Parliament must pass 35 laws by year-end to deliver on EU and World Bank programmes

In September, Ukraine accelerated progress on some of its overdue commitments to the European Union, the International Monetary Fund and the World Bank, but incurred new delays. This puts more than €5 billion in funding at risk under the Ukraine Facility, while also complicating the receipt of the EU’s second macro-financial assistance tranche and the next review of the IMF programme. This comes at a time when Ukraine is facing severe funding shortages and development spending is being put on hold. At the same time, Parliament needs to pass 35 laws by the end of the year to fulfil commitments under EU and World Bank programmes.

Experts from the RRR4U Consortium made the statement during their monthly presentation of monitoring of the IMF programme and EU assistance.

IMF: Second Review Still Pending

Negotiations between the Ukrainian authorities and the IMF mission, which was in Ukraine in early September, ended without a staff-level agreement on the second review of the programme.

One of the key issues discussed was the unfunded state budget deficit for 2027, said Viacheslav Kurylo, Senior Policy and Data Analyst at the Institute for Analysis and Advocacy. Of the $52.6 billion in external financing Ukraine needs, $32.6 billion remains unfunded.

“We do not have much time to address the issues raised by the mission. However, by the start of the next mission in November, we definitely need to have confirmation of all external financing sources required to cover the budget deficit in 2027,” Viacheslav Kurylo said. If the review is successfully completed, Ukraine could receive around $692 million from the IMF.

The IMF is calling for changes aimed at increasing budget revenues. These include abolishing the tax exemption for international postal shipments worth up to €150.

Among other problematic structural benchmarks that were due by the end of August, the expert cited legislation on taxing income earned through digital platforms, which has not yet been signed by the President, as well as raising the threshold to UAH 1 million for conducting unscheduled tax audits in cases involving VAT refunds or a negative VAT balance.

In addition, by the end of September, the National Agency on Corruption Prevention (NACP) was expected to introduce a risk-based system for verifying asset declarations.

World Bank: 11 Triggers Required for $1 Billion

To receive $1 billion under the second component of the World Bank’s Development Policy Financing programme, Ukraine must meet 11 commitments. However, progress on their implementation has been limited since August.

Formally, the commitments can be fulfilled by the end of the first quarter of 2027. However, given Ukraine’s financing needs, they should be completed by the end of 2026.

“We call on both MPs and government representatives to work towards timely implementation of the commitments under both the IMF and World Bank programmes,” Viacheslav Kurylo said.

Ukraine Facility: 84 of 95 Indicators Completed, Delays Mounting

In September, the EU approved Ukraine’s eighth payment under the Ukraine Facility, worth €2.9 billion. Ukraine met 10 indicators to qualify for the payment, bringing the total number of completed indicators to 84 out of 95 whose deadlines have already passed.

“There is progress, but it is slow. In September, the government stepped up its efforts overall to implement all indicators and reforms. Six overdue decisions were adopted that should have been completed back in 2025 and the first half of 2026. One decision was also completed on time, in the third quarter,” said Oleksandra Myronenko, an economist at the Centre for Economic Strategy.

In September, three measures from 2025, worth €0.7 billion, were completed. Of the indicators for the first quarter of 2026, one worth €0.3 billion was completed, while two worth €0.7 billion were completed from the second quarter.

However, eight indicators from these periods remain outstanding, along with another eight for the third quarter of 2026. Among the outstanding reforms from last year, the expert cited amendments to legislation on the civil service, establishing a special status for the National Energy and Utilities Regulatory Commission (NEURC), and lifting the suspension of the State Aid Law. These three measures are valued at €0.7 billion.

Measures for the first quarter of 2026 — transparent selection of prosecutors and simplified bankruptcy procedures for small businesses — are worth €1.1 billion, while measures for the second quarter are worth another €1.05 billion.

The outstanding third-quarter indicators are valued at €2.2 billion. They include strengthening the anti-money laundering framework, ensuring transparency of transfers of funds and certain crypto-assets, and combating the illegal use of payment cards. Some of these draft laws have passed their first reading but still require final approval by Parliament and the President’s signature.

Taken together, failure to fulfil these commitments could put €5 billion in funding at risk.

“€5 billion in funding is critically important for the budget right now, especially as the war is becoming more costly and budgetary needs are not declining,” Oleksandra Myronenko said.

Second EU Macro-Financial Assistance Tranche: Half of the Conditions Met

In 2026, the budgetary and macro-financial assistance component of the Ukraine Support Loan mechanism provides for €8.35 billion, divided into three tranches. Ukraine has already received the first tranche of €3.2 billion.

The second tranche of €3.7 billion was planned for September, while the third, due by the end of the year, amounts to another €1.45 billion.

According to Alona Korohod, Project Expert at DiXi Group, only six of the 12 conditions for the second tranche have been met so far. Outstanding conditions include legislation on taxing income earned through digital platforms, abolishing tax exemptions for imported parcels, a framework law on property valuation, as well as a number of tasks for the State Tax Service and the Verkhovna Rada. “The key task is to complete these measures to ensure that the next tranche is received on time,” she said.

At the same time, in September Ukraine fulfilled two conditions for the third tranche: it submitted to Parliament a draft law reforming the preferential tax regime and the draft 2027 state budget, including an explanation of how the results of the spending review were reflected in budget allocations.

“The priority remains fulfilling all six conditions for the second tranche, because under this mechanism, funds will only be disbursed once all conditions have been met. In other words, unlike the Ukraine Facility, there are no partial payments under this mechanism,” Alona Korohod explained.

Dozens of Laws Need to Be Passed by Year-End

Ukraine continues to meet its international commitments, but progress remains insufficient. Oleksandra Betliy, Lead Expert at the Institute for Economic Research and Policy Consulting (IER), noted that Parliament needs to pass 35 laws by the end of the year just to fulfil commitments under EU and World Bank programmes, while the government needs to complete more than 30 indicators.

“Many of these laws need to be passed by around 10 November if we want to receive at least some funding before the end of this year and, as a result, unlock at least part of capital spending,” Oleksandra Betliy said.

According to her, fulfilling the conditions of the Ukraine Facility, the World Bank and other programmes is only part of Ukraine’s tasks on its path towards EU membership.

“And therefore, slowing down and failing to implement all these measures also means that we are moving further away from fulfilling our national EU integration programme, and consequently, EU accession is being delayed further,” she concluded.

More details are available in the Monitoring report below. Watch the event recording.

RRR4U (Resilience, Reconstruction and Relief for Ukraine) is a Consortium of four Ukrainian civil society organisations: the Centre for Economic Strategy, the Institute for Economic Research and Policy Consulting, the Institute for Analysis and Advocacy, and DiXi Group.