The current IMF program is in limbo due to the failure of the parliament and the government to fulfill key commitments. There is no progress on the implementation of Prior Actions for the new program, which blocks access to USD 8.2 bn from the IMF and about EUR 90 bn from the EU. Without these funds, Ukraine will not be able to finance defense, so the implementation of the Prior Actions must be resumed as soon as possible.
Failure to meet the indicators of the Ukraine Plan for the fourth quarter of 2025 may cost Ukraine
EUR 2.6 bn of unreceived funds , and in total, by the end of 2025, the volume of unfulfilled indicators is worth over EUR 3.9 bn of unreceived financial support . It is important that the vast majority of these indicators are legislative initiatives, the adoption of which falls within the responsibility of the Verkhovna Rada of Ukraine, which emphasizes the importance of returning responsibility to the parliament in ensuring Ukraine’s full access to financing under the Ukraine Facility.
One of the areas of reform that is important in both the numerous IMF programs and the EU support programs is the introduction of effective corporate governance . Much has been done at the legislative level, but the goal is far from being achieved. Today, Ukraine is making another leap in appointing supervisory boards to increase the efficiency of state-owned enterprises.
IMF
The current IMF program is in limbo
We do not fulfill our obligations:
Not fulfilled benchmarks:
#43 New customs service chief
#48 Sectoral plans for public investment management
#53 New property valuation standards
#55 Cancellation of “Lozovyi’s amendments”
#58 External assessment of the National Energy and Utilities Regulatory Commission
Risk of non-fulfillment:
#54 Changes in securitization and mortgage bonds
- Ukraine continues to accumulate unfulfilled obligations under the current IMF program.
- Both the Verkhovna Rada and the Cabinet of Ministers are responsible for the unfulfilled benchmarks.
- Positive news was the review of the selection and appointment of members of the supervisory boards of state-owned enterprises (benchmark #57): this was done with a delay of 4 months.
The new IMF program is vital
No progress with Prior Actions
- The draft law on VAT for individual entrepreneurs was supposed to be submitted to the Rada in January – this did not happen.
- The Cabinet of Ministers took a pause due to political risks and business resistance, despite the Fund’s tough position.
- Ukraine needs to complete Prior Actions as soon as possible to unlock the new collaboration program.
$115+ billion at stake
- $8.2 billion in IMF program funds.
- €90 billion from the European Union, which Ukraine will not receive without a new cooperation program with the IMF.
- Without these funds, Ukraine will not be able to finance defense.
EU
Ukraine Plan : the main updates
- In 2025, Ukraine received €10.6 billion, including €0.6 billion in grants.
- On January 2, 2026, the CMU Resolution No. 1771 came into force, which strengthens the system of management, control and financial transparency regarding the Ukraine Plan.
- Failure to complete 11 indicators for Q4 2025 ‘costs’ more than €2.6 billion. Overall, in 2025, Ukraine failed to meet the indicators by more than €3.9 billion.
- According to the results in Q1 2026, Ukraine may for the first time lose about €0.3 billion without return for failure to fulfill the indicator on increasing the manpower of the High Anti-Corruption Court since Q1 2025
- On January 13, 2026, the European Commission published a proposal establishing a €90 billion Ukraine Support Loan mechanism for 2026-2027.
Breaking ‘records’: 11 unfulfilled indicators in Q4 2025
- 1.2. Legislation to improve procedure for entering, passing, and terminating civil service
- 6.7. Assessment and, if necessary, changes to distinguish PSO from non-PSO in SOEs
- 6.9. Unsuspension of the application of state aid control
- 7.8. Entry into force of the legislation on the Basic Principles of Housing Policy
- 8.2. Deregulation in specific sectors
- 10.3. Improving permitting procedures for renewable energy investments
- 10.7. Appointment of a nominated electricity market operator
- 10.11. Special status of the National Energy and Utilities Regulatory Commission
- 10.14. Supporting the development of efficient and more sustainable district heating
- 11.3. Entry into force of the law on traffic safety and interoperability of railway transport
SPECIAL TOPIC — «Corporate governance reform: how to achieve success?»
Why again about corporate governance in Ukraine?
According to the Ministry of Economy, as of January 1, 2025, 2,916 state-owned companies (SOEs)economy and 345 companies with a state share in the authorized capital > 50%
- Economically active 690 state-owned enterprises and 123 business partnerships
- 397 state-owned enterprises and 82 business associations received profits.
State-owned companies are a source of fiscal risks :.
- Direct support from the state budget to cover losses.
- Conditional debt.
- Quasi-fiscal functions.
! Therefore, great attention has been paid to corporate governance issues by the IMF and the EU: reflected in numerous structural benchmarks and indicators and reforms – most of which have been implemented.
The main principles have already been legislatively adopted ( Law No. 3587-IX of February 22, 2024 , numerous resolutions, recently – Resolution of the Cabinet of Ministers No. 1804 of December 31, 2025 ), but the problem is still there… Questions about the effectiveness of state enterprises remain…
You can view the previous monitors on the website RRR4U
The monitoring was prepared with the support of the International Renaissance Foundation.
RRR4U (Resilience, Reconstruction and Relief for Ukraine) is a consortium of four Ukrainian civil society organisations: Centre for Economic Strategy, Institute for Economic Research and Policy Consulting, Institute of Analytics and Advocacy and DiXi Group.