Local Budgets’ for 2024 and 2025 of the Report on the

Execution of the State Budget of Ukraine, approved by Order No 41 of the Ministry

of Finance of Ukraine of 30 January 2018;

20) Copy of the letter dated 15 July 2026 from the State Treasury Service of Ukraine

and its annex;

21) Copy of the letter dated 15 September 2026 from the State Treasury Service of

Ukraine and its annex;

22) Copy of the technical simplified calculations;

23) Copy of the list of Orders of the Ministry of Health of Ukraine or other decisions

defining the list of projects to be financed under the respective budget programme;

24) Copy of the list of all projects implemented under the respective budget programme.

25) Copy of the list of projects implemented under the respective budget programme

and the related procurements.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 7.14.

The objective of Investment 2 under Chapter 7 (human capital) is to improve Ukraine’s

public healthcare system.

To this end, the State Budgets of Ukraine for 2024 and 2025 earmarked and implemented a

set of dedicated budget programmes covering, among other areas, the safety of healthcare

facilities and the installation of protective structures; the restoration, reconstruction and

modernisation of medical infrastructure; the development of rehabilitation care and

specialised medical care, including paediatric care, cardiology, oncology, medical education

and science; support for healthcare facilities at regional and local level; the provision of

modern medical equipment; and the strengthening of healthcare system capacity and

continuity of care.

The Ukrainian authorities reported eligible expenditure under these budget programmes

amounting to UAH 4.33 billion (EUR 100 million) in 2024 and UAH 4.10 billion (EUR 87

million) in 2025, corresponding to a total of approximately UAH 8.43 billion (EUR 187

million) over the two-year period.

The implementation of the above-mentioned budget programmes continued in 2026 as

required by Step 7.15, which requires investment of at least EUR 400 million in healthcare.

In this respect, the State Budget of Ukraine for 2026 implemented dedicated budget

programmes on healthcare infrastructure and facilities for UAH 4.12 billion (approximately

EUR 81 million). Information on projects and related procurements is collected on a

quarterly basis, and the total reported expenditure for the first six months of 2026 for which

this information can be provided amounted to UAH 597 million (approximately EUR 12

million). Accordingly, for the purpose of the positive assessment, the Commission

considers as valid only the expenditure amounting to EUR 12 million, corresponding to a

total of approximately UAH 9 billion (EUR 199 million).While there is a minimal deviation

from the financial resources relevant to the implementation of Step 7.14, the evidence

submitted demonstrates continued implementation of the relevant healthcare investment

over the subsequent period and confirms the substantive achievement of the policy

objective pursued by the step. On that basis, Step 7.14 can be considered satisfactorily

fulfilled.

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Commission assessment: satisfactorily fulfilled

Step 7.18

Name of the step: 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

Related reform/investment: Investment 5. Investments in providing housing for vulnerable

groups of the population

Financed from: loan

Context

The requirement for Step 7.18 described in the CID Annex is:

‘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.’

Step 7.18 is the first of the two steps in the implementation of Investment 5 of Chapter 7

(human capital). It is followed by Step 7.16 (due on Q3 2027) on investments of at least EUR

350 million in social infrastructure.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Law of Ukraine No 3460-IX of 9 November 2023 ‘on the State Budget of

Ukraine for 2024’ and its annexes;

3) Copy of Law of Ukraine No 4059-IX of 19 November 2024 ‘on the State Budget of

Ukraine for 2025’ and its annexes;

4) Copy of Order No 1146-r of the Cabinet of Ministers of Ukraine of 19 November

2024 for BP 1511040 and BP 1511050;

5) Copy of Order No 1285-r of the Cabinet of Ministers of Ukraine of 20 December 2024

for BP 1511040 and BP 1511050;

6) Copy of Order No 1313-r of the Cabinet of Ministers of Ukraine 26 November

2025for BP 1511800;

7) Copy of Order No 1433-r of the Cabinet of Ministers of Ukraine of 17 December

2025for BP 1511800;

8) Copy of Order No 1473-r of the Cabinet of Ministers of Ukraine of 23 December

2025for BP 1511800;

9) Copy of Resolution No 719 of the Cabinet of Ministers of Ukraine of 19 October 2016

EN 29 EN

for BP 1511040 and BP 1511800;

10) Copy of Resolution No 280 of the Cabinet of Ministers of Ukraine of 18 April 2018for

BP 1511050;

11) Copy of the technical simplified calculations;

12) Copy of the reporting form on Subsection II.1 ‘Expenditure by the Programme

Classification of State Budget Expenditure and Lending’ of Section II ‘Expenditure’ of

the Report on the Execution of the State Budget of Ukraine"’, for 2024 and 2025 of

the Report on the Execution of the State Budget of Ukraine approved by Order No 41

of the Ministry of Finance of Ukraine of 30 January 2018.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all the

constitutive elements of Step 7.18.

The objective of Investment 5 of Chapter 7 (human capital) 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.

To this end, the State Budget of Ukraine for 2024 and 2025 earmarked and implemented a set

of dedicated budget programmes specifically targeting vulnerable groups, namely: persons

with group I or II disabilities who defended Ukraine; family members of fallen or deceased

defenders; and internally displaced veterans who defended Ukraine, subject to the relevant

legal eligibility and housing-registration requirements.

Overall, the total volume of expenditure amounted to UAH 9.82 billion (EUR 226 million) in

2024 and UAH 6.48 billion (EUR 138 million) in 2025, corresponding to a total of

approximately UAH 16.3 (EUR 364 million) over the two years, exceeding the minimum

target of EUR 200 million set out under Step 7.18.

As part of Council Implementing Decision (EU) 2026/2230 of 24 September 2026

establishing the satisfactory fulfilment of the conditions for the partial payment of the eighth

instalment under the Ukraine Plan of the Ukraine Facility, this step was taken into account as

a mitigating factor, in accordance with the methodology for assessing the partial fulfilment of

steps under the Ukraine Plan, solely for the purposes of the application of that Decision. The

assessment of this step has not changed since the adoption of that Decision.

Commission assessment: satisfactorily fulfilled

Step 7.20

Name of the step: 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

Related reform/investment: Reform 6. Improved functioning of the labour market

Financed from: loan

Context

The requirement for Step 7.20 described in the CID Annex is:

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‘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’.

Step 7.20 is the third step in the implementation of Reform 6 of Chapter 7 (human capital)

concerning the 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. It was preceded by Step 7.6 (adoption of the Demographic Development Strategy

for the period up to 2040) which was positively assessed in Q3 2024 and by Step 7.7

(adoption of the Population Employment Strategy) which was positively assessed in Q2

2026. It will be followed by Step 7.21 on the entry into force of the legislation on

occupational health and safety.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of the publication of the strategy in Official Gazette No 116 of 3 June 2026;

3) Copy of Order No 504-p of the Cabinet of Ministers of Ukraine of 27 May 2026

‘on the approval 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’;

4) Copy 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’ as an attachment to Order No 504-p of 27 May 2026.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 7.20.

The objective of Reform 6 of Chapter 7 (human capital) is to contribute to the functioning

of the labour market. To this end, the Cabinet of Ministers of Ukraine adopted Order No

504-p of 27 May 2026 ‘on the approval 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’ (hereinafter ‘the operational plan’). The operational plan is

attached to the approved Order No 504-p.

The operational plan for the period 2026–2028 sets out a structured and policy-relevant

framework aimed at advancing gender equality, with particular emphasis on equal pay,

labour market participation, educational inclusion and access to early childhood education

and care. The planned measures correspond to relevant international and European

commitments in the areas concerned.

Commission assessment: satisfactorily fulfilled

Step 8.12

Name of the step: Adoption of amendments to the resolution on the designation of the

single national metrology institute

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Related reform/investment: Reform 5. Harmonisation of legislation and standards with

the EU

Financed from: loan

Context

The requirement for Step 8.12 described in the CID Annex is:

‘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).’

Step 8.12 is the third and last step in the implementation of Reform 5 of Chapter 8

(business environment). It was preceded by Step 8.7 concerning the adoption of the

resolution for the resumption of market surveillance measures and control of non-food

products (Q4 2024) and Step 8.8 related to the adoption of harmonised standards for three

groups of industrial products (Q3 2025).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Resolution No 1055 of the Cabinet of Ministers ‘on Amendments to

paragraph 1 of Resolution No 330 of the Cabinet of Ministers of Ukraine of 27

May 2015’, dated 19 August 2026.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 8.12.

The objective of Reform 5 of Chapter 8 (business environment) is to resume market

surveillance measures and facilitate the adoption of Union norms and standards in Ukraine,

particularly in the areas of industrial products.

With the adoption of Resolution 1055, the status of national metrology institute is granted

exclusively to State Enterprise ‘All-Ukrainian State Scientific and Production Centre for

Standardisation, Metrology, Certification and Consumer Protection’.

Commission assessment: satisfactorily fulfilled

Step 9.7

Name of the step: 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

Related reform/investment: Investment 1. Investments for the recovery, reconstruction

and modernisation needs of Ukraine’s sub-national authorities

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Financed from: loan

Context

The requirement for Step 9.7 described in the CID Annex is:

‘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.’

Step 9.7 is the first step in the implementation of Investment 1 of Chapter 9. It is followed

by Step 9.8, which requires an allocation of at least 20 % of the overall non-repayable

financial support for meeting recovery, reconstruction and modernisation needs of sub-

national authorities (due by Q3 2027).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Reporting forms on ‘Information on the Implementation of Intergovernmental

Transfer Indicators (Other Grants and Subventions) from the State Budget of

Ukraine to Local Budgets’ for 2024 and 2025, submitted as supporting evidence for

Steps 7.12 and 7.14;

3) List of projects and budget programmes financed in 2024–2025 and reported as

contributing to Step 9.7, including actual financing amounts in UAH and EUR.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 9.7.

The objective of Investment 1 of Chapter 9 (decentralisation and regional policy) is to

support the recovery, reconstruction and modernisation needs of Ukraine’s sub-national

authorities, in particular local self-government.

Step 9.7 requires an interim report demonstrating that the equivalent of at least 5% of the

non-repayable financial support under Pillar I has been allocated for these purposes for

2024 and 2025. On the basis of the EUR 5.27 billion in non-repayable financial support

under Pillar I, the minimum amount corresponding to the 5% requirement is EUR 263.5

million.

The evidence submitted by the Ukrainian authorities shows that, during 2024-2025,

financing contributing to Step 9.7 was provided through three mechanisms.

First, inter-budgetary transfers from the State budget to regional and local budgets financed

investments in education and healthcare infrastructure. These covered, inter alia, the New

Ukrainian School, school buses, fire-protection systems, civil protection structures and

shelters, modernisation of school canteens, vocational education infrastructure, safe

conditions in healthcare facilities and public investment projects in the healthcare sector.

Actual financing through this mechanism amounted to UAH 5.39 billion (EUR 124

million) in 2024 and UAH 13.16 billion (EUR 281 million) in 2025, corresponding to

UAH 18.55 billion (EUR 4051 million) in total.

Second, financing was provided directly for public investment projects implemented at

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regional and local level, including rehabilitation and healthcare infrastructure projects and

investments in the resilience of regional Centres for Disease Control and Prevention, such

as repairs, water-supply infrastructure and autonomous heating systems. Financing under

this mechanism amounted to UAH 117.42 million (EUR 2.70 million) in 2024 and UAH

358.35 million (EUR 7.66 million) in 2025, corresponding to UAH 475.77 million (EUR

10.4 million) in total.

Third, medical equipment was procured centrally and subsequently distributed to

healthcare institutions in the regions on the basis of identified needs and requests. The

value of equipment financed under this mechanism amounted to UAH 896.50 million

(EUR 20.63 million) in 2024 and UAH 711.07 million (EUR 15.2 million) in 2025,

corresponding to UAH 1.61 billion (EUR 35.8 million) in total. Although procurement was

carried out centrally, the equipment was directed to healthcare infrastructure in the regions

and addressed identified sub-national recovery, reconstruction and modernisation needs. It

can therefore be taken into account for the purposes of Step 9.7.

Taken together, the three mechanisms resulted in financing of UAH 6.40 billion (EUR 147

million) in 2024 and UAH 14.22 billion (EUR 304.4 million) in 2025. Total financing

contributing to the recovery, reconstruction and modernisation needs of Ukraine’s sub-

national authorities in 2024-2025 therefore amounted to approximately UAH 20.63 billion

(EUR 451 million).

The supporting evidence identifies the relevant budget programmes, investment areas,

projects and beneficiaries. It demonstrates that the financing was directed to investments

serving regional and local needs, including local self-government. The Commission

considers that the expenditure covered by the three mechanisms falls within the scope of

recovery, reconstruction and modernisation for the purposes of Step 9.7, as it supports the

construction, reconstruction, rehabilitation, modernisation, equipping and resilience of

public infrastructure and services at sub-national level.

The evidence concerns actual financing and budget execution rather than budgetary

allocations alone and therefore demonstrates that the minimum allocation required under

Step 9.7 has materialised.

The EUR 451 million reported under the three mechanisms corresponds to approximately

8.6% of the EUR 5.27 billion in non-repayable financial support under Pillar I. It therefore

exceeds the 5% requirement, corresponding to EUR 263.5 million, by approximately EUR

187.8 million, or 3.6 percentage points.

On the basis of the evidence provided, the Commission considers that the requirement of

Step 9.7 has been satisfactorily fulfilled. The documented allocations amount to EUR 451

million, corresponding to approximately 8.6% of the EUR 5.27 billion in non-repayable

financial support under Pillar I and therefore exceeding the required 5% threshold of EUR

263.5 million.

Commission assessment: satisfactorily fulfilled

Step 10.3

Name of the step: Entry into force of the legislation to improve permitting procedures for

renewable energy investments

Related reform/investment: Reform 2. Improved regulatory framework for increasing

renewable energy and ensuring stable operation of the energy system

EN 34 EN

Financed from: loan

Context

The requirement for Step 10.3 described in the CID Annex is:

‘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’).’

Step 10.3 is the third and last step of Reform 2. It was preceded by Step 10.2 requiring the

introduction of a market-based renewable energy framework in line with Union rules and by

Step 10.4 concerning the approval of a roadmap for the separation of the renewable energy

surcharge from the transmission tariff.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Law No 4963-IX of 2 September 2026.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 10.3.

The overall objective of this reform is to increase the share of renewable energy in the energy

mix of Ukraine by simplifying and shortening permitting procedures for the renewable energy

projects.

To fulfil this step, Law No 4963-IX was adopted on 2 September 2026. Law No 4963-

IX/2026 streamlines and shortens permitting procedures for renewable energy projects, in

compliance with the Energy Community Ministerial Council Recommendation 2024/1/MC-

EnC of 11 December 2024, recommending Ukraine to prepare the legal and institutional

preconditions for the implementation of the Articles 15b, 15c, 15d, 15e, 16, 16a, 16b, 16c,

16d, 16e and 16f of Directive (EU) 2018/2001 on the promotion of the use of energy from

renewable sources (hereafter referred to as ‘the RED Directive’), as amended by Directive

(EU) 2023/2413. Law No 4963-IX of 2 September 2026 transposes into national legislation

all the above-mentioned provisions, by amending Law No 555-IV of 24 March 2003 ‘on

Alternative Energy Sources’. In particular:

• The new Article 99nonies of Law No 555-IV of 24 March 2003 transposes Article 15b

of the RED Directive, requiring the central executive authority responsible for

formulating and implementing the state policy in the electricity sector to carry out a

coordinated mapping exercise to identify the domestic potential and available areas for

the installation of renewable energy facilities and their associated infrastructure which

are necessary to achieve the National Energy and Climate Plan target and the national

contribution to the Energy Community’s objectives.

• The new Article 910 of the Law No 555-IV of 24 March 2003 transposed into national

legislation Articles 15c and 15d of the RED Directive, requiring the Cabinet of

Ministers of Ukraine, taking into account the above-mentioned mapping exercise, to

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approve one or more plans identifying, for one or more types of renewable energy

sources, renewable acceleration areas, i.e. areas where permitting procedures will be

sped -up and simplified. The plans will be subjected to a strategic environmental

assessment and will include the necessary mitigating measures to reduce and/or

prevent damage to the environment. In line with Article 9 of Law No 2354-VIII of 20

March 2018 on strategic environmental assessment, public consultation is a mandatory

state of the strategic environmental assessment process. The plans will also be

published on the Unified State Web Portal of Open Data and reviewed periodically, in

particular when revising and updating the National Energy and Climate Plan.

• The new Articles 142 and 1410 of Law No 555-IV of 24 March 2003 transposed into

national legislation Articles16 and 16f of the RED Directive, defining the main

principles of permit-granting procedures and setting out the principle of the overriding

public interest of energy projects.

• The new Articles 145and 146 of Law No 555-IV of 24 March 2003 transposed into

national legislation Articles 16a and 16b of the RED Directive, setting out deadlines to

finalise permitting procedures for projects located inside and outside renewable

acceleration areas, in line with the RED Directive and simplifying permitting

procedures for projects located in renewable acceleration areas.

• The new Articles 147, 148 and 149 of Law No 555-IV of 24 March 2003 transposed

into national legislation Articles 16c, 16d and 16e of the RED Directive, setting out

specific rules for repowering projects, for the installation of solar energy equipment

and heat pumps.

Law No 4963-IX of 2 September 2026 entered into force on 1 October 2026, i.e. the day

following the date of its publication in Official Gazette No 190 of 30 September 2026.

Commission assessment: satisfactorily fulfilled

Step 10.19

Name of the step: 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

Related reform/investment: Reform 5. Ensuring independence of National Energy and

Utilities Regulatory Commission

Financed from: loan

Context

The requirement for Step 10.19 described in the CID annex is:

‘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,

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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 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.’

Step 10.19 is the third step of Reform 5. It was preceded by Step 10.10, which required the

exemption of the regulatory decisions of the National Energy and Utilities Regulatory

Commission (NEURC) from state registration and by Step 10.11, which provides for the

specification of the special status of NEURC. It is followed by Step 10.20, which requires the

completion of a third-party audit of NEURC. Step 10.11 remains unfulfilled since Q2 2026.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Link to call for tender No 020828 launched by the European Bank for Reconstruction

and Development (EBRD) on 10 August 2026;

3) Copy of the Terms of Reference (ToR) for the assessment of organisational and

integrity practices of NEURC.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all the

constitutive elements of Step 10.19

The overall objective of this reform is to strengthen the independence of the energy regulator

and ensure effective functioning and development of markets in the energy and utilities

sectors. To fulfil the step, NEURC prepared the Terms of Reference (ToR) for the third-party

audit, in close cooperation with the EBRD. The final adopted ToR were included in call for

tender No 020828 launched by the EBRD on 10 August 2026 for the selection of the

consultant. The ToR are aligned with the conditionalities of the CID. In particular, the ToR:

• clarify the scope of the audit, namely, to provide an objective, evidence-based

assessment of the integrity and robustness of NEURC’s internal processes and

governance practices, identify strengths, risks and gaps in integrity and accountability

mechanisms and provide practical, actionable recommendations aligned with EU best

practice and international regulatory standards.

• The ToR require an assessment of five key areas of NEURC’s governance and

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integrity framework, covering all sub-set of conditionalities included in the CID,

namely:

o Decision-Making Processes: to evaluate the integrity and robustness of the

decision-making processes as regards regulatory decisions and identify areas for

potential improvements to strengthen NEURC’s institutional capacity, resilience

and alignment with European and international best practice, including the EU

acquis. The audit will also assess the effectiveness of existing safeguards to ensure

integrity and transparency, documentation standards as well as internal approval

procedures and their traceability.

o Ethical Practices: to assess NEURC’s ethical standards and their effective

implementation. The assessment will include (among other things) a review of

existing codes of ethics/conduct and internal policies, the existence of internal

structures to ensure compliance with such policies and procedures, an evaluation

of conflict-of-interest policies and disclosure practices, including declarations of

interests and recusal procedures.

o Anti-Corruption Programme: to evaluate the design and effectiveness of NEURC’s

anti-corruption measures, including identification of institutional vulnerabilities

and integrity risks.

o Communication Policy: to assess communication practices, including interaction

with EU/EnC regulators, market participants and other Ukrainian public

authorities and mechanisms to ensure transparency, consistency and equal

treatment of relevant stakeholders;

o Financial Component (Decision-making, Budgeting and Reporting): to assess

NEURC’s financial governance and decision-making, budgeting processes and

reporting practices. The assessment will also evaluate the impact of external

approval requirements by the Ministry of Finance of Ukraine and by the Budget

Committee of the Ukrainian Parliament; analyse the allocation and use of funds;

assess internal controls and financial oversight mechanisms, including against

misuse and undue influence and their effectiveness.

• The ToR include a description of the implementation modalities, timeline and

indicative cost of the audit (Sections B, C, D, E, F) and specify that the audit will be

institutional and systems-oriented in nature and will not duplicate or interfere with

ongoing investigations or competencies of law enforcement authorities.

• Finally, an open competition was launched for the auditor’s selection, therefore

ensuring that a plurality of service providers will have access to the ToR.

Commission assessment: satisfactorily fulfilled

Step 12.9

Name of the step: Investments of at least EUR 30 million in demining of agriculture land

Related reform/investment: Investment 1. Investments in demining

Financed from: loan

Context

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The requirement for step 12.9 described in the CID annex is:

‘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.’

Step 12.9 is the first of the two steps in the implementation of Investment 1 of Chapter 12

(agri-food sector). It is followed by Step 12.10 (due on Q3 2027) on investments of at least

EUR 100 million in demining of agriculture land. Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of Resolution No 284 of the Cabinet of Ministers of 12 March 2024 ‘Procedure

for the use of funds provided in the state budget for humanitarian demining’;

3) Copy of Order No 11242 of the Ministry of Economy of 2 May 2024 approving the

passport of the budgetary programme 1201420 for 2024;

4) Copy of Order No 1186 of the Ministry of Economy of 13 February 2025 approving

the passport of the budgetary programme 1201420 for 2025;

5) Copy of Report on the implementation of budgetary programme 1201420 for 2024;

6) Copy of Report on the implementation of budgetary programme 1201420 for 2025;

7) Copy of Treasury report for budgetary programme 1201420 for 2024 and 2025;

8) Copy of a list of contracts for implementation of Step 12.9.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all the

constitutive elements of Step 12.9.

The overall objective of this investment is to support owners or users of agricultural land

undertaking de-mining efforts.

The evidence provided shows that, the State Budgets for 2024 and 2025 included budget

programme 1201420 ‘Compensation for expenses for humanitarian demining of agricultural

land’. Resolution 284 of 12 March 2024 established the administrative procedures for

implementing the programme, including the eligibility criteria and implementation

arrangements and limits support for the demining of agricultural land. Amendments to the

Resolution were made in 2025 and 2026 to increase the efficiency of the programme’s

implementation.

The Ukrainian authorities reported total expenditure of UAH 1,583 million (EUR 34.4

million) under the programme in 2024 and 2025, which was allocated across 120 contracts.

The figure comprises of:

• In 2024, a total of UAH 356 million (EUR 8.2 million) in expenditure was allocated

across 17 contracts,

• In 2025, a total of UAH 1,227 million (EUR 26.2 million) in expenditure was

allocated across 103 contracts.

101 of these contracts, with expenditure of UAH 1,182 million (EUR 25.8 million), were

completed at the time of reporting, whereas 19 contracts amounting to UAH 401 million

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(EUR 8.6 million) are still being implemented.

Taken together, under the completed contracts and contracts under implementation from 2024

and 2025 represent an amount of EUR 34.4 million committed to be spent on the demining of

agricultural land. This exceeds the minimum target of EUR 30 million and corresponds to

around 115% of the target. The quantitative requirement of the step is therefore fulfilled.

The programme supports farmers activities to demine agricultural land. Ukrainian authorities

reported a total of 120 contracts and 87 unique beneficiaries (owners and users of agricultural

land). The contracts cover the clearing of a total of 20,789.7 hectares of agricultural land, of

which 17,338 hectares had already been successfully cleared by the time of reporting.

On this basis, the evidence provided demonstrates that the requirements of Step 12.9 have

been fulfilled. Commission assessment: satisfactorily fulfilled

Step 14.4

Name of the step: 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

Related reform/investment: Reform 2. Digitalisation of public services

Financed from: loan

Context

The requirement for Step 14.4 described in the CID Annex is:

‘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.’

Step 14.4 is the second step in the implementation of Reform 2 of Chapter 14 (digital

transformation). Step 14.3 on the adoption of the Action Plan for digitalisation of public

services until 2026 was positively assessed as part of the fourth instalment (Q1 2025).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of Resolution No 1150 of the CMU of 3 November 2023 ‘on approval of the

Regulations of the Integrated Electronic Identification System’;

3) Copy of Resolution No 689 of the CMU of 11 June 2025 ‘on approval of requirements

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for the issue of wallets with digital identification’;

4) Copy of Resolution No 1400 of the CMU of 24 October 2025 ‘on Some Issues of the

Implementation of an Experimental Project on the Formation and Use of Electronic

Identification Data and Electronic Certificates of Attributes using a Wallet with Digital

Identification as a Functional Feature of the Diia Mobile Application’.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 14.4.

The objective of Reform 2 is to simplify the interaction between the state and citizens via

digitalisation.

Several Resolutions of the Cabinet of Ministers of Ukraine (CMU) constitute the legal

framework for fulfilling this step. CMU Resolution No 1150 is the foundational legal act that

establishes a modern electronic identification infrastructure in Ukraine. CMU Resolution No

689 and CMU Resolution No 1400 are the relevant legal acts and are in line with the

principles of Regulation (EU) 2024/1183.

CMU Resolution No 689 lays down the functional, technical and technological conditions for

the issuance of digital identity wallets, while CMU Resolution No 1400 supports the system’s

further development through an experimental project and the Diia Mobile Application.

Furthermore, the legal acts focus on ensuring interoperability (technological compatibility) of

electronic identification means, intermediate electronic identification nodes (hubs) and

electronic identification schemes by requiring wallets to support common protocols and

interfaces for the formation, exchange and presentation of identity data. More importantly, the

resolutions focus on the recognition of European digital identity wallets and certain electronic

certificates for cross-border use.

Lastly, the resolutions focus on the protection of information resources processed in the

system by extending certain safeguards to digital identity wallets, in particular through

requirements on personal data separation and withdrawal in the event of security breaches.

These safeguards include access control, security monitoring, network protection and

confidentiality and integrity and availability of information.

As part of Council Implementing Decision (EU) 2026/1204 of 28 May 2026 establishing the

satisfactory fulfilment of the conditions for the partial payment of the seventh instalment

under the Ukraine Plan of the Ukraine Facility and amending Implementing Decision (EU)

2024/1447, this step was taken into account as a mitigating factor, in accordance with the

methodology for assessing the partial fulfilment of steps under the Ukraine Plan, solely for the

purposes of the application of that Decision. The assessment of this step has not changed

since the adoption of that Decision.

Commission assessment: satisfactorily fulfilled

Step 15.8

Name of the step: Adoption of the Strategy for implementing the principles of the circular

economy and its Action Plan

Related reform/investment: Reform 5. Increased circular economy

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Financed from: loan

Context

The requirement for Step 15.8 described in the CID Annex is:

‘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.’

Step 15.8 is the second step in the implementation of Reform 5 under Chapter 15 (green

transition and environmental protection). It was preceded by Step 15.9 on the adoption of the

Strategy for implementing the principles of the circular economy and its Action Plan.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

1) Copy of the Strategy for the Development of Ukraine’s Circular Economy as approved

by Order No 934-r of the Cabinet of Ministers of Ukraine of 17 September 2026;

2) Copy of the Action Plan for the Implementation of Ukraine’s Circular Economy

Development Strategy as approved by Order No 934-r of the Cabinet of Ministers of

Ukraine of 17 September 2026;

3) Link to the published strategy: https://www.kmu.gov.ua/npas/pro-skhvalennia-

stratehii-rozvytku-tsyrkuliarnoi-ekonomiky-ukrainy-na-period-do-2035-roku-ta-

zatverdzhennia-operatsiinoho-planu-zakhodiv-z-ii-realizatsii-u-20262028-rokakh-934-

170926.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 15.8.

The objective of Reform 5 is to implement the principles of circular economy and waste

management.

The Strategy identifies seven priority sectors for the transition to a circular economy:

agriculture; food production and distribution; construction; textiles; electrical and electronic

equipment; mining and quarrying; and metallurgy. It also addresses cross-cutting value

chains, notably plastics, packaging and batteries, where resource use, waste generation and

potential for reuse, recovery and recycling are particularly significant.

The overarching objective is to establish a circular and resource-efficient economic model in

Ukraine by 2035, reducing the use of primary resources and waste generation while

promoting reuse, repair, recovery and recycling. The Strategy seeks to contribute to Ukraine’s

sustainable reconstruction and integration into the EU internal market through alignment with

EU legislation and standards. The intended outcome is the development of sustainable circular

business models, secondary raw-material markets and closed-loop value chains, underpinned

by an effective EU-aligned regulatory and institutional framework.

Commission assessment: satisfactorily fulfilled

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Step 15.11

Name of the step: Adoption of amendments to the Procedure for State Water Monitoring

Related reform/investment: Reform 4. Restoration and conservation of natural resources

Financed from: loan

Context

The requirement for Step 15.11 described in the CID Annex is:

‘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.’

Step 15.11 is the first of two steps in the implementation of Reform 4 of Chapter 15 (green

transition and environmental protection). It is followed by Step 15.7 on entry into force of

the Law on reducing deforestation and forest degradation (due by Q4 2026).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled, in line

with the requirements set out in the CID Annex;

2) Copy of Resolution No 754 of the Cabinet of Ministers of Ukraine of 10 June2026,

‘on Amendments to the Procedure for State Water Monitoring’;

3) Copy of Official Gazette No 125 of 16 June 2026, where the Resolution is

published; 4) Link to the published Resolution: Про внесення змін до Порядку здійснення

державного моніторингу вод | Кабінет Міністрів України.

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover all

the constitutive elements of Step 15.11.

The objective of Reform 4 is to reduce deforestation and forest degradation.

On 10 June, the Government adopted Resolution No 754 amending the Procedure on state

water monitoring (https://www.kmu.gov.ua/npas/pro-vnesennia-zmin-do-poriadku-

zdiisnennia-derzhavnoho-monitorynhu-s754100626), aligning it with requirements in the

step description.

The adopted Resolution contains the watch list parameters matching the parameters of

Commission Implementing Decision (EU) 2025/439 of 28 February 2025 establishing a

watch list of substances for Union-wide monitoring in the field of water policy pursuant to

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Directive 2008/105/EC of the European Parliament and of the Council.

The Resolution will enter into force in 2029 as this decision is linked to the planning cycle

for the second River Basin Management Plans (RBMPs). RBMPs operate on a continuous

six-year planning cycle mandated by the European Water Framework Directive. In

Ukraine, RBPMs covering the first planning cycle of 2025-2030 were adopted at the end of

2024 and are now being implemented. Government Resolution No 754 is one of the steps

to prepare for further alignment of the water monitoring system in Ukraine with EU

requirements to ensure that it starts to apply as of the second planning cycle of the RBMPs.

As part of Council Implementing Decision (EU) 2026/2230 of 24 September 2026

establishing the satisfactory fulfilment of the conditions for the partial payment of the

eighth instalment under the Ukraine Plan of the Ukraine Facility, this step was taken into

account as a mitigating factor, in accordance with the methodology for assessing the partial

fulfilment of steps under the Ukraine Plan, solely for the purposes of the application of that

Decision. The assessment of this step has not changed since the adoption of that Decision.

Commission assessment: satisfactorily fulfilled

Assessment of the satisfactory fulfilment of one step in the 10th instalment proposed as a

mitigating factor in line with the methodology for handling the partial fulfilment of steps

in the Ukraine Plan, and solely for the purpose of its application

Step 10.21

Name of the step: Request for an integrated regulatory review service mission at SNRIU by

the International Atomic Energy Agency

Related reform/investment: Reform 8. Reform of State Nuclear Regulatory Inspectorate

Context

The requirement for Step 10.21 described in the CID Annex is:

‘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.’

Step 10.21 is the only step in the implementation of Reform 8 under Chapter 10 (energy).

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Copy of the request made on 23 July 2026 to the International Atomic Energy Agency

(IAEA) by the Permanent Mission of Ukraine to the International Organizations in

Vienna, on behalf of State Nuclear Regulatory Inspectorate of Ukraine (SNRIU), to

conduct an Integrated Regulatory Review Service (IRRS) mission;

3) Copy of the email sent on 29 September 2026 by SNRIU to ask the IAEA to start the

IRRS mission in the first half of 2027;

4) Copy of the 2018 IRRS service guidelines.

Analysis

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The justification and substantive evidence provided by the Ukrainian authorities cover all

constitutive elements of Step 10.21.

The objective of Reform 8 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. To

fulfil the step, on 23 July 2026, the Permanent Mission of Ukraine to the International

Organisations in Vienna, on behalf of SNRIU, sent a request to the IAEA to perform an IRRS

mission in accordance with the 2018 IRRS service guidelines. On 29 September 2026, SNRIU

also submitted a follow-up email asking the IAEA to consider starting the IRRS mission

already in the first half of 2027, in line with the CID.

Commission assessment: satisfactorily fulfilled

Assessment of the partial fulfilment of one quantitative step in the ninth instalment

proposed as a mitigating factor in line with the methodology for handling the partial

fulfilment of steps in the Ukraine Plan, and solely for the purpose of its application

Step 6.3

Name of the step: Appointment of Supervisory boards of state-owned enterprises with a

majority of independent members

Related reform/investment: Reform 2. Improved governance and management of state-

owned enterprises

Context

The requirement for Step 6.3 described in the CID Annex is:

‘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 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.’

Step 6.3 is the second step in the implementation of Reform 2 under Chapter 6

(management of public assets). It was preceded by Step 6.1 concerning entry into force of

the legislation on corporate governance of SOEs. It will be followed by Step 6.4 (due on Q3

2026) on corporatisation of key state-owned enterprises and Step 6.5 (due on Q3 2027) on

submission of a report showing that the principles of corporate governance are duly

followed.

Evidence provided

1) Summary document duly justifying how the step was satisfactorily fulfilled in line

with the requirements set out in the CID Annex;

2) Order No 817-p of the Cabinet of Ministers of Ukraine of 30 August 2024 on some

issues of the Supervisory Board of the ‘Energy Company of Ukraine’;

3) Order No 99-p of the Cabinet of Ministers of Ukraine of 26 January2026 on some

issues of the Supervisory Board of the ‘National Joint Stock Company ‘Naftogaz of

Ukraine’;

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4) Order No 678-p of the Cabinet of Ministers of Ukraine of 7 July2025 on some issues

of the Supervisory Board of the ‘Ukrhydroenergo’ Private Joint-Stock Company;

5) Order No 998-p of the Cabinet of Ministers of Ukraine of 31 October2023 on some

issues of the Supervisory Board of the ‘Limited Liability Company Gas

Transmission System Operator of Ukraine’;

6) Order No 86-p of the Cabinet of Ministers of Ukraine of 28 January2026 on issues

of the Supervisory Board of the ‘National Nuclear Energy Generating Company

‘Energoatom’;

7) Order No 185-p of the Cabinet of Ministers of Ukraine of 25 February2026 on

issues of the Supervisory Board of the ‘National Nuclear Energy Generating

Company ‘Energoatom’;

8) Order No 197-p of the Cabinet of Ministers of Ukraine of 02 March2026 on issues

of the Supervisory Board of the ‘National Joint-Stock Company ‘Naftogaz of

Ukraine’;

9) Order No 663-p of the Cabinet of Ministers of Ukraine of 01 July 2026 on issues of

the Supervisory Board of the ‘National Nuclear Energy Generating Company

‘Energoatom’;

10) Order No 588-p of the Cabinet of Ministers of Ukraine of 17 June 2026 on issues of

the Supervisory Board of the ‘Ukrainian Railway’;

11) Order No 1090-p of the Cabinet of Ministers of Ukraine of 1 October2025 issues of

the Supervisory Board of the ‘Ukrainian Railway’;

12) Order No 900-p of the Cabinet of Ministers of Ukraine of 26 August2025 on issues

of the Supervisory Board of the ‘Ukrposhta’;

13) Order No 46-p of the Cabinet of Ministers of Ukraine of 21 January.01.2025 on

issues of the Supervisory Board of the State Specialized Economic Enterprise

‘Forests of Ukraine’;

14) Order No 524-p of the Cabinet of Ministers of Ukraine of 27 May2026 on issues of

the Supervisory Board of the State Specialized Economic Enterprise ‘Forests of

Ukraine’;

15) Order No 666-p of the Cabinet of Ministers of Ukraine of 15 July 2026 on issues of

the Supervisory Board of the State Specialized Economic Enterprise ’Forests of

Ukraine’;

16) Order No 401-p of the Cabinet of Ministers of Ukraine of 24 April 2026 on issues of

the Supervisory Board of the‘Ukrhydroenergo’ Private Joint-Stock Company;

17) Order No 451-p of the Cabinet of Ministers of Ukraine of 13 May2026 on issues of

the Supervisory Board of the ‘Private Joint-Stock Company National Energy

Company ‘Ukrenergo’;

18) Order No 721-p of the Cabinet of Ministers of Ukraine of 15 July2025 on issues of

the Supervisory Board of the ‘Private Joint-Stock Company Ukrainian Danube

Shipping Company’;

19) Order No 1168-p of the Cabinet of Ministers of Ukraine of 26 November2024 on

issues of the Supervisory Board of the ‘Private Joint-Stock Company National

Energy Company ‘Ukrenergo’;

20) Order No 452-p of the Cabinet of Ministers of Ukraine of 13 May2026on issues of

the Supervisory Board of the ‘Limited Liability Company Gas Transmission System

Operator of Ukraine’;

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21) Order No 450-p of the Cabinet of Ministers of Ukraine of 13 May 2026 on the

announcement of the competitive selection of candidates for the positions of

independent members of the supervisory board of the private joint-stock company

‘Ukrhydroenergo’;

22) Order No 587-p of the Cabinet of Ministers of Ukraine of 17 June 2026 on

termination of powers of members of the supervisory board of the private joint stock

company ‘Ukrhydroenergo’; 23) Order No 664-p of the Cabinet of Ministers of Ukraine of 1 July2026 on issues of

the Supervisory Board of the ‘Limited Liability Company Gas Transmission System

Operator of Ukraine’;

24) Resolution No 1633 of the Cabinet of Ministers of Ukraine of 10 December2025

about the formation of the joint-stock company ‘Guaranteed buyer’;

25) Letter from the head of the State Agency for Forest Resources of Ukraine dated 11

February 2026 on the termination of powers of a member of the Supervisory Board;

26) Protocol/Minutes No 3 of 24 April2026 of the remote extraordinary general meeting

of shareholders of PJSC ‘Centrenergo’;

27) Order No 34 of the Cabinet of Ministers of Ukraine of 07 October 2026 ‘on the

Announcement of the Competitive Selection of Candidates for the Independent

Members of the Supervisory Board of ‘Ukrainian Energy Machines’;

28) Order No 1254 of the Ministry of Economy of Ukraine of 09 March 2023 on ‘some

issues of the supervisory board of the state-owned enterprise ‘Printing Plant

‘Ukraine’ on the production of securities’;

29) Order No 1672 of the Ministry of Economy of Ukraine of 26 April 2023 on ‘some

issues of the supervisory board of the state-owned enterprise ‘Printing Plant

‘Ukraine’ on the production of securities’;

30) Order No 195-p of the Cabinet of Ministers of Ukraine of 7 March 2023 on the

approval of candidates for the positions of members of the supervisory board of the

state enterprise ‘Printing Plant ‘Ukraine’ for the production of securities’;

31) Order No 336-p of the Cabinet of Ministers of Ukraine of 23 April 2024 on the

approval of the candidacy of Rusnyak P.Yu. for the position of a member of the

supervisory board of the state enterprise ‘Printing Plant 'Ukraine’ for the production

of securities’;

32) Order No 1027-p of the Cabinet of Ministers of Ukraine of 7 October 2026 on the

Announcement of Competitive Selection of Candidates the Independent Members of

the Supervisory Board of 'Ukrainian Energy Machines'

Analysis

The justification and substantive evidence provided by the Ukrainian authorities cover some

constitutive elements of Step 6.3.

The objective of Reform 2 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) by enhancing corporate

governance standards and implementing them in top SOEs. To fulfil the step, Ukrainian

authorities must ensure that 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 nomination of the Supervisory board members should be

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conducted by competitive selection process, on the basis of procedures agreed and in place

at the time of the start of the selection.

To fulfil this step, the Ukrainian Cabinet of Ministers has adopted a series of orders

appointing independent members and state representatives to the Supervisory Boards of top

key SOEs, after a competitive selection process, in line with Nomination Committee

procedures, took place. The 10 SOEs where the Supervisory Boards were appointed are JSC

‘Ukrainian Railways’, JSC ‘National Nuclear Energy Generating Company ‘Energoatom’,

NJSC ‘Naftogaz of Ukraine’, LLC ‘Gas Transmission System Operator of Ukraine’

(GTSOU), NPC ‘Ukrenergo’, State Enterprise ‘Forests of Ukraine’, PJSC ‘Ukrainian

Danube Shipping Company’, JSC ‘Energy Company of Ukraine’, State Enterprise ‘Printing

Plant ‘Ukraine’ for the Production of Security Documents’ and PJSC ‘Centrenergo’.

Independent members constitute majorities in all the Supervisory Boards of the SOEs

mentioned above. This represents a 66.7% fulfilment of the requirements of the step.

The Ukrainian authorities intend to further amend the Cabinet of Ministers’ protocol

decision and incorporate additional entities into the list of top key SOEs, as agreed in

discussions with the Commission.

Commission assessment: partially fulfilled