In September, Ukraine officially requested a new cooperation program from the IMF for the coming years (the current $15.5 billion program ends in 2027). A decision by the IMF Board of Directors is expected by the end of the year. No official details have been released yet .
The situation with the implementation of the indicators of the Ukraine Plan in general also does not look very good. The EU Council finally approved the amendments to the Plan, but we have indicators that we should have implemented in the Q1 2025, but they still remain unfulfilled. In addition, due to the fact that one of the indicators was moved forward in implementation to an earlier date, it is now also included in the list of “unfulfilled” indicators. There is still no information in the public space about the report submitted by Ukraine on the implementation of the indicators of the Ukraine Plan for the Q2 2025, which automatically delays the adoption of a decision on the allocation of funds in exchange for reforms from the EU.
According to the September 2025 report of the Accounting Chamber, Ukraine’s untimely fulfillment or incomplete fulfillment of obligations under the Ukraine Facility and the IMF led to a shortfall of 4.5 billion euros in January-June of this year.
IMF
It is expected that the ninth review of the IMF program will take place approximately in November–December. The Fund will assess the implementation of quantitative performance criteria and structural benchmarks as of the end of September 2025. By the end of September, Ukraine was supposed to fulfill 8 structural benchmarks but managed to fully meet only 3, with 2 more completed with delays.
In September, Ukraine officially requested the IMF to launch a new cooperation program for the coming years (the current $15.5 billion program runs until 2027). A decision of the IMF Executive Board is expected by the end of the year. In mid-October, during the government delegation’s visit to Washington, a meeting was held with the IMF leadership to discuss, among other issues, the new support program and the upcoming IMF mission.
Benchmarks to be evaluated during the ninth review
The unfulfilled benchmarks include: extending the NBU’s supervision to critical third parties (51), repealing the “Lozovyi amendments” (55), and revising the process of selection and appointment of supervisory board members in state-owned enterprises (57). Ukraine may still complete them with delays (behind schedule).
EU
- The EU Council approved the updated Ukraine Plan within the Ukraine Facility;
- Unfulfilled obligations are accumulating: 9 indicators for the Q1-Q3 of 2025 have not been met;
- High risk of failure to meet a number of indicators for the Q4: only 2 months remain for the adoption of a number of draft laws.
SPECIAL TOPIC — “De-shadowing the Economy: A Challenge and an Opportunity for Ukraine”
Why are we talking about de-shadowing?
De-shadowing is about a level playing field for business entities
- De-shadowing — higher revenues for state and local budgets — is extremely important today, as it concerns the state’s defense capability.
At the same time, this requires:
- Effective institutions (this includes not only tax and customs administration, but also a law enforcement system that protects property rights)
- Transparent and understandable rules of the game
Measures in the IMF program related to de-shadowing
- Preparation of a plan for changes to the tax system in accordance with the National Revenue Strategy
- Adoption of the reform plan of the State Tax Service and the State Customs Service
- Appointment of heads of the Bureau of Economic Security and the State Customs Service through open and transparent competitions
- IT strategy and operational plan — a joint document of the Ministry of Finance, State Tax Service and State Customs Service
- Corporate governance in state-owned enterprises
Measures in Ukraine Plan related to de-shadowing
- Implementation of the National Revenue Strategy
- Approval of plans for the digitalization of the State Tax Service and the State Migration Service
- ESBU Reform
- Closing existing tax gaps
- Further reform in the field of corporate governance
- Steps to strengthen the judicial system
- Transparent and merit-based selection of prosecutors for leadership positions in prosecutorial bodies and other steps in the field of prosecutorial reform
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.