Ukraine is still slowly fulfilling the obligations that will allow it to receive a tranche of assistance from the World Bank under the Development Policy Operation (DPO-2 2026) support instrument. 12 obligations have been identified for this purpose.
In September, the IMF Mission begins work on the second review of the IMF Program. The structural benchmarks with a deadline of the end of June have been completed. The Mission will most likely also analyze the Draft State Budget for 2027. However, the implementation of the following benchmarks is delayed.
Some of the indicators of the Ukraine Plan were implemented in August with a delay; in particular, the appointment of judges of the High Anti-Corruption Court, a step that was originally scheduled for 2025. Overall, the fulfillment of these “backlogged” indicators is expected to release approximately €2.8 billion. At the same time, 15 indicators for 2025 and the first half of 2026, worth €4.8 billion, remain unfulfilled.
Requirements for Receiving Assistance from the World Bank
DPO 2 – New Challenges
- In August, there were no significant developments in the implementation of obligations, the fulfillment of which will allow Ukraine to receive funds under the second component of the DPO loan in the amount of USD 1 billion.
- Overall, Ukraine must fulfill 12 obligations by the end of 2026 or at least no later than the 1st quarter of 2027.
- Three main areas of reform:
- Private sector financing and investment
- Skilled labor force and employment
- Cross-border market integration
- The obligations include the adoption of legislative and regulatory acts that must comply with EU law.
Private sector financing and investment
Public-private partnership (PPP)
- Adopt the regulatory legal acts necessary for the implementation of the law on public-private partnership: actual implementation of the adopted law on PPP ( No. 4510-IX ) – in progress
Access to finance and cross-border payments
- Adopt regulatory legal acts for the practical implementation of the laws on factoring and the National Development Agency: these laws were adopted for DPO-1 ( No. 4466-IX and No. 4622-IX, respectively ) – in progress
- Adopt the law on investment funds, draft law No. 13246 (registered on May 1, 2025, there is no conclusion from the relevant committee yet – however, there is a statement about its withdrawal )
- Adopt a law on property valuation – draft law No. 13435 (adopted as a basis on June 30) – in progress
- Adopt a law on joining the Single Euro Payments Area – SEPA: the law was transferred from DPO-1. The government draft law was withdrawn due to a change of government, although it is a deputy’s (corresponds to Indicator 4.9. of Ukraine Plan) – the government draft law was withdrawn, it is a deputy’s 14327-1 dated 09.01.2026 – the Committee’s conclusion on the recommendation to adopt in the first reading dated April 7, 2026 – in progress
Privatization and corporate governance of state-owned enterprises
- Announce a privatization tender for at least one state-owned bank – Prime Minister of Ukraine Serhiy Koretsky announced that the Ministry of Finance has been tasked with selling Sense Bank
- Adopt a law on small-scale privatization – there is no draft law yet
- Adopt regulations and legislative amendments to strengthen corporate governance and the work of supervisory boards of state-owned enterprises
IMF
IMF programme: Delays Continue
- The IMF Mission begins its work in early September:
- Assessment of the implementation of structural benchmarks and quantitative criteria as of the end of June 2026
- Assessment and analysis of the draft State Budget for 2027 – a challenge is in changing macroeconomic forecast
- Successful second review of the program = $692 million
- Structural benchmarks with a completion date of the end of June 2026:
- Benchmark No. 7. Approval of an updated strategy for state-owned banks, which takes into account the goals of privatization and the extension of the guarantees of Article 7 of the Law “On Banks and Banking Activities” to all systemically important banks with a majority state share – completed
- Benchmark No. 8. Entry into force of the system of supervision of risks of critical third parties in the financial sector – completed
Other structural benchmarks with deadlines by the end of August – NOT completed as of August 31
Benchmark No. 11. Adoption of legislation on taxation of income received through digital platforms and abolition of tax exemption for inexpensive imported goods in postal items – NOT implemented .
Benchmark No. 12. Submission to the Verkhovna Rada of amendments to the Tax Code regarding the reform of transfer pricing rules and the limitation of interest expenses – as of August 31 – absent .
Benchmark No. 13. Submission of amendments to the Tax Code to increase the threshold for conducting unscheduled inspections in the event of declaring a budget refund or negative VAT value from UAH 100 thousand to UAH 1 million – as of August 31 – absent .
A number of other benchmarks with deadlines in the end of 2026 are at risk of not being completed on time.
EU
Ukraine Plan: Indicators are being met with delays, and debts are accumulating
- For August, 5 indicators were fulfilled with a delay: two for 2025, one for Q1 2026, and two for Q2 2026. Also, the investment indicators for Q2 2026 are considered fulfilled. At the same time, debts remain:
– 6 indicators for 2025
– 3 indicators for Q1 2026
– 5 indicators for Q2 2026
Failure to implement indicators can “cost” ~€ 4.48 billion
Monitoring of Macro-Financial Assistance: Ukraine Support Loan
- 4 of the 12 conditions required to receive the second tranche of assistance have been met: IT concept of the UPI, Budget declaration, expenditure reviews, and adoption of the updated digital development plan of the State Customs Service of Ukraine until 2030.
- Unfortunately, the President has not signed the law introducing taxation of income earned via digital platforms — this is one of the 12 conditions required to receive the second tranche of assistance. We had previously marked this indicator as ‘fulfilled’, but have now reverted it to ‘in progress’.
SPECIAL TOPIC — «New government, new pace: Will Ukraine be able to accelerate reforms?»
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.