Ukraine failed to meet 15 reform benchmarks under the Ukraine Facility in 2025, leaving part of EU support conditional. Most of the shortfall was concentrated in the final quarter.
The Resilience, Reconstruction and Relief for Ukraine Consortium (RR4U), a Ukrainian-led policy and monitoring coalition, estimates that unfulfilled reform indicators under the Ukraine Facility amounted to over €3.9 billion ($4.6 billion) in 2025. Of this total, over €2.6 billion ($3.07 billion) stems from 11 benchmarks missed in the fourth quarter, while approximately €1.3 billion ($1.53 billion) relates to obligations carried over from the first three quarters of the year.
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Under the Ukraine Facility, which provides up to €50 billion ($59 billion) for 2024-2027, the EU allows partial disbursement for some indicators (benchmarks) and gives governments a limited time to catch up on missed reforms. However, if benchmarks remain unfulfilled beyond a set deadline – typically up to one year – the funds can be permanently withheld.
Ukraine’s access to EU money is conditional and depends on progress in governance and reforms. With the closure of USAID, these tranches have become more critical.
While the country continues to receive regular tranches, having persistent delays in completing the reform benchmarks risks reducing future payments, triggering stricter audits, or permanent losses of earmarked funds.
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Missing benchmarks and key analyst concerns
One such case involves the delayed expansion of Ukraine’s High Anti-Corruption Court, where around €300 million ($354 million) could be lost as early as the first quarter of 2026 if the issue is not resolved.
Delays from the first quarter include increasing the staff of the High Anti-Corruption Court, followed by missed second-quarter targets for reforming judicial integrity declaration reviews and digitalizing enforcement proceedings.
In the third quarter, Ukraine failed to pass legislation for the electricity integration package.
For the fourth quarter, several critical reforms are still pending, including amendments to the civil service law, the streamlining of permitting procedures for renewable energy investments, the appointment of a nominated electricity market operator, and the granting of special status to the energy regulator
The key problem for Ukraine, highlighted by RRR4U, is that the authorities announce the reform, prepare the legislation and declare the political will to launch a policy, but then stall the final execution. However, Ukraine still unlocked multiple tranches in 2025 despite these flaws in the policymaking process.
Members of the consortium point to parliamentary gridlock and competing wartime priorities as key bottlenecks, particularly for reforms requiring politically sensitive votes.
“As of Jan. 30, 2026, we have not fulfilled a single obligation for the first quarter. At the same time, there are still many obligations for the following quarters,” analyst Vitaliy Nabok said, according to the RRR4U’s press release.
The situation may worsen in 2026.
According to the monitoring report, Ukraine has not yet fulfilled any reform benchmarks scheduled for the first quarter of the new year, while additional obligations are set to accumulate in subsequent quarters.
This raises the risk that delayed reforms from 2025 could overlap with new deadlines, compounding funding pressures.
The warning comes just weeks after Ukraine received another €2.3 billion ($2.71 billion) tranche from the EU under the Ukraine Facility – which has delivered approximately €26.7 billion ($31.51 billion) since 2024.
The RR4U includes several leading Ukrainian think tanks and NGOs, including the Institute for Economic Research (IER), Dixi Group, the Institute of Analytics and Advocacy, and the Centre for Economic Strategy (CES). The document tracks Ukraine’s progress under the IMF program and the Ukraine Plan – the framework that conditions EU budget financing on reform performance.