| Dokumendiregister | Kaitseministeerium |
| Viit | 5-6/26/1 |
| Registreeritud | 15.01.2026 |
| Sünkroonitud | 16.01.2026 |
| Liik | Sissetulev kiri |
| Funktsioon | - - |
| Sari | - - |
| Toimik | - - |
| Juurdepääsupiirang | Avalik |
| Juurdepääsupiirang | |
| Adressaat | Riigikantselei |
| Saabumis/saatmisviis | Riigikantselei |
| Vastutaja | |
| Originaal | Ava uues aknas |
Resolutsiooni liik: Riigikantselei resolutsioon Viide: Rahandusministeerium / / ; Riigikantselei / / 2-5/26-00098
Resolutsiooni teema: Ukraina toetuslaenu loomine aastateks 2026 ja 2027 tõhustatud koostöö alusel
Adressaat: Rahandusministeerium Ülesanne: Tulenevalt Riigikogu kodu- ja töökorra seaduse § 152` lg 1 p 2 ning Vabariigi Valitsuse reglemendi § 3 lg 4 palun valmistada ette Vabariigi Valitsuse seisukohtade ja otsuste eelnõud järgmiste algatuste kohta, kaasates seejuures olulisi huvigruppe ja osapooli:
- Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL implementing enhanced cooperation on the establishment of the Ukraine Support Loan for 2026 and 2027, COM(2026)20
- Amended proposal for a COUNCIL REGULATION amending Regulation (EU, Euratom) 2020 /2093 laying down the multiannual financial framework for the years 2021 to 2027, COM(2026)21
- Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2024/792 establishing the Ukraine Facility,COM(2026)22
EISi toimiku nr: 26-0020 Tähtaeg: 23.01.2026
Adressaat: Kaitseministeerium, Välisministeerium Ülesanne: Palun esitada oma sisend Rahandusministeeriumile seisukohtade kujundamiseks antud eelnõu kohta (eelnõude infosüsteemi (EIS) kaudu). Tähtaeg: 21.01.2026
Lisainfo: Eelnõu on kavas arutada valitsuse 29.01.2026 istungil ja Vabariigi Valitsuse reglemendi § 6 lg 6 kohaselt sellele eelneval nädalal (28.01.2026) EL koordinatsioonikogus. Esialgsed materjalid EL koordinatsioonikoguks palume esitada hiljemalt 23.01.2026.
Kinnitaja: Nele Grünberg, Euroopa Liidu asjade direktori asetäitja Kinnitamise kuupäev: 15.01.2026 Resolutsiooni koostaja: Sandra Metste [email protected],
.
15.01.2026
Ukraina toetuslaenu loomine aastateks 2026 ja 2027 tõhustatud koostöö alusel
Otsuse ettepanek koordinatsioonikogule
Kujundada seisukoht
Peavastutaja: Rahandusministeerium
Kaasvastutajad: Välisministeerium, Kaitseministeerium
Kaasvastutaja sisendi tähtpäev 21.01.2026
KOKi esitamise tähtpäev 28.01.2026
VV esitamise tähtpäev 29.01.2026
Seisukoha valitsusse toomise alus ja põhjendus
Algatuse reguleerimisala nõuab vastavalt Eesti Vabariigi põhiseadusele seaduse või Riigikogu otsuse vastuvõtmist, muutmist või kehtetuks tunnistamist (RKKTS § 152¹ lg 1 p 1);
Algatuse vastuvõtmisega kaasneks oluline majanduslik või sotsiaalne mõju (RKKTS § 152¹ lg 1 p 2);
Seisukoha võtmist peab oluliseks peaminister või minister (VVS § 20¹ lg 2);
Sisukokkuvõte
2025. aasta 18. detsembri Euroopa Ülemkogu kohtumisel otsustati toetada Ukrainat järgmisel kahel aastal 90 miljardi euro suuruse laenuga, mis põhineb Euroopa Liidu ühisel laenamisel kapitaliturgudelt liidu eelarve tagatisel. Ukraina ei pea laenu tagasi maksma kuni Venemaa on hüvitanud kahjud. Samuti jätab Euroopa Liit endale õiguse kasutada Venemaa keskpanga külmutatud varasid laenu tagasimaksmiseks. Laenus ei osale Ungari, Slovakkia ja Tšehhi, mistõttu vormistatakse laen tõhustatud koostöö raamistikus, milles osaleb 24 liikmesriiki. Tõhustatud koostöö on mehhanism, mis võimaldab ELi liikmesriikidel teha koostööd konkreetsetes valdkondades juhul, kui on selge, et EL tervikuna ei suuda sellise koostöö eesmärke mõistliku aja jooksul saavutada.
Vastavalt ülemkogu suunisele võttis Euroopa Liidu Nõukogu 12. jaanuaril vastu otsuse, mis annab loa kasutada tõhustatud koostööd laenuinstrumendi loomiseks. 14. jaanuaril esitas Euroopa Komisjon ettepaneku "Ukraina toetuslaenu" (Ukraine Support Loan) loomiseks. Pakett koosneb kolmest eelnõust:
2
1. ettepanek kehtestada Ukrainale toetuslaen summas 90 miljardit eurot - COM(2026) 20 final;
2. ettepanek muuta mitmeaastast finantsraamistikku käsitlevat määrust, et võimaldada Ukraina laenu katmine ELi eelarvelae arvelt - COM(2026) 21 final
3. ettepanek muuta Ukraina rahastut (Ukraine Facility) kui üht vahendit eelarvetoetuse rakendamiseks Ukrainale - COM(2026) 22 final.
Ettepaneku kohaselt jaguneks 90 miljardi suurune toetus kaheks komponendiks: ligikaudu kaks kolmandikku ehk 60 miljardit eurot suunataks sõjalisele abile ning ülejäänud kolmandik ehk 30 miljardit eurot eraldataks üldiseks eelarvetoetuseks kas makromajandusliku finantsabi või Ukraina rahastu (Ukraine Facility raames) vastavalt kokkuleppele Ukrainaga. Toetus aitab Ukrainal tugevdada kaitsevõimet ning tagada riigi ja põhiliste avalike teenuste jätkuv toimimine, aidates samal ajal kaasa Ukraina vastupanuvõimele ja tihedamale lõimumisele Euroopa kaitsetööstusliku baasiga.
Esimesed väljamaksed loodetakse Ukrainale teha II kvartali alguseks, mistõttu on vajalik paketti menetleda nõukogus kiireloomuliselt.
Kas EL algatus reguleerib karistusi või haldustrahve? Ei
Kas nähakse ette uue asutuse loomine (järelevalvelised või muud asutused)? Ei
Kas lahenduse rakendamine vajab IT-arendusi? Ei
Eesmärgid
Mõju valdkonnad
Majandus
Ettevõtlus
Sõjalise abi samba raames võib Eesti kaitsetööstusettevõtetele tekkida vastavalt Ukraina vajadustele ja sõltuvalt pakkumise kiirusest võimalus täiendavalt toetada Ukraina kaitsevõimet, sealhulgas koostöös Ukraina kaitsetööstusega
Riigivalitsemine
Riigieelarve
Laenu tagab ELi eelarve. Laenu teenindamisega seotud kulud (sh intressikulud) kaetaks jooksvalt Eesti ELi eelarve makse sees.
Riigikaitse ja välissuhted
Suhted välisriikide ja organisatsioonidega
Algatus ühtib Eesti prioriteediga toetada Ukrainat pikaajaliselt ja võimalikult suures mahus. Samuti tõstab Euroopa Liidu suurenenud toetus Ukrainale Euroopa Liidu
3
nähtavust ja tõsiseltvõetavust väliste partnerite seas. Samuti seostub laen kolmandate riikide, eelkõige ELi-väliste NATO liitlastega seoses kaitsetoodete abikõlbulikkuse kriteeriumitega – komisjoni ettepaneku alusel on kolmandate riikide kaasumine teatud tingimustel võimaldatud (abikõlbulikud kaitsetooted peavad vastama teatud tingimustele ning pärinema ELi riikidest, Euroopa majanduspiirkonna riikidest, Ukrainast või SAFE laenuinstrumendi raames eraldi kokkuleppe sõlminud riikidega (Kanada), kuid pakiliste vajaduste puhul, mida ei ole võimalik hankida EList või ülaltoodud riikidest, nähakse Ukrainale ette võimalus taotleda erandeid).
Riigikaitse
Ukraina võime ennast pikaajaliselt kaitsta Vene agressiooni eest toetab Eesti ja Euroopa julgeolekut laiemalt.
Kaasamine
Võimalusel kaasata asjassepuutuvad huvirühmad
EN EN
EUROPEAN COMMISSION
Brussels, 14.1.2026
COM(2026) 20 final
2026/0008 (COD)
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
implementing enhanced cooperation on the establishment of the Ukraine Support Loan
for 2026 and 2027
EN 1 EN
EXPLANATORY MEMORANDUM
1. CONTEXT OF THE PROPOSAL
• Reasons for and objectives of the proposal
The EU is steadfast in its support to Ukraine, whose future lies within the EU. The EU
supports Ukraine’s independence, sovereignty and territorial integrity within its
internationally recognised borders and is unwavering in its commitment to provide political,
financial, economic, humanitarian, military and diplomatic support1. In light of the escalating
Russian aggression, it is necessary to act swiftly to ensure Ukraine has access to the resources
it urgently needs. This proposal is designed to ensure the establishment of a new instrument to
address those urgent needs, by providing Union assistance to Ukraine in the form of a loan to
be repaid by reparations due by Russia.
The large-scale invasion by Russia of Ukraine, which began on 24 February 2022, has had a
profoundly damaging impact on the country and its citizens. Despite diplomatic efforts by the
US and Europe to achieve a peaceful resolution, and Ukraine’s readiness to engage in
dialogue to end the war, Russia has intensified its attacks on Ukraine, deliberately targeting
civilians and critical infrastructures. This escalation has further exacerbated the humanitarian
crisis, caused immense suffering for the Ukrainian people and raised the colossal human and
financial cost of this unprovoked and unjustified military aggression. Russia’s illegal war of
aggression is a blatant violation of the territorial integrity, sovereignty and independence of
Ukraine, as well as a violation of the prohibition on the use of force enshrined in Article 2(4)
of the United Nations (UN) Charter, which is a peremptory rule of international law, and of
the other principles of the UN Charter. The unwavering determination and courage shown by
Ukrainians in defending their homeland is a testament to their strength and warrants deep
admiration and appreciation.
However, Russia’s intensified aggression has increased Ukraine’s financing needs and calls
for urgent investment in the Ukrainian Defence Technological and Industrial Base. It is now
clear that additional sources of funding both from the EU and the international community are
necessary. Ukraine’s financing needs for 2026 and 2027 are set to surpass existing projections
by the International Monetary Fund (IMF), whose eighth review of the IMF Programme
underlines that risks and uncertainty remain exceptionally high, with the existing programme
having limited scope to absorb any new shocks, including from a more prolonged and intense
war. On 9 September 2025, Ukraine has submitted an official request for a new IMF
programme to cover additional financing needs from 2026 to 2029. The IMF’s ability to
proceed with this programme is contingent upon receiving sufficient financing assurances
from partners, including the Union.
Ukraine’s recently presented draft budget for 2026, developed in cooperation with the IMF,
projects defence and security expenditure of EUR 56 billion, supported by EUR 51.6 billion
of in-kind military assistance. Given the negative impact of the war on Ukraine’s economy,
that budget projects that, in addition to the necessary in-kind assistance, EUR 43 billion of
international aid is needed. As of January 2026, only EUR 25 billion has been firmly
committed. Ukraine has limited room for additional fiscal adjustments, as further spending
cuts or tax increases could further harm the economy, which is already vulnerable due to
damage to key infrastructure, labour shortages, and the ongoing displacement and
mobilisation of people. Swift financial assistance is vital to help Ukraine maintain essential
1 European Council Conclusions, 27 June 2024; EUCO 15/24.
EN 2 EN
state functions, ensure macroeconomic stability, rehabilitate critical energy infrastructures,
and invest into its Defence Technological and Industrial Base. These needs come on top of
significant requirements for medium-term recovery and reconstruction.
In their summit statement of 8 December 2025, G7 Finance Ministers agreed to continue to
work together to develop a wide range of financing options to support Ukraine, including
potentially using the full value of Russian assets immobilised in G7 jurisdictions until
reparations are paid for by Russia, to end the war and ensure a just and lasting peace in
Ukraine, consistent with G7 legal frameworks.
In its conclusions of 27 June 2024, 17 October 2024, 19 December 2024 and 23 October
2025, the European Council has stated that, subject to Union law, Russia’s assets should
remain immobilised until Russia ceases its war of aggression against Ukraine and
compensates it for the damage caused by this war. Additionally, Council Regulation (EU)
2025/26002 temporarily prohibits the transfer of assets or reserves of the Central Bank of
Russia until Russia ceases its war of aggression against Ukraine, Russia provides reparations
to Ukraine to the extent necessary to allow for reconstruction without adverse economic or
financial consequences for the Union, and Russia’s actions in the context of its war of
aggression against Ukraine have objectively ceased to pose a serious risk of severe difficulties
to the economy of the Union and its Member States.
In that context, on 18 December 2025, the European Council has agreed to provide a loan to
Ukraine of EUR 90 billion for the years 2026-2027 based on EU borrowing on the capital
markets backed by the EU budget headroom. The European Council also agreed that by
means of enhanced cooperation (Article 20 TEU) in respect of the instrument based on Article
212 TFEU, any mobilisation of resources of the Union’s budget as a guarantee for this loan
will not have an impact on the financial obligations of the Czech Republic, Hungary and
Slovakia. On the same date, 25 Member States have agreed that this loan would be repaid by
Ukraine only once reparations are received and that until then, Russian Central Bank assets
will remain immobilised and the Union reserves its right to make use of them to repay the
loan, in full accordance with EU and international law. Those Member States underlined the
importance of the following elements in relation to the loan: (a) strengthening of the European
and Ukrainian defence industries; (b) Ukraine continuing to uphold the rule of law, including
the fight against corruption; and (c) the specific character of the security and defence policy of
certain Member States and the security and defence interests of all Member States.
Against this background, it is proposed to establish a new support instrument for Ukraine of
up to EUR 90 billion, which Ukraine would only repay once it receives reparations from
Russia (the ‘Ukraine Support Loan’). Following requests from the Kingdom of Belgium, the
Republic of Bulgaria, the Kingdom of Denmark, the Federal Republic of Germany, the
Republic of Estonia, the Republic of Croatia, Ireland, the Hellenic Republic, the French
Republic, the Republic of Cyprus, the Republic of Latvia, the Republic of Lithuania, the
Grand Duchy of Luxembourg, the Republic of Malta, the Kingdom of the Netherlands, the
Republic of Austria, the Republic of Poland, the Portuguese Republic, Romania, the Republic
of Slovenia, the Republic of Finland, the Kingdom of Spain, the Republic of Italy, the
Kingdom of Sweden, an accompanying proposal from the Commission proposes that
enhanced cooperation be authorised for this loan.
A Ukraine Support Loan
2 Council Regulation (EU) 2025/2600 of 12 December 2025 on emergency measures addressing the
serious economic difficulties caused by Russia’s actions in the context of the war of aggression against
Ukraine (OJ L, 2025/2600, 13.12.2025, ELI: http://data.europa.eu/eli/reg/2025/2600/oj).
EN 3 EN
Despite the massive needs of Ukraine, the ability for the Ukrainian state to take on more debt
is severely limited. Ukraine’s debt to GDP has drastically expanded since the start of the war,
jumping from less than 50% of GDP at end 2021 to 85% of GDP in 2025 (more than 100% of
GDP including ERA loans). Given the significant destruction that the war has had on
productivity and the on-going drag that the war has on growth dynamics, the significant
financing needs of Ukraine are not possible to be addressed by Ukraine taking on further debt.
At the same time, Member State’s finances are still recovering from a succession of crises
during the last decade, including the significant expenses generated by Russia’s war in
Ukraine and Russia’s hybrid campaign against the Union. The mobilisation of additional
significant resources by Member States to be able to finance Ukraine would constitute an
important economic challenge.
In this context of difficult debt dynamics of Ukraine due to the on-going Russian aggression
and the challenges associated with Member States finances, including as of Russia’s actions,
it is appropriate to develop an innovative solution that is not expected to place a financial
burden on either Ukraine or Member States.
In line with the International Law Commission’s Draft Articles on the Responsibility of States
for Internationally Wrongful Acts (ARSIWA)3 and customary international law, Russia – as
the responsible state – is under an obligation to make full reparation for the injury caused by
its war of aggression against Ukraine. In particular, Articles 30 – 32 of ARSIWA provide that
“The State responsible for the internationally wrongful act is under an obligation: (a) to
cease that act, if it is continuing; [...]; “The responsible State is under an obligation to make
full reparation for the injury caused by the internationally wrongful act.” “Injury includes
any damage, whether material or moral, caused by the internationally wrongful act of a
State.”
In the context of this legal obligation on Russia to make reparations for the damage that it has
caused through its illegal war of aggression, it is appropriate for the Union to provide the
Ukraine Support Loan as a limited recourse loan that will become due and payable when
Ukraine receives from Russia cash or non-monetary assets as war reparations, indemnities or
any financial settlement from Russia, other than territory.
Use of funds
Given Ukraine’s financing needs and the considerable uncertainty on the future of the war, it
is critical that the Ukraine Support Loan is designed in a flexible manner that is reactive to the
situation. There should be flexibility to use the money towards the most pressing financing
needs, whether driven by the current war situation or also to support reconstruction should
peace prevail.
This proposal provides for a Ukraine Support Loan that will be delivered in a predictable,
continuous, orderly, flexible and timely manner with a view to supporting Ukraine in
covering its financing and defence needs in 2026 and 2027, in particular those resulting from
Russia’s war of aggression. Specifically, the Ukraine Support Loan should support macro-
financial stability in Ukraine and ease its external financing constraints, whether driven by
war or by reconstruction, and support Ukraine’s defence industrial capacities through
economic, financial and technical cooperation.
3 Articles on Responsibility of States for Internationally Wrongful Acts, 2001, International Law
Commission.
EN 4 EN
To support macro-financial stability in Ukraine and ease its external financing constraints, the
proposal creates multiple options via which the funds can be channelled to support Ukraine,
where support would be able to be provided through macro-financial assistance and through
the Ukraine Facility. Under both instruments, disbursements will be linked to preconditions
and policy conditions. For macro-financial assistance, those conditions would be set out in a
memorandum of understanding (MoU) between the Commission and Ukraine including
conditions to strengthen revenue mobilisation, tackle root causes of corruption, improving the
sustainability and quality of public expenditure and enhance the efficiency, transparency and
accountability of the public finance management systems. For the Ukraine Facility, the
Ukraine Plan should be updated to reflect these additional amounts, including measures to
strengthen the rule of law and the fight against corruption.
To support Ukraine’s defence industrial capacities through economic, financial and technical
cooperation, the proposal provides for assistance that aims at enabling Ukraine to carry out
urgent and major public investments in support of the Ukrainian defence industry and its
integration into the European defence industry in response to and following the current crisis
situation. In order to urgently reinforce the Ukrainian defence industrial base in an efficient
and autonomous manner, eligibility criteria should be structured in a manner that directs the
activities, expenditures and measures to support Ukraine’s defence industrial capacities
towards the reconstruction, recovery and modernisation of the Ukrainian Defence
Technological and Industrial Base, taking into account its gradual future integration into the
European Defence Technological and Industrial Base. Furthermore, in order to allow Ukraine
to use the financial and economic assistance in the way that is the most adapted to the
circumstances, it is appropriate to allow it to employ the funds to support Ukraine’s defence
industrial capacities by different implementation methods that reflect the diversity of the
needs.
The financial and economic assistance available under the Ukraine Support Loan will be
made accessible to Ukraine in line with its financing needs. To that end, Ukraine will submit a
Ukrainian Financing Strategy on Ukraine’s financing needs and sources. Upon assessment of
the Commission, the Council would approve that assessment and determine the amount of
assistance to be made accessible to Ukraine to assist in the implementation of the Ukrainian
Financing Strategy.
• Consistency with existing policy provisions in the policy area
The support under the Ukraine Support Loan will be consistent with and complementary to
the support provided through Regulation (EU) 2024/7924, Regulation (EU) 2021/9475,
Regulation (EC) No 1257/966, Regulation (EC) No 2024/27737 and Regulation (EU)
4 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). 5 Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 2021 establishing
the Neighbourhood, Development and International Cooperation Instrument – Global Europe,
amending and repealing Decision No 466/2014/EU of the European Parliament and of the Council and
repealing Regulation (EU) 2017/1601 of the European Parliament and of the Council and Council
Regulation (EC, Euratom) No 480/2009 (Text with EEA relevance) (OJ L 209, 14.6.2021, p. 1, ELI:
http://data.europa.eu/eli/reg/2021/947/2021-06-14). 6 Council Regulation (EC) No 1257/96 of 20 June 1996 concerning humanitarian aid (OJ L 163,
2.7.1996, p. 1, ELI: http://data.europa.eu/eli/reg/1996/1257/2019-07-26). 7 Regulation (EU) 2024/2773 of the European Parliament and of the Council of 24 October 2024
establishing the Ukraine Loan Cooperation Mechanism and providing exceptional macro-financial
assistance to Ukraine (OJ L, 2024/2773, 28.10.2024, ELI: http://data.europa.eu/eli/reg/2024/2773/oj).
EN 5 EN
2025/11068, and is in line with the respective objectives, intervention logic and rules of these
instruments.
In particular, the Ukraine Support Loan comes in addition and is complementary to the
support provided by the EU under the G7 ERA Loans initiative and the Ukraine Facility.
Specific attention is paid to the consistency and mutual reinforcement of the Ukraine Support
Loan and the implementation of defence policies, provided under the SAFE Regulation and
the proposed EDIP Regulation.
• Consistency with other Union Policies
The support under the Ukraine Support Loan initiative is consistent with the application of
restrictive measures (sanctions) against Russia and complementary to the European Peace
Facility.
Furthermore, the candidate status granted by the European Council on 23 June 2022 and the
decision of the 14-15 December 2023 European Council to open accession negotiations with
Ukraine anchors Ukraine firmly on its European path. For this reason, the whole EU response
in support of Ukraine’s resilience and recovery – including through the Ukraine Support
Loan, which will in turn be consistent with and supporting the implementation of the Ukraine
Facility – will also contribute to the early phase of Ukraine’s pre-accession process.
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
• Legal basis
Article 212 TFEU is an appropriate legal basis for financial assistance programmes granted by
the Union for third countries, which are not developing countries.
• Subsidiarity (for non-exclusive competence)
The subsidiarity principle is respected as the need for a common response in providing
support to Ukraine on adequate scale cannot be sufficiently achieved by the Member States
alone and, by reasons of its scale and effect, can be better achieved by the EU. The main
reasons are the fiscal capacity and budgetary constraints faced at the national level and the
need for strong donor coordination in order to maximise the scale and effectiveness of the
support, while limiting the burden on the administrative capacity of Ukrainian authorities,
which is very stretched in the current circumstances. The EU is in a unique position to deliver
external assistance to Ukraine to provide support in covering urgent budgetary needs in a
predictable, continuous, orderly and timely manner, including those linked to supporting
Ukraine’s defence industrial capacities.
• Proportionality
The continued unprovoked and unjustified military aggression by Russia requires granting
additional financial assistance to Ukraine in line with the objectives and modalities described
under this proposal.
The proposed financial support to Ukraine is considered adequate in size for 2026 and 2027,
based on the elevated funding needs and best estimates of Ukraine’s defence needs submitted
by the national authorities, while taking into account the high uncertainty of the war
8 Council Regulation (EU) 2025/1106 of 27 May 2025 establishing the Security Action for Europe
(SAFE) through the Reinforcement of the European Defence Industry Instrument (OJ L, 2025/1106,
28.5.2025, ELI: http://data.europa.eu/eli/reg/2025/1106/oj).
EN 6 EN
circumstances. Such support does not go beyond what is necessary for the sought purpose to
provide structured support to Ukraine and its related financing.
The proposal is proportionate to the scale and gravity of the deficiencies that have been
identified, including the need to provide budget support to Ukraine, and the need to carry out
urgent and major public investments in support of the Ukrainian Defence Technological and
Industrial Base and its integration into the European Defence Technological and Industrial
Base. The proposal respects the limits of possible Union intervention under the Treaties.
• Choice of the instrument
A Regulation of the European Parliament and of the Council is the appropriate instrument as
it provides directly applicable rules for the implementation of the Ukraine Support Loan.
3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER
CONSULTATIONS AND IMPACT ASSESSMENTS
• Ex-post evaluations/fitness checks of existing legislation
The proposal follows a series of macro-financial assistance operations provided to Ukraine
since 2015. Past ex-post evaluations of previous macro-financial assistance operations to
Ukraine have shown that in general they were highly relevant in terms of their objectives,
financial envelope and policy conditions. In particular, macro-financial assistance operations
proved crucial to support Ukraine in addressing its balance-of-payment problems and
implementing key structural reforms to stabilise the economy and enhance the sustainability
of its external position. They allowed for fiscal savings and financial benefits and acted as a
catalyst for additional financial support and investor confidence. The conditionality attached
to the macro-financial assistance operations was found complementary to the related IMF
programmes. It created a politically reinforcing effect that contributed to the mobilisation of
the Ukrainian authorities around essential reforms, especially in structural policy areas that
are less covered by other international donor programmes.
• Stakeholder consultations
The proposal follows up on the European Council conclusions of 18 December 2025 where
the European Council agreed to provide a loan to Ukraine of EUR 90 billion for the years
2026-2027 based on EU borrowing on the capital markets backed by the EU budget
headroom. In the preparation of this proposal, the Commission services have consulted with
international financial institutions and other bilateral (including Member States and G7
members) and multilateral donors. The Commission is also in regular contact with the
Ukrainian authorities.
Due to the urgency of preparing the proposal for timely adoption by the co-legislators and
ensuring its operational status by early 2026, a formal stakeholder consultation could not be
conducted. This approach aims to address the emerging and escalating defence and budgetary
demands resulting from Russia’s war of aggression. These needs encompass efforts related to
recovery and reconstruction. The European Union will ensure adequate communication and
visibility regarding the objectives and actions implemented under the scope of the Ukraine
Support Loan, both within Ukraine, across the Union, and internationally.
• Collection and use of expertise
The proposal builds on decades long experience with macro-financial assistance as well as on
experience with the Union’s external action support, including the Ukraine Facility since
2024.
EN 7 EN
The Commission based this proposal on a careful analysis, also building on inputs from
international financial institutions and other competent international institutions, of the
defence needs and broader macro-economic situation of Ukraine. This includes discussions on
a regular basis of the latest projections of Ukraine’s funding needs within international fora,
such as the G7 and the IMF, as well as continuous direct contact with the Ukrainian
authorities.
• Impact assessment
Due to the urgent nature of the proposal, which is designed to provide urgent assistance to a
country at war, no impact assessment could be carried out. The ex-ante assessment of needs
proposed to be covered by the Ukraine Support Loan inter alia draw upon recent data from
the IMF and Ukrainian authorities. The support under the Ukraine Support Loan should build
upon the lessons learned and achievements of recent support initiatives, such as the G7 ERA
Loans initiative.
• Regulatory fitness and simplification
The proposal is not linked to regulatory fitness and simplification.
• Fundamental rights
A precondition for granting support under the Ukraine Support Loan is that Ukraine continues
to uphold and respect effective democratic mechanisms and its institutions, including a multi-
party parliamentary system, and the rule of law, and to guarantee respect for human rights,
including those of persons belonging to minorities. Upholding and respecting the rule of law
should include the fight against corruption.
The reform-commitment and political will by the Ukrainian authorities is a positive sign, in
particular as evidenced by the European Council granting candidate status to Ukraine in June
2022 and the European Council decision of December 2023 to open accession negotiations
with Ukraine, by the renewed successful completion of the structural policy conditionality
attached to the recent macro-financial assistance operations to Ukraine and the continuing
implementation of the Ukraine Plan. On 14 May 2025, Ukraine adopted roadmaps on (among
others) the rule of law, public administration reform and on the functioning of democratic
institutions. Bilateral screening meetings were completed in September 2025. Since the
Russian aggression, the Ukrainian authorities have shown an impressive degree of resilience
and have remained committed to pursue these reforms in a transparent manner and working
towards EU standards and in line with the country’s path towards EU integration.
In view of this, the precondition for the Ukraine Support Loan is considered to be met at
present. Concurrently, the continuous adherence to this precondition will be further ensured
by specific conditions relating to the Commission’s assessment of future Ukrainian Financing
Strategies and before disbursements. A similar precondition for support is applicable to the
implementation of the Ukraine Plan.
4. BUDGETARY IMPLICATIONS
The Ukraine Support Loan will take the form of a limited recourse loan to Ukraine of up to
EUR 90 billion to be repaid by reparations due by Russia. The loan will be based on EU
borrowing on the capital markets backed by the EU budget headroom. The Union budget will
also cover the debt service costs (cost of funding and costs of issuing and managing liquidity)
related to the borrowing as well the associated administrative costs. To cater for these
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elements, the Regulation on the multiannual financial framework for 2021-2027 will be
revised.
The debt service costs will be financed by a new special instrument over and above the MFF
expenditure ceilings, the Ukraine Loan Instrument, which may be mobilised solely for this
purpose. When mobilising the Ukraine Loan Instrument in the framework of the budgetary
procedure, budgetary availabilities in other special instruments, applicable sectoral rules, any
legal or other obligations including under the EURI Instrument, priorities, prudent budgeting
and sound financial management will be considered.
This loan will be financed under enhanced cooperation, which in accordance with Article 332
of the Treaty on the Functioning of the European Union implies that the resulting
expenditures, other than administrative costs entailed for the institutions, shall be borne by the
participating Member States.
A new budget line will be created to clearly and transparently identify the expenditure related
to the debt service costs resulting from the enhanced cooperation. The methodology to
calculate the contributions of participating Member States is defined in Article 11 of the
Making Available Regulation (Regulation EU, Euratom No 609/2014). Similarly, should the
EU budget guarantee be called, the amounts will be mobilised over and above the MFF
expenditure ceilings and the financial contributions will be borne by participating Member
States, calculated with the same methodology.
Details on the budgetary implications are provided in the Legislative Financial Statement
attached to this proposal.
5. OTHER ELEMENTS
• Implementation plans and monitoring, evaluation and reporting arrangements
The Ukraine Support Loan will be for a maximum amount of EUR 90 billion, to be made
available in accordance with Ukraine’s financing needs per the provisions of this proposal.
Specifically, for the purposes of implementing the Ukraine Support Loan Regulation, Ukraine
is to submit to the European Commission a Ukrainian Financing Strategy providing details on
Ukraine’s financing needs and financing sources in principle for the forthcoming 12 months.
The Commission is to assess the Ukrainian Financing Strategy and, in case of a positive
assessment, submit a proposal to the Council for the approval of its assessment by means of
an implementing decision. The Commission’s proposal will outline the amount of assistance
to be made available to Ukraine to assist in the implementation of the Ukrainian Financing
Strategy, including the amount of that assistance accessible for (i) assistance through the
Ukraine Facility, (ii) macro-financial assistance and (iii) assistance to support Ukraine’s
defence industrial capacities.
To receive financial and economic assistance under the Ukraine Support Loan, Ukraine will
submit to the Commission a duly justified request for funds, which may be submitted by
Ukraine to the Commission, in principle, six times a year.
Furthermore, the Commission will submit to the European Parliament and to the Council a
report on the implementation of the Ukraine Support Loan Regulation in the preceding year,
which will include an evaluation of that implementation. Additionally, by 30 June 2029, the
Commission will submit to the European Parliament and to the Council an evaluation report,
assessing the results and efficiency of the Ukraine Support Loan provided under the Ukraine
Support Loan Regulation and the extent to which it has contributed to the aims of the
assistance.
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Finally, in order to enhance the dialogue between the Union institutions, in particular the
European Parliament, the Council and the Commission, and to ensure greater transparency
and accountability, the competent committee of the European Parliament may invite the
Commission to discuss the implementation of this Regulation.
• Detailed explanation of the specific provisions of the proposal
Chapter I of the Regulation concerns its general provisions.
Article 1 provides the subject matter of the Regulation, which is the establishment of the
Ukraine Support Loan.
Article 2 defines the general and specific objectives of the Ukraine Support Loan, which are
to provide financial and economic assistance to Ukraine in a predictable, continuous manner,
through supporting Ukraine’s macro-financial stability and defence industrial capacities.
Article 3 provides the definitions applicable under the Regulation.
Article 4 sets the available assistance under the Ukraine Support Loan.
Article 5 prescribes the preconditions for assistance under the Ukraine Support Loan.
Chapter II of the Regulation concerns the implementation of the Ukraine Support Loan.
Article 6 stipulates that Ukraine shall submit to the Commission the Ukrainian Financing
Strategy, providing details on its contents, with specific reference to Ukraine’s needs and
financing resources for the next 12 months.
Article 7 provides for the assessment by the Commission of the Ukrainian Financing Strategy,
defining the necessary criteria to be observed.
Article 8 provides for a Council implementing decision making the financial and economic
assistance accessible.
Article 9 provides for the close cooperation between the Commission, Ukraine, Member
States, relevant international bodies and donors to Ukraine to ensure a coherent and consistent
approach to address Ukraine’s financial and economic assistance needs.
Chapter III of the Regulation concerns the Macro-Financial Assistance.
Article 10 provides for the purpose of macro-financial assistance, notably to contribute to
covering Ukraine’s financing gap as identified in a positively assessed Ukrainian Financing
Strategy.
Article 11 sets out that the Commission shall agree with Ukraine on the policy conditions to
which the support is to be linked, which shall be described in a memorandum of
understanding.
Chapter IV of the Regulation concerns assistance to support Ukraine’s Defence Industrial
Capacities.
Article 12 provides for the purpose of the assistance to support Ukraine’s defence industrial
capacities, notably to carry out urgent and major public investments in support of the
Ukrainian defence industry and its integration into the European defence industry.
Article 13 defines the eligibility conditions for the activities, expenditures and measures to
support Ukraine’s defence industrial capacities.
Article 14 requires Ukraine to produce a schedule for each activity, expenditure or measure
related to a defence product or other product for defence purposes for which it intends to
request assistance.
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Article 15 prescribes the establishment of the Ukraine’s Defence Industrial Capacities Expert
Group.
Article 16 provides for the opening of a special account for the sole purpose of the
management of the financial and economic assistance received by Ukraine to support its
defence industrial capacities.
Article 17 sets out the monitoring requirements for the assistance provided to support
Ukraine’s defence industrial capacities.
Article 18 defines the conditions for the modification of an existing framework agreement or
contract for defence products.
Article 19 allows for Member States, for the sole purpose of the Regulation, to request an
economic operator on its territory, to prioritise certain order of defence products.
Chapter V of the Regulation concerns the financing and implementation of the Ukraine
Support Loan.
Article 20 stipulates that the detailed financial terms of the Ukraine Support Loan shall be laid
down in the Ukraine Support Loan Agreement and sets out certain mandatory requirements.
Article 21 sets out that in order for Ukraine to receive financial and economic assistance, it
shall submit to the Commission a duly justified request for funds.
Article 22 provides for a borrowing cost subsidy for the Ukraine Support Loan.
Article 23 prescribes the requirements on the Commission for making a decision to release an
instalment under the Ukraine Support Loan.
Article 24 empowers the Commission to borrow the necessary funds, on behalf of the Union,
to finance the Ukraine Support Loan.
Article 25 lays out the rules on classified information and sensitive information.
Chapter VI concerns final provisions.
Article 26 empowers the Commission to adopt delegated acts, subject to conditions.
Article 27 regulates the governance through committee procedures.
Article 28 provides for a Ukraine Support Loan dialogue, which foresees to enhance
communication between the Union institutions, in particular the European Parliament, the
Council and the Commission.
Article 29 prescribes the provision of information to the European Parliament and to the
Council.
Article 30 regulates the entry into force.
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2026/0008 (COD)
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
implementing enhanced cooperation on the establishment of the Ukraine Support Loan
for 2026 and 2027
THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular
Article 212 TFEU thereof,
Having regard to Council Decision [XX] of [date] authorising enhanced cooperation on the
establishment of a Loan for Ukraine, and in particular Article 1 thereof,
Having regard to the proposal from the Commission,
After transmission of the draft legislative act to the national parliaments,
Acting in accordance with the ordinary legislative procedure,
Whereas:
(1) On 24 February 2022, the President of the Russian Federation announced a military
operation in Ukraine, and Russia’s armed forces began an unprovoked and unjustified
military aggression against Ukraine. This illegal war of aggression is a blatant
violation of the territorial integrity, sovereignty and independence of Ukraine, as well
as a violation of the prohibition on the use of force enshrined in Article 2(4) of the
United Nations (UN) Charter, which is a peremptory rule of international law, and of
the other principles of the UN Charter.
(2) Since the beginning of Russia’s unprovoked and unjustified war of aggression against
Ukraine, the Union, its Member States and European financial institutions have
mobilised unprecedented support for Ukraine’s economic, social, financial and
defence resilience. That support combines support from the Union budget, including
exceptional macro-financial assistance and support from the European Investment
Bank and the European Bank for Reconstruction and Development, fully or partially
guaranteed by the Union budget, as well as further financial support by Member
States.
(3) Decision (EU) 2022/313 of the European Parliament and the Council9, Decision (EU)
2022/1201 of the European Parliament and the Council10, Decision (EU) 2022/1628 of
the European Parliament and the Council11 and Regulation (EU) 2022/2463 of the
9 Decision (EU) 2022/313 of the European Parliament and of the Council of 24 February 2022 providing
macro-financial assistance to Ukraine (OJ L 55, 28.2.2022, p. 4, ELI:
http://data.europa.eu/eli/dec/2022/313/oj). 10 Decision (EU) 2022/1201 of the European Parliament and of the Council of 12 July 2022 providing
exceptional macro-financial assistance to Ukraine (OJ L 186, 13.7.2022, p. 1, ELI:
http://data.europa.eu/eli/dec/2022/1201/oj). 11 Decision (EU) 2022/1628 of the European Parliament and of the Council of 20 September 2022
providing exceptional macro-financial assistance to Ukraine, reinforcing the common provisioning fund
EN 2 EN
European Parliament and the Council12 collectively made available EUR 25.2 billion
of macro-financial assistance to Ukraine throughout 2022 and 2023. This support
constituted a major contributing factor to Ukraine’s macroeconomic and financial
resilience at a critical time.
(4) On 29 February 2024, Regulation (EU) 2024/792 of the European Parliament and of
the Council13 established the Ukraine Facility as an exceptional medium-term
instrument that brings together the bilateral support provided by the Union to Ukraine,
ensuring coordination and efficiency (the ‘Ukraine Facility’). Over the period 2024 to
2027, the Ukraine Facility helps address Ukraine’s financing needs and contributes to
its recovery, reconstruction and modernisation needs, while at the same time
supporting Ukraine’s reforms effort as part of its path towards accession to the Union.
(5) On 24 October 2024, Regulation (EU) 2024/2773 of the European Parliament and the
Council14 established the Ukraine Loan Cooperation Mechanism and provided
exceptional macro-financial assistance to Ukraine. That assistance was the Union
contribution as part of the G7 ‘Extraordinary Revenue Acceleration Loans for
Ukraine’ initiative, which collectively assisted in addressing Ukraine’s financing gap
for 2025.
(6) Russia’s war of aggression against Ukraine has caused tremendous damage in
Ukraine, with estimated recovery and reconstruction costs of EUR 506 billion as of 31
December 2024. Moreover, Ukraine has lost access to international financial markets
and experienced a significant drop in public revenue, while public expenditure has
increased substantially. Against that background, substantive funding needs for the
coming years can be foreseen.
(7) On 9 September 2025, Ukraine submitted an official request to the International
Monetary Fund (IMF) for a new programme to cover additional financing needs from
2026 to 2029. That programme would succeed the successful implementation of the
existing IMF programme, where Ukraine completed eight reviews, but takes into
consideration that Russia’s war of aggression has continued. The IMF’s ability to
proceed with this programme is contingent upon receiving sufficient financing
assurances from other partners, including the European Union.
(8) Despite ongoing international efforts to broker a peaceful resolution to the conflict, the
prolongation of Russia's war of aggression has resulted in significant damage to
Ukraine's critical defence, civilian and energy infrastructure, necessitating the
mobilisation of substantial additional resources to address the country's immediate
financing needs.
by guarantees by Member States and by specific provisioning for some financial liabilities related to
Ukraine guaranteed under Decision No 466/2014/EU, and amending Decision (EU) 2022/1201 (OJ L
245, 22.9.2022, p. 1, ELI: http://data.europa.eu/eli/dec/2022/1628/oj). 12 Regulation (EU) 2022/2463 of the European Parliament and of the Council of 14 December 2022
establishing an instrument for providing support to Ukraine for 2023 (macro-financial assistance +) (OJ
L 322, 16.12.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/2463/oj). 13 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). 14 Regulation (EU) 2024/2773 of the European Parliament and of the Council of 24 October 2024
establishing the Ukraine Loan Cooperation Mechanism and providing exceptional macro-financial
assistance to Ukraine (OJ L, 2024/2773, 28.10.2024, ELI: http://data.europa.eu/eli/reg/2024/2773/oj).
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(9) Russia’s war of aggression against Ukraine represents a strategic geopolitical threat to
the Union as a whole and requires Member States to stand strong and united. It is
therefore essential that Union support be deployed rapidly and be able to adapt
flexibly for immediate relief and short-term rehabilitation on the way to future
reconstruction.
(10) In line with the Articles on the Responsibility of States for Internationally Wrongful
Acts and customary international law, Russia – as the responsible state – is under an
obligation to make full reparation for the injury caused by its war of aggression.
(11) Decision (CFSP) 2022/335 of 28 February 2022 amending Decision 2014/512/CFSP
concerning restrictive measures in view of Russia’s actions destabilising the situation
in Ukraine15 and Council Regulation (EU) 2022/334 of 28 February 2022 amending
Council Regulation (EU) No 833/201416 prohibits transactions related to the
management of reserves as well as of assets of the Central Bank of Russia including
transactions with any legal person, entity or body acting on behalf of, or at the
direction of, the Central Bank of Russia. In its conclusions of 27 June 2024, 17
October 2024 and 19 December 2024, the European Council has stated that, subject to
Union law, Russia’s assets should remain immobilised until Russia ceases its war of
aggression against Ukraine and compensates it for the damage caused by this war.
(12) Additionally, Council Regulation (EU) 2025/260017 prohibits the transfer of assets or
reserves of the Central Bank of Russia on a temporary basis until Russia ceases its war
of aggression against Ukraine; Russia provides reparations to Ukraine to the extent
necessary to allow for reconstruction without adverse economic or financial
consequences for the Union; and Russia’s actions in the context of its war of
aggression against Ukraine have objectively ceased to pose a serious risk of severe
difficulties to the economy of the Union and its Member States.
(13) On 18 December 2025, the European Council has agreed to provide a loan to Ukraine
of EUR 90 billion for the years 2026 and 2027 based on Union borrowing on the
capital markets backed by the Union budget headroom. The European Council also
agreed that by means of enhanced cooperation in accordance with Article 20 of the
Treaty on European Union, any mobilisation of resources of the Union’s budget as a
guarantee for this loan should not have an impact on the financial obligations of the
Czech Republic, Hungary and Slovakia. On the same date, 25 Member States have
agreed that this loan should be repaid by Ukraine only once reparations are received.
Until then, the assets of the Central Bank of Russia should remain immobilised and the
Union should reserve its right to make use of them to repay the loan, in full
accordance with EU and international law. Those Member States underlined the
importance of the following elements in relation to the loan: (a) strengthening of the
European and Ukrainian defence industries; (b) Ukraine continuing to uphold the rule
of law, including the fight against corruption; and (c) the specific character of the
15 Council Decision (CFSP) 2022/335 of 28 February 2022 amending Decision 2014/512/CFSP
concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (OJ L
57, 28.2.2022, p. 4, ELI: http://data.europa.eu/eli/dec/2022/335/oj). 16 Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No
833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in
Ukraine (OJ L 57, 28.2.2022, p. 1, ELI: http://data.europa.eu/eli/reg/2022/334/oj). 17 Council Regulation (EU) 2025/2600 of 12 December 2025 on emergency measures addressing the
serious economic difficulties caused by Russia’s actions in the context of the war of aggression against
Ukraine (OJ L, 2025/2600, 13.12.2025, ELI: http://data.europa.eu/eli/reg/2025/2600/oj).
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security and defence policy of certain Member States and the security and defence
interests of all Member States.
(14) On [DATE], the Council adopted Decision [XX] authorising enhanced cooperation
between Belgium, Bulgaria, Denmark, Germany, Estonia, Ireland, Greece, Spain,
France, Italy, Croatia, Cyprus, Latvia, Lithuania, Luxembourg, Malta, Netherlands,
Austria, Poland, Portugal, Romania, Slovenia, Finland and Sweden on the
establishment of a Loan for Ukraine.
(15) Given the financing position of Ukraine, the criticality that Ukraine has the resources
to counter Russia’s aggression and, where possible, reconstruct, it is appropriate that
the Union provide additional support to address Ukraine's urgent financing
requirements and facilitate the implementation of the IMF programme. To that end, it
is appropriate to establish an instrument for providing Union support to Ukraine in
2026 and 2027 in the form of a loan to be repaid by reparations due by Russia (the
‘Ukraine Support Loan’).
(16) The Ukraine Support Loan should provide financial assistance to Ukraine in a
predictable, continuous, orderly, flexible and timely manner with a view of supporting
Ukraine in covering its financing and defence needs, in particular those resulting from
Russia’s war of aggression. Specifically, the Ukraine Support Loan should support
macro-financial stability in Ukraine and ease its external financing and support
Ukraine’s defence industrial capacities through economic, financial and technical
cooperation, thereby contributing to providing Ukraine a Qualitative Military Edge.
(17) The Ukraine Support Loan should, subject to conditions, provide support to Ukraine in
the form of a loan of up to EUR 90 000 000 000. In view of the principle of sound
financial management, the Ukraine Support Loan should be made available by the
Commission in instalments, which may be disbursed in one or more tranches.
(18) The support to Ukraine under the Ukraine Support Loan should be made available
under the precondition that 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 those of persons belonging
to minorities. Upholding and respecting the rule of law should include the fight against
corruption.
(19) The financial and economic assistance available under the Ukraine Support Loan
should be made accessible to Ukraine in line with its financing needs. To that end,
Ukraine should submit a Ukrainian Financing Strategy on its financing needs and
sources. That Ukrainian Financing Strategy should contain the main information on
Ukraine’s budget, financial and economic situation, as well as the support that Ukraine
is receiving from the international community.
(20) The Commission should assess the Ukrainian Financing Strategy without undue delay
and should act in close cooperation with Ukraine. Given the significant scale of
Ukraine’s needs for both budget assistance and assistance for defence industrial
capacities, as well as the constraints that some external partners have on the provision
of their support, it is appropriate to establish an indicative distribution of the Ukraine
Support Loan between those two financing needs. Whilst ensuring that Ukraine’s
financing needs as calculated by the IMF for 2026 are fully addressed, that distribution
should be indicative in order to reflect changing circumstances that may impact
Ukraine’s financing needs and to ensure that those needs continue to be addressed in a
predictable, continuous, orderly, flexible and timely manner. In its assessment of the
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Ukrainian Financing Strategy, the Commission should consider the consistency of the
expected external financing gap with that indicative distribution.
(21) In view of the importance of the financial effects of the measures imposed,
implementing powers should be conferred on the Council which should act on the
basis of a Commission proposal. The Council should approve the assessment of the
Ukrainian Financing Strategy by means of an implementing decision, which it should
endeavour to adopt without undue delay from the adoption of the proposal. That
implementing decision should determine the amount of assistance to be made
accessible to Ukraine to assist in the implementation of the Ukrainian Financing
Strategy, including the amount for budget assistance and the amount for supporting
Ukraine’s defence industrial capacities.
(22) Financial and economic assistance in the form of budget assistance should be made
available in view of supporting Ukraine in covering its financing needs. The financial
and economic assistance under this Regulation provides important input into Ukraine’s
post-war economic recovery, long-term growth and prosperity all of which will have
an important role to play in a future peace agreement. To ensure flexibility in
addressing those needs, it is appropriate to use multiple means of delivery, where
support should be able to be provided through macro-financial assistance and through
a loan to be implemented pursuant to Chapter III of the Ukraine Facility.
(23) Chapter III of the Ukraine Facility provides for financing to Ukraine upon satisfactory
fulfilment of the conditions laid down in the Ukraine Plan, which sets out the reform
and investment agenda of Ukraine. As a medium-term instrument that has the
objective to support Ukraine’s recovery and reconstruction, gradual integration into
the internal market, as well as, inter alia, the adoption and implementation of the
political, institutional, legal, administrative, social and economic reforms required to
align to Union values and to progressively align to Union rules, standards, policies and
practices (‘acquis’) with a view to future Union membership, thereby contributing to
mutual stability, security, peace, prosperity and sustainability, it is appropriate to
provide for amounts stemming from the Ukraine Support Loan to be utilised through
the Ukraine Facility. The Ukraine Plan should be updated to reflect these this
additional budget assistance, including measures to strengthen the rule of law and the
fight against corruption.
(24) Macro-financial assistance should be linked to policy conditions to be set out in the
MoU. The MoU should include robust and ambitious reform commitments by
Ukraine, including those to strengthen revenue mobilisation to support Ukraine’s
financing needs and tackle the root causes of corruption in public finances, including
via improving the sustainability and quality of public expenditure and enhancing the
efficiency, transparency and accountability of the public finance management systems.
Such macro-financial assistance may be used by Ukraine to assist in the financing of
compensation, as a form of reparations, to those individuals who have suffered
damage from the illegal actions of Russia, including through the Claims Commission
for Ukraine established under the auspices of the Council of Europe. The Council
implementing decision approving the assessment of the Ukrainian Financing Strategy
should establish the maximum number and indicative value of instalments for the
macro-financial assistance. In view of the principle of sound financial management
and to facilitate the Ukrainian authorities’ liquidity management and ensure
predictability, there should, in principle, be a maximum of four instalments of that
macro-financial assistance.
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(25) In order to ensure uniform conditions for the implementation of this Regulation, and
for reasons of efficiency, the Commission should be empowered to negotiate
conditions for the macro-financial assistance with the Ukrainian authorities under the
supervision of the committee of representatives of the Participating Member States in
accordance with Regulation (EU) No 182/2011 of the European Parliament and of the
Council18. Considering the potentially significant impact of assistance, it is appropriate
that the examination procedure as specified in Regulation (EU) No 182/2011 be used.
Considering the amount of the Ukraine Support Loan, the examination procedure
should apply to the adoption of the MoU and to any reduction or cancellation of the
Ukraine Support Loan.
(26) The Ukraine Support Loan should provide financial and economic assistance to
Ukraine as a country at war, the financial stability of which is intrinsically linked to
and depends on its ability to defend itself against the aggression. This justifies that a
specific amount of the financial and economic assistance to Ukraine is used to increase
Ukraine’s capacity to cope with budgetary needs in relation with the capacity of the
country to strengthen its defence and military capabilities, thereby contributing to
providing Ukraine a qualitative military edge. This financial and economic assistance
should aim at enabling Ukraine to carry out urgent and major public investments in
support of the Ukrainian defence industry and its integration into the European
defence industry in response to and following the current crisis situation. This
assistance should contribute, in particular, to the reconstruction, recovery and
modernisation of the Ukrainian Defence Technological and Industrial Base, with a
view to increasing its defence industrial readiness, taking into account its gradual
future integration into the European Defence Technological and Industrial Base and
through support for the timely availability of defence products and other products for
defence purposes, through cooperation between the Union and Ukraine.
(27) Financial and economic assistance to support Ukraine’s defence industrial capacities
should be made available for activities, expenditures and measures related to defence
products or other products for defence purposes that meet certain eligibility criteria. In
order to urgently reinforce the Ukrainian defence industrial base in an efficient and
autonomous manner, those eligibility criteria should be structured in a manner that
directs the activities, expenditures and measures to support Ukraine’s defence
industrial capacities towards the reconstruction, recovery and modernisation of the
Ukrainian Defence Technological and Industrial Base, taking into account its gradual
future integration into the European Defence Technological and Industrial Base. In
that context, when examining whether manufacturers are controlled by third countries
or third-country entities, control should be understood as the ability to exercise a
decisive influence over a legal entity, directly or indirectly, through one or more
intermediate legal entities.
(28) In order to allow Ukraine to use the financial and economic assistance in the way that
is the most adapted to the circumstances, it is appropriate to allow it to employ the
funds to support Ukraine’s defence industrial capacities by different implementation
methods that reflect the diversity of the needs. The funds may also contribute to the
Ukraine Support Instrument under Regulation (EU) [the EDIP Regulation], the
18 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011
laying down the rules and general principles concerning mechanisms for control by the Member States
of the Commission’s exercise of implementing powers (OJ L 55, 28.2.2011, p. 13,
ELI: http://data.europa.eu/eli/reg/2011/182/oj).
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Ukraine Investment Framework established by the Ukraine Facility for dual-use goods
or other Union programmes. Moreover, the funds should allow Ukraine to engage in a
massive intervention in the demand of defence products in order to create the suitable
conditions to incentivise massive investments in the ramp up of the production
capacity and in the development of new products. To this purpose, Ukraine should be
allowed to use the funds to launch massive procurements of defence products made
from the Ukrainian Defence Technological and Industrial Base and the European
Defence Technological and Industrial Base via procurements under the SAFE
Instrument set out by Council Regulation (EU) 2025/110619 or, subject to validations,
under other modalities.
(29) For certain defence products whose underlying technologies are not widely available
in the Union and which may be difficult to substitute at a large scale, such as air and
missile defence systems and strategic enablers additional conditions should be
required in order to ensure Ukraine’s armed forces freedom related to those products
without limitations imposed by third countries. Therefore, for such defence products,
the manufacturer should have the ability to decide, without any restriction being
imposed by third countries or third-country entities, on the definition, adaptation or
evolution of the design of the defence products procured, including the legal authority
to substitute or remove those components that are subject to restrictions imposed by
third countries or by third-country entities.
(30) To ensure a smooth implementation of this Regulation in conjunction with the SAFE
Instrument, it is appropriate to apply similar eligibility conditions. The SAFE
instrument supports the procurement of defence products as identified in the SAFE
regulation. The list of products being part of Category 1 and 2 has been agreed by the
Council, and it has proven comprehensive enough to allow support for the
procurement of products needed by Member States, including air platforms. Given the
constantly evolving situation on the battlefield, it is essential to avoid that the
existence of a list of products that can be supported constrains Ukraine in getting the
assistance it needs. Taking into account the fact that Ukraine is a country at war whose
capacity to defend its territory might depend on the availability of a given product at
very short term, Ukraine should be allowed to procure products which do not comply
with these eligibility conditions where there is an urgent need for a product and where
no alternative product is available by procurement. To that end, Ukraine should
provide to the Commission the information reasonably available to it to demonstrate
that a derogation is necessary, where whilst the war is ongoing, when Ukraine’s needs
are as such urgent, it should not require extensive market research. In order to ensure
uniform conditions for the implementation of this Regulation, and for reasons of
efficiency, the Commission should be empowered to examine such requests for
derogations under the supervision of the committee of representatives of the
Participating Member States in accordance with Regulation (EU) No 182/2011.
Considering the potentially significant impact of assistance, it is appropriate that the
examination procedure as specified in Regulation (EU) No 182/2011 be used. Due to
the exceptional situation caused by Russia’s war of aggression and the necessity for
the timely availability of defence products, it is appropriate that the duly justified case
referred to in Article 3(3) of Regulation (EU) No 182/2011 is invoked to allow for an
19 Council Regulation (EU) 2025/1106 of 27 May 2025 establishing the Security Action for Europe
(SAFE) through the Reinforcement of the European Defence Industry Instrument (OJ L, 2025/1106,
28.5.2025, ELI: http://data.europa.eu/eli/reg/2025/1106/oj).
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opinion of the committee within a time limit which the chair of the committee may lay
down according to the urgency of the matter. Where necessary, the written procedure
referred to in Article 3(5) of that Regulation should be used.
(31) To further ensure a smooth implementation of Regulation in conjunction with the
SAFE Instrument, it is appropriate that there is the possibility to extend eligibility
conditions to manufacturers within third countries that have concluded an agreement
with the Union in accordance with Article 17 of Council Regulation 2025/1106.
(32) This Regulation is without prejudice to applicable international law prohibiting the
use, development or production of certain defence products and technologies.
(33) The implementation of the assistance to support Ukraine’s defence industrial
capacities should be carried out in line with the principles of sound financial
management ensuring the protection of the financial interests of the Union as set out in
Article 223(4) of Regulation (EU, Euratom) 2024/2509 of the European Parliament
and the Council20. Detailed requirements in this respect might be entered into an
arrangement to be signed between the Commission and Ukraine. Furthermore, for the
management of the financial and economic assistance received to support Ukraine’s
defence industrial capacities, Ukraine should open a single account via which to
manage the assistance, where the Commission should be able to monitor that account.
(34) To support the implementation of assistance to support Ukraine’s defence industrial
capacities, the Commission should establish the Ukraine’s Defence Industrial
Capacities Expert Group. That Expert Group should advise the Commission on
matters related to the assistance to support Ukraine’s defence industrial capacities.
(35) The Commission should monitor the implementation of assistance to support
Ukraine’s defence industrial capacities, notably including the delivery of products. To
that end, various monitoring arrangements should be established to reflect the different
methods of implementation.
(36) Directive 2009/81/EC of the European Parliament and of the Council21 concerns,
amongst other things, the establishment of an appropriate legislative framework on the
coordination of procurement procedures for the award of contracts to meet the security
requirements of Member States and the obligations arising from the TFEU. To achieve
that aim, that Directive 2009/81/EC caters, in particular, for addressing crisis
situations, notably by providing specific provisions applicable in cases of urgency
resulting from a crisis, such as shortening periods for the receipt of tenders and the
possibility to use the negotiated procedure without prior publication of a contract
notice. However, in certain cases of urgency, those rules might be insufficient,
especially where the urgency resulting from the crisis can be addressed only by having
Ukraine and at least one Participating Member State engaging in a common
procurement. In those cases, often the only solution that ensures the security interests
of those countries is to open an existing framework agreement or contract of a
Participating Member State to contracting authorities of Ukraine that was not
20 Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September
2024 on the financial rules applicable to the general budget of the Union (OJ L, 2024/2509, 26.9.2024,
ELI: http://data.europa.eu/eli/reg/2024/2509/oj). 21 Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination
of procedures for the award of certain works contracts, supply contracts and service contracts by
contracting authorities or entities in the fields of defence and security, and amending Directives
2004/17/EC and 2004/18/EC (OJ L 216, 20.8.2009, p. 76, ELI: http://data.europa.eu/eli/dir/2009/81/oj).
EN 9 EN
originally party to it, even though that possibility had not been provided for in the
original framework agreement or contract. As those possibilities are not foreseen in
Directive 2009/81/EC at the moment of the entry into force of this Regulation, the
latter provides for the possibility to complement or derogate from the provisions of
that Directive in the current crisis situation stemming from the war of aggression of
Russia, provided that the agreement of the undertaking which concluded the
framework agreement is obtained. With respect to additional quantities for Ukraine,
Ukrainian contracting authorities should enjoy the same conditions as the original
contracting authority that concluded the original framework agreement. In addition,
appropriate transparency measures should be taken to ensure that all potentially
interested parties are informed.
(37) Council Regulation (EU) 2025/1106 provides for financial assistance to Member
States, enabling them to carry out urgent and major public investments in support of
the European defence industry in response to the crisis situation resulting from the
stark deterioration in the Union’s security context. With that instrument, the Union
started to support Member States so that they can place orders rapidly, incentivising
the defence industrial sector to invest, in the very short term, in the strengthening of
production capacities in order to be able to serve Member States needs by 2030. In
addition, this Regulation supports the placement of Ukrainian orders with the
European Defence Technological and Industrial Base in order to support the
cooperation between the European Defence Technological and Industrial Base and the
Ukrainian Defence Technological and Industrial Base. Such an exceptionally high
demand for a wide range of defence products carries an imminent risk of a severe
negative impact on the proper functioning of the internal market. In order to address
this risk and in view of the objectives of this Regulation, taking into account the
specific situation of Ukraine, prioritisation measures at Union level that aim to ensure
the availability of the defence products concerned could prove to be indispensable in
ensuring the proper functioning of the internal market for defence products and its
supply chains. The Commission should be able to use in this respect, upon a request of
a Participating Member State, priority-rated requests for facilitating the supply of
defence products to meet the objectives of this Regulation.
(38) Priority-rated requests should consist of requests by the Commission, upon an
initiative of a Participating Member State, to relevant economic operators established
in the Union to accept or to prioritise orders of crisis-relevant products. Only to be
used when necessary and proportionate for the purpose of ensuring that defence supply
chains can operate normally, those priority-rated requests should be aimed at
supporting Ukraine which faces severe difficulties either in the placing of an order or
in the execution of a contract for the supply of defence products. Economic operators
should have the possibility to refuse to be subject to a priority-rated request. A
priority-rated request should be taken based on objective, factual, measurable and
substantiated data. It should have regard for the legitimate interests of the undertakings
and the cost and effort required for any change in production sequence. When
accepted, the obligation to perform the priority-rated request should take precedence
over performance obligations under private or public law. In light of the importance of
ensuring the supply of defence products, which are indispensable to the correct
functioning of the internal market and its supply chains, compliance with the
obligation to perform a priority-rated request should not entail liability to third parties
for damages that might result from any breach of contractual obligations governed by
the law of a Member State, to the extent that the breach of contractual obligations was
necessary for compliance with the mandated prioritisation. Where the economic
EN 10 EN
operator has expressly accepted a priority-rated request and the Commission has
adopted an implementing act following such an acceptance, the economic operator
should comply with all the conditions of that implementing act. Non-compliance by
the economic operator with the conditions laid down in the implementing act should
result in a loss of the benefit of a waiver of contractual liability. Where the non-
compliance is intentional or attributable to gross negligence, the Commission should
be able to impose on the economic operator a fine, subject to the proportionality
principle.
(39) Given that specific amounts should be made available for budget assistance and
assistance to support Ukraine’s defence industrial capacities, coherence and
complementarity should be ensured in their respective implementation.
(40) This Regulation should apply without prejudice to the specific character of the security
and defence policy of certain Member States.
(41) This Regulation does not apply to Member States that are not participant to the
enhanced cooperation. In this context, it should be recalled that the non-participation
of certain Member States to this enhanced cooperation does not exempt them from the
obligation to ensure the full enforcement of Article 325 TFEU and the Union acquis
aiming at ensuring the protection of Union’s financial interests, including Council
Regulation (EC, Euratom) No 2988/9522; Regulation (EU, Euratom) No 883/2013 of
the European Parliament and of the Council23, Directive (EU) 2017/1371 of the
European Parliament and of the Council24, the rules of Regulation (EU, Euratom)
2024/2509 and where applicable, Council Regulation (EU) 2017/193925. These
Member States and the economic entities under their jurisdiction should thus fully
collaborate with the Court of Auditor, OLAF, the Commission and, where applicable
EPPO, in the exercise of their competences.
(42) The Ukraine Support Loan Agreement to be concluded between the Commission and
the Ukrainian authorities should contain provisions aligned with the rights,
responsibilities and obligations provided for in the framework agreement under the
Ukraine Facility referred to in Article 9 of Regulation (EU) 2024/792 signed between
the Union and Ukraine that entered into force on 20 June 2024. That will ensure that
the Union’s financial interests linked to the Ukraine Support Loan are protected
efficiently, providing the appropriate measures relating to the prevention of, and fight
against, fraud, corruption and any other irregularities linked to the assistance. It will
also, in accordance with Regulation (EU, Euratom) 2024/2509, grant the necessary
rights and access to the Commission, the European Anti-Fraud Office (OLAF), the
European Court of Auditors and, where applicable, the European Public Prosecutor’s
22 Council Regulation (EC, Euratom) No 2988/95 of 18 December 1995 on the protection of the European
Communities financial interests (OJ L 312, 23.12.1995, p. 1, ELI:
http://data.europa.eu/eli/reg/1995/2988/oj). 23 Regulation (EU, Euratom) No 883/2013 of the European Parliament and of the Council of 11 September
2013 concerning investigations conducted by the European Anti-Fraud Office (OLAF) and repealing
Regulation (EC) No 1073/1999 of the European Parliament and of the Council and Council Regulation
(Euratom) No 1074/1999 (OJ L 248, 18.9.2013, p. 1, ELI: http://data.europa.eu/eli/reg/2013/883/oj). 24 Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on the fight
against fraud to the Union's financial interests by means of criminal law (OJ L 198, , p. 29,
ELI: http://data.europa.eu/eli/dir/2017/1371/oj). 25 Council Regulation (EU) 2017/1939 of 12 October 2017 implementing enhanced cooperation on the
establishment of the European Public Prosecutor’s Office (‘the EPPO’) (OJ L 283, 31.10.2017, p. 1, ELI:
http://data.europa.eu/eli/reg/2017/1939/oj).
EN 11 EN
Office, including from third parties involved in the implementation of Union funds
during and after the availability period of the Ukraine Support Loan. Ukraine should
also report irregularities in relation to the use of the funds to the Commission, in line
with the procedures provided for in the framework agreement under the Ukraine
Facility.
(43) Given the difficult situation of Ukraine caused by Russia’s war of aggression and in
order to support Ukraine on its long-term stability path, it is appropriate for the Union
to provide the Ukraine Support Loan as a limited recourse loan that is to become due
and payable when Ukraine receives from Russia cash or non-monetary assets for war
reparations, indemnities or any financial settlement from Russia, other than territory.
(44) The release of funds under the Ukraine Support Loan should be contingent on the
positive assessment by the Commission of a request for funds submitted by Ukraine.
For the macro-financial assistance, the assessment of the conditions should be without
prejudice to the assessment of the fulfilment of conditions under other Union
programmes and instruments. For the assistance to support Ukraine’s defence
industrial capacities, the release of funds should be linked to contracts or agreements
for activities, expenditures and measures to support Ukraine’s defence industrial
capacities related to defence products or other products for defence purposes.
(45) This Regulation should lay down appropriate provisions for the financing of the
Ukraine Support Loan.
(46) In the context of Ukraine’s financing needs, it is appropriate to organise the financial
assistance under the diversified funding strategy provided for in Article 224 of
Regulation (EU, Euratom) 2024/2509.
(47) In line with the firm support of 25 Heads of State and Government in the margins of
the European Council of 18 December 2025, the Ukraine Support Loan should be
repaid by Ukraine once reparations from Russia are received, and the Union reserves
its right to make use of the Russian assets immobilised in the Union to repay the loan,
in full accordance with EU and international law.
(48) By way of derogation from Article 31(3) of Regulation (EU) 2021/947 of the
European Parliament and of the Council26, the financial liability from loans under this
Regulation should not be supported by the External Action Guarantee, established by
that Regulation. Support in the form of loans under this Regulation should constitute
financial assistance within the meaning of Article 223(1) of Regulation (EU, Euratom)
2024/2509. In considering the financial risks and the presence of guarantees, no
provisioning should be constituted for the support in the form of loans under this
Regulation, to be guaranteed over and above the ceilings, and, by way of derogation
from Article 214(1) of Regulation (EU, Euratom) 2024/2509, no provisioning rate
should be set.
(49) Given the situation of Ukraine, caused by Russia’s war of aggression and to support it
on its long-term stability path, it is appropriate to derogate from Article 223(4), point
26 Regulation (EU) 2021/947 of the European Parliament and of the Council of 9 June 2021 establishing
the Neighbourhood, Development and International Cooperation Instrument – Global Europe,
amending and repealing Decision No 466/2014/EU of the European Parliament and of the Council and
repealing Regulation (EU) 2017/1601 of the European Parliament and of the Council and Council
Regulation (EC, Euratom) No 480/2009 (Text with EEA relevance) (OJ L 209, 14.6.2021, p. 1, ELI:
http://data.europa.eu/eli/reg/2021/947/2021-06-14).
EN 12 EN
(e), of Regulation (EU, Euratom) 2024/2509 and to allow the Union the possibility to
provide a borrowing costs subsidy to cover the costs that would otherwise be borne by
Ukraine. These costs comprise debt service costs (cost of funding and cost of liquidity
management) and related administrative costs. The borrowing costs subsidy to be
granted is deemed appropriate to ensure the effectiveness of the support under the
Ukraine Support Loan within the meaning of Article 223(1) of Regulation (EU,
Euratom) 2024/2509, notably to avoid adding pressure on Ukraine’s public finances.
(50) In accordance with Article 332 TFEU, expenditure other than administrative costs
entailed for the institutions resulting from the enhanced cooperation should be borne
by the Participating Member States. To that effect, Member States which do not
participate in enhanced cooperation should be entitled to an adjustment in accordance
with Article 11 of Council Regulation (EU, Euratom) No 609/201427 in respect of any
operational expenditure borne by the Union budget, comprising in particular debt
service costs, as well as calls on the guarantee. Administrative costs entailed for the
institutions when implementing enhanced cooperation should be borne by the Union
budget without any adjustment for the Member States which do not participate in
enhanced cooperation.
(51) Union support to Ukraine under this Regulation should be managed by the
Commission.
(52) The assistance to Ukraine under the Ukraine Support Loan should be additional and
complementary to the Union support provided under the Ukraine Facility. The
Commission should, wherever possible, seek to minimise the administrative and
reporting burden on Ukraine.
(53) The Commission should duly take into account Council Decision 2010/427/EU28 and
the role of the European External Action Service, in line with their competences.
(54) The competent committee of the European Parliament might invite the Commission to
discuss in a Ukraine Support Loan dialogue matters that concern the implementation
of the Regulation. The Commission should take into account elements arising from the
views expressed through the Ukraine Support Loan dialogue, including the resolutions
from the European Parliament if provided.
(55) In order to ensure that the European Parliament and the Council are able to follow the
implementation of this Regulation, the Commission should regularly inform them of
developments relating to Union assistance to Ukraine under this Regulation and
provide them with the relevant documents.
(56) In order to ensure the continued effectiveness of the arrangements established by this
Regulation, the Commission should regularly review their adequacy and report to the
European Parliament and to the Council thereon, thereby guaranteeing transparency
and accountability.
27 Council Regulation (EU, Euratom) No 609/2014 of 26 May 2014 on the methods and procedure for
making available the traditional, VAT and GNI-based own resources and on the measures to meet cash
requirements (Recast) (OJ L 168, 7.6.2014, p. 39, ELI: http://data.europa.eu/eli/reg/2014/609/oj). 28 Council Decision 2010/427/EU of 26 July 2010 establishing the organisation and functioning of the
European External Action Service (OJ L 201, 3.8.2010, p. 30, ELI:
http://data.europa.eu/eli/dec/2010/427/oj).
EN 13 EN
(57) In order to ensure uniform conditions for the implementation of this Regulation,
implementing powers should be conferred on the Commission. Those powers should
be exercised in accordance with Regulation (EU) No 182/2011.
(58) Since the objectives of this Regulation, namely to provide financial and economic
assistance to Ukraine for 2026 and 2027 in a predictable, continuous, orderly and
timely manner with a view to supporting Ukraine in coverings its financing needs
resulting from Russia’s war of aggression, cannot be sufficiently achieved by the
Member States but can rather, by reasons of their scale and effect, be better achieved
at Union level, the Union may adopt measures, where appropriate by means of
enhanced cooperation, in accordance with the principle of subsidiarity as set out in
Article 5 of the Treaty on European Union. In accordance with the principle of
proportionality, as set out in that Article, this Regulation does not go beyond what is
necessary in order to achieve those objectives.
(59) In view of the urgency entailed by the exceptional circumstances caused by Russia’s
unprovoked and unjustified war of aggression, it is considered to be appropriate to
invoke the exception to the eight-week period provided for in Article 4 of Protocol No
1 on the role of national Parliaments in the European Union, annexed to the Treaty on
European Union, to the Treaty on the Functioning of the European Union and to the
Treaty establishing the European Atomic Energy Community.
(60) In light of the situation in Ukraine, this Regulation should enter into force as a matter
of urgency on the day following that of its publication in the Official Journal of the
European Union,
HAVE ADOPTED THIS REGULATION:
CHAPTER I
GENERAL PROVISIONS
Article 1
Subject matter
1. This Regulation implements enhanced cooperation on the establishment of an instrument
for providing Union assistance to Ukraine for 2026 and 2027 in the form of a loan to be
repaid by reparations due by Russia (the ‘Ukraine Support Loan’).
2. It lays down the objective of the Ukraine Support Loan, its financing, the forms of Union
funding under it and the rules for providing such funding.
Article 2
Objectives of the Ukraine Support Loan
1. The general objective of the Ukraine Support Loan shall be to provide financial and
economic assistance to Ukraine in a predictable, continuous, orderly, flexible and timely
manner with a view to supporting Ukraine in covering its financing needs notably
resulting from Russia’s war of aggression and Russia’s non-payment of reparations due.
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2. To achieve this general objective, the specific objectives of the Ukraine Support Loan
shall be:
a. To support macro-financial stability via easing Ukraine’s external and internal
financing constraints;
b. to support Ukraine’s defence industrial capacities through economic, financial and
technical cooperation.
Article 3
Definitions
For the purposes of this Regulation the following definitions apply:
(1) ‘defence product’ means goods, services and works that fall within the scope of
Directive 2009/81/EC, as set out in Article 2 thereof;
(2) ‘EEA EFTA State’ means a Member of the European Free Trade Association
which is a member of the European Economic Area;
(3) ‘ERA Loans’ means eligible bilateral loans and the Union’s Macro-financial
Assistance loan pursuant to Regulation (EU) 2024/2773;
(4) ‘Non-Participating Member State’ means a Member State which does not
participate in the enhanced cooperation established by Council Decision [XX];
(5) ‘Participating Member State’ means a Member State which participates in the
enhanced cooperation established by Council Decision [XX];
(6) ‘other products for defence purposes’ means any good, service and work other
than those falling within the scope of Directive 2009/81/EC, as set out in
Article 2 thereof, which are necessary for or aimed at defence purposes.
Article 4
Available assistance under the Ukraine Support Loan
1. The Ukraine Support Loan shall be for a maximum amount of EUR 90 000 000 000.
That amount shall be made available to Ukraine in accordance with Ukraine’s financing
needs, as provided for in the Ukrainian Financing Strategy approved in accordance with
Article 8.
2. The Ukraine Support Loan shall be available until 31 December 2027. It shall be made
available by the Commission in instalments, which may be disbursed in one or more
tranches. The disbursement of all such tranches shall take place by 31 December 2028.
3. If the financing needs of Ukraine decrease fundamentally during the period of
availability of the Ukraine Support Loan, including in the event of a settlement by Russia
of Ukraine’s war damages, the Commission, acting in accordance with the examination
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procedure referred to in Article 27(3), may reduce the undisbursed amount of the
Ukraine Support Loan or cancel it.
4. In accordance with Article 332 TFEU, Non-Participating Member States shall be entitled
to an adjustment in accordance with Article 11 of Council Regulation (EU, Euratom) No
609/2014 in respect of expenditure financed from the voted budget resulting from the
implementation of the enhanced cooperation other than administrative costs entailed for
the institutions, borne by the Union budget. Such adjustment shall in particular comprise
any debt service costs as well as calls on the guarantee.
Article 5
Preconditions for assistance under the Ukraine Support Loan
1. A precondition for granting the assistance under the Ukraine Support Loan shall be that
Ukraine continue to uphold and respect effective democratic mechanisms, including a
multi-party parliamentary system, the rule of law, and to guarantee respect for human
rights, including the rights of persons belonging to minorities. Upholding and respecting
the rule of law shall include the fight against corruption.
2. The Commission services and the European External Action Service shall monitor the
fulfilment of the precondition set out in paragraph 1, in particular before the adoption of
the Council implementing decision referred to in Article 8 and the release of funds
referred to in Article 23. Furthermore, the monitoring shall take into account the relevant
recommendations of international bodies, such as the Council of Europe and its Venice
Commission. The Commission shall inform the European Parliament and the Council of
its monitoring.
CHAPTER II
IMPLEMENTATION OF THE UKRAINE SUPPORT LOAN
Article 6
Ukrainian Financing Strategy
1. In order to receive financial and economic assistance under the Ukraine Support Loan,
Ukraine shall submit, in principle each year, to the Commission a Ukrainian Financing
Strategy that shall provide details on Ukraine’s financing needs and financing sources, in
principle for the forthcoming 12 months.
2. The Ukrainian Financing Strategy shall contain:
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a. the main macroeconomic assumptions underpinning the Ukrainian Financing
Strategy;
b. information on Ukraine’s budget, per quarter and year, including:
i. the targeted budget balance for the general government, broken down by
subsector of general government;
ii. the projections for expenditure and revenue for the general government and its
main subsectors, and their main components according to the economic
classification;
iii. relevant information on the general government expenditure by function,
notably on defence;
iv. a description and quantification of the expenditure and revenue measures to be
included in the budget;
v. an annex containing the methodology and assumptions, and any other relevant
parameters underpinning the budgetary forecasts.
c. information on Ukraine’s past and projected financial developments in the general
government, per quarter and year, including:
i. information on the liquidity situation (cash balance) for the general
government and its main subsectors;
ii. debt amortisations;
iii. a debt issuance strategy;
iv. other debt creating and reducing flows;
v. the stock of payment arrears and its projected developments.
d. information on the implementation of previously granted assistance under the
Ukraine Support Loan, including any financial recoveries thereof;
e. information on projected in-kind military assistance needs;
f. on the basis of Ukraine’s budget and the projected in-kind military assistance needs,
the expected external financing needs for the period covered by that Ukrainian
Financing Strategy, including a breakdown of the amounts in that budget necessary
for the purposes of Article 2(2)(a) and (b) of this Regulation. That breakdown shall
EN 17 EN
contain the value of defence products to be purchased outside the Union and
Ukraine;
g. committed and expected external financing and in-kind military assistance at the
time of submission of the Ukrainian Financing Strategy for the period covered by
that Ukrainian Financing Strategy, including a breakdown of the amounts of that
external financing to be used in line with the purposes of Article 2(2)(a) and (b) of
this Regulation;
h. on the basis of the information in points (f) and (g) of this paragraph, the expected
external financing gap for which Ukraine seeks assistance under the Ukraine
Support Loan under that Ukrainian Financing Strategy, including a breakdown of
the amounts of that expected external financing gap for the purposes of Article
2(2)(a) and (b) of this Regulation;
i. in order to support multiannual expenditure under Chapter IV of this Regulation,
information on potential multiannual needs and a corresponding budget.
3. Ukraine may submit updated Ukrainian Financing Strategies until such time as the
maximum amount of the Ukraine Support Loan as referred to in Article 4(1) has been
made accessible under the Ukraine Support Loan in accordance with Article 8.
Article 7
Commission’s assessment of the Ukrainian Financing Strategy
1. The Commission shall assess the Ukrainian Financing Strategy submitted in accordance
with Article 6 without undue delay.
2. When carrying out the assessment referred to in paragraph 1, the Commission shall act in
close cooperation with Ukraine. The Commission may make observations or seek
additional information, including verifying information with Member States, third
countries and international organisations. Ukraine shall provide any requested additional
information and may revise the Ukrainian Financing Strategy if needed, including after
its submission.
3. The Commission shall assess the Ukrainian Financing Strategy and shall, in particular
assess:
a. the completeness, feasibility and coherence of the Ukrainian Financing Strategy
with the underlying assumptions;
EN 18 EN
b. the consistency of the information in the Ukrainian Financing Strategy with external
sources, including any recent reviews of the International Monetary Fund and
information from the Ukraine Donor Platform and the Ukraine Defence Contact
Group;
c. the consistency of the expected external financing gap with the following indicative
distribution of the Ukraine Support Loan:
i. EUR 30 000 000 000 for macro-financial assistance in accordance with
Chapter III or for budget assistance in the form of a loan to be implemented
under the Ukraine Facility pursuant to Chapter III of Regulation (EU)
2024/792;
ii. EUR 60 000 000 000 to support Ukraine’s defence industrial capacities in
accordance with Chapter IV.
d. compliance with the precondition set out in Article 5(1).
4. Where the Commission gives a positive assessment of the Ukrainian Financing Strategy,
it shall, without delay, submit a proposal for a Council implementing decision in
accordance with Article 8.
5. Where the Commission gives a negative assessment of the Ukrainian Financing Strategy,
it shall, without delay, inform Ukraine, giving reasons for its assessment. A negative
assessment shall not prevent Ukraine from submitting a revised Ukrainian Financing
Strategy.
6. Where the Commission assesses an update to the Ukrainian Financing Strategy, the
provisions of this Article shall apply.
Article 8
Council implementing decision
1. Where the Commission makes a positive assessment of the Ukrainian Financing Strategy
or its update, the Commission shall submit a proposal to the Council for an implementing
decision making the financial and economic assistance accessible.
2. The Council implementing decision referred to in paragraph 1 shall:
a. determine the amount of assistance to be made accessible to Ukraine to assist in the
implementation of the Ukrainian Financing Strategy, including the amount of that
assistance accessible:
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i. for budget assistance in the form of a loan to be implemented pursuant to
Chapter III of Regulation (EU) 2024/792;
ii. for macro-financial assistance in accordance with Chapter III;
iii. to support Ukraine’s defence industrial capacities in accordance with Chapter
IV.
b. establish the maximum number and indicative value of instalments for the
assistance accessible for macro-financial assistance in accordance with Chapter III.
3. The determination of the amounts of the Ukraine Support Loan to be made accessible
shall:
a. respect the maximum amount available for the Ukraine Support Loan provided in
Article 4(1);
b. take into account the need to ensure a fair burden sharing with other donors in the
coverage of Ukraine’s financing needs.
c. for budget assistance, determine to what extent regular budget assistance can be
provided in the form of a loan to be implemented pursuant to Chapter III of
Regulation (EU) 2024/792 or as macro-financial assistance, as appropriate.
4. The Council shall adopt the implementing decision referred to in paragraph 1 without
undue delay.
Article 9
Complementarity and coordination
1. In the implementation of the Ukraine Support Loan, the Commission shall act in close
cooperation with Ukraine, Member States, relevant international bodies and donors to
Ukraine, notably through the Ukraine Donor Platform and the Ukraine Defence Contact
Group, to ensure a coherent and consistent approach from those supporting Ukraine to
address Ukraine’s financial and economic assistance needs. In doing so, the Commission
shall draw on the expertise of the European External Action Service.
2. Article 5, Article 7, Article 13, Article 14, Article 15 and Article 23(1)(b) shall apply in
accordance with Decision 2010/427/EU.
EN 20 EN
CHAPTER III
BUDGET ASSISTANCE IN THE FORM OF MACRO-
FINANCIAL ASSISTANCE
Article 10
Purpose
1. The macro-financial assistance shall contribute to covering Ukraine’s financing gap, as
identified in a positively assessed Ukrainian Financing Strategy.
2. The release of the macro-financial assistance shall be managed by the Commission on
the basis of its assessment of the precondition referred to in Article 5 and of the
satisfactory fulfilment of the policy conditions included in the memorandum of
understanding referred to in Article 11.
Article 11
Memorandum of Understanding
1. In respect of the approved amounts of macro-financial assistance as referred to in Article
8(2)(a)(ii), the Commission shall agree with Ukraine on policy conditions to which the
macro-financial assistance is to be linked. Those policy conditions shall be set out in a
memorandum of understanding (MoU).
2. The policy conditions shall include robust and ambitious reform commitments, including
those that aim, in particular, at strengthening revenue mobilisation to support Ukraine’s
financing needs and tackle the root causes of corruption in public finances, including via
improving the sustainability and quality of public expenditure and enhancing the
efficiency, transparency and accountability of the public finance management systems.
Where relevant, those commitments shall be consistent with any programme that
Ukraine has with the IMF whilst going further where appropriate. Progress in attaining
the commitments shall be regularly monitored by the Commission.
3. The Commission shall approve the signature of the MoU and of its amendments by
means of implementing acts. Those implementing acts shall be adopted in accordance
with the examination procedure referred to in Article 27(3).
EN 21 EN
CHAPTER IV
ASSISTANCE TO SUPPORT UKRAINE’S DEFENCE
INDUSTRIAL CAPACITIES
Article 12
Purpose
1. The assistance to support Ukraine’s defence industrial capacities shall aim at enabling
Ukraine to carry out urgent and major public investments in support of the Ukrainian
defence industry and its integration into the European defence industry in response to
and following the current crisis situation. This assistance shall contribute, in particular, to
the reconstruction, recovery and modernisation of the Ukrainian Defence Technological
and Industrial Base, with a view to increasing its defence industrial readiness, taking into
account its gradual future integration into the European Defence Technological and
Industrial Base and through support for the timely availability of defence products and
other products for defence purposes, through cooperation between the Union and
Ukraine.
2. The activities, expenditures and measures to support Ukraine’s defence industrial
capacities shall be related to defence products or other products for defence purposes and
shall aim to:
a. speed up the adjustment of the Ukrainian defence industry to structural changes,
including through the creation and ramp-up of its manufacturing capacities as well
as related supporting activities;
b. improve the timely availability of defence products or other products for defence
purposes for Ukraine, including through the reduction of their delivery lead time,
reservation of manufacturing slots or stockpiling of defence products or other
products for defence purposes, intermediate products or raw materials; or
c. enhance cross-border cooperation between the European Defence Technological
and Industrial Base and the Ukrainian Defence Technological and Industrial Base,
taking into account the defence industrial reinforcement and defence procurement
needs of Ukraine, allowing for interchangeability of defence products or other
products for defence purposes manufactured by the Ukrainian defence industry and
the European defence industry.
EN 22 EN
Article 13
Eligibility
1. Activities, expenditures and measures to support Ukraine’s defence industrial capacities
related to defence products and other products for defence purposes shall be eligible for
assistance provided that they comply with the eligibility conditions set out in this Article.
2. Defence products shall belong to one of the following categories:
a. category one: ammunition and missiles; artillery systems, including deep precision
strike capabilities; ground combat capabilities and their support systems, including
soldier equipment and infantry weapons; small drones (NATO class 1) and related
anti-drone systems; critical infrastructure protection; cyber; and military mobility
including counter-mobility;
b. category two: air and missile defence systems; maritime surface and underwater
capabilities; drones other than small drones (NATO class 2 and 3) and related anti-
drone systems; strategic enablers such as, but not limited to, strategic airlift, air-to-air
refuelling, C4ISTAR systems as well as space assets and services; space assets
protection; artificial intelligence and electronic warfare.
3. The activities, expenditures and measures to support Ukraine’s defence industrial
capacities related to defence products or other products for defence purposes shall not
contravene the security and defence interests of the Union and its Member States as
established in the framework of the common foreign and security policy pursuant to Title
V of the Treaty on European Union, including respect for the principle of good
neighbourly relations, or the objectives set out in Article 2 of this Regulation.
4. Defence products shall be produced in compliance with the following conditions:
a. Manufacturers and subcontractors involved in the production shall be established
and have their executive management structures in the Union, in an EEA EFTA
State or in Ukraine. They shall not be subject to control by a third country which is
not an EEA EFTA State or Ukraine or by another third-country entity which is not
established in the Union, an EEA EFTA State or in Ukraine;
b. By way of derogation from point (a), in order to take into account industrial
cooperation with non-EU partners, defence products that involve a subcontractor
involved in the production which is allocated between 15 % and 35 % of the value
of the contract, and that is not established or does not have its executive
EN 23 EN
management structures in the Union, EEA EFTA State or Ukraine, shall be eligible
providing that at least one of the following conditions are met:
i. a direct contractual relationship related to the defence product has been
established between the manufacturer and that subcontractor prior to 28 May
2025;
ii. the manufacturer commits to studying, within two years, the feasibility of
replacing the input provided by that subcontractor with an alternative,
restriction-free input originating in the Union, EEA EFTA States or Ukraine,
and meeting technical and time requirements.
c. By way of derogation from point (a), defence products involving manufacturers or
subcontractors established in the Union and controlled by another third country or
by another third-country entity which is not an EEA EFTA State or Ukraine shall be
eligible if this manufacturer or subcontractor has been subject to screening within
the meaning of Regulation (EU) 2019/452 and, where necessary, to appropriate
mitigation measures, or if this manufacturer provides guarantees in accordance with
point (d) verified by the Member State in which it is established;
d. The guarantees referred to in point (c) of this paragraph shall provide assurances
that the involvement of the manufacturer or subcontractor in the production of the
defence product does not contravene the security and defence interests of the Union
and its Member States as established in the framework of the common foreign and
security policy pursuant to Title V of the Treaty on European Union. Those
guarantees shall in particular substantiate that, for the purposes of activities,
expenditures and measures, measures are in place to ensure that:
i. control over the manufacturer or subcontractor is not exercised in a manner
that restrains or restricts its ability to carry out the activities, expenditures and
measures supported; and
ii. access by a non-associated third country or by a non-associated third-country
entity to classified or sensitive information relating to the defence product
produced is prevented and the employees or other persons involved in the
production of the defence product have national security clearance issued by a
Member State, where appropriate, in accordance with national laws and
regulations.
EN 24 EN
e. The infrastructure, facilities, assets and resources of the manufacturers and
subcontractors involved in the production shall be located in the territory of a
Member State, an EEA EFTA State or Ukraine. Where manufacturers or
subcontractors involved in the production have no readily available alternatives or
relevant infrastructure, facilities, assets and resources in the territory of a Member
State, an EEA EFTA State or Ukraine, they may use their infrastructure, facilities,
assets and resources which are located or held outside those territories, provided
that such use does not contravene the security and defence interests of the Union
and its Member States;
f. Manufacturers and subcontractors involved in the production may be considered to
fulfil the eligibility conditions referred to in this paragraph where they have fulfilled
equivalent conditions under Regulations (EU) 2018/109229, (EU) 2021/69730, (EU)
2023/152531, or (EU) 2023/241832 of the European Parliament and of the Council or
under Regulation (EU) 2025/1106 and provided that no subsequent changes call
into question the fulfilment of those conditions;
g. The cost of components originating outside the Union, EEA EFTA States and
Ukraine shall not be higher than 35 % of the estimated cost of the components of
the defence product. No component shall be sourced from a third country that
contravenes the security and defence interests of the Union and its Member States;
h. For defence products related to category two as referred to in paragraph 2 of this
Article, manufacturers shall have the ability to decide, without restrictions imposed
by third countries or by third-country entities, on the definition, adaptation and
evolution of the design of the defence product procured, including the legal
29 Regulation (EU) 2018/1092 of the European Parliament and of the Council of 18 July 2018 establishing
the European Defence Industrial Development Programme aiming at supporting the competitiveness
and innovation capacity of the Union’s defence industry (OJ L 200, 7.8.2018, p. 30, ELI:
http://data.europa.eu/eli/reg/2018/1092/oj). 30 Regulation (EU) 2021/697 of the European Parliament and of the Council of 29 April 2021 establishing
the European Defence Fund and repealing Regulation (EU) 2018/1092 (OJ L 170, 12.5.2021, p. 149,
ELI: http://data.europa.eu/eli/reg/2021/697/oj). 31 Regulation (EU) 2023/1525 of the European Parliament and of the Council of 20 July 2023 on
supporting ammunition production (ASAP) (OJ L 185, 24.7.2023, p. 7, ELI:
http://data.europa.eu/eli/reg/2023/1525/oj). 32 Regulation (EU) 2023/2418 of the European Parliament and of the Council of 18 October 2023 on
establishing an instrument for the reinforcement of the European defence industry through common
procurement (EDIRPA) (OJ L, 2023/2418, 26.10.2023, ELI: http://data.europa.eu/eli/reg/2023/2418/oj).
EN 25 EN
authority to substitute or remove components that are subject to restrictions imposed
by third countries or by third-country entities;
i. For the purposes of this paragraph, ‘subcontractors involved in the production’
means any legal entity which provides critical inputs that possess unique attributes
essential for the functioning of a product, which is allocated at least 15 % of the
value of the contract, and which needs access to classified information for the
performance of the contract.
5. By way of derogation from paragraphs 2 and 4 and in full respect of paragraph 3, where
there is an urgent need for a given defence product stemming from Russia’s war of
aggression against Ukraine, the procurement of a defence product which does not
comply with one or more of the conditions set out in paragraphs 2 and 4 shall be eligible
for financial assistance under this chapter provided that:
a. there is no equivalent product that responds to that urgent need which complies with
the conditions set out in paragraphs 2 and 4 or it is not available at the required
scale; or
b. the delivery lead time for such a product is significantly shorter than for a product
which would comply with the conditions set out in paragraphs 2 and 4, even if this
product were subject to a priority rated request as referred to in Article 19.
In such a case, Ukraine shall provide the information reasonably available to it
demonstrating that the conditions for the application of this derogation are met to be
checked by the Commission without undue delay. In the context of point (b), that
information shall include a formal commitment on compliance with the delivery lead
time.
The procurement of defence products from manufacturers established in third countries
shall be made only where there are no other alternatives available in the Union under the
circumstances described in points (a) and (b).
The Commission shall approve such derogations by means of implementing acts, acting
in accordance with the examination procedure referred to in Article 27(3).
6. Where applicable, Participating Member States shall ensure that the procurement
procedures and contracts for other products for defence purposes resulting from
procurements receiving support under the Ukraine Support Loan contain appropriate
EN 26 EN
eligibility conditions to protect the security and defence interests of the Union and its
Member States.
7. By way of derogation from paragraph 4, contributions in accordance with point (e) of
paragraph 8 of this Article shall be utilised in line with the eligibility conditions of the
respective Union programme.
8. Activities, expenditures and measures related to defence products or other products for
defence purposes shall be implemented within one of the following methods of
implementation:
a. procurements by Ukraine, subject to the procurement and delivery being validated
by the Commission or Participating Member States. Ukraine shall be responsible for
such procurements in accordance with Ukrainian law, where validations by the
Commission or Participating Member States shall include on a sample basis checks
on contractual documentation, invoices and delivery certificates, physical
inspections to suppliers and physical verification of deliveries;
b. procurements by Ukraine that are a common procurement in accordance with
Regulation (EU) 2025/1106;
c. agreements between Ukraine and Member States or the European Defence Agency;
d. procurement agreements between Ukraine and international or intergovernmental
organisations;
e. contributions by Ukraine to the Ukraine Support Instrument established by [EDIP
Regulation], the Ukraine Investment Framework established by Regulation (EU)
2024/792 for dual-use goods or other Union programmes.
Activities, expenditures and measures related to other products for defence purposes may
also be implemented by procurements by Ukraine for procurements below EUR 7 000
000, provided that sound financial management and the protection of the financial
interest of the Union are ensured.
9. Contracts entered into by Ukraine relating to procurements, agreements or contributions
referred to in paragraph 8 shall be eligible if signed after 14 January 2025 provided that
they comply with the requirements set out in this Article.
10. The Commission shall be empowered to adopt a delegated act in accordance with Article
26 to supplement this Regulation by extending eligibility criteria to include third
EN 27 EN
countries other than EEA EFTA States and Ukraine that do not contravene the security
and defence interests of the Union and its Member States, provided that such countries
have concluded an agreement with the Union in accordance with Article 17 of Council
Regulation 2025/1106.
Article 14
Product schedules
1. In respect of the approved amounts of assistance to support Ukraine’s defence industrial
capacities as referred to in Article 8(2)(a)(iii), Ukraine shall draw up a schedule for each
activity, expenditure or measure related to a defence product or other product for defence
purposes for which it intends to request assistance. That schedule shall set out:
a. a description of the defence product or other product for defence purposes;
b. information on compliance with Article 13.
2. Ukraine shall consult the schedule with the Commission with a view of ensuring
compliance with Article 13. In determining whether an alternative method of
implementation is more economical or when considering the prices available, the
Commission shall take into consideration any co-financing that is to be provided by
Member States. When proposing to Ukraine the most appropriate method of
implementation, the Commission shall take into consideration the timeliness of delivery
of the relevant product, activity, expenditure or measure, the prices available, the past
experience with that method of implementation and, where warranted, past experience
with manufacturers under that method of implementation. Should Ukraine not identify a
method of implementation in accordance with Article 13(8) or should the Commission
consider that an alternative method of implementation is more economical, efficient or
effective, the Commission may propose a method of implementation to Ukraine.
3. By derogation from paragraph 1, Ukraine shall not be required to draw up a schedule for
implementation in accordance with Article 13(8)(e).
Article 15
Ukraine’s Defence Industrial Capacities Expert Group
1. To support the implementation of assistance to support Ukraine’s defence industrial
capacities, the Commission shall establish the Ukraine’s Defence Industrial Capacities
Expert Group.
EN 28 EN
2. In addition to representatives of the Commission services and the European External
Action Service, the Ukraine’s Defence Industrial Capacities Expert Group shall include
representatives of Participating Member States and EEA EFTA States. Ukraine shall be
invited to the meetings of the Ukraine’s Defence Industrial Capacities Expert Group as
appropriate.
3. The Ukraine’s Defence Industrial Capacities Expert Group shall provide advice,
expertise and support on the defence products and other products for defence purposes,
as well as on the method of implementation.
Article 16
Administration of the assistance to support Ukraine’s defence industrial capacities
Ukraine shall open a special account for the sole purpose of the management of the financial
and economic assistance received to support Ukraine’s defence industrial capacities. In
relation to this account:
a. all payments of the contracts or agreements that are requested for assistance to
support Ukraine’s defence industrial capacities shall be paid from this account;
b. the Commission shall be granted monitoring rights of this account;
c. Ukraine shall provide the Commission with a monthly report, to be submitted
within 10 working days of the end of each month, containing the following
information:
i. the date and amount of each payment made from the account during the
preceding month;
ii. the name of the recipient of each payment;
iii. a description of the purpose of each payment and how it relates to the contracts
or agreements submitted in requests for funds;
iv. any other information as may be reasonably requested by the Commission.
Article 17
Monitoring of implementation
1. The Commission shall monitor the implementation of assistance to support Ukraine’s
defence industrial capacities, notably including the delivery of products, in accordance
with this Article.
EN 29 EN
2. For procurements by Ukraine in accordance with Article 13(8), point (a), that are
validated by the Commission, the Commission shall utilise the validation process therein.
3. For procurements by Ukraine in accordance with Article 13(8), point (a), that are
validated by Participating Member States, the Participating Member State shall monitor
the implementation of the procurement and the delivery in accordance with that
provision and report to the Commission.
4. For procurements by Ukraine in accordance with Article 13(8), point (b), the
Participating Member States that are part of such a common procurement shall monitor
the implementation of the procurement and the delivery and report to the Commission.
Where in the context of a common procurement under Regulation (EU) 2025/1106 a
Non-Participating Member State agrees to be bound by and to apply the eligibility rules
set out in this Regulation, ensures the protection of the financial interests of the Union
and is the contracting authority which acts on behalf of the other countries, Ukraine shall
require as a condition of its participation that the Non-Participating Member State
monitors the implementation of the procurement and the delivery and report to the
Commission.
5. For agreements between Ukraine and Participating Member States in accordance with
Article 13(8), point (c), the Participating Member State shall monitor the implementation
of the agreement and the delivery and report to the Commission. For agreements
between Ukraine and Non-Participating Member States in accordance with Article 13(8),
point (c), Ukraine shall include in such agreements obligations on the respective Non-
Participating Member State to be bound by and to apply the eligibility rules set out in
this Regulation, to ensure the protection of the financial interests of the Union and to
monitor the implementation of the agreement and the delivery and report to the
Commission.
6. For agreements between Ukraine and the European Defence Agency in accordance with
Article 13(8), point (c), the European Defence Agency shall monitor the implementation
of the agreement and the delivery and report to the Commission.
7. For procurement agreements between Ukraine and international or intergovernmental
organisations in accordance with Article 13(8), point (d), Ukraine shall include in such
procurement agreements obligations on the respective international or intergovernmental
EN 30 EN
organisations to monitor the implementation of the procurement and the delivery and to
report to the Commission.
8. Paragraphs 1 to 7 shall not apply to procurements by Ukraine in accordance with Article
13(8) regarding activities, expenditures and measures related to other products for
defence purposes below EUR 7 000 000. However, Ukraine shall regularly report to the
Commission on how it monitors the implementation of these procurements and delivery.
The Commission shall undertake risk-based controls.
9. Should the Commission be notified by Ukraine of the non-implementation of a contract
in accordance with Article 20(2), point (g), or become aware of the non-delivery of
products under this Article or the non-use of funds in the account referred to in Article
16, the Commission shall engage with Ukraine to repurpose those funds in accordance
with the provisions of this Regulation.
Article 18
Modification of framework agreements or contracts
1. Where activities, expenditures and measures related to defence products are implemented
through the methods referred to in paragraph 8(b) or (c) of Article 13 within the Union,
the rules provided for in paragraphs 2 to 4 shall apply to an existing framework
agreement or contract that has as its object the purchase of defence products, which is
used in that implementation method, and which does not provide for the possibility to
substantially amend it. When applying paragraphs 2 and 3, the contracting authority that
concluded the framework agreement or contract shall obtain the prior agreement of the
undertaking with which it has concluded that framework agreement or contract.
2. A contracting authority of a Participating Member State may modify an existing
framework agreement or contract for defence products, where that framework agreement
or contract has been concluded with an undertaking complying with criteria equivalent to
those laid down in Article 13(4) and (5) of this Regulation, in order to add Ukraine as a
party to that framework agreement or contract.
3. By way of derogation from Article 29(2), third subparagraph, of Directive 2009/81/EC, a
contracting authority of a Participating Member State may make substantial amendments
to the quantities set out in a framework agreement or contract, with an estimated value
above the thresholds laid down in Article 8 of Directive 2009/81/EC, where that
framework agreement or contract has been concluded with an undertaking that complies
EN 31 EN
with criteria equivalent to those laid down in Article 13(4) and (5) of this Regulation,
and insofar as the modification is strictly necessary for the application of paragraph 2 of
this Article.
4. For the purpose of calculating the value referred to in paragraph 3, the updated value
shall be the reference point when the contract includes an indexation clause.
5. A contracting authority which has modified a framework agreement or contract in the
cases referred to in paragraph 2 or 3 of this Article shall publish a notice to that effect in
the Official Journal of the European Union in accordance with Article 32 of Directive
2009/81/EC.
6. In the cases referred to in paragraphs 2 and 3, the principle of equal rights and
obligations shall apply between the contracting authorities which are party to the
framework agreement or contract, in particular regarding the cost of additional quantities
procured.
Article 19
Voluntary prioritisation of defence products
1. For the sole purpose of this Regulation and where Ukraine is confronted with severe
difficulties in the placing or in the execution of a contract for the supply of defence
products that are urgently needed and meet the eligibility requirements set out in Article
13(4) or (5), an economic operator together with the Participating Member State on the
territory of which its production site is located may jointly submit a request to the
Commission to issue a prioritisation measure to prioritise a certain order of such products
manufactured by that economic operator.
2. The joint request referred to in paragraph 1 shall include the following elements:
a. The initial request from Ukraine;
b. The list of products to be subject to the prioritisation measure, their specifications
and the quantities in which they are to be supplied;
c. The time limits within which the delivery of these products is to be completed;
d. Evidence that the economic operator cannot meet the request from Ukraine referred
to in point (a) without a prioritisation measure;
e. An indication of a fair and reasonable price at which the prioritisation measure
could be placed as well as elements substantiating that price.
EN 32 EN
3. Upon reception of a request as referred to in paragraph 1, the Commission shall assess
that request without undue delay.
4. The Commission shall base its assessment referred to in paragraph 3 on objective,
factual, measurable and substantiated data, with the aim of determining whether such
prioritisation is indispensable in order to address the severe difficulties referred to in
paragraph 1.
5. Where the assessment referred to in paragraph 3 concludes that the prioritisation is
indispensable, the Commission, by means of an implementing act, shall adopt a
prioritisation measure setting out:
a. the legal basis of the priority-rated request to be complied with by the economic
operator;
b. the list of products subject to the priority-rated request, their specifications and the
quantities in which they are to be supplied;
c. the time limits within which the priority-rated request is to be completed;
d. the beneficiaries of the priority-rated request;
e. the scope of contractual obligations over which the priority-rated request shall have
precedence;
f. the waiver of contractual liability under the conditions laid down in paragraph 7 of
this Article; and
g. the penalties provided for in paragraphs 12 to 18 of this Article for non-compliance
with the obligations stemming from that implementing act.
The implementing act referred to in the first subparagraph of this paragraph shall be
adopted in accordance with the examination procedure referred to in Article 27(3).
6. The prioritisation measure referred to in paragraph 5 shall:
a. be placed at a fair and reasonable price, adequately taking into account the
economic operator’s opportunity costs when fulfilling the prioritisation measure as
compared to existing contractual obligations; and
b. take precedence over any contractual obligations under private or public law related
to the defence products subject to the prioritisation measure, under the conditions
laid down in the implementing act referred to in paragraph 5.
EN 33 EN
7. The economic operator subject to a prioritisation measure pursuant to paragraph 5 shall
not be liable for any breach of contractual obligation that is governed by the law of a
Participating Member State, provided that:
a. the breach of contractual obligation is strictly necessary for compliance with the
required prioritisation;
b. the implementing act referred to in paragraph 5 has been complied with; and
c. the request referred to in paragraph 1 did not have the sole purpose of unduly
avoiding a prior performance obligation under private or public law.
8. The economic operator subject to a prioritisation measure may request the Commission
to modify the implementing act referred to in paragraph 5 where it considers it to be duly
justified based on one of the following grounds:
a. the economic operator is unable to perform the prioritisation measure on account of
insufficient production capability or production capacity, even under preferential
treatment of the request;
b. completion of the prioritisation measure would place an unreasonable economic
burden on, and entail particular hardship for, the economic operator.
9. The economic operator shall provide all relevant and substantiated information to allow
the Commission to assess the merits of the request for modification referred to in
paragraph 8.
10. Based on the examination of the reasons and evidence provided by the economic
operator, the Commission may, after consultation and prior agreement of the
Participating Member State on the territory of which the relevant production site of the
economic operator concerned is located, amend its implementing act to release, partially
or in totality, the economic operator concerned from its obligations under this Article.
11. Where an economic operator, after having expressly accepted to prioritise the orders
requested by the Commission, intentionally or through gross negligence does not comply
with the obligation to prioritise those orders, it shall be subject to fines set out in
paragraphs 12 to 18 of this Article, except where:
a. the economic operator is unable to perform the priority-rated request on account of
insufficient production capability or production capacity, or on technical grounds;
or
EN 34 EN
b. performance or completion of the request would place an unreasonable economic
burden on, and entail particular hardship for, the economic operator, including
substantial risks relating to business continuity.
The revenue from the fines shall constitute external assigned revenue within the
meaning of Article 21(5) of the Regulation (EU, Euratom) 2024/2509 to an external
assistance programme under which Ukraine is eligible.
12. Where it deems it to be necessary and proportionate, the Commission may, by way of
implementing acts, impose on the economic operators fines not exceeding EUR 300 000
where the economic operator, intentionally or through gross negligence, does not comply
with the obligation to perform the priority-rated request pursuant to this Article.
The implementing acts referred to in the first subparagraph of this paragraph shall be
adopted in accordance with the examination procedure referred to in Article 27(3).
13. Before taking a decision pursuant to paragraph 12, the Commission shall provide an
opportunity for the economic operator concerned to be heard in accordance with
paragraph 15. The Commission shall take into account any duly reasoned justification
presented by the economic operator for the purpose of determining whether fines are
deemed necessary and proportionate.
14. In fixing the amount of the fine, the Commission shall take into consideration the nature,
gravity and duration of the infringement, including whether the economic operator has
partially complied with the priority-rated order or the priority-rated request.
15. Before adopting a decision pursuant to paragraph 12, the Commission shall ensure that
the economic operators concerned have been given the opportunity to submit
observations on:
a. the preliminary findings of the Commission, including any matter in relation to
which the Commission has raised objections;
b. the measures that the Commission may intend to take in view of the preliminary
findings pursuant to point (a) of this paragraph.
16. The economic operators concerned may submit to the Commission their observations on
the Commission’s preliminary findings within a time limit which shall be fixed by the
Commission in its preliminary findings, and which may not be less than 14 working
days.
EN 35 EN
17. The Commission shall base its imposition of fines only on objections on which the
economic operators concerned have been able to comment.
18. Where the Commission has informed the economic operators concerned of its
preliminary findings as referred to in paragraph 15, it shall give access, if so requested,
to the Commission's file under the terms of a negotiated disclosure, subject to the
legitimate interest of economic operators in the protection of their business secrets, or in
order to preserve business secrets or other confidential information of any person. The
right of access to the file shall not extend to confidential information and internal
documents of the Commission or the authorities of the Participating Member States, in
particular to correspondence between the Commission and the authorities of the
Participating Member States. Nothing in this paragraph shall prevent the Commission
from disclosing and using information necessary to prove an infringement.
19. This Article is without prejudice to the rights of the Participating Member States to
protect their essential security interests in accordance with Article 346(1)(b) TFEU.
CHAPTER V
FINANCING AND IMPLEMENTATION
Article 20
Ukraine Support Loan Agreement
1. The detailed financial terms of the Ukraine Support Loan shall be laid down in the
Ukraine Support Loan Agreement.
2. In addition to the elements laid down in Article 223(4) of Regulation (EU, Euratom)
2024/2509, the Ukraine Support Loan Agreement shall require that:
(a) the Ukraine Support Loan shall be a limited recourse loan that shall become
due and payable upon the occurrence of a repayment trigger as defined in
subparagraph (j);
(b) Ukraine shall provide the Union a security interest over its claim on Russia for
reparations as security for the Ukraine Support Loan. The value of that security
interest shall at any given time be equal to the value of disbursed funds under
the Ukraine Support Loan;
(c) the rights, responsibilities and obligation provided for in the framework
agreement under the Ukraine Facility referred to in Article 9 of Regulation
(EU) 2024/792 apply to this Ukraine Support Loan Agreement and the funds
therein;
(d) the amount of assistance referred to in Article 8(2)(a)(i) shall be implemented
in accordance with Chapter III of Regulation (EU) 2024/792, with the
exception of rules on the duration and repayment of the loan, including
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borrowing cost subsidy, which shall be governed by the rules of this
Regulation;
(e) Ukraine utilises the same management and control systems as proposed in the
Ukraine Plan established under Regulation (EU) 2024/792, including beyond
the availability period referred to in Article 6(2) in that Regulation;
(f) the Commission have the right to monitor activities, expenditures and measures
under Chapter IV of this Regulation that are carried out by the Ukrainian
authorities, along the whole project cycle;
(g) Ukraine immediately notify the Commission should a draft contract or
agreement financed through the Ukraine Support Loan not be implemented;
(h) Ukraine continues to respect the precondition set out in Article 5(1);
(i) Ukraine does not reverse any measure taken under any other current or
previous instruments of support provided by the Union or IMF concerning anti-
corruption;
(j) Ukraine shall be liable for the repayment of the principal of the Ukraine
Support Loan within 30 days, if any of the following conditions are fulfilled,
each constituting a repayment trigger for the purposes of this Regulation:
i. the receipt of cash by Ukraine for war reparations, indemnities or any
financial settlement from Russia, up to the amount of such settlement; or
ii. 90 days from the receipt of non-monetary assets by Ukraine for war
reparations, indemnities or any financial settlement from Russia, except
territory, up to the amount of such settlement which shall be determined by an
independent valuation. Upon request of Ukraine, the Commission may grant an
extension of this timeframe if strictly warranted; or
iii. that Ukraine is in breach of subparagraph (h); or
iv. it has been established that, in relation to the management of the
Ukraine Support Loan, Ukraine has engaged in any act of fraud, corruption or
any other illegal activity detrimental to the financial interests of the Union.
(k) Ukraine is liable to repay the Ukraine Support Loan:
i. in the event of subparagraph (j), points (i) and (ii), for an amount of the
monetary value of the war reparations, indemnities or any financial settlement
from Russia equal to the proportion of the Ukraine Support Loan outstanding
against the sum of the value of the Ukraine Support Loan outstanding, any
outstanding reparations loans provided by G7 members and any outstanding
liabilities under ERA Loans;
ii. in the event of subparagraph (j), point (iii), for the total outstanding
amount of the Ukraine Support Loan;
iii. in the event of subparagraph (j), point (iv), for the value of fraud,
corruption or any other illegal activity detrimental to the financial interests of
the Union.
(l) any amounts of the Ukraine Support Loan not covered by the liability referred
to in subparagraph (k) shall remain in place until future repayment trigger
events occur;
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(m) in case of payments or recoveries, Ukraine shall indicate the relevant payments
from the Ukraine Support Loan that are being repaid or recovered;
(n) the Union have the right to make use of Russian assets immobilised in the
Union to repay the loan, in full accordance with Union and international law;
(o) Ukraine shall ensure that the procurement procedures and contracts for other
products for defence purpose resulting from procurement receiving support
under the Ukraine Support Loan contain appropriate eligibility conditions to
protect the security and defence interests of the Union and its Member States.
The Ukraine Support Loan Agreement shall also include any other requirements
needed for the implementation of the Ukraine Support Loan, including those
necessary to implement Article 17 of this Regulation.
3. Non-compliance with the terms of the Ukraine Support Loan Agreement shall constitute
a ground for the Commission to suspend or cancel, in full or in part, the release of the
instalment or tranches. Non-compliance with repayment terms of the Ukraine Support
Loan Agreement shall additionally constitute a ground for the total or part of the
outstanding amount of the Ukraine Support Loan to become due and payable.
4. The Ukraine Support Loan Agreement shall be made available, upon request,
simultaneously to the European Parliament and to the Council.
Article 21
Request for funds
1. To receive financial and economic assistance, Ukraine shall submit to the Commission a
duly justified request for funds. Such a request for funds may be submitted by Ukraine to
the Commission, in principle, six times a year. For budget assistance in the form of a
loan to be implemented pursuant to Chapter III of Regulation (EU) 2024/792, the request
for funds shall be submitted in accordance with Chapter III of Regulation (EU)
2024/792.
2. For macro-financial assistance, the request for funds shall be accompanied by a report in
accordance with the provisions of the MoU.
3. For assistance to support Ukraine’s defence industrial capacities:
(a) the request for funds may cover multiple products. For each covered product,
the request for funds shall contain a contract or agreement in compliance with Article
13 and a schedule in accordance with Article 14. Such contracts or agreements may
be signed or in a finalised draft form;
(b) if the request for funds requests funding for an amount greater than 20% of the
amount made accessible in accordance with the Council implementing decision
referred to in Article 8, Ukraine shall provide a detailed justification, including on
the impact for future requests for funds under that decision.
EN 38 EN
Article 22
Borrowing costs subsidy
1. By way of derogation from Article 223(4), point (e), of Regulation (EU, Euratom)
2024/2509 and subject to available resources, the Union may bear the costs arising from
the borrowing for a loan to Ukraine that would otherwise be borne by Ukraine
(‘borrowing costs subsidy’). These costs comprise service costs (cost of funding, cost of
liquidity management, and cost of service for administrative overheads related to the
borrowing and lending).
2. Ukraine may request the borrowing costs subsidy referred to in paragraph 1 each year.
The Commission may award the borrowing costs subsidy for an amount not exceeding
the limits of the appropriations made available in the context of the budgetary procedure.
Article 23
Decision on the release of assistance
1. The Commission shall decide on the release of assistance subject to its assessment of the
following requirements:
(a) for macro-financial assistance:
i. compliance with the precondition set out in Article 5(1);
ii. the satisfactory fulfilment of the policy conditions set out in the MoU
referred to in Article 11; and
iii. compliance with the Ukraine Support Loan Agreement referred to in
Article 20.
(b) for assistance to support Ukraine’s defence industrial capacities:
i. compliance with the precondition set out in Article 5(1);
ii. confirmation that the contracts or agreements are for products in
compliance with Article 13 and that the Commission does not object to the
methods of implementation;
iii. confirmation that Ukraine broadly respects the qualitative and
quantitative steps contained in the Annex to Implementing Decision (EU)
2024/1447 and any amendments thereto;
iv. compliance with the obligations referred to in Article 16 and the
Ukraine Support Loan Agreement referred to in Article 20; and
v. to the extent necessary, the adequacy of the detailed justification of
Ukraine, taking into account the situation in Ukraine and the committed and
expected external financing available.
EN 39 EN
For budget assistance in the form of a loan to be implemented pursuant to Chapter III of
Regulation (EU) 2024/792, the release of assistance shall be implemented in accordance
with Chapter III of Regulation (EU) 2024/792.
2. Subject to compliance with the amount of assistance accessible provided for in the
Council implementing decision adopted in accordance with Article 8, where the
Commission makes a positive assessment of the request for funds, it shall adopt, without
undue delay, a decision authorising the disbursement of the Ukraine Support Loan. For
assistance to support Ukraine’s defence industrial capacities, that amount to be disbursed
shall be equal to the value of the contracts or agreements included in the request for
funds.
3. The Commission may proceed with the decision referred to in paragraph 2 for points (a)
and (b) under paragraph 1 collectively or individually.
4. Where the Commission gives a negative assessment to the request for funds, it shall,
without undue delay, inform Ukraine, giving reasons for its assessment. A negative
assessment shall not prevent Ukraine from submitting a new request for funds.
Article 24
Financing of the Ukraine Support Loan
1. In order to finance the assistance under the Ukraine Support Loan, the Commission shall
be empowered, on behalf of the Union, to borrow the necessary funds on the capital
markets or from financial institutions under the diversified funding strategy referred to in
Article 224 of Regulation (EU, Euratom) 2024/2509.
2. The borrowing and lending operations for the Ukraine Support Loan shall be carried out
in euro.
3. By way of derogation from Article 31(3), second sentence, of Regulation (EU) 2021/947,
the financial assistance provided to Ukraine under the Ukraine Support Loan shall not be
supported by the External Action Guarantee. No provisioning for the Ukraine Support
Loan shall be constituted and, by way of derogation from Article 214(1) of Regulation
(EU, Euratom) 2024/2509, no provisioning rate shall be set.
EN 40 EN
Article 25
Application of the rules on classified information and sensitive information
1. Classified information that is created, handled, stored, exchanged or shared under this
Regulation shall be protected in accordance with the security rules set out in Commission
Decision (EU, Euratom) 2015/44433 or the Agreement between the Member States of the
European Union, meeting within the Council, regarding the protection of classified
information exchanged in the interests of the European Union, as appropriate.
2. The Commission shall use a secured exchange system in order to facilitate the exchange
of classified information and sensitive information between the Commission and Ukraine
and, where appropriate, with the Participating Member States.
3. The Commission shall have access to information, including classified information,
necessary for the tasks assigned to it under this Regulation, in particular for the purpose
of verifying the conditions for disbursement of payments and carrying out the checks,
reviews, audits, investigations, reports as well as the controls and audits, as referred to in
Article 20.
4. Information received as a result of the application of this Regulation shall be used only
for the purpose for which it was requested.
5. The Commission and Participating Member States shall ensure the protection of trade
and business secrets and other sensitive information acquired and generated in
application of this Regulation in accordance with Union law and respective national law.
CHAPTER VI
FINAL PROVISIONS
Article 26
Exercise of the delegation
1. The power to adopt delegated acts is conferred on the Commission subject to the
conditions laid down in this Article.
2. The power to adopt delegated acts referred to in Article 13 shall be conferred on the
Commission for an indeterminate period of time from seven days after the entry into
force of this Regulation.
33 Commission Decision (EU, Euratom) 2015/444 of 13 March 2015 on the security rules for protecting
EU classified information (OJ L 72, 17.3.2015, p. 53, ELI: http://data.europa.eu/eli/dec/2015/444/oj).
EN 41 EN
3. The delegation of power referred to in Article 13 may be revoked at any time by the
European Parliament or by the Council. A decision to revoke shall put an end to the
delegation of the power specified in that decision. It shall take effect on the day
following the publication of the decision in the Official Journal of the European Union or
at a later date specified therein. It shall not affect the validity of any delegated acts
already in force.
4. Before adopting a delegated act, the Commission shall consult experts designated by
each Member State in accordance with the principles laid down in the Interinstitutional
Agreement of 13 April 2016 on Better Law-Making.
5. As soon as it adopts a delegated act, the Commission shall notify it simultaneously to the
European Parliament and to the Council.
6. A delegated act adopted pursuant to Article 13 shall enter into force only if no objection
has been expressed either by the European Parliament or by the Council within a period
of two months of notification of that act to the European Parliament and the Council or
if, before the expiry of that period, the European Parliament and the Council have both
informed the Commission that they will not object. That period shall be extended by two
months at the initiative of the European Parliament or of the Council.
Article 27
Committee procedure
1. The Commission shall be assisted by a committee. That committee shall be a committee
within the meaning of Regulation (EU) No 182/2011.
2. The EDA shall be invited to provide its views and expertise to the committee as an
observer. The EEAS shall also be invited to assist in the work of the committee.
3. Where reference is made to this paragraph, Article 5 of Regulation (EU) No 182/2011
shall apply.
Article 28
Ukraine Support Loan dialogue
1. In order to enhance the dialogue between the Union institutions, in particular the
European Parliament, the Council and the Commission, and to ensure greater
transparency and accountability, the competent committee of the European Parliament
may invite the Commission to discuss the implementation of this Regulation.
EN 42 EN
2. The European Parliament may express its views in resolutions as regards the Ukraine
Support Loan.
3. The Commission shall take into account any elements arising from the views expressed
through the Ukraine Support Loan dialogue, including the resolutions from the European
Parliament if provided.
Article 29
Information to the European Parliament and to the Council
1. The Commission shall inform the European Parliament and the Council of
developments regarding the implementation of this Regulation, including Article 4(4), Article
6(1), Article 7(5), Article 11(4), Article 20(3) and Article 23(2) and shall provide those
institutions with the relevant documents without undue delay. Information transmitted by the
Commission to the Council in the context of this Regulation or its implementation shall
simultaneously be made available to the European Parliament, subject to confidentiality
arrangements if necessary.
2. By 30 June 2027 and 30 June 2028, the Commission shall submit to the European
Parliament and to the Council a report on the implementation of this Regulation in the
preceding year, including an evaluation of that implementation. That report shall:
(a) examine progress made in implementing the Ukraine Support Loan;
(b) provide information on the monitoring referred to in Article 17; and
(c) assess the economic situation and prospects of Ukraine, as well as progress
made in implementing the policy conditions referred to in Article 11(1).
3. By 30 June 2029, the Commission shall submit to the European Parliament and to the
Council an evaluation report, assessing the results and efficiency of the Ukraine Support Loan
provided under this Regulation and the extent to which it has contributed to the aims of the
assistance.
Article 30
Entry into force
This Regulation shall enter into force on the day following that of its publication in the
Official Journal of the European Union.
EN 43 EN
For those Member States which participate in enhanced cooperation by virtue of a decision
adopted pursuant to Article 331(1) TFEU, second or third subparagraph, this Regulation shall
apply as from the date indicated in the decision concerned.
This Regulation shall be binding in its entirety and directly applicable in the participating
Member States in accordance with the Treaties.
Done at Brussels,
For the European Parliament For the Council
The President The President
EN 44 EN
LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3
1.1. Title of the proposal/initiative ...................................................................................... 3
1.2. Policy area(s) concerned .............................................................................................. 3
1.3. Objective(s) .................................................................................................................. 3
1.3.1. General objective(s) ..................................................................................................... 3
1.3.2. Specific objective(s) ..................................................................................................... 3
1.3.3. Expected result(s) and impact ...................................................................................... 3
1.3.4. Indicators of performance ............................................................................................ 3
1.4. The proposal/initiative relates to: ................................................................................. 4
1.5. Grounds for the proposal/initiative .............................................................................. 4
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative ............................................................ 4
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone. ................................................................................. 4
1.5.3. Lessons learned from similar experiences in the past .................................................. 4
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments ....................................................................................... 5
1.5.5. Assessment of the different available financing options, including scope for
redeployment ................................................................................................................ 5
1.6. Duration of the proposal/initiative and of its financial impact .................................... 6
1.7. Method(s) of budget implementation planned ............................................................. 6
2. MANAGEMENT MEASURES................................................................................... 8
2.1. Monitoring and reporting rules .................................................................................... 8
2.2. Management and control system(s) ............................................................................. 8
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed .................. 8
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them............................................................................................................ 8
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure) ........................................... 8
2.3. Measures to prevent fraud and irregularities ................................................................ 9
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10
3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)
affected ....................................................................................................................... 10
EN 45 EN
3.2. Estimated financial impact of the proposal on appropriations ................................... 12
3.2.1. Summary of estimated impact on operational appropriations.................................... 12
3.2.1.1. Appropriations from voted budget ............................................................................. 12
3.2.1.2. Appropriations from external assigned revenues ....................................................... 17
3.2.2. Estimated output funded from operational appropriations......................................... 22
3.2.3. Summary of estimated impact on administrative appropriations ............................... 24
3.2.3.1. Appropriations from voted budget .............................................................................. 24
3.2.3.2. Appropriations from external assigned revenues ....................................................... 24
3.2.3.3. Total appropriations ................................................................................................... 24
3.2.4. Estimated requirements of human resources.............................................................. 25
3.2.4.1. Financed from voted budget....................................................................................... 25
3.2.4.2. Financed from external assigned revenues ................................................................ 26
3.2.4.3. Total requirements of human resources ..................................................................... 26
3.2.5. Overview of estimated impact on digital technology-related investments ................ 28
3.2.6. Compatibility with the current multiannual financial framework.............................. 28
3.2.7. Third-party contributions ........................................................................................... 28
3.3. Estimated impact on revenue ..................................................................................... 29
4. DIGITAL DIMENSIONS .......................................................................................... 29
4.1. Requirements of digital relevance .............................................................................. 30
4.2. Data ............................................................................................................................ 30
4.3. Digital solutions ......................................................................................................... 31
4.4. Interoperability assessment ........................................................................................ 31
4.5. Measures to support digital implementation .............................................................. 32
EN 46 EN
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE
1.1. Title of the proposal/initiative
Proposal for a Regulation of the European Parliament and of the Council
implementing enhanced cooperation on the establishment of the Ukraine Support
Loan for 2026 and 2027.
1.2. Policy area(s) concerned
Economic and Financial Affairs as well as support to the Defence Industry.
1.3. Objective(s)
1.3.1. General objective(s)
To establish the Ukraine Support Loan and make available to Ukraine financial and
economic assistance with a view to supporting Ukraine in covering its financing
needs for 2026 and 2027 notably resulting from Russia’s war of aggression and
Russia’s non-payment of reparations due. The Ukraine Support Loan shall provide
financial and economic assistance to Ukraine in a predictable, continuous, orderly,
flexible and timely manner.
1.3.2. Specific objective(s)
To support macro-financial stability in Ukraine by easing its external and internal
financing constraints, and to support Ukraine’s defence industrial capacities through
economic, financial and technical cooperation.
1.3.3. Expected result(s) and impact
Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.
Ukraine will be provided with sufficient and continuous financial support for 2026
and 2027 in response to and following the current crisis situation. The Ukraine
Support loan is expected to help support Ukraine’s budgetary and defence needs for
the immediate future.
1.3.4. Indicators of performance
Specify the indicators for monitoring progress and achievements.
The authorities of Ukraine will be required to regularly report on the implementation
of previously granted assistance under the Ukraine Support Loan. The Commission
services will remain in close contact with the Ukraine Donor Platform to benefit
from insights from ongoing activities of the respective donors.
As regards the objective on easing financing constraints, the authorities of Ukraine
will be required to provide a report on the compliance with the agreed policy
conditions ahead of the disbursement of the instalment of the macro-financial
assistance. The Commission services will continue to monitor public finance
management, following the operational assessment of the financial circuits and
administrative procedures in Ukraine, which was delivered in June 2020, where an
update will be undertaken.
An annual report on the implementation of this Regulation to the European
Parliament and Council is foreseen. An ex-post evaluation of the Ukraine Support
Loan will be carried out by the Commission.
EN 47 EN
1.4. The proposal/initiative relates to:
☒ a new action
¨ a new action following a pilot project / preparatory action34
¨ the extension of an existing action
¨ a merger or redirection of one or more actions towards another/a new action
1.5. Grounds for the proposal/initiative
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative
For the implementation of the Ukraine Support Loan, the Commission will enter into
a Ukraine Support Loan Agreement with Ukraine detailing the financial terms of the
Ukraine Support Loan.
Once the Ukraine Support Loan Agreement is in place, the disbursements from the
Ukraine Support Loan will be conditional on the submission and positive assessment
of a Ukrainian Financing Strategy. Furthermore, for budget assistance, a
memorandum of understanding (MoU) must be agreed between the Commission and
the authorities of Ukraine for macro-financial assistance and the Ukraine Plan
updated under the Ukraine Facility. Disbursements will then be conditional upon
relevant conditions for both budget assistance and assistance to support Ukraine’s
defence industrial capacities.
The Ukraine Support Loan will be managed by the Commission. Specific provisions
on the prevention of fraud and other irregularities, consistent with the Financial
Regulation, are applicable, including the relevant provisions on ensuring the Union’s
financial interest as laid down in the Framework Agreement under Regulation (EU)
2024/792. The Commission and the Ukrainian authorities would agree on the MoU
setting out reporting requirements.
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone.
Reasons for action at EU level (ex-ante): This proposal responds to the need for a
common response in providing support to Ukraine on an adequate scale, which
cannot be sufficiently achieved by the Member States alone and can be better
achieved by the EU. The main reasons are the fiscal capacity and budgetary
constraints faced at the national level and the need for strong coordination in order to
maximise the scale and effectiveness of the support, while limiting the burden on the
administrative capacity of Ukrainian authorities, which is very stretched in the
current circumstances.
The initiative is part of the EU’s objective to provide support to Ukraine and
reinforces actions by the Union for economic and defence support, as well as the
Union’s initiatives to coordinate multilateral actions.
34 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.
EN 48 EN
Expected generated EU added value (ex-post): The expected EU added value,
notably in comparison to other EU instruments, is to swiftly support macro-financial
stability via easing Ukraine’s external and internal financing constraints and to
support Ukraine’s defence industrial capacities - within an appropriate framework for
reporting requirements.
1.5.3. Lessons learned from similar experiences in the past
Previous macro-financial assistance operations to Ukraine are subject to ex-post
evaluation. Past ex-post evaluations of previous macro-financial assistance
operations to Ukraine have shown that in general they were highly relevant in terms
of its objectives, budget and policy objectives. They proved crucial to support
Ukraine in addressing its balance-of-payment problems and implementing key
structural reforms to stabilise the economy and enhance the sustainability of its
external position. They allowed for fiscal savings and financial benefits, as well as
acted as a catalyst for additional financial support and investor confidence.
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments
The resources for the Ukraine Support Loan will be financed by borrowing under the
diversified funding strategy referred to in Article 224 of Regulation (EU, Euratom)
2024/2509. In considering the financial risks and the budgetary coverage, no
provisioning should be constituted for the support in the form of loans under this
Regulation, to be guaranteed over and above the ceilings, and, by way of derogation
from Article 214(1) of Regulation (EU, Euratom) 2024/2509, no provisioning rate
should be set.
With a view to providing support to Ukraine on a highly concessional basis, the
Union budget will provide for a subsidy for the costs arising from borrowing for a
loan to Ukraine that would otherwise have to be borne by Ukraine. These costs
include debt service costs (cost of funding and costs of issuing and managing
liquidity) and the associated administrative costs. The debt service costs will be
covered by a dedicated special instrument over and above the ceilings of the
Multiannual Financial Framework, in line with an accompanying proposal to amend
Regulation 2020/2093. When mobilising it in the framework of the budgetary
procedure, budgetary availabilities in other special instruments, applicable sectoral
rules, any legal or other obligations including under the EURI Instrument, priorities,
prudent budgeting and sound financial management will be considered.
A new budget line will be created to clearly and transparently identify the
expenditure related to the debt service costs resulting from the enhanced cooperation.
Administrative costs will be borne by the Union budget with staff costs being
covered by Heading 7 of the Multiannual Financial Framework.
1.5.5. Assessment of the different available financing options, including scope for
redeployment
On 23 October 2025, 26 Member States invited the Commission to present, as soon
as possible, options for financial support to Ukraine. The Commission presented a
number of options, where on 18 December 2025 the European Council agreed to
provide a loan to Ukraine of EUR 90 billion for the years 2026-2027 based on EU
borrowing on the capital markets backed by the EU budget headroom.
EN 49 EN
1.6. Duration of the proposal/initiative and of its financial impact
☒ limited duration
– ☒ financial impact from 2026 to 2027 for commitment appropriations and from
2026 to 2028 for payment appropriations.
In addition, an interest rate subsidy to Ukraine may be provided annually over
the duration of the loan.
unlimited duration
1.7. Method(s) of budget implementation planned
☒ Direct management by the Commission
– ☒ by its departments, including by its staff in the Union delegations;
– by the executive agencies
Shared management with the Member States
Indirect management by entrusting budget implementation tasks to:
– third countries or the bodies they have designated
– international organisations and their agencies (to be specified)
– the European Investment Bank and the European Investment Fund
– bodies referred to in Articles 70 and 71 of the Financial Regulation
– public law bodies
– bodies governed by private law with a public service mission to the extent that
they are provided with adequate financial guarantees
– bodies governed by the private law of a Member State that are entrusted with
the implementation of a public-private partnership and that are provided with
adequate financial guarantees
– bodies or persons entrusted with the implementation of specific actions in the
common foreign and security policy pursuant to Title V of the Treaty on
European Union, and identified in the relevant basic act
– bodies established in a Member State, governed by the private law of a
Member State or Union law and eligible to be entrusted, in accordance with
sector-specific rules, with the implementation of Union funds or budgetary
guarantees, to the extent that such bodies are controlled by public law bodies or
by bodies governed by private law with a public service mission, and are provided
with adequate financial guarantees in the form of joint and several liability by the
controlling bodies or equivalent financial guarantees and which may be, for each
action, limited to the maximum amount of the Union support.
Comments
N/A
EN 50 EN
2. MANAGEMENT MEASURES
2.1. Monitoring and reporting rules
The monitoring and reporting obligations under Regulation (EU, Euratom)
2024/2509 apply.
The monitoring of the action by the Commission services will take place based on
the implementation of previously granted assistance under the Ukraine Support Loan.
Furthermore, the monitoring of the action will take into consideration the specific
measures to be agreed with the Ukrainian authorities in the MoU. The Commission
will verify the fulfilment of the policy conditions set out in the MoU. The
Commission will inform the European Parliament and the Council about the results
of that verification.
Finally, the monitoring of the action will take into consideration the engagement with
the Ukrainian authorities, including the respective requests for funds and the
information contained therein, regarding the assistance to support Ukraine’s defence
industrial capacities.
In order to ensure that the European Parliament and the Council are able to follow
the implementation of this Regulation, the Commission should regularly inform them
of developments relating to Union assistance to Ukraine under this Regulation and
provide them with the relevant documents.
The Commission should regularly review the adequacy of such reporting and
monitoring requirements and report to the European Parliament and to the Council
thereon, thereby guaranteeing transparency and accountability.
No later than 30 June 2029, the Commission will submit to the European Parliament
and to the Council an ex-post evaluation report, assessing the results and efficiency
of the Ukraine Support Loan provided under this Regulation and the extent to which
it has contributed to the aims of the assistance.
2.2. Management and control system(s)
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed
The actions to be financed under this proposal will be implemented under direct
management by the Commission. The financial support under the Ukraine Support
Loan will be made available by the Commission. The release of funds can be
organised swiftly to start in the course of 2026 and be completed in 2028 at the latest.
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them
The Commission shall have access to information, including classified information,
strictly necessary for the tasks assigned to it under this Regulation, in particular for
the purpose of verifying the conditions for disbursement of payments and carrying
out the checks, reviews, audits, investigations, reports as well as the controls and
audits, as referred to in Article 20.
To protect the Union’s financial interests linked to the Ukraine Support Loan, the
Ukraine Support Loan Agreement to be concluded between the Commission and the
Ukrainian authorities should contain provisions aligned with the rights,
EN 51 EN
responsibilities and obligations provided for in the framework agreement under the
Ukraine Facility. Ukraine will utilise the same management and control systems as
proposed in the Ukraine Plan established under Regulation (EU) 2024/792.
Ukraine will be required to provide monthly reports providing information covering
all payments. It will open a special account for the sole purpose of the management
of the financial and economic assistance received to support Ukraine’s defence
industrial capacities. All payments of the contracts or agreements that are requested
for assistance to support Ukraine’s defence industrial capacities will be paid from
this account. The Commission will be granted monitoring rights of this account.
Additionally, if it has been established that Ukraine has engaged in acts of fraud,
corruption or other illegal activity with respect to the management of the Ukraine
Support Loan, to the detriment of the Union’s financial interests, the Union can
demand early repayment of the Ukraine Support Loan.
In order to address the risks related to information confidentiality, classified
information that is created, handled, stored, exchanged or shared under this
Regulation should be protected in accordance with the security rules set out in
Commission Decision (EU, Euratom) 2015/444 or the Agreement between the
Member States of the European Union, meeting within the Council, regarding the
protection of classified information exchanged in the interests of the European
Union, as appropriate. The Commission should use a secured exchange system in
order to facilitate the exchange of classified information and sensitive information
between the Commission and Ukraine and, where appropriate, with the Participating
Member States.
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio
between the control costs and the value of the related funds managed), and
assessment of the expected levels of risk of error (at payment & at closure)
The control systems in place have ensured an effective error rate for the macro-
financial assistance type of payments so far of 0%. There are no known cases of
fraud, corruption or illegal activity. Operations have a clear intervention logic, one
that allows the Commission to evaluate their impact. The controls enable the
confirmation of assurance and of attainment of policy objectives and priorities.
Measures to prevent fraud and irregularities
The Ukraine Support Loan Agreement to be concluded between the Commission and
the Ukrainian authorities will require that Ukraine utilises the same management and
control systems as proposed in the Ukraine Plan established under Regulation (EU)
2024/792 that entered into force on 20 June 2024 to ensure that the Union’s financial
interests linked to the Ukraine Support Loan are protected efficiently, providing the
appropriate measures relating to the prevention of, and fight against, fraud,
corruption and any other irregularities linked to the assistance. It will also, in
accordance with the Financial Regulation, grant the necessary rights and access to
the Commission, the European Anti-Fraud Office (OLAF), the European Court of
Auditors and, where applicable, the European Public Prosecutor’s Office, including
from third parties involved in the implementation of Union funds during and after the
availability period of the Ukraine Support Loan. Ukraine should also report
irregularities in relation to the use of the funds to the Commission, in line with the
procedures provided for in the framework agreement under the Ukraine Facility.
EN 52 EN
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE
3.1. Heading(s) of the multiannual financial framework and expenditure budget
line(s) affected
• Existing budget lines
In order of multiannual financial framework headings and budget lines.
Heading of
multiannual
financial
framework
Budget line Type of
expenditure Contribution
Number
Diff./Non-
diff.35
from
EFTA
countries 36
from
candidate
countries
and
potential
candidates 37
From
other
third
countries
other assigned
revenue
2.2 [06.01.03] – Support expenditure for
borrowing and debt management activities
of the European Union
Non-diff. NO NO NO NO
• New budget lines requested
In order of multiannual financial framework headings and budget lines.
Over and
above MFF
ceilings
Budget line Type of
expenditure Contribution
Number
Diff./Non-
diff.
from
EFTA
countries
from
candidate
countries
and
potential
candidates
from
other
third
countries
other assigned
revenue
O [16.07- Ukraine Support Loan Diff. NO NO NO YES
O [16.07.01] – Debt service cost of Ukraine
Support Loan Diff. NO NO NO YES
35 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 36 EFTA: European Free Trade Association. 37 Candidate countries and, where applicable, potential candidates from the Western Balkans.
EN 53 EN
3.2. Estimated financial impact of the proposal on appropriations
3.2.1. Summary of estimated impact on operational appropriations
– The proposal/initiative does not require the use of operational appropriations
– The proposal/initiative requires the use of operational appropriations, as explained below
3.2.1.1. Appropriations from voted budget
EUR million (to three decimal places)
Heading of multiannual financial framework Number
DG: <…….> Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
Operational appropriations
Budget line 16.07.01 Commitments (1a) 0 1 000.000(*) 1 000.000(*)
Payments (2a) 0 1 000.000(*) 1 000.000(*)
Budget line Commitments (1b) 0.000
Payments (2b) 0.000
Appropriations of an administrative nature financed from the envelope of specific programmes
Budget line 06.01.03 (3) 1.000 1.000 2.000
TOTAL appropriations
for DG <…….>
Commitments =1a+1b+3 0.000 0.000 1.000 1 001.000 1 002.000
Payments =2a+2b+3 0.000 0.000 1.000 1 001.000 1 002.000
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
TOTAL operational appropriations
Commitments (4) 0.000 0.000 0 1 000.000(*) 1 000.000(*)
Payments (5) 0.000 0.000 0 1 000.000(*) 1 000.000(*)
EN 54 EN
TOTAL appropriations of an administrative nature financed
from the envelope for specific programmes (6) 0.000 0.000 1.000 1.000 2.000
TOTAL appropriations under
HEADING <….> Commitments =4+6 0.000 0.000 1.000 1 001.000 1 002.000
of the multiannual financial framework Payments =5+6 0.000 0.000 1.000 1 001.000 1 002.000
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
• TOTAL operational appropriations (all
operational headings)
Commitments (4) 0.000 0.000 0.000 0.000 0.000
Payments (5) 0.000 0.000 0.000 0.000 0.000
• TOTAL appropriations of an administrative nature financed
from the envelope for specific programmes (all operational
headings)
(6) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations Under
Heading 1 to 6 Commitments =4+6 0.000 0.000 0.000 0.000 0.000
of the multiannual financial framework
(Reference amount) Payments =5+6 0.000 0.000 0.000 0.000 0.000
(*) These amounts are indicative and based on current forward interest rates and assuming disbursement of EUR 45 billion in 2026 (EUR 15
billion per quarter as of second quarter of 2026). Actual appropriations in 2027 will depend on market conditions at the time of borrowing and
the actual pace of disbursement, and may reach up to EUR 1.3 billion in a scenario of increase in interest rates by 100 basis points compared to
the baseline.
Heading of multiannual financial framework 7 ‘Administrative expenditure’
Year Year Year Year TOTAL
MFF 2021-
2027 2024 2025 2026 2027
Human resources 0.000 0.000 11.366 11.366 22.732
Other administrative expenditure 0.000 0.000 0.336 0.336 0.672
EN 55 EN
TOTAL Appropriations 0.000 0.000 11.702 11.702 23/404
TOTAL appropriations under HEADING 7 of the multiannual financial
framework
(Total
commitments
= Total
payments)
0.000 0.000 11.702 11.702 23.404
EUR million (to three decimal places)
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
TOTAL appropriations under HEADINGS 1 to 7 Commitments 0.000 0.000 12.702 1 012.702 1 025.404
of the multiannual financial framework Payments 0.000 0.000 12.702 1 012.702 1 025.404
3.2.1.2. Appropriations from external assigned revenues
EUR million (to three decimal places)
Heading of multiannual financial framework Number
DG: <…….> Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
Operational appropriations
Budget line Commitments (1a) 0.000
Payments (2a) 0.000
Budget line Commitments (1b) 0.000
Payments (2b) 0.000
Appropriations of an administrative nature financed from the envelope of specific programmes
Budget line (3) 0.000
TOTAL appropriations Commitments =1a+1b+3 0.000 0.000 0.000 0.000 0.000
EN 56 EN
for DG <…….> Payments =2a+2b+3 0.000 0.000 0.000 0.000 0.000
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
TOTAL operational appropriations
Commitments (4) 0.000 0.000 0.000 0.000 0.000
Payments (5) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations of an administrative nature financed
from the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations under
HEADING <….> Commitments =4+6 0.000 0.000 0.000 0.000 0.000
of the multiannual financial framework Payments =5+6 0.000 0.000 0.000 0.000 0.000
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
TOTAL operational appropriations
Commitments (4) 0.000 0.000 0.000 0.000 0.000
Payments (5) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations of an administrative nature financed
from the envelope for specific programmes (6) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations under
HEADING <….> Commitments =4+6 0.000 0.000 0.000 0.000 0.000
of the multiannual financial framework Payments =5+6 0.000 0.000 0.000 0.000 0.000
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
• TOTAL operational appropriations (all
operational headings)
Commitments (4) 0.000 0.000 0.000 0.000 0.000
Payments (5) 0.000 0.000 0.000 0.000 0.000
EN 57 EN
• TOTAL appropriations of an administrative nature financed
from the envelope for specific programmes (all operational
headings)
(6) 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations under Headings 1
to 6 Commitments =4+6 0.000 0.000 0.000 0.000 0.000
of the multiannual financial framework (Reference
amount) Payments =5+6 0.000 0.000 0.000 0.000 0.000
Heading of multiannual financial framework 7 ‘Administrative expenditure’
EUR million (to three decimal places)
DG: <…….> Year Year Year Year TOTAL
MFF 2021-
2027 2024 2025 2026 2027
Human resources 0.000 0.000 0.000 0.000 0.000
Other administrative expenditure 0.000 0.000 0.000 0.000 0.000
TOTAL DG <…….> Appropriations 0.000 0.000 0.000 0.000 0.000
TOTAL appropriations under HEADING 7 of the multiannual
financial framework
(Total
commitments
= Total
payments)
0.000 0.000 0.000 0.000 0.000
EUR million (to three decimal places)
Year Year Year Year TOTAL MFF
2021-2027 2024 2025 2026 2027
TOTAL appropriations under HEADINGS 1 to 7 Commitments 0.000 0.000 0.000 0.000 0.000
of the multiannual financial framework Payments 0.000 0.000 0.000 0.000 0.000
EN 58 EN
3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)
Commitment appropriations in EUR million (to three decimal places)
Indicate
objectives and
outputs
Year 2024
Year 2025
Year 2026
Year 2027
Enter as many years as necessary to show the
duration of the impact (see Section1.6) TOTAL
OUTPUTS
Type38
Avera
ge
cost
N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost Total
No
Total
cost
SPECIFIC OBJECTIVE No 139…
- Output
- Output
- Output
Subtotal for specific objective No 1
SPECIFIC OBJECTIVE No 2 ...
- Output
Subtotal for specific objective No 2
TOTALS
38 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 39 As described in Section 1.3.2. ‘Specific objective(s)’
EN 1 EN
3.2.3. Summary of estimated impact on administrative appropriations
– The proposal/initiative does not require the use of appropriations of an
administrative nature
– The proposal/initiative requires the use of appropriations of an administrative
nature, as explained below
3.2.3.1. Appropriations from voted budget
VOTED APPROPRIATIONS Year Year Year Year TOTAL
2021 - 2027 2024 2025 2026 2027
HEADING 7
Human resources 0.000 0.000 11.366 11.366 22.732
Other administrative expenditure 0.000 0.000 0.336 0.336 0.672
Subtotal HEADING 7 0.000 0.000 11.702 11.702 23.404
Outside HEADING 7
Human resources 0.000 0.000 0.000 0.000 0.000
Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000
Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000
TOTAL 0.000 0.000 11.702 11.702 23.404
3.2.3.2. Appropriations from external assigned revenues
EXTERNAL ASSIGNED REVENUES Year Year Year Year TOTAL
2021 - 2027 2024 2025 2026 2027
HEADING 7
Human resources 0.000 0.000 0.000 0.000 0.000
Other administrative expenditure 0.000 0.000 0.000 0.000 0.000
Subtotal HEADING 7 0.000 0.000 0.000 0.000 0.000
Outside HEADING 7
Human resources 0.000 0.000 0.000 0.000 0.000
Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000
Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000
TOTAL 0.000 0.000 0.000 0.000 0.000
3.2.3.3. Total appropriations
TOTAL
VOTED APPROPRIATIONS
+
EXTERNAL ASSIGNED REVENUES
Year Year Year Year TOTAL
2021 - 2027 2024 2025 2026 2027
HEADING 7
Human resources 0.000 0.000 11.366 11.366 22.732
Other administrative expenditure 0.000 0.000 0.336 0.336 0.672
Subtotal HEADING 7 0.000 0.000 11.702 11.702 23.404
Outside HEADING 7
Human resources 0.000 0.000 0.000 0.000 0.000
EN 2 EN
Other expenditure of an administrative nature 0.000 0.000 0.000 0.000 0.000
Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000
TOTAL 0.000 0.000 11.702 11.702 23.404
3.2.4. Estimated requirements of human resources
– The proposal/initiative does not require the use of human resources
– The proposal/initiative requires the use of human resources, as explained
below
3.2.4.1. Financed from voted budget
Estimate to be expressed in full-time equivalent units (FTEs)
VOTED APPROPRIATIONS Year Year Year Year
2024 2025 2026 2027
Establishment plan posts (officials and temporary staff)
20 01 02 01 (Headquarters and Commission’s Representation Offices) 0 0 43 43
20 01 02 03 (EU Delegations) 0 0 10 10
01 01 01 01 (Indirect research) 0 0 0 0
01 01 01 11 (Direct research) 0 0 0 0
Other budget lines (specify) 0 0 0 0
• External staff (inFTEs)
20 02 01 (AC, END from the ‘global envelope’) 0 0 2 2
20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0
Admin. Support
line [XX.01.YY.YY]
- at Headquarters 0 0 0 0
- in EU Delegations 0 0 0 0
01 01 01 02 (AC, END - Indirect research) 0 0 0 0
01 01 01 12 (AC, END - Direct research) 0 0 0 0
Other budget lines (specify) - Heading 7 0 0 0 0
Other budget lines (specify) - Outside Heading 7 0 0 0 0
TOTAL 0 0 55 55
3.2.4.2. Financed from external assigned revenues
EXTERNAL ASSIGNED REVENUES Year Year Year Year
2024 2025 2026 2027
Establishment plan posts (officials and temporary staff)
20 01 02 01 (Headquarters and Commission’s Representation Offices) 0 0 0 0
20 01 02 03 (EU Delegations) 0 0 0 0
01 01 01 01 (Indirect research) 0 0 0 0
01 01 01 11 (Direct research) 0 0 0 0
Other budget lines (specify) 0 0 0 0
• External staff (in full time equivalent units)
20 02 01 (AC, END from the ‘global envelope’) 0 0 0 0
20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0
Admin. Support - at Headquarters 0 0 0 0
EN 3 EN
line
[XX.01.YY.YY] - in EU Delegations 0 0 0 0
01 01 01 02 (AC, END - Indirect research) 0 0 0 0
01 01 01 12 (AC, END - Direct research) 0 0 0 0
Other budget lines (specify) - Heading 7 0 0 0 0
Other budget lines (specify) - Outside Heading 7 0 0 0 0
TOTAL 0 0 0 0
3.2.4.3. Total requirements of human resources
TOTAL VOTED APPROPRIATIONS
+
EXTERNAL ASSIGNED REVENUES
Year Year Year Year
2024 2025 2026 2027
Establishment plan posts (officials and temporary staff)
20 01 02 01 (Headquarters and Commission’s Representation Offices) 0 0 43 43
20 01 02 03 (EU Delegations) 0 0 10 10
01 01 01 01 (Indirect research) 0 0 0 0
01 01 01 11 (Direct research) 0 0 0 0
Other budget lines (specify) 0 0 0 0
• External staff (in full time equivalent units)
20 02 01 (AC, END from the ‘global envelope’) 0 0 2 2
20 02 03 (AC, AL, END and JPD in the EU Delegations) 0 0 0 0
Admin. Support line
[XX.01.YY.YY]
- at Headquarters 0 0 0 0
- in EU Delegations 0 0 0 0
01 01 01 02 (AC, END - Indirect research) 0 0 0 0
01 01 01 12 (AC, END - Direct research) 0 0 0 0
Other budget lines (specify) - Heading 7 0 0 0 0
Other budget lines (specify) - Outside Heading 7 0 0 0 0
TOTAL 0 0 55 55
12 posts and 2 FTE will come from redeployments from the limited Commission redeployment pool.
The implementation of this proposal requires 41 additional posts on top of the establishment plan, all
to be financed by Heading 7 beyond stable staffing. A statement to this effect will be proposed as part
of the legislative procedure.
All staff will be financed by Heading 7.
The staff required to implement the proposal (in FTEs):
To be covered by
current staff
available in the
Commission
services
Exceptional additional staff*
To be financed
under Heading 7
or Research
To be financed
from BA line
To be financed
from fees
Establishment 12 posts 41 posts N/A
EN 4 EN
plan posts
External staff
(CA, SNEs, INT)
2 CA
Description of tasks to be carried out by:
Officials and temporary staff 53 officials and temporary staff to work on:
- Programming/expert group/Committee
- Implementation: horizontal tasks, thematic/technical expertise for EU and UA
desks
- Ukraine financing strategy
- Work on MFA
- Work on defence support
- Audit and control
- Legal work
- Financial circuit design
- Accounting tasks
- Headroom sustainability
- Borrowing and loan management
- Cash calls, settlement reporting, etc.
- Manage contracts
External staff 2 FTE to support the work on programming/expert group/committee
3.2.5. Overview of estimated impact on digital technology-related investments
Compulsory: the best estimate of the digital technology-related investments entailed
by the proposal/initiative should be included in the table below.
Exceptionally, when required for the implementation of the proposal/initiative, the
appropriations under Heading 7 should be presented in the designated line.
The appropriations under Headings 1-6 should be reflected as “Policy IT expenditure
on operational programmes”. This expenditure refers to the operational budget to be
used to re-use/ buy/ develop IT platforms/ tools directly linked to the implementation
of the initiative and their associated investments (e.g. licences, studies, data storage
etc). The information provided in this table should be consistent with details
presented under Section 4 “Digital dimensions”.
TOTAL Digital and IT appropriations
Year Year Year Year TOTAL
MFF
2021 -
2027 2024 2025 2026 2027
HEADING 7
IT expenditure (corporate) 0.000 0.000 0.336 0.336 0.672
Subtotal HEADING 7 0.000 0.000 0.336 0.336 0.672
Outside HEADING 7
Policy IT expenditure on operational programmes
0.000 0.000 0.000 0.000 0.000
Subtotal outside HEADING 7 0.000 0.000 0.000 0.000 0.000
EN 5 EN
TOTAL 0.000 0.000 0.336 0.336 0.672
3.2.6. Compatibility with the current multiannual financial framework
The proposal/initiative:
– can be fully financed through redeployment within the relevant heading of the
multiannual financial framework (MFF)
– requires use of the unallocated margin under the relevant heading of the MFF
and/or use of the special instruments as defined in the MFF Regulation
– requires a revision of the MFF
3.2.7. Third-party contributions
The proposal/initiative:
– ☒does not provide for co-financing by third parties
– provides for the co-financing by third parties estimated below.
Appropriations in EUR million (to three decimal places)
Year 2024
Year 2025
Year 2026
Year 2027
Total
Specify the co-financing body
TOTAL appropriations co-
financed
3.3. Estimated impact on revenue
– The proposal/initiative has no financial impact on revenue.
– The proposal/initiative has the following financial impact:
– on own resources
– on other revenue
– please indicate, if the revenue is assigned to expenditure lines
EUR million (to three decimal places)
Budget revenue line:
Appropriations
available for the
current financial
year
Impact of the proposal/initiative40
Year 2024 Year 2025 Year 2026 Year 2027
Budget line
For assigned revenue, specify the budget expenditure line(s) affected.
Other remarks (e.g. method/formula used for calculating the impact on revenue or
any other information).
40 As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net
amounts, i.e. gross amounts after deduction of 20% for collection costs.
EN 6 EN
4. DIGITAL DIMENSIONS
4.1. Requirements of digital relevance
The initiative provides support to a third country and does not establish new EU-level
digital public services for natural or legal persons inside the Union. Nonetheless, digital
elements are supportive for the Ukraine Support Loan where financial assistance
management, defence industrial capability support, and loan initiatives require information
exchange, verification, storage and also provision of information to the Council and
European Parliament where applicable.
R1 – Digital processes for financing and implementation (Chapter V and in particular
Article 26)
Description: transmission of reports, statements or supporting documents electronically
using secure channels and Commission systems for workflows such as requests,
verification, implementing decision or disbursements.
Stakeholders: Commission services and Council; beneficiary authorities, and EEAS for
monitoring the preconditions defined in Article 5.
Processes: Reporting, monitoring, financial management, information exchange.
R2 – Administration of defence-industrial capability support (Chapter IV, in particular
Article 16)
Description: Beneficiary authorities must transmit digital documentation demonstrating
progress on supported defence-industrial capabilities, following Commission standard
templates enabling automated verification.
Stakeholders: Beneficiary authorities; Commission services.
Processes: Monitoring of the implementation and validation of procurements in accordance
with the Regulation.
R3 – Exchange with the European Parliament and the Council, including audit-relevant
information (in particular Chapter VI Articles 28 and 29)
Description: The Commission must provide the European Parliament and Council with
reports and sensitive information through secure systems, where necessary.
Stakeholders: Commission services; European Parliament; Council; beneficiary authorities
(upstream).
Processes: Reporting; audit information exchange; transmission of classified/sensitive
documents.
4.2. Data
For R1–R3, the data includes financial figures, disbursement documentation, defence-
industrial capability data, and other information (including potentially sensitive/classified
material).
Data exchanges are purpose-bound, minimal, interoperable and carried out through existing
EN 7 EN
secure EU systems, avoiding duplicate data collection, aligning with the European Data
Strategy.
Existing Commission datasets and reporting channels will get reused and the aim is that
data already submitted for disbursement or monitoring is not requested again, in-line with
the once-only principle.
Providers: Beneficiary authorities (R1–R2).
Recipients: Commission services; European Parliament and Council for reporting (R3).
Triggers: Reporting cycles, disbursement requests, guarantee notifications, audit
requirements.
Frequency: Periodic (e.g. monthly, or as otherwise defined in the Regulation), and ad hoc
for financial or audit needs.
4.3. Digital solutions
4.4. Interoperability assessment
4.5. Measures to support digital implementation
Concerning all relevant requirements of digital relevance (R1-3), the Commission shall use
a secured exchange system and data templates in order to facilitate the exchange of
classified information and sensitive information between the Commission and Ukraine and,
where appropriate, with the Participating Member States.
Responsibility: Commission services and beneficiary authorities or Participating Member
States or third countries, where appropriate.
AI: No AI functionality is mandated.
Compliance: All systems shall comply with the EU cybersecurity framework, eIDAS, data-
protection rules, and Commission rules on handling classified information.
Reusability: All digital solutions build on existing Commission infrastructure.
The Regulation requires secure exchange of classified/sensitive information, access by the
Commission to all necessary data for obligations laid down in the Regulation, including
verification, and protection of data. All obligations are planned to be met using existing
Commission secure systems without interoperability gaps. This supports R1–R3.
As the Commission already provides assistance to the beneficiary country under existing
financial and operational support frameworks, no additional digital implementation
measures are required for R1 and R3. For defence-industrial capability reporting (R2), the
Commission may, at service level, provide guidance and clarification on the digital
templates and secure exchange procedures to ensure readiness and consistent use by the
involved parties.
Eelnõude infosüsteemis (EIS) on antud täitmiseks ülesanne. Eelnõu toimik: 8.1.1/26-0020 - COM(2026) 20 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL implementing enhanced cooperation on the establishment of the Ukraine Support Loan for 2026 and 2027 Arvamuse andmine eelnõu kohta Rahandusministeeriumile vastavalt Riigikantselei 15.01.2026 resolutsioonile Osapooled: Kaitseministeerium; Välisministeerium Tähtaeg: 21.01.2026 23:59 Link eelnõu toimiku vaatele: https://eelnoud.valitsus.ee/main/mount/docList/aade2f67-1e33-4cd1-ba55-601d0e4230be Link menetlusetapile: https://eelnoud.valitsus.ee/main/mount/docList/aade2f67-1e33-4cd1-ba55-601d0e4230be?activity=2 Eelnõude infosüsteem (EIS) https://eelnoud.valitsus.ee/main