Despite the approval of a new IMF program at the end of last year, Ukraine is showing significant negative dynamics in fulfilling its commitments, which affects access to financing in the amount of more than $115 billion. This was stated by experts from the RRR4U analytical consortium during the presentation of the 23-rd monitoring of the implementation of the IMF program and the Ukraine Facility plan.
In particular, the new IMF program is in limbo due to the failure of the parliament and the government to fulfill key commitments. There has been no progress on the prior actions for the new program. This closes access to $8.2 billion from the IMF and could slow down about €90 billion from the EU. Without these funds, Ukraine will not be able to finance state budget expenditures, particularly on defense, so the prior actions must be implemented as soon as possible.
At the same time, failure to meet the indicators of the Plan for Ukraine for the fourth quarter of 2025 could cost Ukraine €2.6 billion in lost funds, and in total, by the end of 2025, the price of unfulfilled indicators exceeds €3.9 billion in lost financial support.
IMF program: $115 billion at stake
According to the consortium, as of the end of January, Ukraine owed a number of milestones under the current IMF program, including:
- Appointment of a new customs chief
- Sectoral plans for public investment management
- New property valuation standards
- Repeal of the “Lozovoy amendments”
- External evaluation of the NEURC.
At the same time, in order to launch a new IMF program worth $8.2 billion, Ukraine must implement a number of “prior actions” aimed at mobilizing budget revenues, including:
- Taxation of parcels
- Introduction of VAT for simplified taxpayers
- Taxation of income from digital platforms.
“Mobilizing domestic resources is not just an IMF requirement, but a matter of survival. We spend half as much on defense as Russia, while there is currently no aid from the US in the form of grants. So these changes are something that Ukrainian society must agree to internally if we want to defend our country against the aggressor,” emphasized Maria Repko, deputy executive director of the Center for Economic Strategy.
According to Maria Repko, the success of the new $8.2 billion IMF program is critical because it is linked to an unprecedented €90 billion loan from the EU (Ukraine Support Loan), which Ukraine is to receive instead of funds from frozen Russian assets. There is also talk of assistance from other donors. The total amount of assistance, anchored by the new IMF program, is about $115 billion.
Ukraine Facility: debt on indicators is growing
The situation with the implementation of the Ukraine Facility also remains alarming. Vitaliy Nabok, senior analyst at the Institute for Analytics and Advocacy, noted that 11 indicators worth €2.6 billion remain unfulfilled for the fourth quarter of 2025 (in total, last year’s shortfall in support due to unfulfilled indicators amounted to over €3.9 billion).
Among the unfulfilled commitments are:
- Increasing the staffing of the High Anti-Corruption Court (Q1)
- Changes regarding the review of judges’ integrity declarations and their verification (Q2)
- Reform of the digitization of enforcement proceedings (Q2)
- Adoption of legislation for the electricity integration package (Q3)
The fourth quarter refers to changes in legislation on public service, improvement of licensing procedures for investments in renewable energy sources, appointment of a nominated electricity market operator, determination of the special status of the National Energy and Utilities Regulatory Commission, support for the development of efficient and more sustainable centralized heat supply, and others.
However, according to the High Council of Science and Education, the competition is still ongoing, so there is a possibility that this indicator will be fulfilled, albeit with a year’s delay, and the funds will still be received.
“But as of now (January 30, 2026), we have not fulfilled a single obligation for the first quarter. At the same time, there are still many commitments in the coming quarters,” said Vitaliy Nabok.
The vast majority of unfulfilled indicators are legislative initiatives, the adoption of which falls within the responsibility of the Verkhovna Rada of Ukraine. This underscores the importance of restoring the parliament’s responsibility for ensuring Ukraine’s full access to funding.
“Therefore, today the situation with the implementation of Ukraine’s Plan is significantly negative, as we have a lot of unfulfilled indicators and are actually losing almost €4 billion. I urge parliament not to treat this as another step ”for the sake of appearances,“ but as a means of ensuring the stability of our budgetary system,” emphasized Nabok.
The full recording of the event is available at: https://www.youtube.com/watch?v=AOf6txvRo8o
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.
