COMMISSION STAFF WORKING DOCUMENT Ukraine 2025 Report Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2025 Communication on EU enlargement policy
Date: 2025-11-04
Institutions: Directorate-General for Enlargement and Eastern Neighbourhood, European Commission
Subjects: Ukraine, accession criteria, accession negotiations, pre-accession strategy, regional cooperation

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.11.2025  SWD(2025) 759 final  COMMISSION STAFF WORKING DOCUMENT Ukraine 2025 Report Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2025 Communication on EU enlargement policy                             {COM(2025) 690 final} - {SWD(2025) 750 final} - {SWD(2025) 751 final} - {SWD(2025) 752 final} - {SWD(2025) 753 final} - {SWD(2025) 754 final} - {SWD(2025) 755 final} - {SWD(2025) 756 final} - {SWD(2025) 757 final} - {SWD(2025) 758 final}  
 
 
Contents 
1. 

Introduction .......................................................................................................................................................... 3 

1.1. Context ............................................................................................................................................................... 3 

1.2. 

Main findings of the report ......................................................................................................................... 3 

1.3  State of play of the accession negotiations ...................................................................................................... 21 

2. Cluster 1: The fundamentals of the accession process ............................................................................................. 21 

2.1. Functioning of democratic institutions and public administration reform ....................................................... 21 

2.1.1 Democracy ................................................................................................................................................ 21 

2.1.2. Public administration reform .................................................................................................................... 25 

2.2. Rule of law and fundamental rights ................................................................................................................. 28 

2.2.1 

2.2.2 

Chapter 23: Judiciary and fundamental rights ................................................................................. 28 

Chapter 24: Justice, freedom and security ...................................................................................... 49 

2.3. Economic criteria ............................................................................................................................................. 58 

2.3.2. The capacity to cope with competitive pressure and market forces within the EU .................................. 64 

2.4. Public procurement, statistics and financial control ......................................................................................... 65 

Chapter 5 - Public procurement ......................................................................................................................... 65 

Chapter 18 - Statistics ........................................................................................................................................ 66 

Chapter 32 - Financial control ............................................................................................................................ 67 

3. Good neighbourly relations and regional cooperation ............................................................................................. 69 

4. Ability to assume the obligations of membership .................................................................................................... 71 

Cluster 2: Internal market ....................................................................................................................................... 71 

Chapter 1 - Free movement of goods ................................................................................................................. 71 

Chapter 2 - Freedom of movement for workers ................................................................................................. 72 

Chapter 3 - Right of establishment and freedom to provide services ................................................................. 72 

Chapter 4 - Free movement of capital ................................................................................................................ 72 

Chapter 6 - Company law .................................................................................................................................. 74 

Chapter 7 - Intellectual property law .................................................................................................................. 74 

Chapter 8 - Competition policy .......................................................................................................................... 75 

Chapter 9 - Financial services ............................................................................................................................ 76 

Chapter 28 - Consumer and health protection .................................................................................................... 77 

Cluster 3: Competitiveness and inclusive growth ................................................................................................... 78 

Chapter 10 - Digital transformation and media .................................................................................................. 78 

Chapter 16 – Taxation ........................................................................................................................................ 80 

Chapter 17 - Economic and monetary policy ..................................................................................................... 81 

Chapter 19 - Social policy and employment ...................................................................................................... 82 

Chapter 20 - Enterprise and industrial policy ..................................................................................................... 83 

Chapter 25 – Science and research ..................................................................................................................... 84 

Chapter 26 - Education and culture .................................................................................................................... 85 

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Chapter 29 - Customs union ............................................................................................................................... 86 

Cluster 4: The green agenda and sustainable connectivity ...................................................................................... 87 

Chapter 14 - Transport policy ............................................................................................................................ 87 

Chapter 15 – Energy ........................................................................................................................................... 89 

Chapter 21 - Trans-European networks .............................................................................................................. 91 

Chapter 27 - Environment and climate change .................................................................................................. 91 

Cluster 5: Resources, agriculture and cohesion ...................................................................................................... 94 

Chapter 11 - Agriculture and rural development ................................................................................................ 94 

Chapter 13 - Fisheries and aquaculture .............................................................................................................. 96 

Chapter 22 – Regional policy and coordination of structural instruments ......................................................... 97 

Chapter 33 - Financial and budgetary provisions ............................................................................................... 98 

Cluster 6: External Relations .................................................................................................................................. 99 

Chapter 30 - External relations........................................................................................................................... 99 

Chapter 31 - Foreign, security and defence policy ........................................................................................... 100 

Annex I - Relations between the EU and Ukraine ................................................................................................ 102 

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1. 

INTRODUCTION1  

1.1. CONTEXT 

Ukraine  has  continued  to  show  remarkable  resilience  and  strong  commitment  to  its  European  path 
despite  the  escalation  of  Russia’s  ongoing  war  of  aggression  including  a  substantial  increase  of 
Russian  air  attacks  against  cities  and  civilian  objects  that  has  led  to  more  civilian  victims.  Ukraine 
applied  for  EU  membership  on  28 February  2022  and  the  intergovernmental  conference  to  open 
accession  negotiations  with  Ukraine  took  place  on  25 June 2024.  Bilateral  screening  meetings  were 
completed  in  September  2025.  On  14 May 2025,  Ukraine  adopted  roadmaps  on  rule  of  law,  public 
administration reform and on the functioning of democratic institutions, as well as an action plan on 
national  minorities  and  its  negotiating  position  for  Cluster  1.  This  progress,  which  has  been  made 
despite the challenge of the Russian aggression, signals Ukraine’s strong commitment to its European 
future. However, there have also been some elements of notable concern, in particular in ensuring a 
robust and independent anti-corruption framework.   

Regular political and economic dialogue between the EU and Ukraine has also continued, including 
through the Association Agreement and the Deep and Comprehensive Free Trade Area, and the joint 
bodies under the agreement.  

Since  the  beginning  of  Russia’s  war  of  aggression,  the  EU  and  its  Member  States  have  mobilised 
EUR  177.6  billion  in  support  of  Ukraine  and  its  people.  The  recommendations  in  this  report  are 
aligned  with  the  main  priorities  of  the  Ukraine  Plan  under  the  Ukraine  Facility  for  the  coming  12 
months.  

The  EU-Ukraine  joint  security  commitments  signed  in  2024  continue  to  guide  the  EU  and  the 
Member  States’  support  for  Ukraine’s  security,  resilience  and  defence  support,  complementary  to 
Member States’ bilateral commitments.  

The EU continues to fully support the independence, sovereignty and territorial integrity of Ukraine, 
within  its  internationally  recognised  borders.  Ukraine  maintains  a  high  level  of  alignment  with  the 
EU’s common foreign and security policy. 

1.2.  MAIN FINDINGS OF THE REPORT 

CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS 

Democracy 

The general framework remains overall conducive to the organisation of democratic elections, upon a 
future lifting of martial law, once circumstances allow. A number of key recommendations from the 
latest  election  observation  mission  reports  of  the  Organization  for  Security  and  Co-operation  in 
Europe  (OSCE)  /  Office  for  Democratic  Institutions  and  Human  Rights  (ODIHR)  have  been 
implemented. Electoral reforms should continue to address outstanding recommendations and prepare 
for a potential scenario of post-war elections. 

Parliament  (Verkhovna  Rada)  can  exercise  its  powers,  including  control  of  the  executive  and 

1 This report covers the period from 1 September 2024 to 1 September 2025. It is based on input from a variety 
of sources, including contributions from the government of  Ukraine and the EU Member States, reports of the 
European  Parliament  and  information  from  various  international  and  non-governmental  organisations.  It  also 
includes the results of comparative assessments and indices produced by other stakeholders, in particular in the 
area of rule of law. 
The  report  uses  the  following  assessment  scale  to  describe  the  state  of  play:  early  stage,  some  level  of 
preparation,  moderately  prepared,  good  level  of  preparation  and  well  advanced.  To  describe  progress  made 
during  the  reporting  period,  it  uses  the  following  scale:  backsliding,  no  progress,  limited  progress,  some 
progress, good progress and very good progress. Where appropriate, interim steps have also been used. 

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involvement in the legislative process, in a partially effective way due to the limitations imposed by 
martial  law.  Through  the  roadmap  on  the  functioning  of  democratic  institutions,  Ukraine  has 
committed to  several measures  aimed  at ensuring  a  comprehensive impact assessments  of  proposed 
legislation,  and  at  strengthening  legislative  oversight  of  the  executive.  These measures  also  include 
monitoring of the implementation of legislation.  

Ukraine’s government has continued to perform its functions in an effective way, prioritising security 
and  defence,  EU  integration,  economic  recovery  and  reconstruction.  Decentralisation  reform  must 
advance in an effective and tangible way, in line with the measures set by the government and in line 
with the Ukraine Plan and public administration reform (PAR) roadmap. 

The institutions in charge of EU integration are in place and are actively involved in coordinating the 
contributions  of  various  stakeholders  to  the  screening  process,  as  well  as  in  strategic  documents 
related  to  the  accession  process.  A  team  has  been  created  to  draft  the  National  Programme  for  the 
Adoption  of  the  Acquis  (NPAA)  and  the  drafting  process  was formally launched  in  May  2025.  EU 
integration  expertise,  planning  and  inter-institutional  mechanisms  should  be  further  strengthened  so 
that Ukraine can transpose the EU acquis into national legislation effectively. The active involvement 
of  all  stakeholders  must  be  ensured,  with  emphasis  on  cooperation  between  the  executive  and 
legislative  powers.  The  government  needs  to  continue  communicating  with  the  public  about  EU 
integration. 

Civil society organisations (CSOs) operate in an overall enabling environment, but there have been 
incidents  of  alleged  political  pressure  on  anti-corruption  activists.  Such  cases,  also  against  human 
right defenders and CSOs, must be monitored and addressed. Three laws were adopted to strengthen 
the  engagement  and  consultation  of  the  public  and  CSOs  in  policymaking  and  decision-making 
processes at the central and sub-national government levels. Once martial law ends, steps will need to 
be taken to implement the laws.  

Public administration reform  

Ukraine  is  between  having  some  and  a  moderate  level  of  preparation  in  the  area  of  public 
administration  and  has  made  good  progress,  notably  in  the  areas  of  service  delivery  and 
digitalisation,  salary  reform  and  alignment  of  legislation  with  the  Law  on  administrative  procedure 
(LAP). The government has resumed medium-term budget planning with the adoption of the budget 
declaration for 2025-2027. The law to improve recruitment procedures and fully restore merit-based 
recruitment was registered. 

The Commission’s recommendations from last year were broadly implemented and remain partially 
valid. In the coming year Ukraine should, in particular: 

→  in  line  with  the  Ukraine  Plan,  adopt  legislation  to  improve  procedures  for  merit-based 
recruitment,  promotion  and  dismissal,  and  resume  merit-based  recruitment  for  all  civil  service 
posts through the unified state web portal of electronic services; further advance the countrywide 
roll-out and use of the human resources management information system; 

→  adopt  new  strategies  for  public  administration  reform  (PAR)  and  public  financial  management 

(PFM) for the period 2026-2030, ensuring full alignment with the PAR roadmap;  

→  complete  legislative  alignment  and  harmonisation  with  the  LAP,  particularly  in  the  areas  of 
taxation,  customs  and  land  relations,  and  align  digital  administrative  procedures  and  secondary 
legislation with the LAP. 

Chapter 23: Judiciary and fundamental rights 

Ukraine  has  some  level  of  preparation  regarding  the  judiciary,  the  fight  against  corruption  and 
respect for fundamental rights and made some progress, with progress seen across all areas.   

Functioning of the judiciary 

Ukraine has some level of preparation in the functioning of the judiciary. Some progress was made 
during the reporting period, notably by adopting and starting to implement legislation to establish the 

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Kyiv  Specialised  District  Administrative  Court  and  the  Kyiv  Specialised  Administrative  Court  of 
Appeal , through the ongoing selection and appointment of judges and members of the High Council 
of Justice (HCJ) and the evaluation of the qualifications of sitting judges (vetting), and by setting up 
the Service of Disciplinary Inspectors (SDI). A roadmap for the e-judiciary system was approved and 
the  development  of  the  e-case  management  system  in  the  criminal  justice  chain  (SMEREKA) 
continued.  However,  the  judiciary  still  suffers  from  severe  understaffing  and  high  workloads. 
Integrity, meritocracy and capacities of the judiciary and prosecutorial service, as well as the status of 
the  Public  Integrity  Council  remain  weak.  The  Parliament  failed  to  appoint  internationally  vetted 
candidates to the Constitutional Court (CCU), further delaying the renewal of the CCU. The position 
of the Prosecutor General remains politicised. The provisions on automatic closure of criminal cases 
due  to  expiry  of  pre-trial  investigation  time  limits  after  the  notice  of  suspicion  and  shortened 
investigation  time  limits  led  to  the  closure  of  several  high-profile  cases  and  others  are  at  risk. 
Legislation  introduced  in  July  2025  allows  for  transfer  and  appointment  of  prosecutors  without 
competition and grants the Prosecutor General access to any pre-trial investigation material (except of 
the  National  Anti-Corruption  Bureau  (NABU)  and  the  Specialized  Anti-Corruption  Prosecutor’s 
Office (SAPO)). 

The  Commission’s  recommendations  from  last  year  were  partially  met  and  remain  valid.  In  the 
coming year, Ukraine should in particular: 

→  in line with the Ukraine Plan, accelerate the filling of judicial vacancies and the evaluation of the 
qualifications  (vetting)  of  sitting  judges,  with  the  involvement  of  the  Public  Integrity  Council; 
operationalise the new specialised administrative courts; 

→  in  line  with  the  Ukraine  Plan,  continue  to  settle  ongoing  disciplinary  proceedings;  adopt 
legislation  to  improve  judges'  declarations  of  integrity  and  their  verification,  the  selection  of 
management-level  prosecutors,  the  disciplinary  system  for  prosecutors  and  the  capacity  of  the 
prosecutorial governance bodies; and launch the criminal e-case management system modules; 

→  in line with the Ukraine Plan, adopt the law to improve the enforcement of court decisions; launch 
the data collection system for the enforcement of court decisions, and implement the roadmap for 
the e-judiciary system; 

→  fill  the  remaining  vacancies  in  the  Constitutional  Court  without  further  delays  and  improve  the 
constitutional procedure in line with the 2021 recommendations of the Venice Commission; adopt 
legislative amendments to make the selection and dismissal procedures for the Prosecutor General 
more objective, transparent and merit-based; improve the selection of Supreme Court judges and 
the verification of integrity declarations of Supreme Court and other highest courts’ judges with 
the  temporary  but  meaningful  involvement  of  independent  experts  nominated  by  international 
partners; remove the provision on the automatic closure of criminal cases due to the expiry of pre-
trial investigation time limits and review the current time limits ; urgently extend the temporary 
involvement of internationally-nominated independent experts in the selection of members of the 
High Qualification Commission of Judges (HQCJ), and improve the transparency and quality of 
the  selection  processes,  in  particular  regarding  the  selection  of  members  of  the  Congress  and 
Council  of  Judges,  Council  of  Prosecutors,  and  the  Head  of  the  State  Judicial  Administration 
(SJA); and advance the reforms of the Bar, legal education and the National School of Judges; 

→  remove  the  provisions  allowing  the  transfer  and  appointment  of  prosecutors  to  regional 
prosecution offices and the Office of Prosecutor General without competition and giving the right 
for  the  Prosecutor  General  to  access  any  pre-trial  investigation  material,  abstain  from  further 
enforcement of these provisions until they are repealed. 

Fight against corruption  

Ukraine has some level of preparation in the area of anti-corruption. Limited progress was made. 
The  specialised  anti-corruption  institutions  (NABU,  SAPO,  HACC)  continued  delivering  on  their 
mandates and building a track-record by stepping up investigations, prosecutions and judgements of 
high-level corruption cases. The trend has been stagnating for investigations into corruption offences 

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by  other  law  enforcement  agencies.  The  Parliament  adopted  a  law  in  July,  dismantling  important 
safeguards  for the independence  of  NABU  and  SAPO  and  putting  their  operational  work  under the 
authority  of  the  politically  appointed  Prosecutor  General.  These  amendments  would  have  severely 
weakened Ukraine’s anti-corruption framework. The independence of NABU and SAPO was swiftly 
restored following domestic protests and strong concerns voiced by international partners. Legislative 
initiatives presented as protecting businesses or national security were registered or adopted that risk 
undermining  the  effectiveness  of  the  fight  against  corruption,  including  by  limiting  transparency  of 
public  registers  and  criminal  liability  for  corruption  offences.  Anti-corruption  institutions  and  civil 
society organisations report about growing pressure from state institutions, including through criminal 
investigations by law enforcement and security agencies. Overall, these developments cast doubts on 
Ukraine’s  commitment  to  its  anti-corruption  agenda.  Ukraine  should  advance  its  anti-corruption 
framework  and  prevent  any  backsliding  on  its  notable  reform  achievements.  Procedural  delays  and 
obstructions in high-level corruption proceedings should be addressed. Statutes of limitation and the 
grounds for their interruption and suspension should be reviewed and adjusted, in line with European 
standards. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  preserve  the  independence  of  anti-corruption  institutions;  expand  the  jurisdiction  of  NABU  to 
cover  all  high-risk  public  positions;  introduce  robust  safeguards  against  interference  with  the 
work  of  NABU  and  SAPO  and  circumvention  of  their  exclusive  jurisdiction  in  high-level 
corruption  cases;  strengthen  SAPO’s  autonomy  to  investigate  Members  of  Parliament  without 
prior approval by the Prosecutor General;  

→  further consolidate its track record on corruption cases, including the seizure and confiscation of 
criminal  assets,  focusing  on  top  officials  and  high-impact  cases;  expand  the  personal  scope  of 
declarants  and  simplify  and  improve  the  procedures  for  the  verification  of  asset  declarations; 
strengthen the capacities and focus of the National Agency on Corruption Prevention (NACP) to 
detect  unexplained  wealth;  amend  the  Criminal  Procedure  Code  to  alleviate  impediments  and 
procedural  delays  to  the  efficient  holding  of  criminal  proceedings,  particularly  in  high-level 
corruption cases; 

→  in line with the Ukraine Plan, increase the number of judges and administrative staff in the High 
Anti-Corruption  Court  (HACC);  develop  and  adopt  the  Anti-corruption  Strategy  and  the  State 
Anti-Corruption Programme. 

Fundamental rights  

The  overall  framework  for  and  enforcement  of  fundamental  rights  remains  satisfactory,  and  the 
government has maintained  its  overall  respect for  fundamental rights  and  shown  its  commitment  to 
their protection. Ukraine has adopted and implemented several key reforms, such as the legislation on 
the  protection  of  victims  of  crimes  (including  war  crimes),  strengthening  the  National  Prevention 
Mechanism,  starting  to  implement  the  Istanbul  Convention,  and  adopting  the  Strategy  for  Ensuring 
the  Right  of  Every  Child  in  Ukraine  to  Grow  Up  in  a  Family  Environment.  The  continued  lack  of 
progress  on  a  number  of  policies,  including  the  criminalisation  of  hate  crimes,  the  creation  of  civil 
partnerships  and  the  reform  of  personal  data  protection,  is  concerning  and  Ukraine  should  remain 
committed in its pursuit of reforms.  

The  Commission’s  recommendations  from  last  year  were  partially  met  and  remain  valid.  In  the 
coming year, Ukraine should, in particular: 

→  continue  implementing  the  amended  legislation  on  the  protection  of  the  rights  of  persons 
belonging to national minorities and the Action Plan on National Minorities, in close cooperation 
with representatives of national minorities, and provide adequate resources and capacity-building 
assistance to the relevant authorities; 

→  review  the  legislation  on  the  functioning  of  the  Ombudsperson  in  line  with  the  UN  Paris 
Principles and the Council of Europe’s Venice Principles on the Protection and Promotion of the 

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Ombudsman Institution; and ensure effective investigation and prosecution of cases of torture and 
ill  treatment in the  prison and  detention system; and adopt  legislation  on  data protection  in  full 
compliance with the EU acquis; 

→  continue  developing  an  inclusive  environment  for  persons  with  disabilities,  including  by 
advancing on de-institutionalisation and, in line with the Ukraine Plan, adopting the legislation on 
the rehabilitation of persons with disabilities. 

Freedom of expression  

Ukraine  is  between  having  some  and  a  moderate  level  of  preparation  regarding  freedom  of 
expression. Despite the constraints resulting from the Russian war of aggression, Ukraine has made 
some progress in this area, notably on the financial independence of the public broadcaster Suspilne, 
transparency of media ownership, and access to information for journalists. 

The  Commission’s  recommendations  from  last  year  were  partially  met  and  remain  valid.  In  the 
coming year, Ukraine should in particular: 

→  ensure  the  safety  and  independence  of  journalists  and  respect  their  public  information  role; 
investigate promptly, independently and effectively cases of direct intimidation and harassment as 
well as indirect forms of pressure against journalists and media outlets; 

→  maintain  adequate  funding  for  the  public  service  broadcaster  to  allow  the  independent  public 
service media to carry out their role as enshrined in Ukraine’s legislation, and ensure that content 
produced  by  publicly  funded  media  are  representative  of  Ukraine’s  political  and  societal 
pluralism; 

→  continue its efforts to maintain and gradually strengthen a transparent, pluralistic and independent 
media landscape, ensuring that restrictions imposed temporarily by martial law comply with key 
public rights and interests, such as access to information and media freedom. 

Chapter 24: Justice, freedom and security 

Ukraine has some level of preparation in the field of justice, freedom and security, and made some 
progress  during  the  reporting  period.  In  particular,  Ukraine  moved  forward  with  the  reform  of  the 
Economic  Security  Bureau  of  Ukraine  (ESBU)  and  the  Asset  Recovery  and  Management  Agency 
(ARMA),  and  strengthened  legislation  and  the  implementation  of  measures  to  better  counter  the 
misuse and trafficking of firearms.  Additionally, the Cabinet of Ministers approved the composition 
of the competition commission for the selection of the Head of the State Customs Service. However, 
overall  institutional  cooperation  and  coordination  mechanisms  remain  weak,  as  do  the  levels  of 
integrity and  accountability.  There is  a  need  for  further  work  on legislative  alignment  and strategic 
documents  outlining  priorities  for  the  near  future,  including  in  the  areas  of  migration  and  firearms. 
Security checks by the Security Service of Ukraine against law enforcement personnel introduced as 
part of July 2025 legislative amendments lack safeguards against possible abuse. 

The  Commission’s  recommendations  from  last  year  were  partially  met  and  remain  valid.  In  the 
coming year, Ukraine should in particular: 

→  make tangible progress in implementing the overarching strategic plan on law enforcement reform 

(OAS AP) and the Chapter 24 parts of the rule of law roadmap; 

→  adopt  the  Law  on  the  delineation  of  powers,  functions  and  responsibilities  of  law  enforcement 
agencies (LEAs) and create an effective system for cooperation and coordination between LEAs; 
introduce transparent and merit-based selection procedures for managerial positions in the central 
and  regional  offices  of  the  National  Police  of  Ukraine  (NPU)  and  the  State  Bureau  of 
Investigation  (SBI),  with  the  meaningful  involvement  of  independent  experts  nominated  by 
international partners, along with strong disciplinary and anti-corruption rules that are tailored to 
the local context and address actual corruption risks;  

→  accelerate  the  adoption  of  a  new  integrated  border  management  (IBM)  strategy  with  an  action 

plan incorporating measurable implementation indicators. 

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Fight against serious and organised crime 

Ukraine  has  some  level  of  preparation  to  implement  the  EU  acquis  and  made  some  progress, 
notably in the gradual implementation of the OAS AP, and in adopting and starting to implement the 
law reforming the Asset Recovery and Management Agency (ARMA). After some delay, the Head of 
the Economic Security Bureau of Ukraine (ESBU) was appointed. There has been some progress in 
preventing  and  fighting  small  arms  and  light  weapons  trafficking,  drug  and  cigarette  smuggling, 
trafficking  in  human  beings,  and  illegal  financial  transactions.  Ukraine  established  the  National 
Firearms Focal Point (NFFP) and an interministerial group on firearms under the coordination centre. 
The legal framework for financial investigations has been completed with the necessary implementing 
legislation.  The  track  record  in  money  laundering  cases  has  improved  but  the  freezing  and 
confiscation of criminal assets remain very limited.  

The  Commission’s  recommendations  from  last  year  were  partially  met  and  remain  valid.  In  the 
coming year, Ukraine should in particular: 

→  implement  the  law  reforming  ARMA,  including  by  adopting  the  relevant  implementing 
legislation, by conducting a transparent selection and appointment process for its head following a 
credible integrity and professionalism check and by undertaking an independent external audit; 

→  advance the reform of the ESBU through the re-attestation of its staff based on integrity and merit 
and by providing the ESBU with appropriate financial, human and technical resources, as well as 
operational  independence;  adopt  and  start  implementing  a  strategic  framework  on  financial 
investigations,  allocate  sufficient  resources,  and  further  build  the  necessary  capacities  to  ensure 
that financial investigations are conducted systematically and effectively; 

→  implement the 2025 comprehensive action plan to combat organised crime based on the results of 
the 2019-2022 serious and organised crime threat assessment (SOCTA); adopt a new 2026-2030 
strategy  following  the  threat  assessment  under  the  2021-2024  SOCTA  methodology;  strengthen 
the institutional and operational capacities (including inter-agency cooperation) to institutionalise 
the SOCTA methodology across the relevant agencies; formally establish the permanent national 
coordinator to fight against organised crime. 

ECONOMIC CRITERIA  

The existence of a functioning market economy 

Ukraine is at some level of preparation and has made good progress in establishing a functioning 
market  economy.  The  Ukrainian  authorities  remain  committed  to  macroeconomic  stability  and  the 
implementation  of  reforms.  While  the  pace  of  recovery  has  slowed,  the  economy  continues  to 
demonstrate  resilience,  underpinned  by  sound  policymaking,  strong  international  support,  and  the 
adaptability of the private sector. Despite the challenging wartime context, progress has been made on 
fiscal  structural  reforms,  while  efforts  to  strengthen  the  tax  administration  and  increase  domestic 
revenues  have  continued,  which  have  led  to  a  slight  reduction  in  the  fiscal  deficit  in  2024  despite 
strong  expenditure  pressures.  The  roll-back  of  emergency  measures  introduced  at  the  beginning  of 
Russia’s  war  of  aggression  has  progressed,  with  the  National  Bank  of  Ukraine  gradually  easing 
foreign  exchange  restrictions  and  maintaining  a  managed  float  for  the  hryvnia.  The  business 
environment  has  benefited  from  steps  to  make  it  easier  to  do  business,  supported  by  ongoing 
deregulation efforts. The banking sector has remained resilient, with credit activity showing signs of 
recovery.  

The  Commission’s  recommendations  from  last  year  were  well  implemented.  In  the  coming  year 
Ukraine should, in particular: 

→  advance the implementation of the National Revenue Strategy and domestic revenue mobilisation, 
take  steps  to  improve  the  sustainability  of  the  pension  system,  and  improve  fiscal  transparency 
through the timely publication of general government data; continue pursuing policies supporting 
macroeconomic  and  financial  stability,  including  by  implementing  the  Financial  Sector 
Development Strategy roadmap;  

8 

 
 
→  continue  improving  the  business  environment  and  market  competition;  accelerate  deregulation 
and reduce administrative burdens, particularly those associated with tax compliance; advance the 
corporatisation  of  state-owned  enterprises  and  the  appointment  of  supervisory  boards  with  a 
majority  of  independent  members,  while  safeguarding  their  independence  in  line  with  OECD 
standards; 

→  take steps to facilitate the labour market integration of displaced persons and war veterans, while 

intensifying efforts to reduce informality and promote formal employment. 

The capacity to cope with competitive pressures and market forces within the EU 

Ukraine is between an early stage of preparation and having some level of preparation and has 
made  good  progress  to cope  with  competitive  pressures and market  forces  within  the  EU.  Ukraine 
has  continued  to  strengthen  the  foundations  for  long-term  competitiveness.  Reform  efforts  in 
education  have  progressed,  including  the  continued  implementation  of  the  New  Ukrainian  School 
Reform and the entry into force of a new law on preschool education. Additional steps were taken to 
align  the  education  and  training  system  with  the  needs  of  Ukrainians  abroad,  while  reforms 
undertaken  under  the  Ukraine  Plan  are  set  to  strengthen  vocational  education  and  training.  Ukraine 
approved a new Global Innovation Development Strategy, which seeks to boost innovation through 
better infrastructure, regulation and access to funding. In parallel, Ukraine restored and expanded its 
energy  generation  capacity,  advanced  its  digital  connectivity  and  reformed  public  investment 
management.  

The  Commission’s  recommendations  from  last  year  were  well  implemented.  In  the  coming  year 
Ukraine should, in particular: 

→  continue  taking  measures  to  support  the  repair,  rehabilitation  and  building  of  infrastructure,  in 
particular related to energy generation capacity, including from decentralised renewable sources; 

→  continue implementing the commitments in the Roadmap for Public Investment Management, in 
particular by adopting sectoral strategies that include the main goals and priorities for investments 
by sector; 

→  continue  taking  steps  to  improve  the  quality  of  education  and  training  to  ensure  that  outcomes 

align with the needs of the labour market, including the skills required for reconstruction. 

Chapter 5 - Public procurement 

Ukraine  has  some  level  of  preparation  in  the  area  of  public  procurement.  Limited  progress  was 
made,  by  implementing  the  Strategy  for  Reforming  the  Public  Procurement  System  for  2024-2026. 
The long-due public procurement law was not adopted, while the public-private partnership (PPP) law 
was adopted albeit with significant gaps vis-à-vis EU standards. 

The Commission’s recommendations from last year were only partially met and remain valid. In the 
coming year, Ukraine should in particular: 

→  make  progress  towards  further  aligning  legislation  on  public  procurement,  concessions,  public-
private  partnerships,  and  defence  and  security  procurement,  complying  with  the  EU  acquis  and 
ensure that EU operators can participate on fully non-discriminatory legal terms; 

→  enhance the e-procurement functionality, including development of new procurement tools and e-
contracting in the Prozorro system, as well as operational interoperability with DREAM system 
and other applicable state IT systems; 

→  amend the Strategy for Reforming the Public Procurement System for 2024-2026 to better define 
the strategic goals, tasks and performance indicators as well as to streamline measures related to 
control and anti-corruption, including by strengthening the effectiveness of exclusion criteria for 
economic operators on all grounds foreseen in the EU acquis, especially, over corruption-related 
convictions. 

9 

 
 
Chapter 18 - Statistics 

Ukraine has some level of preparation in the area of statistics and made some progress, including by 
preparing an amendment to the law on official statistics and by re-starting the collection of statistical 
data after an amendment to the martial law as of July 2025.  

The  Commission’s  recommendations  from  last  year  were  partially  implemented  and  remain  largely 
valid. In the coming year, Ukraine should in particular:  

→  gradually  increase  the  production,  dissemination  and  transmission  of  good-quality  statistics  to 

Eurostat, disaggregated by sex and age where relevant;  

→  ensure the full professional independence of the SSSU and of other bodies  that produce official 

statistics; 

→  restart the implementation of statistical surveys and observations to produce good-quality official 

statistics. 

Chapter 32 - Financial control 

Ukraine has some level of preparation in implementing financial control and made  good progress 
by amending the Law on the Accounting Chamber.   

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  increase  the  quality  of  public  sector  internal  audit  by  applying  the  new  Global  Internal  Audit 

Standards and strengthening the role and capacities of the Centralised Harmonisation Unit;  

→  strengthen  the  political  and  financial  independence,  and  administrative  capacities,  of  the 

Accounting Chamber, including by forming and operationalising its Board; 

→  in line with the Ukraine Plan, adopt the amendments to relevant legislation on financial control to 
strengthen  the  state  financial  control  system,  including  the  role  and  capacity  of  the  State  Audit 
Service  in  protecting  the  financial  interests  of  the  EU  and  the  monitoring  of  procurement 
procedures,  prioritising  preventive  risk-based  audits  and  effectively  acting  upon  detected 
violations. 

CLUSTER 2: INTERNAL MARKET 

Chapter 1 - Free movement of goods 

Ukraine is moderately prepared in the area of free movement of goods. It made some progress by 
reintroducing market surveillance, and by aligning with the EU acquis on metrology and with several 
pieces of EU ‘new and global approach’ product legislation. 

The Commission’s recommendations from last year were partially implemented and remain valid.  In 
the coming year, Ukraine should in particular: 

→  adopt  the  law  on  market  surveillance,  which  is  aligned  with  the  EU  acquis;  and  make  further 
progress in aligning with the EU harmonised product  acquis, especially “old approach” product 
acquis; 

→  make progress in ensuring compliance with Articles 34-36 of the Treaty on the Functioning of the 
European Union and relevant case law of the Court of Justice of the European Union (CJEU), in 
order to eliminate quantitative restrictions on the free movement of goods, especially in the non-
harmonised area;  

→  continue its efforts to join the EU standardisation and metrology bodies. 

Chapter 2 - Freedom of movement for workers 

10 

 
 
 
Ukraine remains at an early stage of preparation on the freedom of movement for workers. Limited 
progress was made in the reporting period, with the adoption of the action plan preparing the relevant 
authorities to join the European Network of Employment Services (EURES).  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  align national legislation with the EU acquis on access for EU citizens to the labour market;  

→  conclude agreements on social security coordination and healthcare insurance with EU Member 

States;  

→  step up preparations for joining EURES, upon accession.  

Chapter 3 - Right of establishment and freedom to provide services 

Ukraine  has  some  level  of  preparation  in  relation  to  the  right  of  establishment  and  freedom  to 
provide  services.  Limited  progress  was  made,  including  on  the  full  postal  market  opening  to 
competition.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  take  measures  to  eliminate  barriers  to  the  provision  of  services  between  the  EU  and  Ukraine, 
using the possibilities offered by the Association Agreement, and initiate alignment with the EU 
Services Directive; 

→  make progress in aligning with the EU postal acquis, including the Postal Services Directive and 

the Regulation on cross-border parcel delivery services; 

→  make  progress  on  aligning  with  the  EU  acquis  on  the  mutual  recognition  of  professional 

qualifications.  

Chapter 4 - Free movement of capital 

Ukraine  is  between  having  some  and  a  moderate  level  of  preparation  in  the  area  of  the  free 
movement  of  capital.  Some  progress  was  made,  in  particular  as  regards  the  relaxation  of  foreign 
currency restrictions introduced as part of the regime of martial law. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  continue  the  progress  towards  the  liberalisation  of  capital  movements,  and  as  far  as  the 
circumstances  allow  for  it,  gradually  remove  the  additional  restrictions  introduced  under  the 
martial law; 

→  advance  alignment  with  the  Payment  Services  Directive  2,  the  SEPA  Regulation,  the  Cross-

Border Payments Regulation 2 and the E-Money Directive 2;  

→  make  progress  in  the  fight  against  money  laundering  and  terrorist  financing:  in  line  with  the 
Ukraine  Plan,  implement  the  next  National  Risk  Assessment  in  accordance  with  the  updated 
methodology  for  the  national  assessment  of  money  laundering  and  terrorist  financing  risks  in 
Ukraine and set up a registry of bank accounts for individuals and personal bank deposit boxes, in 
line  with  the  EU  acquis;  introduce  new  measures  to  complement  the  legislation  on  beneficial 
ownership registration for all types of corporate and legal entities in Ukraine, including trusts. 

Chapter 6 - Company law 

Ukraine has some level of preparation in the field of company law and has made limited progress in 
the  past  year,  notably  by  adopting  the  strategy  and  action  plan  on  sustainability  reporting  and 
preparing draft legislation in this area and in the area of corporate governance. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 

11 

 
 
the coming year, Ukraine should in particular: 

→  continue aligning with the EU acquis including by providing for a legal framework for the nullity 
of  joint-stock  companies,  cross-border  mergers,  divisions  and  conversions,  takeover  bids, 
shareholders’ rights and digital tools and processes in the company law; 

→  continue aligning with the EU acquis concerning transparency requirements for capital markets, 

corporate governance and reporting; 

→  further  develop  the  technological  solution/Unified  State  Register  to  enable  fully  online 
registration of companies and branches as well as fully online filing of company information, and 
access to companies’ financial statements in the business register. 

Chapter 7 - Intellectual property law 

Ukraine has some level of preparation in the area of intellectual property law. Some progress was 
made, notably by developing draft laws on copyright, patents, trademarks and trade secrets.   

The Commission’s recommendations from last year were not implemented and remain fully valid. In 
the coming year, Ukraine should in particular: 

→  improve the functioning of collective management organisations and the payment of  royalties to 

rights holders;  

→  further  improve  the  industrial  property  rights  (IPR)  enforcement  system,  in  particular  by 

combating piracy and counterfeit products; 

→  adopt the draft laws on copyright, industrial property rights as well as on trade secrets; adopt the 
intellectual  property  strategy  2025-2030,  and  continue  alignment  with  the  EU  acquis  in  all 
relevant areas. 

Chapter 8 - Competition policy 

Ukraine  has  some  level  of  preparation  in  the  area  of  competition  policy.  Limited  progress  was 
made in the reporting period, notably by preparing to further align the legislation on the protection of 
competition  and  State  aid  and  by  partially  restoring  State  aid  control.  The  number  of  decisions  in 
cases  for  anticompetitive  concerted  actions,  abuse  of  dominant  position  and  mergers  has  increased 
compared with the year before. 

The Commission's recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  in line with the Ukraine Plan, amend the Law on State aid to further align it with the EU acquis 
and  lift  the  suspension  of  the  application  of  State  aid  control  by  the  Antimonopoly  Committee 
(AMCU); 

→  make further progress on finalising a reliable and comprehensive inventory of existing State aid 

measures; 

→  in line with the Ukraine Plan, pursue further steps towards aligning with the EU acquis under this 

chapter, including on services of general economic interest. 

Chapter 9 - Financial services 

Ukraine has some level of preparation in the field of financial services. Some progress was made in 
the reporting period, with the entry into force of new banking regulations and legislation on insurance 
distribution and motor third-party liability. 

The Commission's recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  continue  alignment  with  the  EU  acquis  on  banking  regulation,  in  particular  with  the  Capital 
Requirements Regulation (CRR) and the Capital Requirements Directive (CRD), as well as with 

12 

 
 
the frameworks on bank recovery and resolution and on deposit guarantee schemes; 

→  continue  aligning  legislation  with  the  EU  acquis  on  insurance  and  occupational  pensions; 

investment firms, investment funds, and financial market infrastructures;  

→  continue aligning legislation with the EU acquis on securities and capital markets. In line with the 
Ukraine  Plan,  further  implement  the  Law  on  the  improvement  of  state  regulation  of  capital 
markets  and  organised  commodity  markets,  following  the  principles  of  the  International 
Organization of Securities Commissions.   

Chapter 28 - Consumer and health protection 

Ukraine  is  between  having  some  and  a  moderate  level  of  preparation  in  consumer  and  health 
protection. Over the reporting period, good progress was made, notably by: (i) lifting the moratorium 
on inspections and checks; (ii) strengthening the protection of consumer rights in financial services; 
(iii) adopting a strategy to develop the healthcare system; (iv) adopting a strategy and action plan to 
combat antimicrobial resistance; (v) adopting a law on the mental healthcare system.  

The Commission's recommendations from last year were partially implemented and remain valid.  In 
the coming year, Ukraine should in particular: 

→  align with the General Product Safety Regulation; 

→  develop,  approve  and  start  implementing  a  national  health  emergency  preparedness  plan,  along 
with  its  associated  response  mechanisms,  and  align  national  legislation  with  the  EU  health 
security acquis; 

→  embed the technical aspects of the e-Health system into a robust governance system involving all 
the relevant entities to ensure effective coordination and the efficient enforcement of decisions. 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH 

Chapter 10 - Digital transformation and media 

Ukraine  is  between  a  moderate  and  a  good  level  of  preparation  in  the  field  of  digital 
transformation and media. In the reporting period, it made some progress, notably on roaming.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  ensure that independent telecom and media regulators and central executive bodies in the field of 
electronic communications have adequate funding and human resources to perform their role;  

→  align national legislation with the EU’s 5G Security Toolbox and fully implement the Protocol of 
Intent on 5G Security, including the enactment of provisions to exclude high-risk suppliers from 
5G auctions; 

→  in line with the Ukraine Plan, further align national legislation with the European Digital Identity 

Framework.   

Chapter 16 - Taxation 

Ukraine has some level of preparation in the field of taxation. Good progress was made, notably by 
amending the Tax Code on value added tax (VAT) and excise duties. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  further align national legislation with the EU acquis on the common system of VAT and on excise 
duties,  especially  regarding  procedures,  rates  and  exemptions,  and  continue  implementing  the 
National Revenue Strategy; 

13 

 
 
 
→  further align with the Anti-Tax Avoidance Directive and the directives on mutual assistance and 

administrative cooperation in the field of taxation; 

→  continue  strengthening  the  administrative  and  operational  capacity  of  the  tax  administration,  in 
particular by developing IT systems and ensuring their interoperability with the IT systems at EU 
level. 

Chapter 17 - Economic and monetary policy 

Ukraine  is  moderately  prepared  in  the  field  of  economic  and  monetary  policy  and  made  some 
progress, with a gradual return to an inflation-targeting regime, gradual easing of foreign exchange 
restrictions, and improvements in the medium-term budgetary framework. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  further implement the National Bank of Ukraine’s (NBU) ‘Strategy for easing foreign exchange 
restrictions, transitioning to greater exchange rate flexibility and returning to inflation targeting’;  

→  continue strengthening the legal framework to ensure the independence of the NBU in line with 

the EU acquis and to avoid monetary financing of the state budget; 

→  continue  improving  the  medium-term  budgetary  framework  by  preparing  detailed  revenue  and 
expenditure projections at the general government level linked to explicit budgetary targets and 
detailing in the framework how these targets will be achieved.  

Chapter 19 - Social policy and employment 

Ukraine remains at an early stage of preparation in the field of social policy and employment. Some 
progress  was  achieved  over  the  reporting  period  with  the  adoption  of  the  resolution  on  the 
procurement of social services for children with disabilities and the adoption of the strategy for the 
de-institutionalisation  of  alternative  care  for  children.  Ukraine  needs  to  continue  on  alignment  with 
EU acquis in the area of non-discrimination and equality, including also gender equality. 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  adopt  new  framework legislation  for  labour relations  and  occupational safety and  health in line 
with  the  EU  acquis,  ensure  an  enabling  environment  for  bipartite  and  tripartite  social  dialogue, 
and strengthen the capacities of social partners;  

→  in line with the Ukraine Plan, adopt the employment strategy; 

→  continue  reforming  the  social  benefits  system  and  implement  the  new  procurement  system  for 
social services and further align national legislation with the EU acquis on non-discrimination and 
equality between women and men in employment and social policy.  

Chapter 20 - Enterprise and industrial policy 

Ukraine is between having some and a moderate level of preparation in the field of enterprise and 
industrial policy and made some progress, notably with the implementation of the action plan of the 
small and medium-sized enterprises (SMEs) strategy, the deregulation plan, and incentives for private 
sector and industrial development in the higher value-added sectors.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  continue  improving  the  framework  conditions  for  entrepreneurship,  innovation  and  investment, 
including  by  adopting  business  regulations  conducive  to  rebuilding  investor  confidence,  and 
facilitating access to finance; 

→  begin to align with the EU acquis on the Late Payment Directive. 

14 

 
 
Chapter 25 – Science and research 

Ukraine is moderately prepared in the field of science and research. Good progress has been made 
in  the  reporting  period,  notably  by  seizing  further  opportunities  provided  by  Horizon  Europe  and 
designing regional smart specialisation strategies.   

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  make  full  use  of  its  participation  in  Horizon  Europe,  by  stepping  up  the  work  of  the  Horizon 
Europe office in Ukraine, as well as of the network of national contact points across the country; 

→  continue to enable the administrative conditions necessary to design regional smart specialisation 

strategies; 

→  adopt the European Research Area roadmap for 2025-2027 to further link the Ukrainian research 

and innovation ecosystem with European research and innovation resources. 

Chapter 26 - Education and culture 

Ukraine is between having some and a moderate level of preparation in the field of education and 
culture. Good progress was made, with the entry into force of the laws on preschool education and on 
the  national  qualifications  system,  the  adoption  of  the  law  on  vocational  education  and  training 
(VET),  the  approval  of  the  strategy  for  the  development  of  Ukrainian  culture,  and  joining  the 
European Alliance for Apprenticeships (EAfA).  

The  Commission’s  recommendations from last  year were  largely implemented.  In  the  coming  year, 
Ukraine should in particular:  

→  continue implementing the reformed legislation on preschool education; 

→  implement the legislation on vocational education and training and activate national, regional and 

local stakeholders to join EAfA to support VET and apprenticeships through pledges; 

→  implement the strategy for the development of Ukrainian culture. 

Chapter 29 - Customs union 

Ukraine has a good level of preparation with regard to the customs union and made good progress 
over the last year, notably by endorsing the draft of the new Ukrainian Customs Code in line with the 
EU Customs Code by the Cabinet of Ministers, as well as by updating the Medium Term Action Plan 
of  measures  to  achieve  the  objectives  of  customs  reform,  further  digitalising  the  customs 
administration and by preparing a competency-based staff management approach.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  adopt  the  new  Ukrainian  Customs  Code  in  line  with  the  EU  Customs  Code,  develop  relevant 

secondary legislation and start preparation for its implementation; 

→  continue implementing the Strategic Plan for the digitalisation of the State Customs Service for 
2024-2026, in accordance with the Union Customs Code Work Programme and the Multiannual 
Strategic Plan for Electronic Customs (MACP-C); make progress in developing new national IT 
systems for clearance of customs declarations and for risk management;  

→  in  order  to  improve  administrative  capacity,  ensure  that  the  State  Customs  Service  has  the 
competencies to carry out the effective enforcement of national law to counter the smuggling of 
goods, complete the reform of the Service, including the delayed selection of the new Head and 
the  re-attestation  of  staff,  and  advance  implementation  of  the  new  competency-based  people 
management framework. 

15 

 
 
 
CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY 

Chapter 14 - Transport policy 

Ukraine  has  some  level  of  preparation  in  the  field  of  transport  policy,  and  made  some  progress, 
notably  through  the  adoption  of  the  national  transport  strategy  for  the  period  until  2030  and  the 
strategy to develop and construct border infrastructure with EU Member States and the Republic of 
Moldova until 2030.  

The  Commission’s  recommendations  from  last  year  were  partially  implemented  and  remain  valid. 
Over the coming year, Ukraine should in particular: 

→  in  line  with  the  Ukraine  Plan,  adopt  the  law  on  traffic  safety  and  interoperability  of  Railway 
Transport of Ukraine and prepare for the adoption of the law on the railway transport market to 
create  an  institutional  and  legislative  set-up  for  a  competitive  rail  market  in  line  with  EU 
standards; 

→  in  line  with  the  Ukraine  Plan,  adopt  the  law  on  merchant  shipping  and  shipping  on  inland 

waterways;  

→  align the social and market rules for road transport with the EU road transport acquis, strengthen 
the enforcement of haulage market rules and traffic safety measures, and establish inspection and 
investigation bodies for rail, road and waterborne transport. 

Chapter 15 - Energy 

Ukraine has a  good level of preparation in the field of energy. It made  some progress during the 
reporting  period  with  steps  to  implement  its  national  energy  and  climate  plan  (NECP)  and  the 
Regulation on wholesale energy market integrity and transparency (REMIT), and to set up a market-
based  legislative  and  regulatory  framework  for  renewable  energy.  Russia’s  massive  destruction  of 
Ukraine’s energy infrastructure continued, exposing existing weaknesses in Ukraine’s energy system. 
The gas market remained monopolised and closed, with the positive exception of the first exports of 
biomethane.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming period, Ukraine should in particular:  

→  accelerate  energy  market  reforms:  gradually  remove  the  wholesale  electricity  price  cap;  start 
working  on  setting  up  a  mechanism  to  support  vulnerable  energy  consumers;  in  line  with  the 
Ukraine  Plan,  adopt  a  roadmap  to  gradually  liberalise  gas  prices,  adopt  and  implement  the 
electricity integration package, and appoint a nominated electricity market operator; 

→  prioritise  the  energy  transition  by  focusing  on  renewable  energy  (RES)  and  energy  efficiency: 
resolve  the  issue  of  debt  settlement  for  RES  producers;  in  line  with  the  Ukraine  Plan,  adopt 
legislation to improve RES permitting and efficiency in district heating, cancel the moratorium on 
raising heat and hot water tariffs, adopt a programme to modernise heat generating enterprises and 
set minimum energy efficiency performance levels for buildings; 

→  improve governance in the energy sector: complete the supervisory boards and revise charters of 
major  state-owned  energy  companies  such  as  Energoatom;  in  line  with  Ukraine  Plan,  adopt 
legislation to further strengthen the energy regulator’s independence and build a track record of 
fair and transparent decision-making.  

Chapter 21 - Trans-European networks 

Ukraine  has  some  level  of  preparation  in  the  field  of  Trans-European  networks  (TEN).  Some 
progress was achieved during the reporting period, related to the adoption of the national transport 
strategy until 2030, in which Ukraine outlined some steps for the integration of its transport system 
into Trans-European transport networks. Ukraine also advanced electricity interconnection projects on 
its borders with Romania and Slovakia.   

16 

 
 
The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  continue  planning  and  implementing  upgrades  to  critical  energy  and  transport  infrastructure, 
including  with  neighbouring  countries;  ensure  better  connections  with  EU  neighbours  through 
more  efficient  trans-European  transport  network  (TEN-T)  rail  and  road  border  crossing  points. 
Prioritise investments in these areas also in the Single Project Pipeline;  

→  further align with and implement the TEN-T and the Trans-European networks for energy (TEN-
E):  accelerate  alignment  with  the  new  TEN-T  and  TEN-E  Regulations,  improve  the  permitting 
process  for  TEN-E  projects  and,  in  line  with  Ukraine  Plan,  adopt  legislation  to  simplify  the 
accession  of  immovable  property  to  external  engineering  networks  and  to  improve  legal 
regulation in the field of pipeline transport; 

→  accelerate  the  implementation  of  key  TEN-T  infrastructure,  with  particular  focus  on  the 

integration of railway systems with the EU standard gauge network. 

Chapter 27 - Environment and climate change 

Ukraine has some level of preparation in the field of environment and climate change and has made 
good  progress  in  the  reporting  period.  It  made  advancements  in  the  area  of  climate,  through  the 
resumption  of  compulsory  monitoring,  reporting  and  verification  of  greenhouse  gas  emissions,  the 
adoption of the action plan for setting up a national emissions trading system, and the framework law 
on climate policy, which aligns with the EU’s long-term target of climate neutrality by 2050. Ukraine 
also adopted the national waste management plan and the legislation on the prevention, reduction and 
control  of  industrial  pollution,  the  adoption  of  the  river  basin  management  plans,  and  the 
environmental control reform strategy.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

technical  expertise  and  ensure  environment  and  climate  policy 

→  continue reinforcing responsible authorities with clearly defined competencies, adequate staffing 
and 
implementation 
mainstreaming. Focus should be on the application of horizontal environmental legislation in line 
with  the  EU  acquis,  in  particular  on  environmental  impact  assessments  (EIAs)  and  strategic 
environmental  assessments  (SEAs),  for  all  relevant  projects,  plans  and  programmes  including 
those  relating  to  reconstruction.  This  implies  limiting  the  regime  of  exemptions,  implementing 
and enforcing environmental crime, enforcing liability and ensuring access to justice mechanisms;  

→  in  line  with  the  Ukraine  Plan,  submit  a  new  nationally  determined  contribution  under  the  Paris 
Agreement  and  continue  preparations  in  view  of  the extension  of  the monitoring,  reporting  and 
verification  system  and  the  introduction  of  emission  trading  in  Ukraine;  additionally,  ratify  the 
Kigali  Amendment  to  the  Montreal  Protocol  and  adapt  national  legislation  to  EU  standards  on 
ozone-depleting substances and fluorinated gases;  

→  in line with the Ukraine Plan, adopt a Strategy and an Action Plan on the Circular Economy and a 

law to align with the provisions of the EU Regulation on deforestation. 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION 

Chapter 11 - Agriculture and rural development 

Ukraine is between an early stage and having some level of preparation in the field of agriculture 
and rural development. Good progress was made  by adopting the strategy for agriculture and rural 
development  up  to  2030  including  an  updated  operational  plan  2025-2027,  and  the  implementing 
legislation on the State Agrarian Register (SAR). 

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

17 

 
 
 
→  continue  implementing  the  strategy  for  agriculture  and  rural  development  up  to  2030,  and 

strengthen the administrative capacity for its implementation;  

→  adopt  the  framework  law  on  the  paying  agency  and  proceed  with  the  implementation  of  the 
framework law on the paying agency, on the farm sustainability data network and the integrated 
administration and control system; 

→  continue the development of a land parcel identification system.  

Chapter 12 - Food safety, veterinary and phytosanitary policy 

Ukraine  is  moderately  prepared  in  the  field  of  food  safety,  veterinary  and  phytosanitary  policy. 
Some progress was made in the reporting period, in particular by the adoption of the framework law 
on  plant  health and plant  protection  and  by expanding  the  use  of the  EU’s  trade  control  and  expert 
system (TRACES).  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  advance  alignment  with  the  EU  acquis  on  General  Food  Law  provisions,  animal  health,  plant 
health  and  protection,  genetically  modified  organisms,  and  official  controls;  complete  the 
alignment  with  EU  animal  welfare  legislation,  strengthen  the  administrative  capacities  for  its 
effective implementation and prepare a national plan to upgrade establishments producing food, 
feed and animal by-products to meet EU structural standards;  

→  extend the use of TRACES through new certificates for phytosanitary and other purposes;  

→  continue  the  reform  of  food  safety  bodies  and  strengthen  official  controls  in  line  with  EU 

requirements.  

Chapter 13 - Fisheries and aquaculture 

Ukraine has some level of preparation in the field of fisheries and aquaculture. Some progress was 
made  in  the  reporting  period,  notably  the  monitoring  of  the  use  by  fishing  companies  of  the  state 
electronic  fisheries  management  system  (e-Fish),  the  introduction  of  a  ‘one-stop  shop’  to  obtain 
fishing permits and adoption of the legislation for membership of the General Fisheries Commission 
for the Mediterranean (GFCM). However, e-Fish requires significant additional developments.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  continue  to  align  Ukrainian  legislation  with  the  EU  acquis,  including  on  the  collection, 
management and use of data, on the functioning of the fisheries and aquaculture market and on 
state control; 

→  take  preparatory  steps  towards  establishing  a  fisheries  control  system,  including  a  dedicated 

fisheries control body to combat illegal, unreported and unregulated fishing; 

→  further develop the functionality and interoperability of Ukraine’s e-Fish system and harmonise it 

with the equivalent EU registers. 

Chapter 22 – Regional policy and coordination of structural instruments 

Ukraine has some level of preparation in the area of regional policy and coordination of structural 
instruments. Some progress was made during the reporting period, notably on implementing regional 
development  policy,  with  the  adoption  of  the  action  plan,  regional  development  funding,  and 
implementation of territorial cooperation programmes (Interreg) with Member States.  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular:  

→  report on the implementation of the State Regional Development Strategy and finalise the updated 

18 

 
 
regional  and  local  development  strategies  to  prioritise  investments  for  all  regional  and  local 
stakeholders, and operationalise the State Fund for Regional Development; 

→  fully  implement  the  law  on  the  principles  of  state  regional  policy  by  clarifying  the  content  and 
structure of local strategic planning documents, facilitating their digitalisation, and linking them 
to adequate financial resources; strengthen the capacities of regional and local administrations on 
project development; 

→  ensure the systematic and inclusive engagement of regional and local stakeholders at all the stages 

of the programming cycle in the coordination and institutional framework. 

Chapter 33 - Financial and budgetary provisions 

Ukraine is at an early stage of preparation in the area of financial and budgetary provisions. There 
was some progress in the areas covered by the chapter, notably an EU budget unit was created in the 
Ministry of Finance to coordinate  the activities of national institutions that are included in the EU's 
own resources system. 

The  Commission’s  recommendation  from  last  year  was  implemented.  In  the  coming  year,  Ukraine 
should: 

→  prepare  and  adopt  a  roadmap  for  implementation  of  an  own  resources  system  and  further 

strengthen awareness among key stakeholders. 

CLUSTER 6: EXTERNAL RELATIONS 

Chapter 30 - External relations 

Ukraine has a good level of preparation in the field of external relations and made limited progress 
in the reporting period. Ukraine’s trade policy has largely remained in compliance with World Trade 
Organization  (WTO)  commitments  and  the  rules  of  the  Association  Agreement/Deep  and 
Comprehensive Free Trade Area (AA/DCFTA).  

The Commission’s recommendations from last year were partially implemented and remain valid. In 
the coming year, Ukraine should in particular: 

→  continue  to  ensure  that  its  trade  policy  remains  in  compliance  with  WTO  and  AA/DCFTA 
commitments,  most  notably  by  not  introducing  any  measures  which  unjustly  favour  domestic 
products or producers; 

→  before  entering  any  new  bilateral  trade  agreement,  assess  its  impact,  in  light  of  Ukraine’s 
candidate status and forthcoming accession, ensuring that any such agreement contains a clause 
allowing early termination in the event of EU accession; 

→  make progress to align national legislation on the screening of foreign investments with the EU 

FDI Screening Regulation. 

Chapter 31 - Foreign, security and defence policy 

Ukraine  has  a  good  level  of  preparation  in  this  field,  and  good  progress  was  demonstrated  by 
continued intense political dialogue with the EU at all levels, the significantly improved security and 
military  cooperation  with  the  EU  and  its  Member  States,  and  by  reaching  a  high  rate  of  alignment 
with the EU’s common foreign and security policy (CFSP). Ukraine also became a full state party of 
the International Criminal Court (ICC).  

The recommendations from last year were implemented but remain valid. In the coming year, Ukraine 
should in particular: 

→  further  align  Ukraine’s  legislative  framework  with  the  provisions  of  the  Rome  Statute  of  the 

International Criminal Court (ICC) and its related instruments; 

19 

 
 
 
→  further  align  with  the  CFSP  (Statements  by  the  High  Representative  on  behalf  of  the  EU  and 
Council decisions on restrictive measures) and ensure that restrictive measures are implemented. 

1.3 STATE OF PLAY OF THE ACCESSION NEGOTIATIONS   

Following  the  first  Intergovernmental  Conference  that  opened  accession  negotiations  with  Ukraine, 
the  bilateral  screening  meetings  that  began  on  8 July 2024  were  concluded  on  30 September 2025. 
The screening reports on five of the six clusters have been presented to the Council. 

*** 

2. CLUSTER 1: THE FUNDAMENTALS OF THE ACCESSION PROCESS 

2.1. FUNCTIONING OF DEMOCRATIC INSTITUTIONS AND PUBLIC ADMINISTRATION REFORM 

2.1.1 Democracy 

The  functioning  of  democratic  institutions  in  Ukraine  is  generally  stable,  despite  the  restrictions 
imposed  under  martial  law.  Martial  law  has  remained  in  place  since  it  was  invoked  on 
24 February 2022. and its seventeenth extension  is valid until 3 February 2026. Martial law permits 
the introduction of certain restrictions on individual rights and freedoms, and on the rights and legal 
interests of legal entities. While its application has been proportionate overall, it remains essential to 
ensure that such powers are not exercised in ways that could jeopardise the positive reform agenda. 

Elections  

No  elections  took  place  during  the  reporting  period,  as  they  are  prohibited  under  martial  law.  On 
the 
25 February 2025, 
Parliament 
a 
Resolution to hold elections 
after  a  comprehensive,  just, 
and  sustainable  peace  has 
been secured.  

passed 

In  the  absence  of  an  active 
parliamentary 
working 
group  on  electoral  reform, 
the  development  of 
the 
the 
Roadmap 
Functioning  of  Democratic 
Institutions,  coordinated  by 
the  Office  of  the  Deputy 
for 
Prime 
European and Euro-Atlantic 
Integration, has become the primary framework for setting electoral reform priorities, particularly in 
response  to  outstanding  OSCE/ODIHR  recommendations  and  to  the  need  to  ensure  alignment  with 
European democratic standards.  

Minister 

on 

In the future, the most pressing issues for the first post-war elections will include: (i) safeguarding the 
political rights of Ukrainian citizens displaced in Ukraine and abroad, as well as the rights of military 
personnel;  (ii)  auditing  and  updating  the  State  voter  register;  (iii)  countering  cybersecurity  and 
disinformation  threats,  in  particular  by  continuing  to  strengthen  a  transparent,  further  safeguarding 
media freedom, media pluralism and editorial independence ; and (iv) reforming the rules on political 
advertising.  

Parliament 

Parliament continues to exercise its powers amidst the ongoing war and martial law. It has been taking 

20 

 
 
 
 
an  active  part  in  the  overall  reform  process  and  has  carried  out  its  legislative  tasks.  Between 
1 September 2024 and [31 August 2025, 208 laws were adopted, out of which 192 have fully entered 
into force.  

Ukraine took several steps to strengthen its legislative process and transparency. In September 2025, 
Parliament  decided  to  resume  live  broadcasts  of  its  open  plenary  sessions.  In  January  2025, 
Parliament adopted amendments to the Law on parliamentary committees and other connected laws. 
Changes  are  related  to  live  streaming  of  committee  meetings,  as  well  as  to  the  participation  of 
journalists  and  civil  society  representatives  in  those  meetings.  The  law  is  yet  to  be  signed  by  the 
President.  

On  parliamentary  oversight  and  control,  Parliament  amended  legislation  that  strengthens  the 
independence of the Accounting Chamber, Ukraine’s supreme audit institution. It also introduced an 
obligation  for  relevant  parliamentary  committees  to  consider  external  audit  reports  prepared  by  the 
Accounting  Chamber.  Furthermore,  during  the  reporting  period  the  ‘Hour  of  Questions  to  the 
Government’ was reinstated.  

The  legislation  on  political  parties  is  still  in  need  of  a  comprehensive  update,  including  regarding 
procedures  for  holding  political  parties  accountable  for  breaches  of  financing  rules.  Women  still 
remain  underrepresented  in  politics  and  decision  making,  with  the  proportion  of  female  MPs 
remaining  stable  at  21%  (in  April  2025).  Some  opposition  MPs  continued  to  be  subject  to  certain 
restrictions, especially regarding travelling abroad or freezing of assets. It is important for democratic 
resilience  to  continuously  ensure  that  the  rights  of  the  opposition  are  respected.  No  legislative 
initiatives regulating the rights of the parliamentary opposition have been developed or registered. 

EU integration 

The  institutions  in  charge  of  the  EU  integration  process  are  in  place.  There  remains  an  overall 
consensus, which includes the parliamentary opposition, that EU integration is a priority. 

While Parliament continued to adopt the reforms necessary for EU accession in the future, the pace of 
adoption gradually slowed down over the course of the reporting period. 

A team has been created to draft the National Programme for the Adoption of the Acquis (NPAA) and 
formally  launched  in  May  2025.  The  European  Integration  Committee  within  Parliament  is  tasked 
with assessing whether draft legislation under deliberation complies with the EU acquis. Negotiation 
Working  Groups  have  been  formed  for  each  negotiation  chapter  and  include  representatives  of  the 
relevant line ministries, Parliament and CSOs. They serve as discussion platforms for topics related to 
EU integration. 

Ukraine  started  regular  reporting  on  the  implementation  of  the  roadmaps  on  rule  of  law,  public 
administration  reform  and  on  the  functioning  of  democratic  institutions  and  on  the  action  plan  on 
national  minorities  adopted  in  May,  and  is  developing  a  system  for  coordinated  monitoring  and 
implementation. 

Governance 

Ukraine’s  government  has  continued  to  function  effectively  amidst  Russia’s  full-scale  war  of 
aggression.  During  the  reporting  period,  there  were  changes  in  the  composition  of  the  government 
(which  has  been  in  place  since  March  2020).  In  July,  there  was  a  significant  government  reshuffle 
marked  by  the  appointment  of  a  new  Prime  Minister  and  First  Deputy  Prime  Minister.  Several 
ministries  were  merged,  including  the  merger  of  the  Economy,  Ecology  and  Agriculture  portfolios 
into  a  single  department.  The  Ministry  of  Defence  was  expanded  to  encompass  responsibilities 
previously held by the Ministry of Strategic Industries. The Ministry of National Unity was dissolved, 
and  its  functions  were  transferred  to  the  Ministry  of  Social  Policy,  Family  and  Unity.  Leadership 
changes affected multiple ministries, with several officials transitioning into new roles, including into 
the  Office of the Deputy Prime Minister for European and Euro-Atlantic Integration, as well as the 
Ministers  for  Defence,  Energy,  and  Justice.  The  government  focused  on  strengthening  security  and 
defence,  pursuing  reforms  related  to  EU  integration,  ensuring  macroeconomic  stability,  and 
supporting economic and general recovery. 

21 

 
 
Ukraine’s multi-level governance continues to function effectively, despite wartime challenges. The 
decentralisation  reform  focuses  on  maximising  the  potential  of  local  government  authorities  and 
should  remain  a  central  element  of  Ukraine’s  efforts  to  fulfil  the  requirements  of  EU  accession, 
including  those  requirements  set  out  in  the  Ukraine  Plan  and  PAR  Roadmap,  and  in  line  with  the 
European Charter of Local Self-Government. Progress in creating an effective and transparent multi-
level  governance  system  remains  limited,  particularly  in  terms  of  introducing  a  prefecture-type 
proportionate system of state local administrations’ oversight over local government decisions, while 
reforming the territorial organisation of executive authorities. Good and consistent efforts have been 
made  to  define  the  concept  and  the  principles  of  delineating  powers  and  sectoral  competences 
between the state executive level and local self-governments. This should be translated into relevant 
legislation on delineation of powers based on the subsidiarity principle. There are still concerns about 
the  growing  number  of  local  military  administrations  and  the  unclear  legislative  framework  for 
resuming  local  governance  in  de-occupied territories.  Fiscal  decentralisation  was  maintained  during 
the  reporting  period,  with  64%  of  personal  income  tax  (PIT)  allocated  to  municipalities,  while 
military-related  PIT  continued  to  be  reduced.  Ukraine  should  progress  on  the  planned  legislative 
amendments  to  the  framework  for  the  financing  of  the  local  government  level  related  to  the  fair 
distribution  of  personal  income  tax  based  on  the  taxpayer’s  residence,  and  further  the  work  on 
developing the management at local level of public investments. 

The adoption of the Law on public consultations, the 2025 Comprehensive Government Action Plan 
on  regional  development  and  decentralisation,  the  further  development  of  the  Digital  Restoration 
Ecosystem  (DREAM),  and  the  restoration  of  mid-term  budgeting  at  the  local  level  constitute 
significant steps regarding local government. The publication of the study on the possibility to grant 
legal personality to municipalities, and the ambition of the Ministry for Development of Communities 
and Territories to adopt a suitable action plan are meaningful to advance decentralisation. This should 
be followed up with an open and comprehensive debate between government and local stakeholders, 
and a reflection on possible future legislative steps.   

Civil society 

Civil  society  organisations  (CSOs)  operate in  an overall enabling  environment, but there have  been 
incidents of alleged political pressure on anti-corruption activists. In 2024 and early 2025, three key 
laws were adopted to strengthen the engagement of the public and CSOs in policymaking at national 
and local level in the areas of ensuring transparency and democracy in local self-government, as well 
as public consultations. Authorities should prepare for the implementation of these laws once martial 
law is lifted and ensure that civil society in its diversity is meaningfully engaged in decision-making. 
Even though the formal state-CSO partnership structures mandated by legislation have not yet been 
fully established, civil society and the authorities have engaged in positive collaborations, especially 
in the context of the EU integration process. 

The  authorities  cooperate  with  civil  society  to  investigate  reports  of  instances  of  pressure  against 
investigative  journalists,  human  rights  defenders  and  CSOs  with  a  view  of  bringing  perpetrators  to 
justice. Such cases are of serious concern and highlight the importance of ensuring that civil society 
can continue to operate freely and independently. 

Registration of CSOs is overall accessible, but organisations sometimes face bureaucratic hurdles and 
lengthy  processes.  The  electronic  registration systems  that are  available for business  entities should 
also  be  provided  to  CSOs.  The  legislative  framework  governing  volunteer  activities  is  in  need  of 
systemic  reform  and  strategic  policy  planning  by  the  state.  An  important  first  step  would  be  the 
adoption of the State Target Programme for the Development of Volunteering in Ukraine 2025-2030 
with matching funds for its  implementation. Some positive initiatives to increase public  funding for 
civil  society  were  recorded,  but  overall  further  improvements  are  required  as  there  is  no 
comprehensive  and  accessible  funding  system  in  place  across  the  different  institutions,  which 
negatively  affects  the  financial  sustainability  of  CSOs.  The  cuts  to  USAID  funding  have  further 
highlighted  the  reliance  of  CSOs  on  international  donors,  substantially  affecting  their  ability  to 
operate effectively and seriously challenging their long-term sustainability. 

Instances of CSOs being denied financial services have increased considerably. In the context of the 

22 

 
 
2025 money laundering and financing of terrorism national risk assessment, the risks associated with 
the non-profit sector should be assessed and vulnerabilities addressed through focused, proportionate 
and  risk-based  measures,  in  line  with  revised  recommendation  No.  8  of  the  Financial  Action  Task 
Force.  The  responsible  authorities  and  the  banking  sector  should  continue  a  credible  and  regular 
engagement with civil society to ensure they have adequate access to financial services.  

The  initiatives  taken  by  the  Presidential  Office  and  the  Ministry  of  Defence  during  the  reporting 
period to improve civilian oversight of the security and intelligence sector through cooperation with 
civil society are positive. They should continue and, where possible, expand. 

2.1.2. Public administration reform  

Strategic framework for public administration reform  

The strategic framework for public administration is in place. In May 2025, the government adopted 
the public administration reform (PAR) roadmap, which serves as the key guiding document for the 
PAR  reform  process  during  the  EU  accession  negotiations.  Both  the  PAR  and  the  public  financial 
management (PFM) strategies for the 2026-2030 period are under development. The strategies should 
be  developed  and  adopted  through  an  inclusive  consultation  process  and  aligned  with  the  Ukraine 
Plan and the PAR roadmap.  

In  July,  due to  the  Government  reshuffle,  the  institutional  framework  for  PAR  was  changed.  The 
responsibility  for  coordination  of  the  implementation  of  PAR  was  assigned  to  the  Deputy  Prime-
Minister for European and Euro-Atlantic Integration, while the First Deputy Prime Minister-Minister 
for Digital Transformation is responsible for digitalisation  in civil service  and service delivery. The 
Secretariat of the Cabinet of Ministers (SCMU) continues to exercise a formal coordination role at the 
administrative level. Cooperation and synergy among the responsible institutions, in particular in the 
field of civil service reform, including digitalisation, needs to be significantly improved. The reform 
process  needs  strong  political  leadership,  which  is  essential  to  ensure  consistent  progress  across  all 
areas  of  PAR.  The  political  responsibility  for  civil  service  policy  development  and  implementation 
should be clearly assigned to a member of the Cabinet of Ministers. 

Management and coordination mechanisms for the implementation of the PAR and PFM strategies 
are  in  place  and  operational.  The  role  of  the  PAR  Coordination  Council  in  overseeing  the 
implementation  of  the  PAR  strategy  should  be  strengthened  to  ensure  a  more  results-oriented 
approach, particularly in addressing reform bottlenecks, improving inter-institutional coordination and 
ensuring  effective  and  strategic  steering  of  reform.  The  financial  sustainability  of  PAR  remains  a 
challenge. 

Policy development and coordination  

The policymaking system is coordinated by the SCMU, while the area of national strategic planning is 
led by the Ministry of Economy, following the approval of the Concept of National Strategic Planning 
System (NSPS) by the Government in  August. The law on the NSPS is yet to be adopted. In 2025, 
Ukraine  initiated  the  development  of  the  concept  of  the  National  Programme  for  the  Adaptation  of 
Ukrainian Legislation to EU acquis (NPAA); its adoption, including the action plan, is pending.  

The capacity for evidence-based policymaking remains insufficient. The role of the government as 
an  initiator  of  draft  legislation  remains  limited,  as  the  majority  of  adopted  legislation  continues  to 
originate  from  Members  of  Parliament  (only  32%  of  adopted  laws  are  initiated  by  the  Cabinet  of 
Ministers).  

The quality of explanatory notes and impact assessments accompanying legislative proposals remains 
weak and should be improved in line with European standards. While the law on public consultations 
introduced mandatory consultations for the government and local government authorities, it does not 
extend this requirement to the legislative initiatives of Members of Parliament.  

The monitoring of the implementation of policies and legislation needs further strengthening. Some 
progress was made in 2024, when Ukraine introduced a ‘reform matrix’ - an analytical tool designed 
to  support  decision-making  and  monitoring  of  reforms.  It  systematises  and  aligns  all 

23 

 
 
recommendations  and  conditionalities  jointly  agreed  with  international  partners.  To  monitor  and 
report on the implementation of the commitments in the field of European integration, the information 
system  ‘Accession  Pulse’  is  prepared  to  be  launched.  The  future  National  Programme  for  the 
Adoption  of  the  EU  acquis  should  facilitate  a  more  consistent  approach  to  evidence-based 
policymaking.  

Public financial management 

PFM is broadly in place and efforts to improve it are ongoing. The PFM reform strategy for 2022-
2025  remains  credible  and  relevant  and  is  being  implemented.  Annual  monitoring  reports  on  the 
implementation  of  the  strategy  are  prepared  under  the  coordination  of  an  inter-ministerial  working 
group. The PFM reform strategy for 2026-2030 is being prepared.  

The  government  has  resumed  medium-term  budget  planning.  On  30 June 2025,  the  Cabinet  of 
Ministers approved the budget declaration for 2026-2028, which showed progress towards alignment 
with  the  EU  acquis  on  medium-term  budgetary  frameworks.  Notably,  it  included  headline  revenue 
and  expenditure  projections  for  the  pension  and  unemployment  funds,  alongside  more  detailed 
projections for the state and local budgets. The government has taken steps to improve the quality of 
public  expenditure  through  annual  spending  reviews  of  the  state  budget.  In  April,  the  government 
launched a spending review of the 2025 state budget, covering 31 policy areas. The methodology for 
conducting spending reviews is being improved. The optimal number of key spending units needs to 
be  determined  to  improve  spending  efficiency.  Efforts  are  also  ongoing  to  create  a  framework  for 
identifying,  assessing,  and  managing  fiscal  risks,  including  for  the  budgets  of  local  government 
authorities.  The  link  between  strategic  planning  and  budgeting  needs  to  be  further  strengthened.  In 
January 2025, a law amending the Budget Code was adopted, which provides for the application of 
gender-based budgeting at the state and local levels.  

An effective oversight of the budget process is needed, notably by setting up an  independent fiscal 
institution 
the  government’s  budgetary 
assumptions, and assess the performance of previous forecasts. 

the  government’s  forecasts,  scrutinise 

to  evaluate 

The  public  investment  management  (PIM)  framework  is  being  reformed  in  line  with  the  PIM 
roadmap  and  action  plan  for  2024-2028.  Core  to  the  new  system  is  the  creation  of  single  project 
pipelines  at  the  central,  regional  and  local  levels,  which  rely  on  transparent  prioritisation,  appraisal 
and selection mechanisms to form portfolios of public investment projects. Further strengthening of 
the  PIM  institutional  framework  is  essential,  including  the  strategic  planning  system  at  the  central 
level.  As  the  PIM  system  is  being  operationalised,  it  is  essential  that  the  sub-national  levels  of 
government are enabled to play their role in the new system. While there has been progress in piloting 
the Digital Restoration Ecosystem for Accountable Management (DREAM) as an integral part of the 
PIM system’s IT architecture, its role should be formally established and its functionality ensured. 

Budget transparency and openness needs to be restored unless security concerns preclude it.  

Public service and human resources management  

Martial  law  continues  to  have  a  significant  effect  on  the  civil  service  regulatory  framework. 
Competitive recruitment and selection to the civil service based on merit and equal opportunities 
is still suspended. The selection and recruitment procedures should be improved, particularly for the 
top management positions, and aligned with European best practices. Draft legislation was registered 
to  restore  and  improve  the  procedures  for  merit-based  recruitment  and  selection,  including  by 
strengthening integrity in the civil service. The adoption of this legislation should be followed by the 
full restoration  of merit-based recruitment in  the  civil  service.  All  civil  service vacancies should  be 
transparently published on the unified state web portal of electronic services. 

Progress  has  been  made  in  the  area  of  civil  service  remuneration.  In  March  2025,  legislative 
amendments were adopted to introduce a salary based on job classification, set a cap on the variable 
part of the salary at 30% of the total guaranteed part, and limit the seniority supplement to 30% of the 
base salary, thus reducing management discretion in setting salaries. The salary system is still based 
on the concept of ‘levels of jurisdiction’ of institutions, which differentiates salaries for comparable 

24 

 
 
roles  based  on  the  perceived  and  politically  determined  importance  of  an  institution.  The 
implementation of the reform should be analysed to address implementation gaps and further improve 
the salary system. 

The  roll-out  of  the  human  resource  management  information  system  (HRMIS)  has  advanced 
slowly, with approximately 52 000 posts now covered. Its actual use by state bodies remains limited. 
The  roll-out  of  the  HRMIS,  including  its  payroll  module,  across  all  government  entities  should  be 
accelerated.  This  should  result  in  fully  transparent,  real-time  and  comparable  human  resource  and 
payroll data across the entire civil service. The National Agency of Ukraine on Civil Service, which 
administers the HRMIS, continues to lack sufficient administrative capacity to implement the system. 
A comprehensive plan, endorsed by the government, to roll out the HRMIS is still lacking. In parallel, 
the Ministry of Digital Transformation is advancing with the implementation of Diia.Office, a portal 
for civil servants. Its alignment with the HRMIS should be ensured. The gender balance in the civil 
service remains uneven. As of June, senior civil service management comprised 74% men and 26% 
women, middle management 33% men and 67% women, while 21% of non-managerial civil servants 
were men and 79% women.  

Accountability of the administration  

Ukraine  keeps  the  system  of  public  accountability  operational,  however  certain  mechanisms  need 
improvement.  The  recommendations  of  the  independent  oversight  bodies  (the  Ombudsman  and  the 
Accounting  Chamber)  should  be  addressed  by  the  relevant  bodies.  During  the  reporting  period, 
Ukraine  adopted  legislative  amendments  aimed  at  improving  state  external  control  in  line  with 
international standards, as well as strengthening financial independence and expanding the powers of 
the Accounting Chamber to oversee the flow and use of all local budget funds.  

Internal governance  within ministries continues to lack a clear separation of  responsibilities at the 
highest  level  of  management,  namely  between  deputy  ministers  and  state  secretaries.  Policy  areas 
continue  to  be  managed  and  coordinated  by  political  appointees  (deputy  ministers)  instead  of 
professionally selected senior civil service managers. The internal reorganisation of ministries should 
advance to strengthen the policymaking capacities of ministries in a sustainable manner, and to ensure 
that  ministries  strategically  direct  and  coordinate  their  subordinated  bodies  through  result-based 
performance management. 

In October 2024, nearly 200 laws were aligned with the  Law on administrative procedure (LAP). 
The alignment of secondary legislation with the LAP started with the harmonisation of 167 legal acts. 
Since January 2025, the LAP applies to the public services provided by the National Bank. Further 
alignment  and  harmonisation  with  the  LAP  are  still  needed,  namely  in  the  areas  of  taxation  and 
customs  legislation  and  land  relations.  All  digital  administrative  procedures  and  secondary 
legislation should be aligned with the LAP. Training for officials at all levels continues but should be 
particularly  strengthened  at  the  level  of  local  government  authorities.  The  adoption  of  the  Law  on 
citizen  appeals  to  differentiate  between  administrative  procedure  cases  and  other  forms  of  public 
petitions is still pending. The adoption of the new code on administrative violations is necessary to 
systematise penalties for administrative violations and should be aligned with the LAP. The majority 
of public bodies have adopted anti-corruption programmes; however, some are still lacking.  

The  right  of  individuals  to  access  public  information  is  well-regulated  and  consistently  applied. 
Ukraine  regularly  and  systematically  publishes  open  data  on  a  dedicated  government  portal,  but 
access to certain public information remains restricted due to martial law. 

As  for  the  right  to  administrative  justice,  in  February  and  September  2025,  Ukraine  adopted 
necessary  legislation  to  establish  the  Kyiv  Specialised  District  Administrative  Court  and  the  Kyiv 
Specialised  Administrative  Court  of  Appeal.  Cases  of  the  old  Kyiv  district  administrative  court 
(abolished in December 2022) were redistributed between administrative courts, which facilitated the 
treatment  of  the  pending  cases  and  improved  access  to  justice.  The  new  courts  should  be 
operationalised  without  delay  to  ensure  that  people  can  access  their  right  to  administrative  justice 
involving central government bodies.  

Service delivery to citizens and businesses 

25 

 
 
The  delivery  of  services  to  both  the  public  and  businesses  continues  to  function  well.  The  new 
Government  Priority  Action  Plan  for  2025-2026  adopted  in  September  continues  to  prioritise  the 
digitalisation  and enhancement  of  public  service  provision to  improve  transparency,  efficiency  and 
accessibility for all citizens and businesses. In March, the government adopted the Action plan for the 
digitalisation  of  public  services  until  2026,  covering  more  than  30  areas,  including  education, 
healthcare, social protection of veterans, military services, and construction, in 25 state bodies.  

The Unified State Web Portal (Diia) remains one of the most widely used platforms to access public 
services, as online services continued to develop. All digital services should be aligned with the Law 
on administrative procedure. 

The offline provision of public services continued through a broad network of local administrative 
service  centres  (ASC).  At  the  beginning  of  2025,  the  number  of  ASCs  increased  by  9%  compared 
with  the  previous  year.  The  number  of  ASCs  accessible  to  people  with  disabilities  and  reduced 
mobility  reached  74%  in  2025,  compared  to  72%  in  2024.  To  further  strengthen  the  capacity  to 
provide  administrative  services  and  to  better  regulate  the  policy  on  the  funding  of  administrative 
services, Ukraine should adopt the law on administrative fees. 

2.2. RULE OF LAW AND FUNDAMENTAL RIGHTS 

2.2.1  Chapter 23: Judiciary and fundamental rights 

The  EU’s  founding  values  include  the  rule  of  law  and  respect  for  human  rights.  An  effective 
(independent, high quality and efficient) judicial system and an effective fight against corruption are 
of paramount importance, as is respect of fundamental rights in law and in practice. 

Functioning of the judiciary 

Strategic documents 

The  strategic  framework  is  partly  in  place.  In  May  2025,  Ukraine  adopted the rule  of law  roadmap 
outlining the  key  pre-accession  reforms.  Ukraine  should still adopt a  new mid-term  strategy for the 
development  of  the  justice  system  and  constitutional  judiciary  that  is  aligned  with  and  holistically 
complements the rule of law roadmap.  

Management bodies 

The management bodies are in place and continued  to function adequately overall. However, issues 
related to the selection and appointment of their members, as well as institutional capacities, including 
IT and analytical tools, and access to databases, need to be resolved without delay.  

Since  spring  2025,  the  High  Council  of  Justice  (HCJ)  operated  with  a  minimum  quorum  of  15 
members  (out  of  21),  but  in  October  2025,  the  President  appointed  two  internationally  vetted 
members.  The  filling  of  two  HCJ  vacancies  from  the  quota  of  the  Congress  of  Judges  needs  to  be 
urgently  accelerated,  while  the  Congress  of  Attorneys  still  refuses  to  launch  the  competition  for  its 
two vacancies, quoting martial law as the reason. The incomplete composition of the HCJ negatively 
affected  how  it  discharged  of  its  constitutional  functions.  Two  international  members  of  the  Ethics 
Council (a body assisting in the selection of HCJ members) resigned due to personal reasons and were 
successfully replaced in September. 

The  filling  of  the  one  remaining  vacancy  in  the  High  Qualification  Commission  of  Judges  (HQCJ) 
was delayed after the HCJ, in January, did not appoint either of the two candidates put forward by the 
HQCJ selection commission. In May, the selection commission nominated two new candidates and in 
August, the HCJ appointed one of them.  

The mandate of the selection commission for the HQCJ, which includes international experts, expired 
in  June.  While  the  mandate  of  the  current  HQCJ  runs  until  2027,  Ukrainian  law  would  require  the 
formation  of  a  new  HQCJ  selection  commission  composed  of  representatives  from  unreformed 
national  bodies.  To  ensure  the  sustainability  of  judicial  reform  and  the  integrity  of  the  reformed 
HQCJ,  the  formation  of  such  selection  commission  should  be  discontinued  and  instead,  the 

26 

 
 
 
involvement  of 
meaningful 
nominated 
internationally 
independent  experts 
the 
in 
selection  of  HQCJ  members 
In 
be 
should 
should 
parallel,  Ukraine 
launch 
the 
the 
national bodies involved in the 
the  HQCJ 
selection 
members.  

reform  of 

extended. 

of 

Growing 
the 
resistance 
involvement  of  internationally 
nominated 
independent 
experts in various selection or 
vetting  processes,  including  a 
pending constitutional petition and a legislative initiative challenging all internationalised processes, 
raises serious concern.  

to 

The  State  Judicial  Administration  (SJA)  continued  to  operate  with  an  acting  Head  following  the 
dismissal of its previous  Head on suspicion of corruption. After some delays, the HCJ relaunched a 
competition to select the new Head of the SJA. 

improving 

The  new  Public 
Integrity 
Council (PIC), composed of 20 
representatives, 
civil  society 
was  formed  in  August  2025. 
Given its  workload  and  critical 
role in judicial renewal, the PIC 
strengthened, 
to  be 
needs 
especially  by 
its 
access  to  judicial  dossiers  and 
its analytical capacities, and by 
sufficiently 
creating 
resourced 
The 
Council  of  Prosecutors  and  the 
Qualification  and  Disciplinary 
Commission of Prosecutors (QDCP) need to become more independent, in particular from the Office 
of  the  Prosecutor  General.  There  is  a  need  to  strengthen  their  integrity,  powers  and  autonomous 
resources,  and  establish  independent  and  objective  pre-selection  procedures  for  their  members, 
following the advice of the Venice Commission.  

a 
secretariat. 

Independence and impartiality 

The independence and impartiality of the judiciary is guaranteed by the constitution and the relevant 
legislation,  but  certain  shortcomings  in  the  law  and  in  practice  persist.  Public  trust  in  the  judiciary 
remains very low.  

In September 2024, the Council of Judges approved a new version of the Code of Judicial Ethics. The 
HCJ  and  the  Council of  Prosecutors  should  be more proactive in  protecting judges  and prosecutors 
from undue interference. The automatic allocation of cases to judges should be further improved as 
part of the renewal of the unified judicial information and telecommunication system. The legislation 
on recusals and conflicts of interest needs to be strengthened. Ukraine still needs to introduce a system 
to randomly allocate cases to prosecutors based on clear and objective criteria, with proper safeguards 
against  possible  manipulation,  ensure  consistent  justification  for  and  provide  appeal  mechanisms 
against reassignment decisions.  

In July 2025, the Parliament adopted a law that, inter alia, subordinated the independent specialised 

27 

 
 
anti-corruption  agencies  –  the  National  Anti-Corruption  Bureau  (NABU)  and  the  Specialized  Anti-
Corruption Prosecutor’s Office (SAPO) – under the authority of the politically appointed Prosecutor 
General. Following domestic protests and international criticism, another law was swiftly adopted that 
restored  the  independence  of  NABU  and  SAPO,  but  it  failed  to  address  several  other  problematic 
provisions,  including  those  that  allow,  during  martial  law,  to  transfer  and  appoint  prosecutors  to 
regional  prosecution  offices  and  the  Office  of  Prosecutor  General  (OPG)  without  competition,  and 
that  grant  the  Prosecutor  General  access  to  any  pre-trial  investigation  materials  (except  those  of 
NABU  and  SAPO).  These  provisions  undermine  meritocracy  within  prosecutorial  service  and  raise 
risks  of  undue  interference  in  criminal  cases.  They  should  be  repealed,  and  in  the  meantime,  their 
application should be put on hold. 

In  spring  2025,  the  State  Bureau  of  Investigation  (SBI)  searched  the  premises  of  the  HQCJ  and 
questioned  its  members  as  part  of  several  criminal  investigations.  The  HQCJ,  the  PIC  and  CSOs 
expressed serious concern about these actions of the SBI and considered them as an encroachment on 
the independence of the HQCJ. 

In January 2025, the HQCJ adopted a regulation on the methodology to evaluate qualifications and on 
the  indicators  of  compliance.  In  May  2025,  Parliament  adopted  a  law  to  streamline  the  judicial 
selection procedure. The judiciary still suffers from severe understaffing with 2 198 judicial vacancies 
remaining to be filled (as of August), due to the slow pace of selections and appointments, ongoing 
retirements and resignations. The HQCJ continued the competitions to recruit 1 800 first instance, 550 
appeal  court  and  High  Anti-Corruption  Court  (HACC)  judges.  In  total,  from  September  2024  to 
August 2025, the President appointed 180 judges upon their nomination by the HCJ. Given the slow 
pace  of  work  and  persistent  understaffing,  the  capacities  of  the  HQCJ,  the  HCJ  and  PIC  should  be 
strengthened urgently. 

After  the  resignation  of  the  Prosecutor  General  in  autumn  2024,  a  new  Prosecutor  General  was 
appointed in June 2025. To reduce the risk of politicisation, the selection and dismissal procedures for 
the  Prosecutor  General  should  be  made  more  objective,  transparent  and  merit-based  in  line  with 
European standards. In June, the new Prosecutor General cancelled the pilot procedure for forming a 
reserve  list  of  candidates  to  fill  managerial  positions  in  the  prosecutor’s  offices,  shortly  before  the 
reserve list of candidates of high integrity and professionalism was finalised. In addition, prosecutors 
started being transferred to regional prosecution offices and the OPG without competition by invoking 
the problematic legal provisions introduced in July 2025. The system for selecting management-level 
prosecutors needs to be improved, in particular to enhance transparency and ensure credible integrity 
and  professionalism  checks,  while  competitions  need  to  be  urgently  restored  for  transfers  and 
appointments at lower levels. Prosecutors’ salaries remain lower than those of judges even though the 
subsistence minimum used to calculate the salaries for prosecutors was raised as of 1 August. Overall, 
the prosecutorial reform process has slowed down due to the structural changes.  

The transparent selection of judges to the Constitutional Court of Ukraine (CCU) continued with the 
involvement of the Advisory Group of Experts. However, in January 2025, the CCU lost its quorum 
of 12 judges  (out of a total of 18 judges) after the mandates of several judges expired. In February 
2025, the Advisory Group of Experts recommended ten duly vetted candidates to fill five vacancies 
under the  President’s  and Parliament’s  quotas.  In  June  and  September,  the  President  appointed  two 
new  judges  to  the  CCU,  which  restored  the  Court’s  quorum.  However,  in  October  2025,  the 
Parliament  failed  to  appoint  two  judges  from  its  quota,  delaying  the  renewal  of  the  CCU.  The 
appointing  authorities  must  urgently  proceed  with  the  selection  and  appointment  of  the  vetted 
candidates, avoiding further delays. In May 2025, the Supreme Court annulled the presidential decree 
that dismissed a former CCU judge. The Supreme Court held that the President had no authority to 
dismiss  a  CCU  judge  by  simply  revoking  the  previous  President’s  decree  of  appointment.  This 
Supreme Court decision strengthened the independence of CCU judges. The Law on the constitutional 
procedure should still be improved in line with the 2021 Venice Commission recommendations. 

Accountability 

28 

 
 
The  accountability  of  the  judiciary  is  broadly  satisfactory  but  needs  to  be  further  improved  and 
enforced in practice. The HQCJ has continued to evaluate the qualifications of sitting judges (vetting) 
with  the  involvement  of  the  PIC,  albeit  at  a  slow  pace  due  to  persisting  capacity  constraints.  By 
September  2025,  2 549  judges  have  undergone  this  procedure,  while  1 413  judges  still  have  to 
complete  it.  During  the  reporting 
period, 
recommended 
dismissing  a  total  of  30  judges  who 
failed  to  pass  the  evaluation,  while 
the  HCJ  dismissed  10  judges.  The 
capacities  of  all  institutions  involved 
should  be  strengthened  urgently.  In 
particular,  the  HQCJ  should  develop 
to  conduct 
autonomous  capacities 
of 
checks 
credible 

the  HQCJ 

integrity 

the 

should 

review 

expedite 

reasoning  of 

further 
candidates  and 
digitalise  its  work.  It  still  has  to 
improve 
its 
decisions  that  override  a  negative 
opinion of the PIC. The HCJ needs 
to 
of 
the 
submissions from the HQCJ on the 
dismissal of judges who failed the 
evaluation  of  qualifications  and 
improve 
its 
decisions.  The  Supreme  Court  did 
not  reverse  its  controversial  decision  of  June  2024  on  the  evaluation  of  judges’  qualifications  that 
weakened the role of the PIC, and rendered further decisions on judicial selection and the disciplinary 
liability  of  judges  that  were  criticised  by  civil  society  for  lack  of  consistency  and  for  potentially 
undermining judicial reforms. 

reasoning  of 

the 

The  new  Service  of  Disciplinary  Inspectors  (SDI)  was  established  in  December  2024  as  an 
autonomous department of the HCJ to assist the latter in processing disciplinary cases against judges. 
The  head  and deputy  head  of  the  SDI,  as  well  as 21  disciplinary inspectors,  were appointed  by the 
HCJ  following  a  transparent  procedure  with  the  involvement  of  independent  experts.  In  April,  the 
HCJ  launched  the  competition for  filling  five  new  disciplinary inspector  positions.  The  SDI  started 
handling the heavy backlog of about 11 000 disciplinary complaints against judges. Since December 
2024, the HCJ, with the assistance of the SDI, reviewed some 6 000 disciplinary complaints. During 
the  reporting  period,  36  judges  received  disciplinary  sanctions,  and  the  dismissal  procedure  was 
launched  for  7  judges.  The  HCJ  rules  on  the  prioritisation  of  disciplinary  cases  should  be 
systematically applied, and priority cases handled without delays.  The HCJ should also improve the 
reasoning  and  uniformity  of  practice  in  disciplinary  cases  and  revise  its  rules  to  ensure  that  HCJ 
members  from  the  judiciary  do  not  review  disciplinary  complaints  against  judges  from  their  own 
courts.  The  SDI  should  receive  greater  financial  and  institutional  support  to  sustain  its  operations. 
Disciplinary offences relating to judges’ conduct need to be defined more precisely, in line with the 
recommendations  of  the  Council  of  Europe’s  Group  of  States  against  Corruption  (GRECO).  The 
current legislation still allows judges who are subject to disciplinary proceedings to resign before the 
HCJ’s decision on dismissal, thus avoiding negative consequences, and requires the HCJ’s approval 
before an appeal procedure against an HCJ decision can be launched. In March 2025, a new draft law 
was  registered  to  comprehensively  revise  the  disciplinary  liability  system  for  judges,  but  it  was 

29 

 
 
criticised by  CSOs. The HCJ requested its review by the Venice Commission. Ukraine  will have to 
take into account the latter’s recommendations and engage in further expert discussions when revising 
the draft law.  

To  increase  the  accountability  of  the  judiciary,  legislation  improving  the  system  of  judges’ 
declarations  of  integrity  should  be  adopted,  including,  as  a  temporary  measure,  the  meaningful 
involvement  of  independent  experts,  nominated  by  international  partners,  in  the  verification  of  the 
declarations of integrity made by judges from the highest courts. To  address corruption risks in the 
Supreme  Court,  such  experts  should  also  be  temporarily  involved  in  the  selection  of  new  Supreme 
Court judges.  

In  December  2024,  following  inclusive  consultations,  the  HCJ  approved  the  unified  indicators  for 
evaluating  the  integrity  and  professional  ethics  of  judges.  However,  some  of  the  indicators  would 
need  to  be  clarified  to  allow  an  effective  evaluation  aligned  with  European  standards.  The  detailed 
procedures to verify declarations of assets and lifestyle monitoring for ordinary and CCU judges still 
need  to  be  agreed  between  the  National  Agency  on  Corruption  Prevention,  the  High  Council  of 
Justice and the CCU. In July, the CCU approved new rules on the professional ethics of judges of the 
CCU, which will need to be effectively applied in practice. 

The  attestation  of  prosecutors  is  continuing  and  should  be  completed  without  any  further  delays. 
Prosecutors who fail it should be dismissed in line with the law, while pending court cases should be 
resolved.  In  autumn  2024,  it  became  known  that  dozens  of  prosecutors  had  been  benefiting  from 
allegedly  unlawful  disability  pensions.  As  a  result,  administrative  and  criminal  investigations  were 
launched,  including  more  than  330  disciplinary  proceedings.  Dismissal  decisions  were  adopted  in 
relation  to  four  prosecutors.  Apart  from  indictments  in  two  criminal  proceedings,  no  progress  was 
made in related criminal cases. Ukraine should adopt legislation  to improve the disciplinary system 
for  prosecutors  and  strengthen  the  institutional  capacity  of  the  QDCP,  in  line  with  GRECO 
recommendations.  A  transparent  selection  procedure  for  all  members  of  the  QDCP  should  be 
introduced, including a credible integrity check. The power to review complaints against decisions of 
the QDCP should be transferred to the Council of Prosecutors.  

Quality of justice 

the 

ensure 

The  quality  of  justice  should  be 
further  improved.  More  efforts 
are  needed 
the 
to 
uniformity  of  court  practice 
first,  appeal  and 
within 
instances.  Periodic 
cassation 
performance 
of 
evaluations 
judges and prosecutors still need 
to  be 
introduced,  based  on 
objective  rules  and  assessment 
criteria  in  line  with  GRECO 
recommendations  and  European 

standards.  

No progress was made on reform of the Bar. Concerns about the abuse of disciplinary mechanisms 
against  lawyers  and  uneven  disciplinary  practices  remain.  The  Ukrainian  National  Bar  Association 
(UNBA) has still not launched the competition for the HCJ members from its quota. In addition, the 
Bar’s self-governing bodies have not held elections, despite their  mandates having expired. Ukraine 
needs to urgently launch a comprehensive reform of the Bar, with the aim to ensure that the bodies of 
the  UNBA  are  created  on  the  basis  of  a  transparent  and  credible  procedure  and  to  substantially 
improve  qualifications,  admissions,  disciplinary  liability,  financial  management  and  continuous 
training systems. 

Some  aspects  of  legal  education  have  improved  and  a  concept  on  higher  legal  education  was 
developed,  but  comprehensive  reforms  are  still  pending.  New  legislation  should  address:  (i)  the 

30 

 
 
institutional  separation  of  legal  education  and  law  enforcement  training;  (ii)  the  allocation  of  state 
funds based on merit; (iii) the strengthening of 
the  admission  criteria  for  law  school  and  of 
licensing  requirements;  and  (iv) 
integrity 
issues  in  legal  education.  Further  steps  are 
needed  to  develop  and  spread  knowledge  of 
EU  law  and  of  specialised  competencies, 
including in the area of ethics.  

and 

transparency 

The  National  School  of  Judges  of  Ukraine 
(NSJU)  and  the  Prosecutor’s  Training  Centre 
improved 
international  cooperation.  The 
announcement  of  a  competitive  selection  of 
the position of vice-rector a is a positive step 
towards 
institutional 
accountability. However, the selection process 
lacks  clear  criteria  on  integrity,  competence, 
transparency and merit-based evaluation. Transparent and merit-based procedures are needed for the 
selection of its management and staff, and new accountability and anti-corruption procedures should 
be  established.  In  October  2024,  the  NSJU  launched  a  Training  Laboratory  on  EU  law.  The 
curriculum, and teaching and evaluation methods should be further modernised. The budget allocation 
for the NSJU for 2025 meets 41.2% of its expenditure requirements, compared with 58.9% in 2024. 
The budget allocated for the Prosecutor’s Training Centre met 100% of its expenditure requirements 
and was increased for 2025.  

Efficiency 

The efficiency of justice is negatively affected by a persistent lack of human, financial and technical 
resources against the backdrop of the ongoing Russian war of aggression. Funding for the judiciary in 
the 2025 budget covered only around 61% of its needs, even though it was increased compared with 
2023 and 2024. The budget of the prosecution service was also increased by 11% in 2025. However, 
prosecutors still receive lower salaries than judges. The judicial governance bodies have adjusted the 
judicial system to the challenging realities, facilitating remote hearings in certain cases and adopting 
new  security  protocols.  While  clearance  rates  well  exceeded  90%  across  all  court  instances  and 
specialisations,  a  backlog  of  cases  continued  to  accumulate.  Ukraine  should  further  improve  its 
system  to  collect  and  analyse  judicial  statistics  to  strengthen  evidence-based  judicial  policymaking 
and management of the courts. Further efforts are needed to optimise the judicial network.   

Kyiv 

In  autumn  2024,  the  SJA  launched  the 
allocation  of  20 000  pending  cases  from 
the dissolved Kyiv District Administrative 
Court 
to  other  district  administrative 
in 
courts.  Legislation  was  adopted 
February and September 2025 to establish 
District 
the 
Specialised 
Administrative  Court  and 
the  Kyiv 
Specialised  Administrative  Court  of 
Appeal  to  hear  cases  involving  national 
state  agencies.  In  September,  the  HQCJ 
formed  the  Expert  Council,  composed  of 
international 
three  national  and 
members, to assist in the selection of their 
judges.  The  establishment  of 
these 
important courts needs to progress without further delays. 

three 

The provision, introduced in May 2024, which allows certain high-level officials (including Members 
of  Parliament)  to  opt  for  their  criminal  cases  in  any  court  to  be  heard  by  a  panel  of  three  judges, 

31 

 
 
regardless of the severity of the  possible penalty, should be reviewed in  terms of its proportionality 
and  impact  on  judicial  efficiency.  Ukraine  should  also  remove  from  the  relevant  legislation  the 
provision on the automatic closure of criminal cases due to the expiry of the time limits for pre-trial 
investigation and review the current time limits to ensure sufficient time for criminal investigations. 

and 
(ii) 

written 
envisaging 

To  further  improve  the  efficiency  of  justice,  procedural  reforms  are  needed,  such  as:  (i) expanding 
court 
simplified 
proceedings; 
for 
alternative  dispute  resolution  in  certain 
categories  of  cases;  (iii)  reducing  the 
scope for procedural delays and abuses; 
(iv) and further streamlining procedural 
codes  in  line  with  good  EU  practices. 
Reforms  are  also  needed  to  modernise 
the  digitalisation  of  the  justice  system, 
including  for 
the  courts  and  case 
management, and to better enforce court 
decisions.  A  detailed  roadmap  for  the 
development  of  IT  solutions  in  the 
judiciary  was  approved  in  December 
2024. Ukraine also continued to develop 
an  e-case  management  system  in  the 
criminal justice system and created an inter-agency working group in December.  

In December 2024, the Law on judicial oversight of the enforcement of court decisions entered into 
force,  which  provides  additional  instruments  to  courts  to  improve  the  currently  low  rate  of 
enforcement of decisions. Ukraine needs to adopt additional legislation on improving the enforcement 
of  court  decisions  related  to  monetary  and  non-monetary  obligations,  on  the  digitalisation  of 
enforcement proceedings, and to create a system to collect data on enforcement.  The legal status of 
private bailiffs needs to be strengthened. Ukraine should also prepare a roadmap for the abolition and 
revision of existing moratoria, and continue to implement the strategy and action plan for resolving 
the  problem  of  non-enforcement  of  domestic  court  decisions.  More  efforts  are  needed  to  execute 
judgments of the European Court of Human Rights.  

The  level  of  implementation  of  the  2021  mediation  law  is  still  insufficient.  There  is  no  national 
system  to  collect  data  on  various  forms  of  alternative  dispute  resolution.  The  planned  mandatory 
mediation  for  specific  categories  of  disputes  still  needs  to  be  prepared  and  implemented,  public 
awareness  of  mediation  should  be  further  promoted,  and  arbitration  should  be  developed  and  used 
more frequently. 

International crimes 

As  of  September  2025,  184 030  criminal  proceedings  related  to  international  crimes  had  been 
registered,  1 217  people  had  been  indicted  and  449  convicted  for  war  crimes  and  the  crime  of 
aggression. The Rome Statute entered into force in Ukraine in January 2025, following its ratification. 
The  minimum  required  changes  were  introduced  to  align  Ukraine’s  criminal  law  with  the  Rome 
Statute,  while  a  comprehensive  alignment  with  international  criminal  law  standards  is  still 
outstanding.  

The  Victims  and  Witness  Coordination  Centre  strengthened  its  regional  presence.  Following  the 
conclusion  of  a  memorandum,  the  Centre  started  cooperating  with  the  Register  of  Damages  and 
sharing  information  with  victims  and  witnesses  about  the  possibility  of  registering  claims.  In 
November  2024,  Parliament  adopted  a  law  that  established  the  legal  status  of  a  victim  of  conflict-
related  sexual  violence  and  the  possibility  to  receive  immediate  interim  reparations,  as  a  result  of 
Russia’s  war  of  aggression.  Implementation  of  these  provisions,  however,  requires  the  adoption  of 
implementing legislation. 

32 

 
 
Fight against corruption 

Track record 

Ukraine  continued  to  make  progress  on  building  a  track  record  in  the  fight  against  high-level 
corruption.  

NABU and SAPO maintained pressure by 
exposing  major  cases  of  corruption, 
including at highest levels of government. 
The  number  of  indictments  in  NABU 
cases increased, while the total number of 
suspects  and  indicted  persons  declined 
slightly.  The  number  of  indictments  in 
the 
corruption  cases 
National  Police  (NPU),  the  State  Bureau 
of  Investigation  (SBI)  and  the  Economic 
Security  Bureau  (ESBU)  decreased.  A 
large  number  of  cases  remained  without 
court  decision,  while 
there  was  an 
increase in the number of closed cases. 

investigated  by 

and 

addressed. 

agreements 

The  number  of  cases  considered  by  the 
High  Anti-Corruption  Court 
(HACC) 
remains  at  a  similar  level  to  the  previous 
year  while  the  number  of  verdicts  issued,  including  final  convictions,  has  increased  slightly.  The 
average  duration  of  criminal  trials  at  the  court  is  very  high,  resulting  in  a  backlog  that  needs  to  be 
urgently 
The 
number of cases resolved with 
plea 
of 
convicted  persons  released  on 
probation  is  increasing.  There 
are  very  few  final  convictions 
for  illicit enrichment  and  false 
declarations, both in high-level 
and  non-high-level  corruption 
requires 
cases, 
which 
corrective 
at 
institutional 
legislative  and 
levels.  

measures 

of 
civil 
application 
The 
unjustified 
of 
confiscation 
assets is progressing with most 
claims 
partially 
satisfied.  The  number  of 
seizures  and  final  confiscation  of  assets  in  high-level  corruption  cases  remains  low  and  further 
progress is needed, including through carrying out effective parallel financial investigations.  

fully 

or 

The number of internal corruption reports received by the National Agency on Corruption Prevention 
(NACP) has increased considerably (from 534 in 2023 to 982 in 2024) but the number of confirmed 
whistle-blowers fell from 25 in 2023 to 17 in 2024. Only a small number of people were convicted in 
criminal proceedings based on whistle-blower reports (0.47% of proceedings at the level of ordinary 
courts; 5% in HACC proceedings). 

Legal framework 

The  legal  framework  for  the  fight  against  corruption  is  broadly  in  place  but  needs  to  be  further 
strengthened. Ukraine should extend the statute of limitation periods and review the grounds for its 

33 

 
 
interruption  and  suspension,  in  line  with  European  standards,  to  ensure  a  sufficient  timeframe  to 
properly investigate, prosecute and adjudicate corruption and corruption-related offences. 

In  2024,  Ukraine  adopted  legislative  amendments  that  improve  the  regulations  on  plea  bargains  in 
corruption  cases.  Ukraine  also  adopted  rules  of  ethical  conduct  for  lobbyists  during  the  reporting 
period. The Law on lobbying entered into force in September 2025 following an initial postponement 
due  to  delays  in  putting  the  Transparency  Register  into  operation.  The  NACP  needs  to  develop  its 
capacities to effectively and impartially monitor compliance with the lobbying framework. 

In December 2024, Ukraine adopted legislation to align with the accession criteria of the OECD Anti-
Bribery Convention by introducing autonomous corporate liability for foreign bribery and explicitly 
prohibiting deductibility of bribes for all tax purposes.  In October 2025, the OECD Working Group 
on  Bribery  in  International  Business  Transactions  approved  Ukraine’s  request  of  accession  to  the 
OECD Anti-Bribery Convention, while outlining remaining issues to be addressed, including on the 
definition of a foreign public official and successor liability for legal entities. This opens the way for 
the  ratification  process.  Further  strengthening  of  the  corporate  liability  regime  is  still  necessary  to 
address domestic corruption.  

Anti-corruption proofing of draft legislation by NACP or Parliament’s Committee on Anti-Corruption 
Policy  is  not  systematic,  and  their  recommendations  are  not  consistently  followed.  The  Parliament 
adopted legislative amendments, allegedly aimed at promoting business interests or national security, 
which however negatively affect other public interests, transparency and oversight. These include the 
law on the protection of good faith purchasers of illicitly privatised land, adopted in April, as well as 
the law curtailing public access to key state registers, adopted in August. Other legislative initiatives, 
exempting certain defence companies from criminal liability or introducing unwarranted restrictions 
regarding  criminal  liability  and  investigations,  including  for  corruption  and  other  economic  crimes, 
should be substantially amended or not pursued further. 

NABU’s  jurisdiction  needs  to  be  reviewed  with  the  aim  of  covering  all  high-risk  public  positions 
(such  as  leadership  of  the  President’s  Office,  heads  of  regional  administrations,  etc.).  Further 
strengthening of safeguards against circumvention of NABU’s investigative jurisdiction by other law 
enforcement authorities has yet to be introduced. Legislative amendments should also be adopted to 
address  frequent  procedural  delays  in  criminal  proceedings  effectively.  The  legal  framework  on 
whistle-blower protection still requires full alignment with the EU acquis.  

Strategic documents 

The impact of the 2021-2025 Anti-Corruption Strategy and the State Anti-Corruption Programme has 
been  limited  due  to  a  gap  in  their  implementation,  indicating  the  need  for  whole-of-government 
engagement.  

The  new  2026-2030  Anti-Corruption  Strategy  and  State  Anti-Corruption  Programme  must  be 
developed and adopted without delay in a transparent and inclusive manner. They should include an 
ambitious but realistic level of priority measures in the areas most prone to corruption, such as public 
procurement, reconstruction, energy, infrastructure, construction and land management, the judiciary 
and  law  enforcement,  customs  and  taxation,  extraction  industries  and  natural  resources.  To  avoid 
implementation  challenges  with  the  future  strategy,  strengthening  of  capacities  and  resources  is 
needed,  including  at  the  level  of  the  NACP.  In  addition,  enforcement  structures  and  the  regular 
engagement of (high-level) political coordination bodies should be stepped up urgently. 

Most public authorities have adopted anti-corruption programmes, but they rarely address root causes 
of  corruption  and  the  NACP  should  strengthen  its  quality-control.  Certain  local  government 
authorities and smaller state-owned enterprises are not required to develop such programmes, which 
remains a concern to be addressed.  

Institutional framework 

Ukraine’s institutional framework for the fight against corruption had remained overall effective and 
the specialised anti-corruption institutions had continued to operate independently and effectively. 

34 

 
 
In  June  2025,  the  Parliament  established  a  Temporary  Investigative  Commission  with  a  broad 
mandate  to  investigate  possible  corruption  in  law  enforcement  agencies,  courts  and  judicial 
authorities. It is important that parliamentary oversight does not erode public trust in anticorruption 
institutions  through  unwarranted  public  statements  nor  overstep  the  limitations  stemming  from  the 
separation of powers. 

In July, the OPG, the State Security Service of Ukraine (SSU) and the State Bureau of Investigations 
(SBI) conducted a substantive number of searches concerning the staff of NABU. Some NABU staff 
were  arrested  and  placed  in  pre-trial  detention.  In  addition,  the  SSU  carried  out  unannounced 
inspections related to the handling of classified information by NABU and SAPO. 

Shortly after, the Parliament adopted a law dismantling important safeguards for the independence of 
NABU and SAPO and putting their operational work under the authority of the politically appointed 
Prosecutor General. Following domestic protests and international criticism, a law was subsequently 
adopted  restoring  NABU  and  SAPO’s  independence.  Undue  pressure  on  anti-corruption  agencies 
remains a matter of concern.  

The  first  external  independent  performance  audit  of  NABU,  completed  in  May  2025,  assesses  the 
institution  as  moderately  effective.  The  audit’s  recommendations  should  be  fully  complied  with. 
NABU and SAPO maintain a relatively low overall rate of cases ending in acquittal or dismissal, and 
are increasing their efforts in pre-trial investigations, but NABU needs to focus more on high-impact 
investigations.  The  problems  with  NABU’s  access  to  timely  and  impartial  forensic  examinations 
should be addressed urgently. NABU still requires independent wiretapping capacities in practice. To 
this end, a memorandum of understanding between NABU and the SSU was signed in October 2024, 
providing for an implementation plan after the lifting of martial law. It will be equally important for 
NABU to address internal structural issues and procedures to prevent and address effectively the risks 
that have been identified of improper disclosure of information about investigations, and to ensure the 
full effectiveness of its internal control department. NABU continues to gradually increase its human 
resources, which will require extensive training. The limitations preventing the full deployment of the 
e-Case management system are yet to be addressed. 

The external independent audit of SAPO should be carried out to ensure proper control and oversight, 
and  its  recommendations  should  be  implemented.  SAPO’s  powers  and  competencies  need 
strengthening,  particularly  to  allow  the  head  of  SAPO  to  launch  investigations  and  approve 
investigative actions against Members of Parliament independently of the Prosecutor General. 

Following  the  launch  of  competitions  by  the  High  Council  of  Justice  and  the  High  Qualification 
Commission of Judges to recruit 25 additional judges for the High Anti-Corruption Court, only 2 out 
of  140  candidates  succeeded  and  were  appointed.  To  fill  the  remaining  23  posts,  additional 
competitions  were  swiftly  launched  and  are  currently  ongoing;  it  will  be  important  that  the  Public 
Council of International Experts remains engaged in this process until the selection of the remaining 
posts  is  completed.  Ukraine  has  also  adopted  legislative  amendments  to  streamline  the  selection 
process  and  eligibility  criteria  for  judges,  which  had  a  positive  impact.  To  address  the  significant 
delays,  reduce  the  backlog  of  cases  and  shorten  the  disposition  time,  the  HACC  should  develop  a 
comprehensive strategy to ensure the efficiency of adjudication. The HACC still needs new premises 
to accommodate additional judges and auxiliary staff.  

Overall,  the  NACP  maintains  its  central  role  in  anti-corruption  policy  making  and  preventing 
corruption, but concerns have been raised regarding its impartiality and effectiveness in some of its 
operations.  The  Agency  should  urgently  implement  the  outstanding  recommendations  of  the  report 
issued in July 2023 of the commission that conducted an independent assessment of the effectiveness 
of  the  NACP.  The  next  independent  assessment  of  the  NACP  effectiveness  should  be  conducted 
without further delay, applying a credible methodology and criteria. The Agency in particular needs to 
ensure  that  its  internal  processes  are  regulated  through  binding  bylaws  after  broader  stakeholder 
consultations, instead of through non-binding recommendations or similar documents. A competitive 
level of salaries as well as clear internal human resource policies should be continuously guaranteed 
to recruit and retain skilled employees. The Agency has created sectoral expertise units, which should 

35 

 
 
be  empowered  to  provide  additional  methodological  support  to  anti-corruption  units  and  officials 
from public bodies and state-owned enterprises. The skills, professionalism and accountability of anti-
corruption officers should also be strengthened. 

The  asset  declaration  system  needs  to  be  strengthened  to  prevent  and  detect  unexplained  wealth 
effectively. The practical and legal shortcomings that remain to be addressed concern the (automated) 
verification  process,  including  the  verification  methodology  and  the  applied  risk-based  approach. 
Some  degree  of  external  oversight  of  the  logic  and  arithmetic  control  of  declarations  should  be 
enabled. The NACP continues to steadily increase its efficiency and improve its results on monitoring 
the lifestyles of public officials, including effective follow-up and civil confiscations approved by the 
HACC. More attention to high-level officials is needed in the practical application of financial control 
tools,  in light  of  the  number  of  allegations  of  unexplained  wealth  and  hidden  assets  that  have  been 
reported.  Parliament  should  further  increase  the  penalties  for  unexplained  wealth  and  reduce  the 
applicable  thresholds  to  make  the  sanctions  regime  more  relevant  and  effective.  In  addition,  the 
personal scope of the obligation to declare assets should also cover the staff of private offices of high-
level 
including 
assistants. 

officials, 
and 

political 

advisers 

to 

of 

number 

The 
public 
authorities  and  other  entities 
the 
that  are  connected 
Whistle-blowers’ 
Unified 
remains 
Portal 
Reporting 
limited  and 
increasing 
is 
slowly.  The  challenges  with 
addressing 
Portal’s 
shortcomings  and  ensuring 
confidentiality  needs 
to  be 
addressed because it may lead 
to an increase in violations of 
whistle-blowers’  rights  and 
undermine public confidence.  

the 

Fundamental rights  

General framework 

The general framework for fundamental rights is satisfactory. Martial law has led to some restrictions, 
but they have generally been in proportion to the security situation and applied cautiously. Ukrainian 
institutions should continuously assess restrictions related to martial law and, in consultation with the 
affected  groups,  where  deemed  to  be  unnecessary  or  disproportionate,  proceed  with  the  necessary 
steps  to  lift  them.  Ukraine  should  also  develop  a  strategy  to  swiftly  restore  all  restricted  rights  and 
freedoms once security circumstances allow and martial law ends. 

International human rights instruments 

Cooperation  with  international  human  rights  bodies  and  the  follow-up  to  their  recommendations  is 
overall satisfactory. Ukraine has ratified most of the key international human rights instruments.   

In October 2024, Ukraine ratified the Rome Statute of the International Criminal Court, which came 
into force on 1 January 2025. Ukraine invoked Article 124 of the statute for a seven-year transitional 
opt-out on the prosecution of war crimes committed by its nationals. Additional amendments to the 
Criminal Code should be adopted to further align it with the text of the Rome Statute. 

European Court of Human Rights  

The cooperation with the European Court of Human Rights and the implementation of its judgments 
must  improve.  During  the  reporting  period,  the  European  Court  of  Human  Rights  (ECtHR)  found 
breaches of the European Convention on Human Rights relating mainly to the protection of property, 

36 

 
 
the right to a fair trial, the right to liberty and security of persons and the prohibition of torture. There 
are  currently  694  (as  of  31 August 2025)  cases  under  enhanced  supervision  by  the  Committee  of 
Ministers. These cases predominantly concern issues related to unlawful arrests, length of detention 
on remand, violations of the right to life, ill treatment by police, poor detention conditions and lack of 
adequate medical treatment, as well as the excessive length of criminal and civil proceedings and lack 
of  effective  remedy.  Ukraine  needs  to  address  systemic  or  structural  issues  raised  by  the  Court,  in 
particular  in  the  areas  of  the  judiciary,  law  enforcement  and  human  rights,  and  to  ensure  the 
systematic and timely enforcement of ECtHR judgments. 

Promotion and enforcement of human rights 

The legal and institutional framework for the promotion, protection and enforcement of human rights 
is  broadly  in  place. The  Parliamentary  Commissioner  for  Human  Rights  –  the  Ombudsperson  –  is 
active  and  efficient  but  remains 
under-resourced. The financial and 
operational  independence  of  the 
Ombudsperson  should  be  ensured 
by  adapting  its  legal  base  in  line 
with 
and  Venice 
Principles,  and  in  full  alignment 
with the EU acquis. The proposed 
draft law on the Commissioner for 
Human  Rights  still  needs  to  take 
this fully into account. 

the  Paris 

its 
Ukraine  needs 
positive  track  record  by  updating 
its  national  human  rights  strategy 
and  developing  a  corresponding 
action plan.  It should  also finalise 
and  implement  the  strategy  for  restoring  power  and  reintegrating  the  population  of  the  occupied 
territories  of  Ukraine  with  a  view  to  the  eventual  reintegration  of  territories  currently  outside 
government control, while promoting social cohesion and ensuring that the fundamental rights of the 
Ukrainian citizens that have lived under Russian occupation are upheld. 

to  continue 

Prevention of torture and ill treatment 

Ukraine’s  legislation  provides  some  legal  guarantees  on  the  prevention  of  torture  and  ill  treatment; 
aligning it further with international law and advancing with criminal proceedings in torture  cases is 
key  to  ensure  accountability. There  have  been  some  positive  developments  in  terms  of  legal 
safeguards, material conditions in particular facilities and improved capacities of the State Bureau of 
Investigation (SBI) to investigate allegations of torture. Still, torture and ill treatment remain an issue 
of concern in Ukraine’s prison and detention system; the investigation and prosecution of such cases 
need  to  become  prompt 
and effective.  

annual 

The 
public 
to  Parliament 
reporting 
on the work of the Office 
of the Prosecutor General 
and  the  SBI  on  cases  of 
torture  has  not  yet  been 
introduced. 
The 
effectiveness  of measures 
to  address 
ill 
treatment  and  corruption 
–  for  instance  via  the 
internal 
introduction  of 

torture, 

37 

 
 
security  units  –  should  be  carefully  monitored  to  ensure  a  strict  separation  of  custodial  and  law 
enforcement functions. Simultaneously, it is equally important to ensure that investigations of cases of 
torture  and  ill  treatment  are  carried  out  by  the  dedicated  independent  and  impartial  bodies.  The 
conditions in the prison system and detention centres remain an issue of concern and Ukraine should 
closely  comply  with  the  guidance  issued  by  the  Council  of  Europe’s  committee  on  prevention  of 
torture (CPT), including by implementing its recommendations.  

National 

The 
Preventive 
Mechanism  (NPM)  fulfils  an 
important function in monitoring 
places  of  detention,  but  requires 
adequate 
sustainable 
and 
funding, including to compensate 
for  CSO  monitors  participating 
in NPM visits to fully implement 
its mandate. 

Execution of criminal sanctions 

The  system  for  the  execution  of 
criminal 
(including 
sanctions 
probation) needs to be further improved. In November 2024, two laws aimed at protecting the rights 
of  convicts  were  adopted.  The  new  laws  provide  the  possibility  to  serve  sentences  in  the  form  of 
community  service  and  fines,  and  the  right  to  be  compensated  for  poor  conditions  in  prison. 
Commissions for complaints on inadequate detention conditions were introduced in January 2025 but 
the right  to  appeal  a  Commission’s 
decision  has  not  been  implemented 
and  requires  amendments  to  the 
Criminal Procedure Code.  

Probation  supervision,  as  a  new 
type  of  criminal  punishment  as  an 
alternative  to  a  custodial  sentence, 
was  introduced  last  year,  and  the 
number  of  court  verdicts  applying 
probation  supervision  has  been 
constantly  increasing  since  then. 
Access 
rehabilitation 
opportunities,  including  vocational 
training,  should  be  strengthened  to 
facilitate reintegration and reduce the risk of recidivism. The recommendations of the CPT to transfer 
responsibility for prison healthcare to the Ministry of Health have yet to be implemented.  

to 

Protection of personal data 

The  legal  framework  for  the  protection  of  personal  data,  and  the  capacities  of  the  data  protection 
agency are not sufficient. Ukraine made no progress in aligning its legal framework on personal data 
protection  with  the  EU  acquis.  The  final 
adoption  of  draft  laws  on  personal  data 
protection and on the National Commission 
on  Personal  Data  Protection  and  Access  to 
Public  Information,  registered  in  2022,  is 
still pending.  

Freedom of religion or belief 

legal  guarantees  on 
Ukraine  provides 
freedom  of  religion  or  belief. Incidents  of 
hate  speech  and  intimidation  based  on 

38 

 
 
religion or belief remain rare. Ukraine needs to ensure that the implementation of the Law on religious 
organisations,  which  prohibits  the  activities  of  religious  organisations  affiliated  with  the  Russian 
Orthodox Church in Ukraine, for instance as regards the Metropolis of Kyiv, remains in accordance 
with international standards on freedom of religion or belief, including the ECtHR’s jurisprudence in 
this area, especially at the local and regional level.  

Regarding conscientious objection during wartime, a number of  persons who  claimed conscientious 
objections based on grounds of religion or belief have been sentenced to prison for evading military 
service.  Ukraine  needs  to  establish  safeguards  protecting  individuals  from  criminal  prosecution  in 
case of conscientious objection taking into account the amicus curiae brief of the Venice Commission 
of March 2025. 

During  the  reporting  period  a  draft  law  to  introduce  a  special  coordinator  for  preventing  and 
combating antisemitism was withdrawn, with a new draft law being prepared for re-submission. 

---------------------------------------------------------------------------------------------------------------------------
------------------------- 

Freedom of expression 

Overall, Ukraine provides adequate legal guarantees on freedom of expression; further improvements 
are needed to ensure an enabling environment for the media to operate freely and independently. 

Intimidation of journalists 

Ukraine  needs  to  continue  its  efforts  to  ensure  the  safety  and  protection  of  journalists.  During  the 
reporting  period,  a  number  of  cases  of  alleged  harassment  and  intimidation  of  journalists  were 
recorded in government-controlled Ukraine. These cases concern local and investigative journalism in 
particular,  while  previously  reported  cases  were  followed  up  by  law  enforcement  to  some  degree. 
However,  the  effectiveness  of  investigations  into  offences  committed  against  journalists  and  media 
workers  needs  to  be  improved.  Cases  of  strategic  lawsuits  against  public  participation  (SLAPPs) 
related  to  journalistic  investigations  remain  an  issue  in  Ukraine.  A  working  group  on  developing 
effective  mechanisms  to  counter  SLAPPs  was  established  in  June  2025  and  legislative  work  has 
begun to align with the EU acquis (Anti-SLAPP Directive and Recommendation) in this field, which 
should also ensure a systematic monitoring of such cases. 

Legislative environment 

Ukraine  should  continue  its  efforts  to  make  progress  with  regards  to  legislative  reforms  and  avoid 
delays.   

The draft law amending certain laws on media activity, registered in Parliament in October 2024, aims 
to  strengthen  the  institutional  and  functional  independence  of  the  national  media  regulator.  It  also 
aims to improve the disclosure of information on media ownership and the media regulator’s authority 
to verify compliance with transparency obligations concerning media entities’ ownership structures, 
with a view to further aligning with the European Media Freedom Act. 

At the end of November 2024, a draft law was registered in Parliament which aims to regulate legal 
relations  in  the  field  of  advertising.  The  draft  takes  into  account  law  enforcement  practice  and  the 
market  changes  caused  by  the  rapid  growth  of  the  digital  advertising  segment,  as  well  as  the 
development  of  digital  technologies,  in  particular,  artificial  intelligence.  The  draft  aims  to  further 
align Ukraine with the EU Audiovisual and Media Services Directive and other EU acquis. 

In January 2025, Parliament adopted a law aimed at improving access for journalists and the public to 
official events of parliamentary committees, particularly those held online. 

In July 2025, a law was adopted introducing as administrative offence the identification of a lawyer 
with  their  client.  The  broad  protective  clause  does  not  provide  for  a  sufficient  balance  with  the 
protection  of  freedom  of  expression  and  the  law  should  be  revised  to  ensure  legality,  legitimacy, 
necessity, and proportionality in line with international standards. 

In September 2025, a draft law was introduced in Parliament amending the Civil Code with the aim to 

39 

 
 
better regulate a number of fundamental rights. However, certain provisions risk restricting the space 
of  freedom  of  expression  as  well  as  potentially  leading  to  a  surge  in  SLAPP  cases  and  need  to  be 
reconsidered.  

Implementation of legislation/institutions 

In  2024,  the  provisions  of  the  Law  on  media  providing  for  an  appropriate  budget  for  the  regulator 
were again suspended for the 2025 budget, resulting in the continued underfunding of the Council. 

Ukraine  needs  to  continue  to  implement  the  media  roadmap  that  supports  the  full  restoration  of  a 
pluralistic, transparent and independent post-war media space after martial law ends. Even before this, 
public  service  media  should  ensure  that  Ukraine’s  political  and  societal  pluralism  are  adequately 
represented. 

There  is  a  regular  policy  dialogue  between  the  Ukrainian  government,  the  media  regulator,  civil 
society, journalists’ unions and independent outlets to discuss media reforms. 

Public service broadcaster and other media outlets 

For  2025,  the  Ukrainian  public  broadcaster  Suspilne  was  allocated  almost  all  of  the  budget  it  had 
requested, but due to general public budget constraints, this was still below the amount mandated by 
Ukrainian law. In April 2025, the Chair of the Board of Suspilne was re-elected following an open, 
competitive and merit-based competition.  

In  October  2024,  Suspilne  officially  announced  its  withdrawal  from  the  united  news  Telethon  and 
launched  its  own  independent  news  channel.  Since  then,  the  Telethon  pools  together  the  remaining 
media  outlets  and  continues  to  receive  state  funding.  The  reassessment  of  the  publicly  funded 
Telethon  should  take  place  at  the  latest  by  the  time  of  the  eventual  suspension  of  martial  law,  in 
particular given the ongoing decline in public trust and outreach. Rada TV resumed live broadcasting 
of Parliament’s sessions as of 16 September 2025.  

Economic factors 

Ukraine’s independent media continues to suffer from the economic impact of the war, especially at 
regional level and near the frontline. Sudden  funding cuts by external donors have notably added to 
the  difficulties  and  have  particularly  affected  independent  regional  and  local  media  outlets.  The 
financial sustainability of local media outlets remains a concern. 

Transparency of media ownership has seen some progress in the past, but the previously introduced 
amendments  requiring  greater  disclosure  of  media  ownership  structures,  including  the  ultimate 
beneficial owners, still require increased enforcement efforts. This is especially the case in instances 
involving  online  platforms  and  regional  media  where  ownership  structures  can  still  be  obscured. 
Ukraine’s progress in media pluralism requires further steps to fully ensure pluralism and protect all 
media from political or oligarchic influence.  

Internet 

Access to internet resources still needs to be fully aligned with European standards and the EU acquis 
on  freedom  of  expression.  Mechanisms  to  block  web  resources,  introduced  in  response  to  national 
security concerns under martial law, lack sufficient legal safeguards. The transparency of decisions to 
restrict access to internet resources should be increased to limit the potential for abuse by authorities. 
The use of face-recognition systems and other intrusive technologies should be aligned with European 
standards in the field of personal data protection and privacy. 

Professional organisations and working conditions 

Low salaries and the declining economic perspectives of small independent media further increase the 
pressure on qualified media personnel, and lead to a deterioration of working conditions, as well as to 
personnel seeking alternative employment offering higher salaries. 

---------------------------------------------------------------------------------------------------------------------------
------------------------- 

40 

 
 
Freedom of assembly and association 

Ukraine provides overall adequate legal guarantees of freedom of assembly and association, and the 
regulation  of  assemblies  is  adequate.  The  authorities  generally  exercise  restraint  when  introducing 
temporary restrictions on the right to peaceful assembly in the context of martial law, but these are not 
always consistently applied or clearly communicated in all parts of the country. There is a need for a 
comprehensive review of its legislation to ensure full compliance with international standards related 
to the organisation and conduct of peaceful assemblies. 

Property rights 

The legal and institutional framework for enforcing property rights is broadly in place. Property rights 
continue  to  be  generally  respected,  and  the  modernisation  of  the  state  land  registry  system  is  still 
ongoing.  The  authorities  are  applying  property  rights  legislation  introduced  at  the  start  of  the  full-
scale  invasion,  in  particular  on  the  monitoring  of  and  compensation  for  property  damage.  Recent 
legislation effectively inhibits the possibility for local authorities to reclaim illicitly alienated land, if 
the transaction dates more than 10 years, while other legislation on the expropriation of plots of land 
to develop digital infrastructures and the relocation of strategic objects requires careful monitoring. 

Non-discrimination 

Ukrainian  society  is  increasingly  open  and  tolerant  towards  persons  in  vulnerable  situations. 
Generally, instances of hate offences are prosecuted. However, the legal and institutional framework 
should  be  strengthened.  As  concerns  the  criminal  law  framework  for  hate  offences,  the  Ukrainian 
legislation  is  currently  not  aligned  with  the  EU  acquis,  i.e.  the  2008  Framework  Decision  on 
combating racism and xenophobia, including as concerns the definitions and scope of these offences. 
Systematic collection of hate crime data is not in place yet and sexual orientation and gender identity 
are not covered under its criminal legislation. 

The legal and institutional framework for non-discrimination remains to be fully aligned inter alia as 
regards the Racial Equality Directive and the Directives on standards for equality bodies.  

Efforts to increase the capacities of police officers, prosecutors, judges and staff of the Ombudsperson 
to tackle discrimination, hate speech and hate crime are ongoing and should continue through suitable 
training  and  effective  enforcement.  Ukraine  needs  to  consistently  implement  strategic  measures  on 
anti-racism, rights of LGBTIQ persons and rights of persons with disabilities. 

Gender equality 

41 

 
 
for 

Gender 

launched 

discrimination 
violence. 

The  legal  and  institutional  framework  on  gender  equality  and  combating  gender-based  violence  is 
broadly  in  place.  In  March  2025, 
Ukraine 
its  own  Gender 
Equality  Index  using  the  European 
Equality 
Institute 
methodology,  scoring  61.4  compared 
with the EU-27’s median score of 71 in 
2024. Ukraine has several laws in place 
to promote gender equality and counter 
and 
gender-based 
gender-based 
Effective 
implementation and enforcement of the 
legislation,  as  well  as  policies  and 
action  plans,  especially  at  local  level, 
should  be  ensured.  Ukraine  has  taken 
certain  steps to  align  its  domestic legislation  with the  Council  of  Europe  Convention  on  preventing 
and combating violence against women and domestic violence (the Istanbul Convention). A draft law 
registered  in  Parliament  in  December  2024  proposes  amendments  to  the  Criminal  and  Criminal 
Procedural Codes to further align with the Istanbul Convention and the EU Directive on combating 
violence against women and domestic violence. Gender-based violence remains a critical issue; more 
decisive measures are needed to tackle it. Access to and awareness of specialised support services and 
infrastructure  for  victims  of  gender-based  violence,  domestic  violence  and  conflict-related  sexual 
violence  should  be  strengthened,  and  stable  budgetary  funding  for  long-term  support  and 
rehabilitation should be ensured.  

In November 2024, Parliament adopted a Law on the status of victims of sexual violence related to 
the  armed  aggression  of  the  Russian  Federation  against  Ukraine,  and  on  urgent  interim  reparations 
and access to rehabilitation services. Implementation and stable funding have not yet been ensured. 

Rights of the child 

The  legal  and  institutional  framework  on  the  rights  of  the  child  is  generally  in  place,  but  further 
efforts  are  needed  for  its  implementation  and  enforcement.  Ukraine  continued  to  strengthen 
mechanisms  for  child  protection  and  increased  support  for  families.  Procedures  and  criteria  for 
determining  the  best  interests  of  the  child,  however,  still  need  to  be  developed.  As  regards  the 
integrated child protection system, further steps need to be taken to prevent family separation, and to 
support the transition towards alternative family-based care of children deprived of parental care and 
children  with  disabilities.  Similarly,  it  is  important  to  ensure  the  reintegration  of  children  from 
temporarily occupied territories through recognition of their acquired education and support for their 
psycho-social adaptation.  

In July 2025, the National Strategy on Child Justice and its Operational Plan for 2025-2028 has been 
adopted. Ukraine has made progress in setting up 12 child-friendly, interdisciplinary and multi-agency 
centres, and in adopting  the Barnahus model, but alternative services ensuring child-friendly justice 
and free legal aid are still to be further developed. Adequate specialised training for professionals also 
needs to be further ensured. Ukraine continues to develop tools and programmes for juvenile justice 
and should in doing so further promote non-judicial measures and the use of non-custodial sentences 
as well as restorative approaches. 

In November 2024, Ukraine adopted the Strategy for Ensuring the Right of Every Child in Ukraine to 
Grow  Up  in  a  Family  Environment.  Sustained  progress  on  the  implementation  of  the  strategy  is 
needed, including through strengthening local ownership and resources in child welfare, developing 
tailored  action  plans  for  all  regions,  investing  in  diversified  social  service  providers  at  community 
level,  and  enhancing  the  staffing  and  expertise  of  the  social  service  workforce.  The  number  of 
children in institutional care remains high at 51 462 children, of which 25 620 stay round the clock in 
institutions.   

Persons with disabilities 

42 

 
 
The  legal  and  institutional  framework  on  the  rights  of  persons  with  disabilities  remains  to  be  fully 
aligned  with  the  EU  acquis,  including  the  European  Accessibility  Act,  and  its  implementation  and 
enforcement needs to be further improved. 

The number of persons with disabilities continues to grow (both among civilians and veterans) due to 
the armed aggression of the Russian Federation against Ukraine, presenting the Ukrainian authorities 
with  challenges  in  implementing  accessibility  policies  and  upholding  the  rights  of  persons  with 
disabilities. Increased efforts are still required to ensure the accessibility of buildings and other types 
of infrastructure, especially in the context of reconstruction efforts. Increased efforts are also needed 
on  public  services  in  general  as  well  as  support  for  the  legal  means  for  persons  with  disabilities  to 
claim their rights. 

Regarding  the  deinstitutionalisation  of  adults,  Ukraine  adopted  the  Strategy  of  reform  of  psycho-
neurological  and  other  institutions  and  deinstitutionalisation  of  care  for  adults  with  disabilities  and 
elderly  until  2034  and  adopted  an  operational  plan  for  its  implementation  for  2025-2027.  The 
implementation  of  this strategy and  plan needs  to  be ensured.  Ukraine is  yet to adopt legislation  to 
improve the rehabilitation system for persons with disabilities.  

LGBTIQ persons 

While  the  generally  positive  trend  of  increasing  tolerance  and  acceptance  of  lesbian,  gay,  bisexual, 
transgender, intersex and queer (LGBTIQ) persons continued, progress has stalled on key pieces of 
legislation to ensure the legal protection of the rights of LGBTIQ persons. These include, since 2021, 
the  draft  law  amending  the  Code  on  Administrative  Offences  and  the  Criminal  Code  to  combat 
manifestations of discrimination, which will include sexual orientation and gender identity under its 
definition  of  hate  crimes.  The  ECtHR  judgment  in  the  Maymulakhin  and  Markiv  v.  Ukraine  case 
reiterated  the  requirement  for  the  state  to  ensure  the  legal  recognition  and  protection  of  same-sex 
couples in Ukraine. In June 2025, a district court in Kyiv formally granted certain family rights to a 
same-sex  couple,  setting  a  first  legal  precedent.  However,  Parliament  still  did  not  progress  on  two 
draft laws on the institution of registered partnerships.   

Procedural rights and victims’ rights 

The legal framework on procedural rights is partially aligned with the EU acquis. Further efforts need 
to be made to ensure full alignment with the EU acquis on the rights of victims of crime. Procedural 
rights  are  outlined  in  the  Law  on  the  judiciary  and  status  of  judges  and  in  the  Criminal  Procedure 
Code,  but  their  implementation  suffers  from  inefficiencies  and  weaknesses  in  the  judicial  system. 
Violations of the right to access justice and to a fair trial, along with excessively lengthy proceedings 
and  misconduct  by  law  enforcement  officers,  remain  a  challenge.  The  legislation  has  to  be  further 
aligned  with  the  EU  acquis,  in  particular  regarding  the  scope  of  application  of  procedural  rights. 
Ukraine’s legislation on victims’ rights still needs to be fully aligned with the EU’s Victims’ Rights 
Directive  and  the  Directive  relating  to  compensation  to  crime  victims,  as  well  as  with  sectoral 
legislation on victims’ rights that responds more directly to the specific needs of victims of particular 
types of crime such as domestic violence, human trafficking and child abuse.  

The free legal aid system provided more than 1 million legal services in 2024 and legal awareness-
raising  activities  were  carried  out  to  inform  the  general  population.  In  April  2025,  the  Verkhovna 
Rada adopted a law on the effective guarantee of the right of detainees and convicted persons to free 
legal aid, which provides for a mechanism to provide free legal aid defence counsel within 24 hours in 
cases where a convicted person in prison is subject to disciplinary proceedings. 

The approach of the Ukrainian authorities towards some categories of victims of war crimes needs to 
be addressed. It is important to ensure that the classification of crimes does not function as a barrier to 
accessing  victim  support.  In  particular,  after  the  release  of  Ukrainian  prisoners  subjected  to 
deportation  from  occupied  territories  to  Russia,  they  should  have  the  same  access  to  benefits  and 
services  as  other  types  of  victims,  such  as  humanitarian  support,  financial  compensation, 
rehabilitation  and  recognition  of  their  victim  status.  Ukraine  is  encouraged  to  adopt  a  general 
reparation mechanism for victims of violent intentional crime in line with the EU acquis. 

43 

 
 
Protection of minorities 

The  rights  of  persons  belonging  to  minorities  continue  to  be  generally  upheld.  Following  the 
introduction in 2023 of legislation on national minorities,  in May 2025  Ukraine adopted the Action 
Plan for the Protection of the Rights of National Minorities, which was developed in consultation with 
representatives  of  national  minorities  and  international  partners.  The  Action  Plan  should  be 
implemented  in  close  consultation  with  representatives  of  national  minorities.  The  administrative 
capacities of the ministries and implementing bodies involved at all levels of government should be 
ensured  and  the  Council  of  National  Minorities  should  be  further  developed  as  a  representative 
interlocutor.  

Roma2 

The  legal  and  institutional  framework  on  Roma  is  largely  in  place,  but  the  implementation  and 
enforcement  of  policies  are  inadequate,  while  Roma  people  still  face  discrimination.  Progress  in 
implementing  Ukraine’s  National  Roma  Integration  Strategy  and  Action  Plan  was  limited  and  not 
sufficient to meet the significant challenges. Due to limited capacities and political priorities focused 
elsewhere  both  nationally  and  locally,  implementation  of  the  policies  adopted  in  the  fields  of 
education,  health  services,  employment,  access  to  identity  documents,  displacement,  housing, 
discrimination and exclusion, and poverty remain below expectations.  

Internally displaced persons 

Based on the International Organization for Migration data for April 2025, almost 3.8 million people 
are  displaced  within  Ukraine,  with  a  further  5.7  million  persons  fleeing  the  Russian  military 
aggression  from  Ukraine  elsewhere  in  the  world  recorded  by  UNHCR  as  of  September  2025.  The 
Ukrainian government continues to implement its strategy on internal displacement, accompanied by 
an operational plan, which runs until 2025. It is expected that these efforts will be prolonged, while 
persistent difficulties remain in ensuring sufficient budget allocations for social services. Ukraine has 
committed to ensuring access to housing for people in need, in particular internally displaced persons. 
Challenges remain in ensuring evacuation and accessible facilities and housing for displaced elderly 
and  persons  with  disabilities.  Ukraine  still  needs  to  ensure  that  the  protection  of  citizens  from  the 
occupied territories and of internally displaced persons remains a priority. 

Citizenship rights 

A draft law allowing Ukrainians to also hold the nationality of certain other countries, including EU 
Member  States,  was  adopted  by  Parliament  in  June  2025.  Attention  should  be  paid  to  the  rights  of 
Ukrainian  nationals  in  occupied  territories  (in  particular  children  born  under  occupation)  who  are 
forced by Russian occupiers to accept Russian citizenship, to ensure alignment with the EU acquis.  

2.2.2  Chapter 24: Justice, freedom and security 

The EU has common rules for border and migration management, visa policy, and asylum.. Schengen 
cooperation entails the lifting of border controls inside the EU. Member States also cooperate in the 
fight  against  serious  and  organised  crime  and  terrorism,  and  judicial,  police  and  customs 
cooperation, all with the support of the EU Justice and Home Affairs agencies. 

Fight against serious and organised crime 

The  legal  framework  on  serious  and  organised  crime  is  partially  aligned  with  the  EU  acquis.  The 
capacity to fight against serious and organised crime needs to be improved. 

Legal alignment, strategic and institutional frameworks  

Ukrainian law enforcement agencies (LEAs) have started to implement some of the measures within 

2  In  line  with  the  terminology  of  European  institutions  the  umbrella  term  ‘Roma’  is  used  here  to  refer  to  a 
number of different groups, without denying the specificities of these groups. 

44 

 
 
 
the overarching strategic plan on law enforcement reform (OAS AP). Continuous implementation of 
the OAS AP until the end of 2027, along with the corresponding Chapter 24 parts of the rule of law 
roadmap,  is  crucial  to  reforming  the  civilian  security  sector  in  line  with  European  standards.  After 
some delay and following national and international criticism, the government appointed the head of 
the Economic Security Bureau (ESBU) proposed by the internationalised selection commission. The 
ESBU reform should now continue with the revision of its strategic development plan and focusing on 
the re-attestation of ESBU staff based on integrity and merit. In order to enable the ESBU to deliver 
on its mandate, it should be granted the necessary financial, human and technical resources, as well as 
adequate operational independence. It is important that Ukraine implements the 2025 comprehensive 
action  plan to combat  organised  crime  based  on the  results  of  the 2019-2022  serious  and  organised 
crime  threat  assessment  (SOCTA).  Ukraine  should  also  conduct  a  threat  assessment  based  on  the 
SOCTA methodology for the period 2021-2024, which should inform the development of the  2026-
2030  Strategy  for  Combating  Organised  Crime,  along  with  an  action  plan  for  its  implementation. 
Overall, Ukraine should strengthen the institutional and operational capacities of its LEAs to further 
institutionalise the SOCTA methodology. There is still a lack of progress in setting up a permanent 
national  coordination  body  for  the  fight  against  organised  crime.  The  law  on  the  organisation  and 
legal  principles of  combating  organised  crime is  outdated and  not  aligned  with  the  EU  acquis.  The 
legislation on witness protection also needs to be modernised. A policy for reforming forensics in line 
with international best practices remains to be developed and implemented. 

Ukraine  has  strengthened  the  legal  framework  on  financial  investigations  by  adopting  appropriate 
implementing legislation. The strategy for financial investigations is being prepared by the Ministry 
of Internal Affairs and needs to undergo adequate stakeholder consultations prior to finalisation. It is 
important to allocate sufficient resources, provide training, grant access to necessary databases,  and 
develop  practical  guidelines  and  tools  to  ensure  that  financial  investigations  are  conducted 
systematically,  effectively,  and  at  an  early  stage  alongside  criminal  investigations.  Financial  crime 
investigations  are  often  triggered  by  civil  society  and  media  reports,  hence  recent  legislative 
amendments  that  disproportionately  reduced  transparency  of  state  registers  during  martial  law  raise 
concerns.  Further  controversial  amendments  to  the  Criminal  Procedure  Code  are  being  pursued  in 
Parliament,  with  the  declared  aim  of  protecting  businesses.  If  adopted,  they  could  undermine  the 
effectiveness  of  financial  and  criminal  investigations  of  economic  crime  and  the  investigative 
independence of the ESBU. 

A legislative package to introduce, among others, a bank account registry of individuals and whistle-
blower  protection  in  the  field  of  Anti-Money  Laundering  and  Countering  the  Financing  of 
Terrorism  was  withdrawn  from  Parliament  following  the  government’s  reshuffle  and  should  be 
resubmitted.  In  September  2024,  Ukraine  launched  a  mechanism  for  obliged  entities  to  report 
discrepancies  on  beneficial  ownership  information.  However,  mandatory  reporting  on  beneficial 
ownership  by  legal  entities  is  suspended  during  martial  law.  The  legislative  gap  on  virtual  assets 
needs to be urgently filled (see Chapter 4). 

In December 2024, Ukraine adopted legal amendments introducing autonomous criminal liability for 
legal  entities, including special  confiscation  of their properties.  The law  on  the  reform  of  the  Asset 
Recovery  and  Management  Agency  (ARMA)  was  adopted  in  June  2025.  It  introduced  a  system  of 
competitive  selection  for  the  agency’s  head,  regular  independent  audits  and  a  revised  asset 
management  system.  The  head’s  selection  is  ongoing,  while  the  full  implementation  of  the  reform 
requires the adoption of the necessary implementing legislation, as well as an independent assessment 
of the Agency’s effectiveness. Ukraine should amend the Criminal Procedure Code to enable pre-trial 
asset  seizure  for  the  purpose  of  extended  confiscation  and  confiscation  of  proceeds  (‘special 
confiscation’).  The  rules  on  non-conviction-based  confiscation  in  criminal  proceedings  should  be 
further aligned with the EU Directive on asset recovery and confiscation. 

In early 2025, the State Financial Monitoring Service (SFMS), Ukraine’s Financial Intelligence Unit, 
underwent a swift reorganisation, with a number of staff and functions transferred to the Ministry of 
Finance. The SFMS should be guaranteed the necessary capacities and resources to effectively fulfil 
its mandate, in particular to produce timely and quality intelligence. 

45 

 
 
On cybercrime, Ukraine should ratify and implement the Second Additional Protocol to the Budapest 
Convention and should consider removing the reservations it made to the Budapest Convention. The 
Internet Organised Crime Threat Assessment, as planned under the OAS AP, is under preparation and 
the system should be implemented by LEAs and the prosecution service by the end of 2025. On child 
sexual abuse, Ukraine is aligned with the Council of Europe Convention on Protection of Children 
against  Sexual  Exploitation  and  Sexual  Abuse,  also  known  as  ‘the  Lanzarote  Convention’,  and  has 
participated  in  the  Victims  Identification  Task  Force  hosted  by  Europol.  In  addition,  the  legal 
framework  needs  to  be  aligned  with  the  Directive  on  combating  the  sexual  abuse  and  sexual 
exploitation of children and child pornography. The National Police (NPU) is planning to establish a 
dedicated  unit  within  its  structure  specialised  in  counteracting  online  child  sexual  exploitation  and 
abuse.  

The  legal  and  strategic  framework  linked  to  trafficking  in  human  beings  needs  further  alignment 
with international standards and the EU acquis. The adoption of the new anti-trafficking law should 
be accelerated. 

The legal framework for the acquisition and possession of firearms needs further alignment with the 
EU acquis, but some progress has been made. In November 2024, a law improving the procedure for 
obtaining,  declaring  and  handling  firearms  was  enacted.  The  national  plan  focused  on  the  integral 
control and fight against firearms trafficking has not been adopted. The Criminal Code does not fully 
comply with international obligations, notably with the UN protocol on firearms. Legislation on the 
acquisition and possession of military-grade firearms by civilians needs further alignment with the EU 
acquis.  In  February  2025,  a  permanent  National  Firearms  Focal  Point  (NFFP)  was  established  and 
became operational, under the framework of the interministerial committee “Coordination Centre for 
Combating Illicit Trafficking in Firearms, their Parts, Components and Ammunition”. 

There  was  no  progress  during  the  reporting  period  in  reforming  the  Security  Service  (SSU).  Its 
mandate should focus on national security tasks. Its pre-trial investigation functions should be either 
transferred  to  the  dedicated  LEAs  or  strictly  limited  to  crimes  related  to  national  security,  while 
introducing effective safeguards against abuse. The SSU’s monopoly on wiretapping communications 
should  be  lifted.  Its  internal  and  external  oversight  and  anti-corruption  mechanisms  need  to  be 
strengthened, along with the rules on selecting its management and staff.   

Corruption  in the  law  enforcement  authorities  remains  a  serious  concern,  with  several  high-ranking 
officials removed from office due to corruption cases. In 2024 the NPU issued 495 protocols against 
police officers for administrative corruption offences, and 570 in the first half of 2025. Ukraine should 
focus  on  strengthening  integrity  and  anti-corruption  measures  in  the  criminal  justice  system  and 
among LEAs, to build public trust and to fight more effectively against serious and organised crime. 
In  particular,  Ukraine  should  introduce  transparent  and  merit-based  recruitment  and  selection 
procedures  for  the  key  managerial  positions  in  the  central  and  regional  offices  of  the  NPU  and  the 
State Bureau of Investigation (SBI), with the temporary but meaningful involvement of independent 
experts nominated by international partners, and strong disciplinary and anti-corruption frameworks 
tailored to the local context, addressing actual corruption risks. 

Implementation and enforcement capacity 

Ukrainian  home  affairs  institutions  continue  to  demonstrate  strong  resilience  and  determination  to 
deliver on their core mandates, while also being partially engaged in  countering the Russian war of 
aggression.  

46 

 
 
of 

the 

and 

The risks of war-related crimes linked to trafficking in arms, drugs and human beings (mostly for the 
purpose 
sexual 
labour 
exploitation)  remain  high.  Cooperation 
between  agencies  is  still  lacking  in 
efficiency.  Existing  rules  and  court 
practice  on 
inadmissibility  of 
evidence  gathered  by  non-competent 
LEAs,  along  with  unclear  division  and 
competencies, 
of 
fragmentation 
undermine  the  fight  against  complex 
forms  of  organised  crime  and  increase 
the  risk  of  corruption.  Establishing  a 
for 
permanent  national 
combating  organised 
should 
improve  this  situation.  There  has  been 
limited  progress  in  implementing  the 
intelligence-led  policing, 
concept  of 
mainly  due  to  the  lack  of  a  unified 
information-  and  intelligence-  gathering 

coordinator 
crime 

system for all LEAs. 

The  number  of  new  investigations,  final 
court  decisions  and  final  convictions  of 
organised crime groups were slightly higher 
in 2024 than in 2023, with a notable increase 
in  the  number  of  indictments.  A  slight 
increase  from  2023  to  2024  can  also  be 
noted  in  the  number  of  new  investigations 
and  indictments  in  serious  crime  cases, 
while  the  number  of  final  court  decisions 
and final convictions dropped slightly.  

Financial  investigations  are  still  hindered 
by a lack of reliable information on property 
ownership,  company  structures,  banking 
records  and  cross-border  transactions.  A 
“follow  the  money”  approach  is  largely 
missing,  while  the  Unified  Register  of  Pre-Trial  Investigations  does  not  keep  statistics  on  financial 
investigations. In  2024,  the  SFMS  received  1 750 940  reports  (1 429 594  in  2023)  on  financial 
transactions  that  were  subject  to  monitoring,  marking  a  23%  increase  compared  with  the  previous 
year. Of these, 82% pertained to threshold transactions, while the remaining 18% involved suspicious 
activities.  Following  analysis,  the  SFMS  forwarded  over  1 000  case  files  to  LEAs  (608  in  2023), 
involving transactions totalling UAH 62.6 billion (UAH 102.1 billion in 2023).  

On  money  laundering,  the  track  record  improved.  In  2024,  3 187  criminal  proceedings  were 
investigated. Of these, however, only 94 were based on materials from the SFMS. In 2024, there was 
a  51% increase  in the  number  of  cases  sent  to  court compared  with  the  previous  year,  however  the 
clearance  rate  stagnated,  leading  to  a  growing  number  of  pending  cases  (870).  In  2024,  157 
defendants were convicted, more than twice as many as in 2023, however a large number of sentences 
(105)  were  passed  on  the  basis  of  plea  bargains  with  subsequent  release  without  serving  a  prison 
sentence.  

The  confiscation  of  proceeds  (‘special  confiscation’)  and  extended  confiscation  are  largely 
underutilised, while consolidated statistics on confiscations are not produced. ARMA tracked 53 936 
more units of immovable and movable property in 2024 compared with the previous year, however 
less  than  8%  of  units  were  frozen  and  less  than  3%  entrusted  to  the  agency  for  management.  The 

47 

 
 
income from assets managed by ARMA increased by 146% compared with 2023, while the number of 
management contracts signed fell to seven. The agency’s audit by the Accounting Chamber revealed 
some  shortcomings  in  asset  management  and  in  the  selection  of  asset  managers,  which  should  be 
addressed in light of the ongoing reform of the agency.  

International cooperation with police and prosecutorial bodies continued to produce positive results, 
including in uncovering cross-border organised crime activities. During the reporting period, Ukraine 
cooperated  with  the  European  Union  Agency  for  Law  Enforcement  Cooperation  (Europol)  and  the 
European Union Agency for Law Enforcement Training (CEPOL). CEPOL’s training courses should 
be  institutionalised  across  all  relevant  Ukrainian  LEAs  and  integrated  within  the  national  law 
enforcement  training  system.  During  the  reporting  period,  Ukraine  was  involved  in  92  cases  at 
Eurojust. In 2024, there were 35 joint investigative teams (JITs) operating between Ukraine and EU 
Member States, of which 16 were new that year, and 19 were continuing their operations.  

SIENA and SIENA-CT, the Europol secure information exchange platforms for EU law enforcement 
on serious and organised crime and counterterrorism respectively, are operational in Ukraine. Ukraine 
participated  in  222  operational  actions  within  the  European  Multidisciplinary  Platform  Against 
Criminal Threats (EMPACT), and was co-leader on one operational action plan.  

On  trafficking  in  human  beings,  in  the  reporting  period  Ukraine  participated  in  operational  law 
enforcement activities within the EMPACT framework. The State Border Guard Service (SBGS) and 
the NPU increased measures to counter trafficking in human beings at border crossing points. Ukraine 
should  equip  law  enforcement  officials  with  up-to-date  skills  to  conduct  complex  investigations. 
Ukraine  should  increase its  efforts  to  detect  and  identify  victims  of  trafficking  in  human  beings,  in 
particular  child  victims  and  victims  of  exploitative  surrogacy,  and  strengthen  the  capacity  of  social 
services to provide adequate protection. 

Ukraine  made  good  progress  in  countering  the  trafficking  of  small  arms  and  light  weapons. 
Ukraine  engaged  with  EU Member  States to reduce the  risk  of  illicit firearms trafficking in a  post-
conflict  context  by  engaging  in  different  operational  actions  of  the  EMPACT  firearms,  and  by 
regularly sharing records of lost, stolen and seized weapons with Europol. Further efforts should be 
focused on data sharing and establishing effective cooperation between the NFFP and its counterparts 
abroad. In 2024, law enforcement officers seized 1 334 rifled firearms, 529 other firearms, 41 smooth 
bore firearms, 177 grenade launchers, 4 784 hand grenades, and 602 799 rounds of ammunition. By 
August 2025, 11 684 firearms (including 6 560 automatic) and 5.4 million rounds of ammunition have 
been declared.  

The witness protection system is underdeveloped and fragmented, and no progress was made in its 
reform. 

Some efforts have been made to further introduce a gender perspective into the work of LEAs. The 
ESBU carried out a gender audit aiming at an inclusive approach to victim support and a gender-based 
perspective during all phases of an investigation. 

Cooperation in the field of drugs 

The legal framework for cooperation in the 
field  of  drugs  needs  to  be  improved  and 
aligned with the EU acquis. 

Legal alignment, strategic and institutional 
frameworks 

During 
the  reporting  period,  Ukraine 
successfully cooperated with the European 
Union  Drugs  Agency,  through  regular 
exchanges  of  information,  participation  of 
Ukrainian  experts  in  the  agency’s  events, 
the 
capacity-building 

initiatives, 

and 

48 

 
 
gradual  integration  of  Ukraine  into  the  EU  Early  Warning  System.  Progress  was  made  with  the 
reporting of drug-related data and quality of the data provided. The national drug policy strategy for 
the  period  up  to  2030  has  been  approved,  without  prior  consultation  with  the  EU.  There  was  no 
progress  in  setting  up  the  national  drugs  observatory  nor  the  national  early  warning  system  on  the 
detection  of  new  psychoactive  substances.  There  is  a  need  to  adopt  and  implement  the  legal 

framework required to formalise the national drugs observatory within the Public Health Centre with 
sufficient human and financial resources, the nomination of a correspondent to the EU Early Warning 
System and the setting up of a national early warning system.  

Within  the  integrated  border  management  (IBM)  system,  in  January  2025  the  NPU  and  the  State 
Customs  Service  approved  a  joint  action  plan  particularly  aimed  at  identifying,  preventing  and 
stopping:  (i)  criminal  offences  related  to  the  trafficking  of  narcotic  drugs,  psychotropic  substances, 
their analogues and precursors; and (ii) customs violations under the Customs Code of Ukraine, which 
may occur in the customs territory of Ukraine, along the national border, or in customs control zones. 

Implementation and enforcement capacity 

The use of drugs and other illegal substances is a growing problem. Drugs, especially synthetic drugs, 
are  sold  and  widely  available  across  Ukraine,  including  at  the  frontline.  The  illicit  production  of 
synthetic  drugs  continues.  Drug  monitoring  is  heavily  affected  by  the  war.  Cooperation  between 
judicial entities and LEAs should increase, as should international cooperation in this area, including 
within the framework of EMPACT.  

Fight against terrorism and prevention of radicalisation and violent extremism 

The  legal  framework  on  the  fight  against  terrorism,  countering  violent  extremism  and  critical 
infrastructure  protection,  as  well  as  resilience  of  critical  entities  is  partially  aligned  with  the  EU 
acquis. 

Legal alignment, strategic and institutional frameworks  

Under martial law, the State Special Communications Service is the authorised body in the field of 
critical  infrastructure  protection.  The  provisions  related  to  resilience  in  critical  infrastructure 
protection  (CIP)  are  to  a  significant  extent  already  part  of  the  legislation.  Ukraine  is  a  party  to  the 
relevant UN and Council of Europe counterterrorism conventions and protocols. The national system 
to fight against terrorism and the dedicated legislation are comprehensive, with the SSU as the major 
agency  within  the  national  system  and  other  relevant  institutions  involved,  ensuring  an  integrated 
approach.  

Ukraine  should  develop  and  adopt  a  new  policy  on  combating  terrorism  until  2030,  along  with  the 
corresponding  action  plan for its implementation,  by the end  of  2025.  Ukraine should  also  set  up a 
coordination mechanism to develop and adopt a strategy and action plan on preventing and countering 
violent extremism. Ukraine should transpose the directive on combating terrorism and implement the 
Terrorist Content Online regulation. 

49 

 
 
Implementation 
capacity 

and 

enforcement 

in 

charge 

institutions 

The 
of 
counterterrorism  work  effectively  and 
in  a  professional  manner.  The  SSU 
deals  with  the  terrorism  threat  in 
connection  with  Russia’s  war  of 
aggression.  Its  counterterrorism  units 
heavily 
in 
involved 
also 
are 
countering 
investigating 
and 
international crimes committed by the 
the 
Russian 
in 
critical 
protection 
infrastructure. As of April 2025, the SSU is administering the list of terrorist organisations, published 
on the SSU website and on the Unified State Open Data Portal. 

and 
of  Ukraine’s 

authorities 

Judicial cooperation in criminal, civil and commercial matters  

Judicial cooperation in civil and criminal matters needs to be improved. The legal framework in this 
area  is  partially  aligned  with  the 
EU acquis.  

Law. 

Ukraine  is  a  party  to  all  core 
conventions 
adopted  by  The 
Hague  Conference  on  Private 
Ukraine 
International 
maintained  good  cooperation  with 
partners on mutual legal assistance 
(MLA) 
in  civil  and  criminal 
matters  and  has  been  participating 
in 
the  negotiations  on  a  new 
Council  of  Europe instrument  that 
aims 
judicial 
cooperation in matters of criminal asset recovery. In 2024, the number of incoming MLA requests in 
civil  matters  was  higher  than  in  the  previous  two  years,  which  indicates  international  partners’ 
growing  reliance  on  Ukraine  for  legal  cooperation  in  civil  matters,  but  less  so  for  criminal  ones. 
Nevertheless, Ukraine needs to further improve the timeliness and efficiency with which it processes 
judicial  cooperation  requests,  particularly  requests  for  MLA  in  criminal  matters,  through  the 
application  of  relevant  Council  of  Europe  Conventions  and  by  ensuring  sufficient  administrative 
capacity for the authorities dealing with such cases. 

strengthen 

to 

In  the  reporting  period,  Ukraine  participated  in  129  new  cases  at  Eurojust,  including  16  joint 
investigation teams (JITs), related to fraud, organised crime, money laundering and drug trafficking; 
40  of  these  cases  were  opened  at  the  request  of  the  Liaison  Prosecutor.  Ukraine  worked  with  the 
European Judicial Network (EJN) and developed cooperation with the European Public Prosecutor’s 
Office (EPPO). A liaison officer from OPG was seconded to the EPPO in October 2024. In 2024, the 
EPPO sent two requests for MLA to the Ukrainian authorities. 

The insolvency regime should be further aligned with the EU acquis. In September 2024, Parliament 
adopted a law to align Ukraine with the Directive on preventive restructuring frameworks. Additional 
legislation on simplified insolvency procedures for micro, small and medium-sized enterprises should 
be developed and adopted. 

Legal and irregular migration 

The  legal  framework  on  legal  and  irregular  migration  is  partially  aligned  with  the  EU  acquis.  The 
management of legal and irregular migration needs to be improved.  

50 

 
 
Institutional set-up and legal alignment 

Inter-agency  coordination  and  cooperation  between 
the  relevant  authorities  needs  further 
strengthening. In the reporting period, Ukraine continued to reform the State Migration Service. The 
National  Contact  Point  in  Ukraine  of  the  European  Migration  Network  became  operational.  Full 
alignment with the EU acquis on the status of third-country nationals who are long-term residents, on 
the right to family reunification on the Blue Card Directive, on intra-corporate transferees, on seasonal 
workers  and  on  a single  permit  for  work  and residence  for third-country  nationals has  not  yet  been 
achieved.  The  establishment  of  the  situational  centre  for  monitoring  the  migration  process  and 
assessing migration risks would help to improve the coordination of migration management.  

The legislative framework for a mass influx of migrants is in place, but a mechanism for inter-agency 
coordination  in  the  event  of  a  migration  crisis  is  still  lacking.  The  voluntary  returns  procedure  was 
rarely  applied  during  the  reporting  period.  The  rules  on  passenger  information  and  the  visa 
verification  obligations  for 
carriers  transporting  foreign 
nationals  to  Ukraine  have 
adopted.  The 
not  been 
Passenger  Information  Unit 
has not been set up. The law 
on collecting and processing 
Passenger 
Advance 
Information  and  Passenger 
Name  Record  data  has  not 
been adopted. 

Implementation 
enforcement capacity 

and 

In  2024, 
the  number  of 
irregular  migrants  detected 
by the State Migration Service throughout Ukraine was almost four times larger than in the previous 
year,  returning  to  similar  levels  as  before  the  full-scale  invasion.  The  largest  number  of  migrants 
detected originated from the Republic of Moldova, Azerbaijan and Russia. The majority of irregular 
migrants were detained for irregular border crossings. Cases of the illegal smuggling of people have 
been  registered  as  criminal  offences  and  investigated  by  the  relevant  authorities.  The  migrant 
accommodation centres have sufficient capacity, although the staffing remains below the number of 
posts  envisaged.  The  Chernihiv migrant  accommodation  centre  was reopened. Ukraine  continues  to 
take part in the Global Alliance to Counter Migrant Smuggling and is invited to renew its engagement 
at the occasion of the Global Alliance’s second conference scheduled to take place end of 2025. 

Regarding  border  control,  the  SBGS  continued  to  cooperate  with  the  European  Border  and  Coast 
Guard  Agency  on  information  exchange,  joint  risk  analysis,  operations  and  staff  training,  with  no 
major changes. 

The  2007  EU-Ukraine  readmission 
agreement  was  continuously  applied, 
together  with  the  protocols  facilitating 
its 
implementation,  signed  between 
Ukraine  and  ten  EU  Member  States. 
Ukraine 
implementing 
protocol  with  Slovakia  and  the  protocol 
with Latvia came into force, while those 
with  Hungary,  Spain  and  Serbia  are 
awaiting 
integrated 
signature.  The 
migration  management  system  is  not 
fully operational. 

signed 

an 

51 

 
 
Asylum 

The legal framework on asylum is partially aligned with the EU acquis. The management of asylum 
needs to be improved. 

Legal alignment, strategic and institutional frameworks 

Due  to  a  lack  of  capacity  and  a  shortage  of  staff,  limited  support  is  available  to  asylum  seekers.  
Following  last  year’s  recommendation,  Ukraine  needs  to  start  developing  a  roadmap  for  bilateral 
cooperation with the EU Agency 
for Asylum. 

Implementation  and  enforcement 
capacity 

The  number  of  applications  for 
international  protection  declined 
during  the  reporting  period.  No 
cases  of  refoulement  or  non-
admission  at  the  borders  were 
reported, although the capacity to 
integrate 
refugees 
recognised 
limited.  The  average 
remains 
duration of the asylum procedure 
did  not  change.  In  2024,  there 
were  59  asylum  applications,  to 
Ukraine, continuing the decreasing trend since the full-scale invasion. Ukraine should ensure that the 
conditions for identifying applicants for international are in line with the EU acquis. 

Visa policy 

The  national  visa  regime  is  largely  aligned  with  the  EU  acquis,  including  on  the  processing  of 
applications, the  criteria  and  process  for  issuing visas.  Ukraine’s list  of  visa-free  countries  diverges 
from the EU list by 15 countries. The phasing out of non-biometric passports by 2026 is ongoing. The 
issuance  of  visas  at  the  border  was  suspended  on  24 February  2022  and  has  not  been  resumed.  In 
February  2025,  the  Ministry  of  Foreign  Affairs  resumed  the  issuance  of  electronic  visas.  The  visa-
free  regime  with  the  EU  is  in  place.  Ukraine  continues  to  meet  the  EU  benchmarks  on  visa 
liberalisation.  

Schengen governance and external borders 

The  legislative  and  strategic  framework  for  the management of  external  borders  is  partially  aligned 
with the EU acquis. The management of borders needs to be improved. 

Legal alignment, strategic and institutional frameworks 

Given the need to reinforce and establish solid foundations for the Schengen system, it is necessary to 
continue strengthening the national Schengen governance by establishing the Schengen Action Plan 
(SAP) covering the whole Schengen framework. The SAP is foreseen to be developed by the end of 
2025. 

Ukraine  should  adopt  additional  legislation  on  border  control,  and  the  simplification  of  border  and 
customs  procedures  in  line  with  the  Schengen  Border  Code  and  Directive  supplementing  the 
provisions  of  Article  26  of  the  Convention  implementing  the  Schengen  Agreement.  Full 
implementation of the Integrated State Border Management (IBM) action plan for 2023-2025 and the 
adoption of a new strategy and ensuing action plan for 2026-2030, including clear indicators for its 
assessment and based on principles of the European Integrated Border Management, is needed. 

Implementation and enforcement capacity 

The  institutional  capacities  and  inter-agency  cooperation  mechanisms  for  IBM  should  be  further 
improved.  During  the  reporting  period,  the  Inter-Agency  Working  Group  for  IBM  met  twice.  The 

52 

 
 
National Coordination Centre needs to be strengthened to bring concrete operational results. There is 
still no structured crisis response mechanism.  

Shortages of staff, infrastructure and equipment are  the main challenges for the border management 
agencies  capacity  to  carry  out  their  work.  While  border  controls  meet  minimum  standards,  the 
technical infrastructure requires a significant upgrade. A comprehensive asset management system for 
the  border  agencies  is  required.  Additional  capacities  are  needed  to  counter  smuggling,  including 
weapons  and  people.  Border  surveillance  is  not  fully  effective,  despite  a  satisfactory  risk  analysis 
based on the border surveillance mechanism in place. The funding gap remains substantial. Half of the 
border  crossing  points  remain  closed.  Two  new  border  crossing  points  were  opened  at  the  borders 
with Hungary and Poland.  

Further  efforts  by  the  SBGS  and  the  State  Customs  Service  in  the  fight  against  corruption  at  the 
border are needed. The SBGS continues its cooperation with the European Border and Coast Guard 
Agency  on  information  exchange,  joint  risk  analysis,  operations  and  staff  training.  On  operational 
cooperation with neighbouring countries, Ukraine continued to establish bilateral agreements on joint 
controls with Poland and Slovakia. 

Counterfeiting of the euro (criminal law aspects) 

The  relevant  legislation  on  the  suppression  of  counterfeit  currency  is  partially  aligned  with  the  EU 
acquis. 

2.3. ECONOMIC CRITERIA 

2.3.1.  The existence of a functioning market economy 

Economic governance  

Despite  the  significant  challenges  imposed  by  Russia’s  continued  war  of  aggression,  Ukraine 
remains  committed  to  implementing  reforms  agreed  with  both  the  EU  and  International 
Monetary Fund, although the pace of implementation has recently slowed. All policy conditions 
for  the  first  three  regular  payments  under the  Ukraine  Plan  were met,  while  there  are  delays  in  the 
implementation of a subset of measures linked to the fourth and fifth payments. Reform conditionality 
under  the  exceptional  macro-financial  assistance  loan  provided  through  the  G7’s  Extraordinary 
Revenue  Acceleration  (ERA)  initiative  –  fully  aligned  with  the  Ukraine  Plan  –  was  fully  met, 
unlocking  EUR 18.1  billion  in  urgent  budget  support.  The  IMF’s  eighth  programme  review  was 

53 

Table 19:2021202220232024Ukraine - Key economic figuresGDP per capita (% of EU-27 in PPS)2935282928Real GDP growth (% change)-0.3 3.4-28.85.52.9Activity rate of the population aged 15-70  (%), total1)62.361.857.756.7-Unemployment rate of the population aged 15-70 (%), total1)9.19.925.020.014.0Employment of the population aged 15-70 (annual growth %)-0.6-0.9-21.54.8Nominal wages (annual growth %)22.5 20.96.017.4Consumer price index (annual growth %) 16.49.420.212.96.5Exchange rate against EUR29.1 32.334.039.643.5Current account balance (% of GDP)-0.6 -1.94.9-5.3-8.4Net foreign direct investment, FDI (% of GDP) -2.3-3.8-0.1-2.5-1.8General government balance (% of GDP)-2.4 -3.4-16.1-20.1-17.6General government debt (% of GDP) 67.249.077.883.391.2Sources: WiiW, State Statistics of Ukraine, National Bank of Ukraine, Ministry of Finance2015-20 average 
 
 
in 

the 

delays 

despite 

sector 
Implementation  of 

successfully  completed  at  the  end  of 
June, 
the 
implementation  of  reforms  relating  to 
and 
customs, 
financial 
the 
governance. 
National  Revenue  Strategy  advanced 
with  initial  steps  taken  to  boost  revenue 
mobilisation and strengthen the State Tax 
Service, although progress on some areas 
has been slower than anticipated. Around 
75% of the measures scheduled for 2024 
have  been  completed  so  far.  In  August 
2025, a medium-term reform plan for the 
State  Customs  Service  was  adopted,  aiming  to  accelerate  digitalisation,  strengthen  EU  alignment, 
improve governance and transparency, and reduce corruption risks. 

Economic governance has further improved, with progress in key areas. In October 2024, a law 
on  public  consultations  was  passed,  creating  a  formal  framework  for  stakeholder  engagement  in 
policymaking, aimed at improving transparency, accountability, and regulatory quality. Medium-term 
budget  planning  has  resumed.  On  30 June 2025,  the  Cabinet  of  Ministers  approved  the  budget 
declaration  for  2026-2028,  which  showed  progress  towards  alignment  with  the  EU  acquis  on 
medium-term budgetary frameworks. A new state debt management strategy for 2026–2028 is being 
prepared,  setting  debt  sustainability  targets  and  measures  to  deepen  the  domestic  bond  market.  In 
April, the government launched a spending review of the 2025 budget, covering 31 policy areas. The 
National Bank of Ukraine (NBU) has continued the gradual easing of foreign exchange restrictions, 
while maintaining a managed float for the hryvnia and pursuing its medium-term inflation target of 
5%. The NBU has refrained from monetary financing since the beginning of 2023.  

Macroeconomic stability  

robust 

economy 

Ukraine’s 
has 
demonstrated  significant  resilience, 
but  signs  of  a  slowdown  have 
growth 
emerged.  After 
extending into early 2024, momentum 
weakened  noticeably  from  mid-year. 
Real  GDP  growth  slowed  from  6.8% 
year-on-year  in  the  first  quarter  of 
2024  to  a  slight  contraction  of  0.1% 
by 
This 
a  weaker 
deceleration 
alongside 
agricultural 
persistent labour shortages and ongoing attacks on critical infrastructure, which weighed on economic 
activity. As a result, real GDP growth fell to 2.9% in 2024, down from 5.5% in 2023, leaving output 
at 23% below pre-war levels. Economic weakness has persisted into 2025: real GDP grew by 0.9% 
year-on-year in the first quarter, while goods exports declined by 2.3% year-to-date in July compared 
to the same period in 2024, driven by poor performance in metallurgy and agriculture. 

reflected 
harvest, 

quarter. 

fourth 

the 

The  current  account  deficit  widened  over  2024,  rising  from  5.3%  of  GDP  in  2023  to  8.4%  in 
2024. This deterioration was driven by a further weakening of the investment income balance and a 
decline in international grants, which were increasingly replaced by loans. The former reflected both 
lower income receipts from abroad and higher income payments to foreign investors – notably in the 
form  of  distributed  earnings  –  following  a  partial  relaxation  of  capital  controls.  At  the  same  time, 
elevated  import  needs,  related  defence  and  repair,  kept  the  trade  balance  firmly  in  deficit,  at 
approximately -20% of GDP, despite some export  recovery supported by the effective use of Black 
Sea  and  Danube  routes.  Strong  external  financing  inflows  from  international  partners  continued  to 
underpin reserve accumulation, with gross international reserves reaching USD 46.0 billion in August 

54 

 
 
2025, equivalent to approximately 5 months of imports. 

Inflation accelerated visibly, prompting the NBU to tighten monetary policy. Inflation rose from 
a low of 3.3% in May 2024 to 14.1% in July 2025, driven by higher electricity and labour costs, rising 
food prices, and depreciation of the hryvnia. In response, the NBU halted its monetary easing cycle 
and has raised the key policy rate by a cumulative 2.5 percentage points since end-2024, bringing it to 
15.5%  in  March  2025.  Nonetheless,  inflation  expectations  –  particularly  among  households  –  have 
increased  and  remain  above  the  NBU’s  target.  After  depreciating  from  38  UAH/USD  to  42.1 
UAH/USD  over  2024,  the  hryvnia  stabilised  in  early  2025,  supported  by  foreign  exchange 
interventions. 

The fiscal deficit narrowed slightly in 2024 but remains very high, and its financing is heavily 
reliant on external support. Revenue measures – including higher excise duties, a military tax, and a 
windfall  tax  on  banks  –  helped  lower  the  general  government  deficit  to  17.6%  of  GDP  (23.5% 
excluding  international  grants)  in  2024,  down  from  20.1%  of  GDP  in  2023  (26.6%  excluding 
international grants). However, expenditures remain elevated as the war continues: military personnel 
costs reached 18% of GDP in 2024, while defence procurement, including ammunition, represented 
9% of GDP. The deficit of the pension fund, estimated at around 4% of GDP, is set to increase in the 
absence  of  pension  reform.  As  a  result,  public  debt  rose  to  91.2%  of  GDP  in  2024,  from  83.3% in 
2023.  Ukraine  continues  to  rely  on  very  concessional  external  financing  and  more  costly  domestic 
borrowing.  The  very  concessional  terms  of  external  financing  and,  specifically,  the  financing  under 
the G7’s ERA initiative (representing up to EUR 45 billion until 2027), which is expected to be repaid 
from windfall revenues linked to immobilised Russian Central Bank assets, are essential for ensuring 
in  a  forward-

debt  sustainability 
looking manner.  

Ukraine  has  made  progress 
in 
advancing  reforms  to  improve  the 
efficiency  and  effectiveness  of  its 
revenue administration and the tax 
system,  but  weaknesses  remain.  In 
September  2024,  the  Ministry  of 
Finance  adopted  a  new  methodology 
tax  expenditures. 
for  evaluating 
Benchmark systems for the four main 
tax 
tax, 
personal income tax, value added tax, 
and  excise  tax),  which  will  serve  as 
reference  to  identify tax  expenditures,  have  been  established.  A  comprehensive  inventory  of  all  tax 
expenditures,  detailing  all  exemptions,  deductions  and  credits,  is  planned  for  inclusion  in  the  2027 
budget. The State Tax Service advanced towards a risk-based compliance approach, supported by the 
adoption  of  a  digital  development  plan,  improved  capacity  for  international  information  exchange, 
and  the  launch  of  a  pilot  project  for  tax  risk  management.  Still,  revenue  collection  continues  to  be 
weakened by high levels of informality, complex and burdensome tax compliance processes, tax fraud 
and  a  broadly  applied  and distortive  presumptive tax regime.  Additionally,  the  publication  of  fiscal 
data at the general government level remains limited, and access to this data is restricted.  

types  (corporate 

income 

The  macroeconomic  policy  mix  remains  appropriate  and  has  helped  sustain  macroeconomic 
stability  despite  substantial  challenges  linked  to  Russia’s  ongoing  war  of  aggression.  Fiscal 
policy  will  need  to  focus  on  strengthening  domestic  revenue  mobilisation,  where  the  National 
Revenue Strategy should remain a key anchor, reducing reliance on external financing in the medium-
term, and ensuring long-term fiscal sustainability, while prioritising the efficient use of public funds 
to  support  recovery  and  reconstruction.  Monetary  policy  remains  adequately  calibrated  and 
sufficiently  tight  to  contain  inflationary  pressures.  The  key  challenge  to  macroeconomic  stability 
includes a potential intensification of Russia’s war of aggression against Ukraine, which could lead to 
further  destruction  of  productive  capacity  and  trigger  additional  outward  migration  and  further 
weaken the current account balance. 

55 

 
 
Functioning of product markets  

Business environment  

Despite  ongoing  reform  efforts,  Ukraine’s  business  environment  remains  constrained  by 
structural  and  wartime  challenges.  Business  surveys  show  that  war-related  disruptions,  labour 
shortages  and  inflation are  the top  three  impediments  to  business  activity.  In  addition, cumbersome 
procedures  –  particularly  inefficiencies  in  tax  administration,  such  as  excessive  documentation 
requirements and processing delays – increase compliance costs and place a disproportionate burden 
on smaller firms. High market concentration and low dynamism of young businesses point to weak 
market competition. Nonetheless, some progress has been made to improve the business climate, with 
firms increasingly expressing confidence in the legal system’s ability to enforce contracts and protect 
property rights.  In September 2024, Ukraine adopted a comprehensive Action Plan on Deregulation 
aimed  at  simplifying  permitting  procedures,  introducing  risk-based  supervision,  and  advancing 
digitalisation through the e-permit system, in line with EU standards. In line with this plan, new laws 
adopted  in  September  and  November  2024  introduced  cost-free  notifications  for  most  economic 
activities – so that permits are not required except in high-risk areas – and aligned licensing rules with 
general  administrative procedures.  Deregulation  efforts,  coordinated  by  an  inter-ministerial  working 
group,  led  to  the  repeal  of  200  approvals  and  permits  in  April  2025.  Reforms  of  the  insolvency 
framework  were  also  advanced  to  streamline  procedures  and  improve  restructuring  options.  At  the 
same  time,  informality  remains  a  major  structural  challenge,  driven  by  weak  enforcement  of 
legislation, limited institutional capacity, high fiscal burdens, and disruptions linked to the war. 

State influence on product markets  

The state footprint in the economy remains high. Although the public sector’s share of gross value 
added declined slightly to 21% in 2024, it remains well above the pre-war level of 6%. State-owned 
enterprises  (SOEs),  including  state-owned  banks,  continue  to  play  a  major  role  in  the  economy, 
employing around 568 000 people (4% of total employment), holding 14% of national business assets, 
and  generating  net  income  equivalent  to  15%  of  GDP.  Although  some  are  profitable,  SOEs 
underperform  compared  to  private  firms,  reflecting  operational  inefficiencies.  Administered  prices 
cover  22.1%  of  the  consumer  price  index  basket,  compared  to  around  9%  in  the  EU.  Energy  price 
liberalisation  has  made  little  progress.  In  June  2024,  household  electricity  tariffs  were  raised  from 
UAH 2.64/kwh to UAH 4.32/kwh, but still cover only half the cost of supply, while small businesses 
in Kyiv pay UAH 8.96/kwh.  

Privatisation and restructuring  

Some  progress  was  made  in  the  privatisation  and  restructuring  of  SOEs,  though  there  have 
been some setbacks on corporate governance reform. Privatisation auctions generated an historical 
high  of  UAH  19.7  billion (around  EUR  492 million)  for  state and  local  budgets  in  2024,  including 
UAH 6.5 billion (EUR 162 million) from large-scale and over UAH 4 billion (EUR 100 million) from 
small-scale  privatisation.  On  29 November 2024,  the  government  adopted  a  new  policy  on  state 
ownership,  setting  out  the  criteria  for  keeping  SOEs  in  state  ownership,  setting  out  improved 
corporate  governance  standards  (aligned  with  OECD  principles),  and requiring regular  performance 
reviews  of  state  assets.  In  December  2024,  the  Cabinet  of  Ministers  approved  the  triage  of  SOEs, 
classifying  companies  into  three  categories:  those  to  remain  under  state  ownership,  those  to  be 
privatised or liquidated, and those for which privatisation is temporarily suspended under martial law. 
In April 2024, the authorities adopted an action plan setting out steps to ensure a mandatory structural 
separation  of  accounts  between  public service  obligation  (PSO)  activities  and  non-PSO  activities  in 
the  biggest  SOEs.  These  steps  aim  to  streamline  the  state’s  portfolio  and  improve  the  efficiency, 
transparency  and  accountability  of  SOE  management.  In  May  2025,  the  authorities  amended  the 
statutes of key SOEs in the energy sector, as well as the transport sector, introducing a de facto power 
of veto for state representatives on their supervisory boards on key strategic decisions including the 
appointment and dismissal of CEOs. This undermines the independence of supervisory boards, which 
is  a  key  component  of  recent  reforms  adopted  as  part  of  the  Ukraine  Plan,  in  line  with  OECD 
corporate  governance  principles.  In  addition,  the  supervisory  boards  of  several  SOEs  remain 
incomplete,  and  procedures  for  the  selection  of  state  representatives  do  not  follow  a  merit-based 

56 

 
 
competitive process, negatively affecting the SOEs’ independence and stable governance. 

Functioning of the financial market  

The  Ukrainian  banking  sector  remains  resilient.  Liquidity  levels  are  around  three  times  the 
regulatory  minimum,  and despite  the retroactive  increase  in  the tax  rate  on  bank  profits  to  50% for 
2024, the sector continued to generate sizeable profits, though this largely reflects banks’ exposure to 
sovereign risk. The National Bank has resumed the annual resilience assessment of Ukrainian banks, 
with  a  detailed  report  expected  to  be  published  in  the  first  quarter  of  2026.  The  first  results  were 
issued on 1 September 2025. As part of the strategy to reduce non-performing loans (NPLs), banks 
have started applying since January 2025 an updated methodology for calculating NPL ratios, aimed 
at improving statistical comparability and bringing practices closer to EU standards, although a formal 
assessment  of  compliance has  not  yet  been  conducted.  The  NPL  ratio  fell  by  6.6  percentage  points 
over  the  year  but  remained  high  at  30%  in  March,  with  stark  differences  by  ownership:  42.9%  for 
state-owned  banks,  12.6%  for  private  Ukrainian  banks,  and  10.9%  for  foreign-owned  banks,  which 
can be partially explained by legacy factors. Provisioning remains robust, with a 95.6% NPL coverage 
ratio. The share of state-owned banks in total assets declined slightly to 53.5%.  

Lending  to  households  and  businesses  increased  markedly  in  2024,  but  overall  credit 
penetration remains low. Lending growth reached 22% for business loans and 38% for household 
credit, supported by public and international financial institution (IFI)-backed guarantee and support 
schemes,  lower  interest  rates,  and  stabilising  real  estate  prices.  Still,  the  loan-to-GDP  ratio  is  just 
11%, compared to around 80% in the EU. The NBU has started implementing significant measures 
under  its  Lending  Development  Strategy,  including  transitional  provisions  for  EU  regulatory 
alignment.  Capital  markets  remain  underdeveloped,  and  the  National  Securities  and  Stock  Market 
Commission  (NSSMC)  remains  under-resourced,  impacting  its  capacity  to  supervise  market 
participants  effectively  and  enforce  compliance  with  international  standards.  In  line  with  IMF 
programme requirements, work is ongoing to develop a roadmap to guide the implementation of the 
updated  Financial  Sector  Development  Strategy,  setting  out  concrete  reform  measures  for 
strengthening financial market infrastructure.  

Functioning of the labour market  

War-related  labour  shortages  have  become  a  growing  structural  constraint  on  the  economy. 
Around  38%  of  businesses  reported  difficulties  in  finding  qualified  workers,  and  estimates  suggest 
that labour shortages reached 16% of total labour demand in 2024. The problem is particularly acute 
for  skilled  blue-collar  professions,  especially  in  the  transport  and  construction  sectors.  While 
shortages  have  contributed  to  a  rise  in  the  labour  market  participation  of  women,  traditionally 
underrepresented  in  Ukraine’s  workforce,  the  gender  gap  in  the  labour  force  participation  remains 
notable. On 15 October 2024, the government adopted a medium-term labour market forecast to better 
align vocational education and training with projected labour needs. In addition, in November 2024, 
the Cabinet of Ministers approved an action plan to operationalise the Strategy for the Demographic 
Development  of  Ukraine  until  2040,  which  seeks  to  counterbalance  workforce  shortages  linked  to 
external  and  internal  population  displacement  induced  by  Russia’s  war  of  aggression.  Legislative 
amendments  submitted  to  Parliament  in  May  2025  introduced  tax  reporting  obligations  for  digital 
platform  operators,  with  the  aim  of  improving  tax  compliance  and  formalising  employment  in  the 
platform economy. Work is ongoing on a new Labour Code, designed to align with EU best practices, 
remove impediments to labour mobility, and raise labour market participation. 

2.3.2. The capacity to cope with competitive pressure and market forces within the EU 

Education and innovation  

The  authorities  continue  to  take  steps  to  improve  the  quality  of  education.  Public  spending  on 
education as a share of GDP has remained steady and similar to that in the EU. Results from the most 
recent  PISA  (Programme  for  International  Student  Assessment)  study  in  2022  showed  a  decline  in 
performance  compared  to  the  previous  round  in  2018,  likely  due  to  the  combined  effects  of  the 

57 

 
 
pandemic  and  the  war3.  Ukraine  has  continued  its  ongoing  reform  efforts,  including  through  a  new 
law on preschool education which entered into force in January 2025 and aims to achieve universal 
coverage  and  improve  educational  outcomes.  The  implementation  of  the  New  Ukrainian  School 
Reform  of  Curricula  and  the  Pedagogical  Approach  has  continued,  with  the  launch  of  the  pre-pilot 
project  in  upper  secondary  education  starting  from  September  2025.  The  authorities  have  also 
continued to take steps to prepare the education and training system to meet the needs of Ukrainians 
currently  living  abroad.  These  include  accelerated  curricula,  modified  distance-learning  courses  on 
Ukrainian  language  and  history,  recognition  of  education  received  abroad,  and  allowing  university 
applicants to use temporary exam centres abroad to qualify for entrance to Ukrainian bachelor’s and 
master’s programmes. In addition, the Ukraine Plan contains a number of measures and investments 
to improve human capital, in particular through improvements to vocational education. Spending on 
research  and  development remains  low  at  0.37%  of GDP  in  2024,  though  Ukraine  approved  a  new 
Global  Innovation  Development  Strategy  to  2030  aimed  at  boosting  innovation  by  improving 
infrastructure, reducing regulation, improving access to funding and creating centres of excellence in 
areas such as defence and healthcare. 

Physical capital and quality of infrastructure  

Amidst  tight  budgetary  conditions,  Ukraine  has  continued  to  address  urgent  reconstruction 
needs,  in  particular  for  energy  generation,  where  4  GW  of  generation  capacity  was  restored  and 
830 MW built in 2024 (together worth over a quarter of peak winter demand), but also for housing 
and roads. The Ministry of Economy has commissioned 600 MW of additional distributed generation 
in 2025. The NBU and 17 commercial banks signed a memorandum to increase financing for energy 
needs,  with  the  total  financed  generation  capacity  above  1 GW  since  June  2024.  In  addition,  the 
Ministry  for  Development  of  Communities  and  Territories  and  the  Ministry  of  Energy  have 
introduced ‘energy independence passports’ for each region of Ukraine to assess the potential for the 
development  of  distributed  generation  in  each  region,  and  to  allow  for  regions  to  develop  detailed 
actions  plans.  Procedures  for  building  and  reconstructing  gas  transport  and  power  lines  have  been 
simplified. Ukraine has made strong progress in reforming public investment management, creating 
the strategic investment council and the single project pipeline, using the DREAM digital  platform, 
developing much of the regulatory framework for the new public investment management system and 
amending  the  budget  code  to  better  embed  public  investments  in  the  budget  cycle,  in  line  with  the 
Ukraine  Plan.  Ukraine  has  also  made  notable  progress  in  maintaining  and  expanding  household 
internet access with a 1.2% increase in fixed access points overall and a 6.3% increase in rural areas.  

Sectoral and enterprise structure  

The ongoing war continues to impact the structure of the economy. Agriculture’s share of GDP 
fell  from  over  12%  in  2021  to  around  8%  in  2024,  following  a  30%  decrease  in  total  agricultural 
production  in  2022,  from  which  Ukraine  has  only  partially  recovered.  However,  Ukraine’s  exports 
continue to rely heavily on agricultural products, which account for 63% of all exports, despite major 
challenges,  including  supply-chain  disruptions,  loss  of  farmland,  risks  from  mines,  destruction  of 
machinery, and soil damage. Industry has seen a similar decline to around 17% of GDP in 2024, the 
share of construction nearly halved, while the relative size of the service sector grew to around 70% 
of GDP. Industrial production is dominated by energy, basic metals, mining and other lower value-
added  industries.  The  information  and  communication  technology  sector,  where  Ukraine  had  been 
developing  a  comparative  advantage,  maintained  its  relative  share  of  output  at  5.2%  of  GDP,  and 
digital services made up 12% of total exports.  

Economic integration with the EU and price competitiveness  

3 The PISA study was conducted in October 2022 in 18 of Ukraine’s 27 regions. The results are thus not entirely comparable 
with  those  from  2018.  Nevertheless,  the  authorities  themselves  do  make  the  comparison  (in  their  contribution  to  the 
enlargement report) and conclude that ‘the educational loss of Ukrainian 15-year-olds in reading can be estimated to be 
about two years of schooling.’ 

58 

 
 
 
The  overall  openness  of  the  economy,  as  measured  by  the  trade-to-GDP  ratio,  declined  from 
about 87% in 2022 to 78% in 2024, where it has since stabilised as a result of disruptions related 
to the war. The EU remains Ukraine’s largest trading partner, accounting for over half of Ukraine’s 
exports  and  imports  of  goods  and  services.  The  EU  is  also  the  largest  source  of  foreign  direct 
investment  (FDI)  in  Ukraine,  accounting  for  over  three  quarters  of  FDI  inflows  in  2023  and  2024. 
However,  much  of  this  reflects  reinvested  earnings,  driven  by  capital  controls  that  restrict  the 
repatriation of dividends. The real effective exchange rate again appreciated slightly in 2024, driven 
by higher inflation and a slower exchange rate depreciation of the hryvnia as a result of the NBU’s 
managed floating exchange rate policy. 

2.4. PUBLIC PROCUREMENT, STATISTICS AND FINANCIAL CONTROL  

Chapter 5 - Public procurement 

EU  rules  ensure  that  the  public  procurement  of  goods,  services  and  works  in  any  Member  State  is 
transparent  and  open  to  all  EU  economic  operators  on  the  basis  of  non-discrimination  and  equal 
treatment.  

Institutional set-up and legal alignment 

The  legal  framework  on  public  procurement  is  partially  aligned  with  the  EU  acquis  on  public 
procurement. Due to Russia’s war of aggression, Ukraine introduced temporary exceptions from the 
public  procurement  legislation  by  way  of  government  decrees.  The  scope  of  exemptions,  mainly 
related to the needs of the martial law, has increased. 

A  new  centralised  procurement  body  was  created  under  the  State  Agency  for  Reconstruction  and 
Development  of  Infrastructure  in  pilot  mode  for  a  two-year  period.  The  two  central  defence 
procurement bodies respectively for non-military and military procurement, continued their operations 
although  instances  of  political  interference  were  noted  in  their  governance.  Lack  of  legal  clarity 
related  to  the  distinction  between  conventional  and  defence  procurement  also  continued  to  persist. 
Procurement  officer  positions  have  been  created  within  military  units,  to  improve  decentralised 
defence procurement. 

Some  progress  has  been  made  in implementing  the  Strategy for  Reforming  the Public  Procurement 
System for 2024-2026 and its Action Plan, notably on the professionalisation of public procurers and 
further  development  of  the  electronic  procurement  system  Prozorro,  enhancing  transparency  and 
efficiency, which could result into Ukraine’s more effective participation in EU instruments. 

The adopted Law on Concessions and Public-Private Partnerships (PPP), in several aspects still falls 
short  of  compliance  with  the  EU  acquis.  The  law  fails  to  fully  treat  the  EU  economic  operators 
equally as domestic ones. Ukraine needs to take steps to fully align with the EU acquis which would 
make its framework for public-private partnership and concessions more attractive for investment. As 
a result, this law, in its current form, is not in line with the DCFTA. 

Implementation and enforcement capacity  

Ukraine’s public procurement market represented 11.6% of nominal GDP (compared with 12.1% in 
2023),  out  of  which  68%  were  contracted  via  competitive  procedures  with  an  average  number  of 

59 

 
 
bidders of 1.55, impacted by many procedures where only a single bid is submitted. The overreliance 
on  price  as  the  sole  award  criterion  indicates  a  significant  imbalance  in  prioritisation  of  price  over 
quality. 

The  State  Audit  Service  (SAS)  continues  to  carry  out  monitoring  of  legal  compliance  of  contract 
award  and  implementation.  A  new methodology for  determining automatic risk indicators,  their list 
and  procedure  for  application  were  adopted  by  the  Ministry  of  Finance.  However,  so  far  only  a 
minority  of  monitoring  actions  were  triggered  by  automatic  risk  indicator.  The  violations identified 
continue to be challenged in court only in a minority of cases, with a low success rate for SAS. The 
procurement audit guide, aimed to enhance the compliance audit capacity, has been approved by the 
decision of ACU Chairperson. 

The  contracting  authorities  need  to  continue  to  build  capacity  of  management  of  public 
procurement processes across the institutions. Following a comprehensive needs assessment in July 
2024, progress was made in updating the training offer, including different free online courses.  

While  a  legal  and  institutional  framework  on  the  prevention  of  corruption  is  in  place,  risk 
assessments within the contracting authorities, conflict of interest prevention, as well as internal and 
external  controls  remain  weak,  particularly  in  the  pre-awarding  phase.  A  sectoral  anti-corruption 
strategy  is  still  awaiting.  Integrity  criteria  for  bidders,  alongside  the  monitoring  and  enforcement 
capacity, require further strengthening. 

Efficient remedy system 

The legislation on the right to legal remedy in the field of public procurement is partly aligned with 
the  EU  acquis.  In  2024,  the  Antimonopoly  Committee  (AMCU)  received  10 535  complaints  out  of 
which 70.8% have been determined as justified. In 2024, 140 decisions of the AMCU were appealed 
to the court out of which 130 are still under consideration while 10 decisions were confirmed. 

Chapter 18 - Statistics 

European statistics are developed, produced and disseminated by EU Member States, guided by the 
principles  and  criteria  elaborated  in  the  Regulation  on  European  statistics,  such  as  professional 
independence, impartiality, reliability, accessibility and statistical confidentiality. Common rules are 
provided  for  the  methodology,  production  and  dissemination  of  statistical  information,  which  are 
further specified in sectoral legislation that constitute the EU acquis on statistics. 

On statistical infrastructure, the professional  independence of the State Statistical Service (SSSU) 
was  negatively  affected  by  the  sudden  dismissal  of  its  head  in  March  2025.  The  new  head  was 
nominated  without  a  due  procedure.  Ukraine  should  amend  and  adopt  a  revised  statistical  law  to 
ensure the full professional independence of the SSSU and the enforcement of all rules under the law 
on official statistics, including the selection, appointment and duration of assignment of the head of 
the  SSSU.  The  allocation  of  adequate  financial  and  human  resources  is  needed  to  achieve  full 
alignment with the EU acquis. The coordination role of the SSSU of the national statistical systems 
and  the  definition  of  responsibilities  of  the  producers  of  official  statistics  should  be  outlined  in  a 
revised law on official statistics. 

For statistical reporting that has been made voluntary during martial law and hindering the SSSU from 
collecting  data  from  reporting  units,  progress  was  made.  On  18 June 2025,  Ukraine  adopted  a  law 
requiring legal entities to resume statistical and financial reporting to state statistical bodies, including 
to submit within three months from the date of entry into force of the law any missing reports not filed 
since 2022. The law also enabled the SSSU to resume surveys of households. Following the adoption 
of the law, reporting by businesses to the SSSU on the years 2022-2025 has resumed and the SSSU 
has launched a pilot for the Labour Force Survey for the current year.  

Ukraine should continue putting in place the necessary infrastructural elements to use the Statistical 
Data and Metadata Exchange (SDMX) standard for the exchange of statistical data at the international 
level, including the transmission of data to Eurostat. 

On classifications and registers, some of the major European classifications are already in place, but 

60 

 
 
newer versions of the classification of individual consumption according to purpose (COICOP-2018), 
statistical classification  of economic  activities  (NACE  rev.  2.1), statistical  classification  of  products 
by activity (CPA rev 2.2) and classification of occupations harmonised with international standard of 
classification of occupations (ISCO-08) need to be introduced by 2027.     

On macroeconomic statistics, the compilation of macroeconomic and government finance statistics 
remains disrupted due to the martial law. National accounts and gross national income (GNI) data in 
Ukraine  partially  comply  with  the  European  System  of  Accounts  2010  standards  but  no  data  are 
submitted to Eurostat. Ukraine is encouraged to conclude a memorandum of understanding between 
the SSSU, the National Bank and the Ministry of Finance and to set up a dedicated working group in 
the area of macro-economic statistics. 

On  sectoral  statistics,  energy  statistics  have  improved.  Substantial  progress  is  still  required  in  the 
areas  of  business,  social,  health,  international  trade,  price,  science,  technology,  innovation, 
agriculture, tourism and transport statistics.  

Chapter 32 - Financial control 

The EU promotes the reform of national governance systems to improve managerial accountability, 
sound  financial  management  of  income  and  expenditure,  and  external  audit  of  public  funds.  The 
financial control rules further protect the EU’s financial interests against fraud in the management of 
EU funds and the euro against counterfeiting.  

Public internal financial control (PIFC)  

The  strategic  framework  for  PIFC  is  in  place  as  part  of  the  public  finance  management  reform 
strategy for 2022-2025. While the structure is formally in place, its operational effectiveness needs to 
be  improved.  The  delegated  managerial  accountability  and  risk  management  practices  have  already 
been incorporated in the legal framework, however administrative practices are yet to be strengthened, 
including through identification and operationalisation of institutional pilots. 

A  certification  commission  for  the  internal  audit  function  has  been  created  within  the  Ministry  of 
Finance. The creation of an Audit Committee at central government level by the end of 2025 would 
strengthen the independent functioning of internal audit.    

In January 2025, new amendments to the Budget Code were adopted which updated the definition of 
“internal  audit”  in  accordance  with  Global  Internal  Audit  Standards,  clarified  and  strengthened 
managerial responsibility for the functioning of internal control and the performance of internal audit, 
and mandated the creation of audit committees in key spending units.  

External audit  

The  current legal framework  for  external  audit  was  further aligned  with  the  International  Standards 
for Supreme Audit Institutions (ISSAI) in December 2024, following amendments to the Law on the 
Accounting Chamber. Ukraine should continue to bolster the political and financial independence of 
the Accounting Chamber (ACU), particularly through the selection and operationalisation of the ACU 
Board, and its administrative capacities. 

To achieve full compliance with the ISSAI, the ACU should prioritise the effective implementation of 
approved ISSAI-based audit methodologies in its audit practices. Moreover, the ACU should develop 
robust quality assurance mechanisms to regularly assess the effectiveness of its audits, ensuring that 
they meet international benchmarks for transparency and accountability. 

Progress has been made in monitoring audit recommendations and developing specialised IT tools. To 
facilitate reforms, audits should be selected based on risk and impact assessments, which need to be 
reflected in the ACU's operational plan for 2026. The process of conducting initial financial audits on 
the  annual  consolidated  financial  statements  of  institutions  has  commenced.  The  ACU  should 
significantly  expand  its  audits  of  annual  consolidated  financial  and  budget  statements  during  2026. 
Key decisions in this process must include establishing a timeline, allocating resources, and sourcing 
qualified financial auditors.  

Protection of the EU’s financial interests  

61 

 
 
The national legislation is partly aligned with the EU acquis in terms of protection of EU’s financial 
interests. Ukraine still needs to fully align its national legislation with the EU Directive on the fight 
against fraud to the EU’s financial interests by means of criminal law. A national anti-fraud strategy 
to  protect  EU’s  financial  interests  still  needs  to  be  adopted  and  implemented  by  2027.  Moreover, 
Ukraine needs to focus legislation on strengthening measures to monitor procurement procedures. 

On  the  institutional  set-up,  the  State  Audit  Service  (SAS)  has  been  designated  as  the  anti-fraud 
coordination  service  (AFCOS)  but  its  mandate  and  capacity  to  protect  the  EU’s  financial  interests 
need to be consolidated. A corresponding AFCOS network of 13 national authorities involved in the 
detection, investigation, prosecution and prevention of fraud affecting EU funds has also been created 
during the reporting period.  

In January 2025, the SAS established a working relationship with representatives of the Secretariat of 
Ukraine  Facility  Audit  Board  focusing  on  measures  to  strengthen  control  over  the  expenditure  of 
funds under the Ukraine Facility. In March 2025, a memorandum of cooperation was signed between 
the SAS as Anti-fraud coordination service (AFCOS) and the Ukraine Facility Audit Board. Based on 
the KPMG audit report of May 2025, the Audit Board carried out an initial assessment of Ukraine’s 
internal audit system, and is finalising its first recommendation report, while also building cooperation 
with  the  European  Public  Prosecutor’s  Office  on  investigations  into  fraud,  corruption,  and  other 
illegal activities affecting the EU’s financial interests. The AFCOS has quickly worked together with 
OLAF to set up a reporting structure for the Irregularity Management System, for which access was 
granted in July 2025.  

Human and financial resource shortages limit effective internal control and audit. Ex ante controls of 
public procurement remain limited, with few cases of detected violations being successfully remedied, 
particularly for high-value contracts. 

Protection of the euro against counterfeiting 

Ukraine has made no progress on the ratification of the 1929 Geneva Convention for the Suppression 
of Counterfeiting Currency.  

3. GOOD NEIGHBOURLY RELATIONS AND REGIONAL COOPERATION 

Ukraine is an active participant in a variety of regional formats, including in the Eastern Partnership, 
the  Central  European  Initiative,  Black  Sea  Economic  Cooperation,  the  Organisation for  Democracy 
and Economic Development and the Regional Cooperation Council. Moreover, Ukraine has invested 
diplomatic capital in improving ties with its neighbours, especially with EU Member States. 

Ukraine and Hungary have continued efforts to strengthen dialogue, particularly in the fields in which 
Hungary  provides  Ukraine  with  support  and  in  the  protection  of  the  rights  of  persons  belonging  to 
national  minorities.  Numerous  meetings,  including  some  at  Heads-of-State  level,  have  taken  place. 
The Hungarian government organised a non-binding national consultation on Ukraine’s accession to 
the EU. 

Poland  is  one  of  Ukraine’s  closest  strategic  partners  in  the  context  of  Russia’s  war  of  aggression. 
Poland  provides  vital  political,  humanitarian,  economic,  technical  and  defence  assistance  and  hosts 
the largest number of Ukrainian persons fleeing Russian military aggression, as well as logistical hubs 
for  the  delivery  of  EU  humanitarian  and  civil  protection  support  to  Ukraine.  Both  countries  have 
shown  strong  political  commitment  to  finding  solutions  to  some  longstanding  issues.  In  November 
2024,  they  reached  an  agreement  and  issued  a  joint  statement  on  the  exhumation  of  victims  of  the 
Volyn Tragedy, which led to search and exhumation efforts starting in April 2025. 

Ukraine  and  Romania  continue  to  cooperate  closely  and  have  recently  strengthened  their  bilateral 
political  dialogue.  Since  early  2022,  Romania  has  provided  strong  political  support  to  Ukraine, 
including  by  facilitating  the  export  of  Ukrainian  food  products  through  EU  solidarity  lanes  and 
hosting logistical hubs for the delivery of EU humanitarian and civil protection support to Ukraine. 
The first meeting of the new trilateral cooperation format that brings together Moldova, Romania and 
Ukraine  took  place  in  June  2025,  with  a  focus  on  regional  security,  countering  hybrid  threats  and 

62 

 
 
cybersecurity,  energy  security,  cross-border  cooperation,  logistical  connectivity,  military  and 
technical cooperation, and European integration. 

Ukraine’s good relations with Slovakia have also been enhanced during Russia’s war of aggression. 
Slovakia continues to host a network of logistical hubs to channel EU in-kind assistance to Ukraine. 
Slovakia also hosts a significant number of Ukrainian persons fleeing Russian military aggression (per 
capita rate) under temporary protection arrangements. 

Relations with Bulgaria are bolstered by Bulgarian political, financial, military and humanitarian aid 
for  Ukraine,  and  by  growing  economic  ties.  They  were  also  nurtured  by  Bulgaria’s  support  for  EU 
solidarity lanes. 

Ukraine  maintains  longstanding  and  close  ties  with  neighbouring  Moldova.  Bilateral  political 
dialogue has been strengthened at all levels, reflecting Moldova’s strong support for Ukraine in the 
context of Russia’s war of aggression. The dialogue on EU accession has been further boosted by the 
fact that the screening process for Ukraine and Moldova took place simultaneously. The two countries 
also discuss regional and security issues, the situation in the Transnistrian region and the management 
of the water resources of the Nistru River, which remains a challenging topic. 

Ukraine and Georgia continue to implement a strategic partnership that began in 2017. While Georgia 
supports Ukraine’s territorial integrity and sovereignty, Ukraine has expressed concerns that Georgia 
has not aligned itself with EU sanctions against Russia and does not cooperate on military-technical 
matters.  The  de  facto  halt  of  Georgia's  accession  process  has  led  to  further  political  dissonance 
between  the  two  countries.  Relations  deteriorated  during  the  reporting  period.  Ukraine  imposed 
sanctions  on  the  honorary  Chair  of  Georgian  Dream  and  19  other  officials  in  December  2024.  In 
March 2025, Georgia reduced the maximum duration of  visa-free travel for Ukrainian citizens from 
three years to one year. 

Türkiye  is  a  partner  of  strategic  significance  for  Ukraine,  with  important  economic  and  people-to-
people  ties,  evidenced  by  a  bilateral  visa-free  regime  and  a  free  trade  agreement  (not  yet  ratified). 
Bilateral  relations  have  been  bolstered  since  the  beginning  of  Russia’s  full-scale  war  by  Türkiye’s 
technical, humanitarian and military support for Ukraine, and by its co-sponsoring of UN resolutions 
supporting  Ukraine’s  territorial  integrity  and  sovereignty.  In  January  2024,  Ukraine  and  Türkiye 
signed  an  accord  that  will  allow  Turkish  companies  to  take  part  in  the  reconstruction  of  Ukrainian 
infrastructure.  Türkiye  has consistently supported Ukraine’s sovereignty and territorial integrity and 
has  continued  to  highlight  its  role  as  facilitator  and  potential  mediator,  as  underpinned  by  hosting 
direct talks  between  Russia  and  Ukraine in May, June  and July  2025 in  Istanbul.  Türkiye  refrained 
from  aligning  with  the  EU’s  restrictive  measures  against  Russia  in  relation  to  Russia’s  war  of 
aggression  against  Ukraine  while  continuing  constructively  collaborating  with  the  EU  to  find 
solutions addressing sanctions’ circumvention. 

Relations  with  Albania  and  Bosnia  and  Herzegovina  are  based  on  their  support  for  Ukraine’s 
territorial  integrity  and  sovereignty  and  its  condemnation  of  Russia’s  war  of  aggression.  The  ties 
between  Ukraine  and  North  Macedonia  are  strong  and  deepening  through  political  dialogue, 
diplomatic support and military assistance in the face of Russia’s full-scale war. Ukraine-Montenegro 
relations  remain  strong,  bolstered  by  the latter’s  continued support  in  UN  forums  and  on sanctions, 
trade and technical and military assistance. 

Ukraine-Serbia  relations  have  improved,  although  Serbia  has  not  joined  the  sanctions  against  the 
Russian Federation. The Ukrainian and Serbian presidents held in February 2024  their first meeting 
since Russia’s full-scale invasion, where the latter confirmed Serbia’s support for Ukraine’s territorial 
integrity and sovereignty and committed to increasing humanitarian assistance for Ukraine. Serbia is 
Ukraine’s  biggest  trading  partner  in  the  Western  Balkans,  though  negotiations  on  a  free  trade 
agreement still need to be concluded. 

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Ukraine has not recognised the independence of Kosovo* but has indicated continued support for EU-
facilitated  dialogue  between  Belgrade  and  Pristina.  On  a  voluntary  basis,  Kosovo  supports  all 
declarations  on  Ukraine  by  the  High  Representative  on  behalf  of  the  EU  and  has  aligned  with  EU 
restrictive measures related to Russia’s war of aggression against Ukraine.  

4. ABILITY TO ASSUME THE OBLIGATIONS OF MEMBERSHIP 

CLUSTER 2: INTERNAL MARKET 

This  cluster  covers:  the  free  movement  of  goods  (Chapter  1);  freedom  of  movement  for  workers 
(Chapter  2);  right  of  establishment  and  freedom  to  provide  services  (Chapter  3);  free  movement  of 
capital  (Chapter  4);  company  law  (Chapter  6);  intellectual  property  law  (Chapter  7);  competition 
policy (Chapter 8); financial services (Chapter 9); and consumer and health protection (Chapter 28). 

Chapter 1 - Free movement of goods 

The free movement of goods ensures that many products can be traded freely across the EU based on 
common rules and procedures. Where products are  governed by national rules, the principle of the 
free movement of goods prevents these rules from creating unjustified barriers to trade. 

General principles 

The Deep and Comprehensive Free Trade Area (DCFTA) provides for the possibility to conclude an 
Agreement  on  Conformity  Assessment  and  Acceptance  (ACAA)  once  Ukraine has fully  aligned  to, 
implemented  the  EU  harmonised  acquis,  and  selected  product  legislation.  The  preparations  for 
negotiating  an  ACAA  are  at  an  advanced  stage,  pending  the  adoption  of  an  aligned  market 
surveillance law. 

Non-harmonised area 

Ukraine is not yet aligned with all the general principles governing the free movement of goods. It has 
not yet started activities for screening national technical regulations for compliance with Articles 34-
36 of the TFEU and relevant CJEU case law. 

Harmonised area: quality infrastructure  

Ukraine’s legislation is fully aligned with the EU acquis on standardisation. The national standards 
body  needs  to  replace  staffing  loses  and  to  apply  to  becoming  a  full  member  to  the  European 
Committee  for  Standardisation  (CEN)  and 
the  European  Committee  for  Electro-technical 
Standardisation.  Ukraine  is  fully  aligned  to  the  EU  acquis  on  accreditation  and  on  conformity 
assessment  and  is  partly  aligned  on  metrology.  Ukraine  currently  has  62  conformity  assessment 
bodies in place, covering over 20 different sectors. 

Ukraine  is  partly  aligned  with  the  EU  acquis  on  market  surveillance,  new  law  designed  be  fully 
aligned  with  the  EU  acquis  on  market  surveillance  needs  to  be  adopted.  Ukraine  fully  restored  all 
market surveillance at  the end  of  December  2024,  but  market  surveillance  bodies  still  lack  funding 
and face serious staffing issues. During 2024, the market surveillance authorities had conducted 2 004 
scheduled and 1 218 unscheduled inspections resulting in 12 607 corrective measures.  

Harmonised area: sectoral legislation 

During  the  reporting  period,  Ukraine  adopted  legislation  designed  to  be  fully  aligned  with  the  EU 
‘new and global approach’ product acquis on lifts, on cableways, on gas appliances, on equipment 
and  protective  systems  intended  for  use  in  explosive  atmospheres  (ATEX),  on  simple  pressure 
vessels,  on  noise  emissions  by  outdoors  equipment,  personal  protective  equipment,  and  on 
construction products.  

* This designation is without prejudice to positions on status and is line with UNSCR 1244/1999 and the ICJ Opinion on the 
Kosovo declaration of independence. 

64 

 
 
  
 
No progress was made on alignment with EU ‘old approach’ product acquis. 

On procedural measures, there were no developments on alignment with the EU acquis.  

Corruption  risk  mitigation  and  effective  penalties  remain  a  serious  challenge  in  regard  to  market 
surveillance. 

Chapter 2 - Freedom of movement for workers 

Citizens of one Member State have the right to work in another Member State and must be given the 
same working and social conditions as other workers. 

On access to the labour market, there were no significant legislative developments in the reporting 
period. Ukraine’s legislation remains not aligned with the EU acquis on access to the labour market. 
EU  nationals  fall  under  the  same  conditions  as  nationals  of  non-EU  countries  and  need  to  obtain  a 
permit  for  employment  in  Ukraine  from  the  State  Employment  Service.  EU  citizens  do  not  have 
access to public posts. 

In October 2024, Ukraine adopted an action plan to prepare the authorities for joining the European 
Network of Employment Services (EURES), focusing on institutional and informative measures. 

On  the  coordination  of  social  security  systems,  there  were  no  developments  on  establishing  an 
electronic  system  for  exchange  of  social  security  data  and  no  new  bilateral  agreements  have  been 
concluded over the reporting period. Ukraine signed a Memorandum of Understanding with Slovenia 
on comprehensive support of Ukrainian citizens temporarily displaced to Slovenia. 

With regards to the European Health Insurance Card, a national health insurance card has yet to be 
implemented in Ukraine. 

Chapter 3 - Right of establishment and freedom to provide services 

EU  natural  and  legal  persons  have  the  right  to  establish  themselves  in  any  Member  State  and  to 
provide  cross-border  services.  For  certain  regulated  professions,  there  are  rules  on  mutual 
recognition of qualifications. EU rules on postal services focus on improving the quality of universal 
service, gradual market opening to competition, and the establishment of an independent regulator. 

The EU-Ukraine Association Agreement allows the right of establishment and cross-border supply 
of services to EU natural and legal persons in Ukraine, with some exceptions which are not in line 
with the EU acquis. Ukraine has not started the process to eliminate these exceptions and should start 
making progressive steps to align with the Services Directive.  

Further  efforts  are  needed  to  align  with  the  mutual  recognition  of  professional  qualifications, 
particularly  with  the  Directive  on  the  recognition  of  professional  qualifications  and  the  minimum 
training requirements for professions benefiting from the automatic recognition, the directives on the 
free  movement  of  lawyers  and  the  Directive  on  a  proportionality  test  before  adoption  of  new 
regulation  of  professions.  No  agreement  for  mutual  recognition  of  professional  qualifications 
currently exists with the EU. 

In  the  area  of  postal  services,  Ukraine  is  partially  aligned  with  the  EU  postal  acquis.  The  postal 
monopoly on some specific services (such as sending citizens’ driver’s licenses, vehicle registration 
certificates and license plates) has been abolished in January 2025, while the state-owned designated 
universal service provider maintains the exclusive right to provide a universal postal service. Ukraine 
has  continued  to  guarantee  universal  service  on  its  territory,  despite  the  full-scale  invasion  and 
significant  destruction  of  the  postal  infrastructure.  Further  alignment  is  needed  with  the  remaining 
rules  of  the  EU  postal  acquis,  including the  Regulation  on  cross-border  parcel delivery  services,  in 
line with Ukraine’s taken commitments related to postal and courier services under the Association 
Agreement. 

Chapter 4 - Free movement of capital 

In the EU, capital and investments must be able to move without restrictions, with common rules for 
cross-border payments. Banks and other economic operators apply certain rules to support the fight 
against money laundering and terrorist financing. 

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On capital movements and payments, the National Bank of Ukraine (NBU) continued to implement 
its strategy for easing the war-related foreign currency restrictions and transition to greater exchange 
rate flexibility. At the same time, the NBU introduced additional war-induced restrictions to safeguard 
economic  and  financial  stability.  As  soon  as  conditions  allow,  Ukraine  should  lift  the  restrictions 
enacted following the martial law and continue the liberalisation of pre-existing restrictions to foreign 
exchange transactions. In addition, Ukraine must address the restrictions which remain embedded in 
the national legislation on the acquisition of agricultural land by EU nationals, contrary to the relevant 
EU acquis. 

On  payment  services,  progress  was  made  in  the  area  of  the  instant  credit  transfers.  A  law  was 
adopted in October 2024 aiming to implement EU Regulation 2024/886. Furthermore, in March 2025, 
the NBU updated requirements for credit and debit transfers in the domestic currency, aiming to align 
with  Regulation  260/2012.  The  registration  of  the  payment  market  participants  was  amended  as  of 
January 2025. Going forward, Ukraine should enhance efforts to align with the relevant EU acquis. 
On 1 August 2025, Chapter 4 of the Law on Payment Services, covering the procedure for payment 
service providers to access users’ accounts (Open Banking), came into effect. The NBU has adopted 
regulations  on  open  banking,  outlining  requirements  for  authorization,  electronic  trust  services, 
liability insurance, risk management, regulatory capital, and governance systems. 

On  the  fight  against  money  laundering  and  terrorism  financing (AML/CFT),  the  government  – 
following its reshuffle – is to resubmit to Parliament in Q4 2025 a comprehensive legislative package 
aiming to align with the AML/CFT acquis through, in particular: the establishment of the Register of 
Accounts  and  Individual  Bank  Safes  of  Natural  Persons,  their  authorised  people  and  beneficial 
owners; the creation of a register of beneficial owners of trusts and other types of legal arrangements; 
and the introduction of whistle-blower protection in the field of AML/CFT. Ukraine should increase 
efforts to advance with alignment with the EU acquis. 

A  dedicated  AML/CFT  policy  department  was  created  within  the  Ministry  of  Finance,  transferring 
personnel  and  functions  from  the  State  Financial  Monitoring  Service  (SFMS),  Ukraine’s  financial 
intelligence unit. In March 2025, the Cabinet of Ministers appointed a new head of the SFMS. The 
appointment was carried out without competitive procedure, due to the legal regime of martial law. 
The SFMS should promptly be ensured the necessary capacities and resources to fulfil its mandate. 
The  fourth  AML/CFT  National  Risk  Assessment  of  money  laundering  and  terrorist  financing  risks 
was launched in April 2025 with the aim to be completed by the end of 2025. Going forward, Ukraine 
should further strengthen its supervisory capacities. 

Further progress is needed in some areas, including regulation and supervision of virtual assets and 
their  service  providers.  A  new  draft  law  on  virtual  assets  aiming  to  align  with  EU  Regulation 
2023/1113 and EU Regulation 2023/1114 (Markets in Crypto-Assets) was adopted by Parliament in 
first  reading  in  September  2025.  In  2024,  the  SFMS  received  1  750  940  reports  on  financial 
transactions  subject  to  monitoring,  marking  a  23%  increase  compared  with  the  previous  year.  Of 
these,  82%  pertained  to  threshold  transactions,  while  the  remaining  18%  involved  suspicious 
activities.  In  the  first  half  of  2025  the  SFMS  received  1  118  158  reports.  With  more  than  99%  of 
suspicious transaction reports being submitted by banks, Ukraine needs to improve the capacities of 
other reporting entities, in particular designated non-financial businesses and professions, to comply 
with the AML/CTF obligations.  

The NBU, the Ministry of Finance, the SFMS and other responsible bodies should strengthen internal 
oversight  of  conflicts  of  interest  and  promote  the  reporting  of  misconduct  through  whistle-blower 
channels. The effectiveness of their respective anti-corruption programmes in preventing, identifying, 
and sanctioning misconduct should be further improved, and cooperation with anti-corruption bodies 
and law enforcement agencies further streamlined. 

Chapter 6 - Company law 

The EU has common rules on the formation, registration and disclosure requirements of a company, 
with complementary rules for accounting and financial reporting, and statutory audit. 

In  the  area  of  company  law  and  corporate  governance,  on  9 January 2025,  the  Verkhovna  Rada 

66 

 
 
adopted the Law on regulation of the activity of certain types of legal entities, restoring the obligation 
of  reporting  to  the  National  Securities  and  Stock  Market  Commission  (NSSMC)  that  had  been 
suspended  during martial  law.  A  draft  Law  has  been  submitted  to  the  Rada,  aiming  at  harmonising 
corporate  governance-related  aspects  of  protection  of  investors’  rights  and  improvement  of  gender 
balance with the acquis. The NSSMC also adopted in May 2025 a resolution with recommendations 
on the quality of information disclosure in corporate governance reports. 

In the area of company reporting, in October 2024, the Cabinet of Ministers adopted a strategy and 
action  plan  to  introduce  sustainability  reporting.  A  draft  law  regarding  the  introduction  of 
sustainability  reporting  has  been  submitted  to  the  Rada  in  August  2025.  Ukraine  should  take  into 
account  the  evolution  of  the  EU  acquis  in  this  area.  The  Ministry  of  Finance  continued  bringing 
national  accounting  regulations  (standards)  in  line  with  the  International  Financial  Reporting 
Standards. 

In  the  area  of  statutory  audit,  Ukraine  is  developing  a  draft  law  setting  out  provisions  related  to 
corporate sustainability reporting assurance, bearing in mind ongoing developments in the EU acquis. 

Chapter 7 - Intellectual property law 

The EU has to a large extent harmonised rules for the legal protection and enforcement of intellectual 
property  rights  (IPR),  covering  notably  patents,  biotechnological  inventions  and  pharmaceuticals, 
including  supplementary  protection  certificates  (SPCs),  trade  marks,  designs,  geographical 
indications (GIs), including craft and industrial GIs, as well as copyright and related rights. 

On copyright and related rights, the Ukrainian authorities produced a draft law aimed at increasing 
the  alignment  with  the  EU  acquis.  It  is  of  concern  that  the  accreditation  procedures  for  collective 
management organisations (CMOs) remain suspended under martial law, which negatively affects the 
collection and distribution of royalties to the rightsholders. 

On  industrial  property  rights,  rules  on  drafting,  filing  and  examination  of  an  application  for  an 
invention  and  a  utility  model  entered  into  force  in  October  2024  and  respective  guidelines  were 
approved  in  May  2025.  The  order  “On  Approval  of  the  Procedure  for  Consideration  of  the 
Application for Supplementary Protection for Rights to Inventions”  entered into force in June 2025. 
Further  alignment  is necessary in  particular  with  regard  to  supplementary  protection  certificates  for 
plant protection products and medicinal products, compulsory licensing of pharmaceutical patents and 
biotechnological inventions. New rules for drafting and submitting a trademark application came into 
force in September 2024.  

On the enforcement of intellectual property rights, in May 2025, a law was adopted to resume the 
pre-war standard procedural timelines for IP-related actions – such as filing, fee payments, responses 
to office communications, and renewals. The Ukrainian National Office for Intellectual Property and 
Innovations  (NIPO)  has  published  its  consolidated  data  on  IP  enforcement  on  for  2024  on  30  June 
2025,  pointing  to  year-on-year  reduction  of  IP-infringement  related  cases  in  the  consideration  of 
enforcement  bodies.  The Office  provided technical trainings  and information  campaigns,  as  well  as 
concluded  memoranda  of  understanding  with  the  involved  enforcement  authorities.  The  Intellectual 
Property Court is still not operational.  

On  the  institutional  framework,  NIPO  continued  close  collaboration  with  the  European  Union 
Intellectual  Property  Office  (EUIPO).  In  particular,  Ukraine  started  integrating  with  the  EU 
Intellectual  Property  Network’s  Tools  and  Common  Practices.  The  integration  of  data  on  national 
trademarks (from UANIPIO Special Information System API) into the EUIPO was completed. 

Chapter 8 - Competition policy 

EU rules protect free competition. They include antitrust rules against restrictive agreements between 
companies  and  abuse  of  dominant  position,  and  also  include  rules  on  concentrations  between 
companies which would significantly impede effective competition. EU rules also set out a system of 
State aid control. Governments are only allowed to grant State aid if restrictive conditions are met, 
with a view to preventing distortion of competition. 

67 

 
 
Antitrust and mergers 

On  the  legislative  framework,  some  provisions  of  the  Law  on  the  protection  of  economic 
competition and the implementing legislation still need to be aligned with the EU acquis. A draft law 
was  registered  in  Parliament  in  January  2025,  aiming  at  further  aligning  aspects  of  the  Ukrainian 
legislation with the EU acquis but is still pending adoption. 

On  implementation,  the  Antimonopoly  Committee (AMCU)  continued  adopting  decisions  in  cases 
for anticompetitive concerted actions, abuse of dominant position and mergers. The amounts of fines 
imposed  by  the  AMCU  as  a  conclusion  to  these  cases  has  increased,  notably  in  cases  of 
anticompetitive concerted actions. AMCU applied the newly introduced leniency mechanism in three 
cases, resulting in decisions on full exemption of liability, and carried out a dawn raid in one case. 
The AMCU’s enforcement record could be further improved. 

State aid 

On the legislative framework, the State aid law needs to be amended on a number of issues to ensure 
alignment  with  the  EU  State  aid  rules,  as  regards  substantive  and  procedural  rules.  Ukraine  is 
expected to amend and put into force the updated legislation on State aid, including rules on services 
of general economic interest, together with the unsuspension of the application of State aid control.  

Ukraine approved further implementing provisions on criteria for assessing the compatibility of State 
aid  to  undertakings.  It  also  submitted  to  the  Commission  a  report  showcasing  some  progress  in 
compiling  a  State  aid  inventory  but  still  needs  to  prepare  and  submit  complete  and  comprehensive 
information on the inventory of existing State aid measures. 

Further alignment with the EU State aid acquis and, where necessary, amendments to the legislation 
are needed, combined with a focus on enforcement. This further includes specific aspects, such as the 
transparency of financial relations with public undertakings as well as financial transparency within 
certain undertakings, and separation of accounts in undertakings in order to avoid cross-subsidisation 
of  economic  activities  from  public  service  obligations  and/or  SGEI-related  activities  within  the 
undertakings. 

In terms of implementation, the State aid control remains suspended under the martial law, and there 
is no obligation to notify to AMCU new or modified State aid measures. Ukraine has been preparing 
legislative  amendments  for  the  unsuspension  of  State  aid  control,  and  they  need  to  be  adopted 
together  with  the  necessary  administrative  arrangements  to  enable  implementation.  The  State  aid 
control has already been partially restored as regards aid granted through the Business Development 
Fund as of November 2024. 

Chapter 9 - Financial services 

EU rules aim at ensuring fair competition among financial institutions and the stability and integrity 
of financial markets, namely in the fields of banking, insurance, supplementary pensions, investment 
services  and  securities.  They  include  rules  on  authorisation,  operation  and  supervision  of  these 
institutions.  

On banking and financial conglomerates, the NBU has resumed the annual resilience assessment of 
Ukrainian banks, with a detailed report expected to be published in the first quarter of 2026. Results 
were  issued  on  1  September  2025:  the  assessment  covered  60  banks,  with  39  undergoing  only  the 
Asset Quality Review (AQR) and 21 also stress-tested, representing over 90% of sector assets.  

In  December  2024,  the  NBU  adopted  a  series  of  new  regulations  on  on-site  banking  supervision, 
organisation of risk management systems and determining the minimum settlement risk in banks and 
banking  groups.  On  27  December  2024,  the  NBU  Board  adopted  a  resolution  on  the  procedure  for 
consolidated supervision of non-bank financial groups. In April 2025, the NBU updated the procedure 
on credit risk weighing of banks' exposures. From 1 January 2025, new definition of non-performing 
exposures came into force, aiming to align with Regulation 575/2013, and to strengthen monitoring of 
such  exposures  by  supervisors.  On  6  June  2025,  the  Law  on  Factoring  was  adopted,  introducing 
regulatory conditions for the launch of the NPL market and set to enter into force in June 2026. 

68 

 
 
In March 2025, a law was adopted that envisages a new type of financial services provider – banks of 
financial  inclusion  –  servicing  both  people  (including  vulnerable  groups)  and  micro-enterprises  in 
difficult to reach areas. 

On 23 June 2025, the NBU Board adopted Resolution 68, establishing a 3% minimum leverage ratio 
for banks and banking groups. 

On insurance and occupational pensions, a new law on mandatory insurance against civil liability 
in respect of the use of motor vehicles, aiming to partially align with the EU acquis, entered into force 
in January 2025.  

The  regulation  on  authorising  insurance  intermediaries  and  terms  and  conditions  for  distribution 
insurance and/or reinsurance products was approved in January 2025, as part of the implementation of 
the Law on Insurance. 

The National Securities and Stock Markets Commission  adopted in January 2025 a White Paper on 
voluntary  pensions  accumulation  reform.  The  aim  is  to  modernize  voluntary  funded  pension 
provision, increasing the efficiency of management of voluntary pension savings and ensuring their 
proper protection, as well as at transforming Non-State Pension Funds into Funded Pension Funds in 
accordance with the requirements of EU legislation. 

As  regards  financial  market  infrastructure,  there  were  no  developments  in  the  reporting  period. 
Ukraine remains partially aligned with the EU acquis.  

On  the  securities  markets  and  investment  services,  on  6 September 2024,  the  NSSMC  adopted  a 
regulation on the public and private issuance of corporate bonds. On 14 November 2024, the NSSMC 
approved  the  procedure  on  appointing  heads  of  professional  participants  in  capital  markets  and 
organised commodity markets, as well as the internal control system officers and people responsible 
for  financial  monitoring.  Ukraine  should  further  implement  the  law  on  the  NSSMC’s  operational 
independence.  

Ukraine  should  undertake  further  efforts  to  align  with  the  EU  acquis  on  securities  markets  and 
investment services, taking into account the evolution of the EU acquis. 

On sustainable and digital finance, in December 2024, the NBU updated its macroprudential policy 
strategy, including ESG risks as a potential systemic threat for financial stability. In March 2025, the 
NSSMC  approved  the  Sustainable  Finance  Roadmap  2025–2030,  outlining  measures  to  foster 
sustainable finance in Ukraine by promoting ESG integration, ensuring a stable regulatory framework, 
and preparing the market for the transition to sustainable finance. 

Ukraine needs to take further actions on virtual assets as a matter of priority. 

On digital operational resilience, in March 2025, a new law was adopted clarifying NBU powers and 
procedures, as well as banks’ cybersecurity and information security requirements, and the operation 
of  the  national  cyber  incident  response  system.  In  February  2025,  the  NBU  Board  adopted  a 
resolution  to  enhance  regulation of cybersecurity,  information security, and electronic trust  services 
oversight in the banking system. 

On anti-corruption, the NBU continued to implement its anti-corruption programme and resolved all 
identified conflicts of interests. The NSSMC updated its Code of Ethics. The reform of the Deposit 
Guarantee Fund should ensure its independence and accountability, including competitive procedures 
for the transfer of bank assets. 

Chapter 28 - Consumer and health protection 

EU  rules  protect  consumers’  economic  interests  and  in  relation  to  product  safety  and  liability  for 
defective product. The EU also ensures high common standards for tobacco control, blood, tissues, 
cells and organs, and medicinal products for human and veterinary use. The EU also has rules for 
upholding patients’ rights in cross-border healthcare, and in preparing for and responding to serious 
cross-border health threats including communicable diseases.  

Consumer protection 

69 

 
 
On horizontal aspects, progress was made in the field of protection of consumer rights in financial 
services. Ukraine strengthened enforcement of consumer information and awareness and training of 
judges on consumer rights. On enforcement and redress, progress is needed on cooperation between 
national authorities responsible for the enforcement of consumer protection laws, and on alternative 
dispute resolution.  

On  product  safety,  Ukraine  needs  to  adopt  legislation  that  is  fully  aligned  with  the  EU  acquis  on 
market surveillance and control of non-food products. Ukraine needs to adopt legislation aligned with 
the general product safety regulation. Ukraine has already developed a rapid alert system based on the 
model of the EU Safety Gate system and a national market surveillance risk assessment tool based on 
the EU ‘Safety Gate’ guidelines. 

In  December  2024,  Ukraine  reintroduced  market  surveillance  [See  under  Chapter  1,  above,  for 
further information on market surveillance]. 

Public health  

On  horizontal  aspects,  in  January  2025  Ukraine  approved  the  Strategy  for  healthcare  system 
development.  The  adoption  of  implementing  legislation  for  the  2023  law  on  public  health  is  still 
pending,  and  resource  constraints  continue  to  hamper  the  healthcare  system  and  access.  There  was 
notable  update  to  Ukraine's  e-Health  system.  However,  Ukraine  should  continue  to  work  towards 
alignment  with  existing  EU  e-Health  recommendations  and  with  the  General  Data  Protection 
Regulation. 

While Ukraine increased its level of alignment of its national tobacco control legislation with the EU 
acquis,  further  work  remains,  and  it  needs  to  ensure  its  formal  accession  to  the  WHO  Protocol  to 
Eliminate Illicit Trade in Tobacco Products. On  communicable diseases and serious cross-border 
health threats, Ukraine remains partly aligned with the EU acquis. The epidemiological surveillance 
system needs to be integrated with the relevant EU's systems. A multi-sectoral national public health 
emergency  preparedness  plan  (including inter-ministerial  governance mechanisms),  integration  with 
the EU early warning and response system, and alignment with the guidelines of the European Centre 
for Disease Prevention and Control (ECDC) are all still needed. In December 2024, Ukraine approved 
a strategy and action plan to combat antimicrobial resistance. 

Ukraine has strengthened cancer screening and addressed gaps on non-communicable diseases. The 
National  Cancer  Registry  needs  to  be  fully  integrated  into  the  e-health  system.  The  Strategy  for 
tackling cancer, and its action plan, need to be fully implemented. On blood, further steps were taken 
to make the national blood system operational. In March 2025, Ukraine established an annual process, 
for  defining  reference  blood  entities,  costs,  and  prices,  alongside  forecasting  national  needs, 
coordinated  by  the  National  Transfusion  Centre.  Ukraine’s  law  on  medicinal  products  aims  to  be 
aligned  with  the  EU  acquis  on  medicinal  products  for  human  use,  some  of  its  provisions  only 
entering  into  force  in  January  2028.  In  April  2025,  Ukraine  joined  the  EU  agreement  on  the  joint 
procurement of medical countermeasures. A new law on the  mental health care system, which is a 
national  priority,  was  adopted  in  January  2025,  which  includes  a  clear  policy  shift  towards 
community-based care. 

There was no progress on alignment with the EU acquis on tissues, cells, and organs, on patients’ 
rights  in  cross-border  healthcare,  on  medical  devices,  on  cosmetic  products,  on  nutrition  and 
healthy  lifestyle,  on  health  inequalities,  on  rare  diseases,  or  on  drug  abuse  and  prevention. 
Ukraine is encouraged to draw up a roadmap for the implementation of the Regulation on standards of 
quality and safety for substances of human origin intended for human application and to strengthen 
the  administrative  capacity  and  oversight to  properly implement  and  enforce  it.  Ukraine  is  partially 
aligned with the EU Regulation on health technology assessment because it has a long-established 
national  system  on  this  matter.  While  there  was  no  progress  on  alignment  with  the  EU  acquis  on 
medicinal products for veterinary use, a new draft law on veterinary medicines is being prepared. 

Anti-corruption  in  public  health  is  a  key  priority,  particularly  in  the  area  of  medical  procurement, 
licensing  and  accreditation,  conflict  of  interests  and  management  of  financial  resources.  In  January 
2025 the Supervisory Board of the medical procurement enterprise was created, while the Ministry of 

70 

 
 
Health is expected to adopt a new anti-corruption programme. [See also corruption-related issues on 
market surveillance under Chapter 1] 

CLUSTER 3: COMPETITIVENESS AND INCLUSIVE GROWTH 

This cluster covers: digital transformation and media (Chapter 10); taxation (Chapter 16); economic 
and  monetary  policy  (Chapter  17);  social  policy  and  employment  (Chapter  19);  industrial  policy 
(Chapter  20);  science  and  research  (Chapter  25);  education  and  culture  (Chapter  26);  and  customs 
union (Chapter 29). 

Chapter 10 - Digital transformation and media 

The  EU  supports  the  smooth  functioning  of  the  internal  market  for  electronic  communications, 
electronic commerce and audiovisual services. The rules protect consumers and support the universal 
availability of modern services. 

On electronic communications, after fulfilling all EU requirements, including as regards alignment 
with  the  EU  roaming  acquis,  as  defined  in  the  EU-Ukraine  Association  Agreement,  Ukraine  will 
effectively join the EU Roam Like at Home area as of 1 January 2026.  

Ukraine  shows  progress  in  alignment  with  EU  acquis  on  connectivity.  Ukrainian  legislation  is 
partially aligned with the Broadband Cost Reduction Directive (BCRD) 2014/61/EU. The provisions 
on  infrastructure  sharing,  access  to  infrastructure,  transparency,  reduction  of  bureaucracy  and 
streamlining administrative procedures are already reflected in Ukrainian legislation. For the rest of 
BCRD provisions Ukraine aims to ensure full alignment by the end of 2025.  

Ukraine  is  also  invited  to  continue  efforts  on  alignment  with  the  Gigabit  Infrastructure  Act 
(Regulation  (EU)  2024/1309)  as  some  of  the  GIA  provisions  (regarding  Single  Information  Point, 
judicial  remedies,  access  point  as  well  exemptions  for  certain  types  of  civil  works)  are  already 
reflected in the national legislation of Ukraine. 

Due to current security constraints, Ukraine has not yet been able to fully implement the acts related 
to the regulatory framework for radio spectrum policy, in particular the release of the 700 MHz band 
from TV broadcasting for mobile communications. Nonetheless, on 1 November 2024, the Cabinet of 
Ministers adopted amendments to the plan for the allocation and use of the radio frequency spectrum, 
introducing  a  number  of  harmonisations  measures.  In  November  2024,  the  regulator  conducted 
spectrum auction in the 2100/2300/2600 MHz bands for mobile communications. 

On digital services, the Government approved the Strategy for Digital Development of Innovations 
until 2030 (WINWIN), detailing sectoral strategies for digitalisation of social sphere, education and 
science, public finances and SMEs, among others.  

The full enactment of consumer protection regulations is delayed due to martial law.  

Ukraine took initial steps towards aligning its national law with the Platform-to-Business Regulation 
(P2B), the Digital Services Act (DSA) and the Digital Markets Act (DMA) and is currently working 
on identifying a competent authority. Ukraine should continue preparation of draft legislation of the 
DSA,  DMA  and  P2B,  in  consultation  with  relevant  stakeholders.  Ukraine  should  continue  seeking 
alignment  with  the  European  Interoperability  Framework  (EIF)  and  the  provisions  present  in  the 
Interoperable  Europe  Act  to  make  their  public  services  more  efficient  and  at  the  service  of  their 
businesses and citizens. 

Ukraine  shows notable  progress  on  open  data  usage,  maintaining more  than  80 000  datasets  on  its 
open data portal. Alignment with EU acquis like the Open Data Directive and Data Governance Act 
remains partial, requiring further legislative amendments. The Diia Platform confirmed in 2023 that it 
meets or exceeds the relevant requirements of the e-IDAS Regulation. In addition, the operator of the 
e-IDAS  Node  in  Ukraine  has  obtained  ISO/IEC  27001  certification  in  June  2025,  demonstrating 
compliance  with  international  best  practices  in  information  security  management.  One  remaining 
challenge  with  respect  to  full  compliance  with  the  e-IDAS  Regulation  concerns  the  certification  of 
qualified  signature  creation  devices,  where  Ukraine  must  rely  on  certification  by  designated  bodies 

71 

 
 
 
within EU Member States. 

On digital trust and cybersecurity, Ukraine has continued to strengthen its cybersecurity framework 
through  significant  legal  reforms  and  capacity-building  measures.  A  comprehensive  Cybersecurity 
Strategy  is  in  place  alongside  updated  legislation.  The  amendments  to  certain  laws  on  information 
protection  and  cyber  defence  of  state  information  resources,  objects  of  critical  information 
infrastructure  adopted  in  March  2025,  establishes  a unified  national  system  for  responding to  cyber 
incidents. A number of pertinent rules of the EU acquis still need to be fully implemented to ensure 
alignment with the NIS II Directive. 

Institutional  capacity  has  been  bolstered:  the  State  Service  of  Special  Communications  and 
Information  Protection  (SSSCIP)  leads  coordination,  supported  by  CERT-UA  (the  national  CERT) 
and  other  bodies,  to  protect  critical  information  infrastructure.  This  enhanced  capacity  has 
underpinned strong cyber resilience during Russia’s ongoing war of aggression. Notably, cooperation 
with ENISA and other EU cyber institutions has advanced, building Ukraine’s ability to manage cyber 
incidents and crises. 

Regarding  5G  security,  Ukraine  has  adopted  a  Protocol  of  Intent  on  5G  Security  between  the 
responsible authorities, which includes an action plan to develop and implement rules on 5G security 
in  line  with  the  EU’s  5G  Cybersecurity  Toolbox,  including  the  exclusion  of  high-risk  suppliers. 
However,  Ukraine  has  made  limited  progress  in  implementing  these  commitments.  Notably,  in  a 
recently  launched  5G  pilot  project  in  Lviv,  the  National  Commission  for  the  Regulation  of  State 
Electronic  Communications,  Radio  Frequency  Spectrum  and  Postal  Services  (NCEC)  granted  a 
licence  to  a  high-risk  supplier,  contradicting  the  spirit  of  the  Protocol  and  risking  increased 
dependence  on  high-risk  vendors,  thereby  posing  a  threat  to  the  security  of  critical  infrastructures. 
Ukraine should effectively and quickly address such risks. 

On  media,  Ukrainian  legislation  is  broadly  in  line  with  the  Audiovisual  Media  Services  Directive 
(AVMSD) and only partially aligned with the European Media Freedom Act. To increase alignment, 
Ukraine’s  legislation  would  need  to,  among  others, remove  the requirement for  state registration  of 
the media regulator’s legal acts by the Ministry of Justice, introduce additional legal guarantees for 
the regulator's independence and provide guarantees for adequate financial and human resources for 
the media regulator.  

The  current  media  restrictions  imposed  by  martial  law,  including  restricting  the  transmission  of 
programmes  and  audiovisual  commercial  content/communications,  are  still  considered  necessary  to 
protect  Ukraine’s  information  space  in  the  current  security  situation,  although  they  will  need  to  be 
reassessed  upon  lifting  of  martial  law.  In  light  of  the  European  Media  Freedom  Act  (EMFA) 
requirements,  Ukraine  should  work  on,  among  others,  enhancing  the  editorial  freedom  and 
independence of media service providers and ensuring that an assessment of the impact of key media 
market concentrations on media pluralism and editorial independence is provided in the national law. 

Several  amendments  to  the  media  legislation  are  planned,  among  others,  on  the  financial 
independence of  the media  regulator; provisions  on  disclosure  of  the  ownership  structure  of  online, 
print  and  non-linear  media  with  a  view  to  further  align  with  the  EMFA;  and  amendments  to  the 
LawOn  Law-Making  Activities  with  a  view  to  exclude  state  registration  of  regulatory  acts  of  the 
National Council with the Ministry of Justice. 

On  semiconductors,  Ukraine  is  not  yet  fully  aligned  with  the  Chips  Act.  Ukraine  is  currently 
developing  a  National  Semiconductor  Strategy  and  is  working  on  the  first  draft  legislation  to 
harmonise its standard with the Chips Act.  

On  artificial  Intelligence  (AI),  Ukraine  is  not  yet  aligned  with  the  EU’s  AI  Act.  Ukraine’s  white 
paper on AI Regulation and the AI Regulation roadmap pave the way of Ukraine’s alignment with the 
AI Act. Ukraine plans to develop and adopt its National AI Strategy 2030 by end of 2025. In August 
2025,  the  Ukrainian  government  announced  the  launch  of  its  first  state  infrastructure  for  AI 
development, the AI Factory, and efforts to build its own national LLM (large language model). 

Chapter 16 – Taxation 

72 

 
 
EU rules on taxation cover value added tax and excise duties and aspects of corporate taxation. They 
also cover cooperation between tax administrations, including the exchange of information to prevent 
tax evasion. 

Ukraine made progress in further aligning the national legislation on  indirect taxation with the EU 
acquis.  The  law  amending  the  Tax  Code  to  revise  the  rates  of  excise  duties  on  tobacco  products 
introduces  a  gradual  alignment  with  Directive  2011/64/EU  on  excise  duty  rates  on  manufactured 
tobacco by 2028. The law was adopted and entered into force in March 2025. Ukraine needs to align 
its tax warehousing system for alcohol, tobacco and energy products with the EU acquis.  

Further steps are needed to align national VAT rules with the EU acquis on common system of VAT. 
In July 2025, a law amending the Tax Code entered into force, ensuring equal treatment for welfare 
and  social  service  providers  by  making  them  eligible  for  VAT  exemption,  provided  they  are  in  the 
Register  of  Social  Service  Providers.  This  aligns  national  legislation  more  closely  with  EU  VAT 
rules,  which  require  Member  States  to  exempt  activities  of  public  interest  from  VAT  based  on  the 
nature of the service rather than the status of the provider. Improvements are still needed in VAT rules 
related to reduced rates, exemptions, deductions, and special schemes. 

On direct taxation, there were no changes to personal income tax. The corporate income tax is not 
yet fully in line with the EU acquis. Ukraine does not have exit taxation rules equivalent to the EU 
ones and global minimum taxation rule.  

On  administrative  cooperation  and  mutual  assistance,  in  August  2025,  the  Ministry  of  Finance 
approved the implementation of certain requirements of the Directive on Administrative Cooperation 
(DAC) 1, including clear deadlines for responding to requests from Member States’  tax authorities, 
rules  on  group  requests,  and  procedures  for  managing  incoming  and  outgoing  requests.  National 
legislation still needs to be aligned with the DAC 7 and reporting rules for digital platforms.  

On  operational  capacity  and  computerisation,  Ukraine  made  progress  by  approving  the  strategy 
and implementation plan for the development of a competency-based approach in key human resource 
processes for 2025–2030 in the State Tax Service (STS). The list of tax competencies was approved. 
Further integration of a competency-based people management approach into selection, performance 
appraisal and professional development with revisions of current training programmes is needed. The 
functionality of the STS’ online information system has been improved with connections to the VAT 
Information  Exchange  System  (VIES)  to  verify  the  validity  of  VAT  identification  numbers  for 
taxpayers registered in the EU. In December 2024, the Ministry of Finance approved a strategic plan 
for the digitalisation of the STS up to 2030. A roadmap on the deployment of IT solutions required for 
EU accession needs to be developed.  

In March 2025, the STS updated its Anti-Corruption Action Plan for 2024-2025 and created a unified 
anti-corruption department. In 2024, 21 STS employees were subject to disciplinary actions, while 
law enforcement agencies continued to uncover large-scale tax evasion schemes by business entities. 
As  reported  by  the  National  Agency  for  Corruption  Prevention,  in  2024,  15.8%  of  taxpayers 
experienced corruption with the tax system (up from 13.1% in 2023, however the lowest among all 
the institutions surveyed).  

Chapter 17 - Economic and monetary policy 

EU  rules  require  the  independence  of  central  banks  and  prohibit  them  from  directly  financing  the 
public sector. Member States coordinate their economic policies and are subject to fiscal, economic 
and financial surveillance. 

In  terms  of  monetary  policy,  in  September  2024,  the  NBU  approved  new  medium-term  monetary 
policy guidelines, reintroducing flexible inflation targeting with a three-year time horizon. The NBU 
continued to ease  foreign currency  restrictions in a  series of  steps, mostly  recently  in  August  2025, 
which did not cause significant market reaction. The NBU law generally provides for the functional, 
institutional,  personal,  and  financial  independence  of  the  NBU,  though  further  steps  are  needed  to 
fully align it with the EU acquis. In particular, the primary objective should focus explicitly on price 
stability,  safeguards  should  be  introduced  to  prevent  interference  from  Parliament  and  government, 

73 

 
 
and the grounds of dismissal of the Governor and the other members of the decision-making bodies 
should be brought in line with the ESCB/ECB Statute. The right of judicial review of the Governor to 
the CJEU and of the other members of the decision-making bodies to the national courts, should also 
be  enshrined  in  the  central  bank  law.  Although  monetary  financing  has  been  possible  under  the 
martial law, it has been avoided since the start of 2023. 

On  economic  policy,  fiscal  rules  have  been  continually  suspended  through  the  annual  budget  laws 
since the start of the Russia’s war of aggression. On 30 June 2025, the Cabinet of Ministers approved 
the budget declaration for 2026-2028, which showed progress towards alignment with the EU acquis 
on  medium-term  budgetary  frameworks.  Notably,  it  included  headline  revenue  and  expenditure 
projections for the pension and unemployment funds, alongside more detailed projections for the state 
and local budgets. However, further steps will be needed to ensure full alignment with EU standards. 
These  include:  (i)  ensuring  that  general  government  data  is  consolidated  in  line  with  the  European 
System  of  Accounts  methodology;  (ii)  preparing  detailed  medium-term  projections  for  revenue  and 
expenditure items covering the general government level (not only the central and local budgets), and; 
(iii) linking these projections to clear budgetary targets (such as on deficit and debt) and explaining 
which  policies  will  be  used  to  meet  them,  to  the  extent  possible  under  martial  law.  This  will  help 
Ukraine  to  prepare  for  implementing  the  new  EU  fiscal  framework.  While  preparatory  work  has 
started, there is no independent fiscal institution to evaluate the government’s forecasts, scrutinise the 
government’s  budgetary  assumptions,  or  assess  the  performance  of  previous  forecasts.  Martial  law 
and security concerns continue to disrupt the collection of key macroeconomic and financial statistics, 
including those needed for the macroeconomic imbalance procedure, as well as budget reporting.  

Chapter 19 - Social policy and employment 

EU  rules  in  the  social  field  include  minimum  requirements  for  labour  law,  equality  and  non-
discrimination  and  health  and  safety  at  work.  They  also  promote  social  inclusion  and  social 
protection, and social dialogue at EU level. 

On  labour  law,  the  Ukraine  national  labour  legislative  framework,  with  a  labour  code  from  1971, 
needs to be modernised and aligned with the EU acquis. Ukraine is developing a new labour code and 
in  July  2025  the  government  and  social  partners  signed  a  memorandum  of  understanding  and 
cooperation on reforming labour legislation and labour relations.  

On occupational safety and health at work (OSH) the current national legal framework has yet to 
be aligned with the EU acquis and international standards. Alignment with the EU OSH Framework 
Directive  is  expected  as  part  of  the  Labour  Code  reform.  In  2024,  1 013  inspections  took  place 
reporting 9 537 labour safety violations. 

Labour inspection legislation is not yet aligned with the EU acquis and international labour standards 
and the capacities of the State Labour Service is limited. In addition, the enforcement functions of the 
State  Labour  Service  continue to  be  limited due to the  martial law.  Inspection  visits  for  undeclared 
work increased slightly from 92 in 2023 to 112 in 2024, while inspections on labour safety decreased 
from 1 954 in 2023 to 695 in 2024.  

On  social  dialogue,  the  National  Tripartite  Social  and  Economic  Council  faces  challenges  such  as 
high staff turnover, unclear roles and limited resources. It remains inactive, as its head has not been 
appointed. This prevents timely, systemic and meaningful consultations. Authorities need to develop 
an  enabling  environment for effective social  dialogue  and  capacities for  both  bipartite  and tripartite 
social dialogue need to be strengthened.  

On employment policy, the State Employment Service trained 66 600 people while assisting 327 000 
people  to  find  employment  in  2024.  In  October  2024,  the  authorities  created  a  working  group  to 
prepare  proposals  for  a  Population  Employment  Strategy.  In  2024,  the  unemployment  rate  in 
Ukraine was estimated at 14%.  

The  adequacy  of  the  social  protection  and  inclusion  system  in  Ukraine  remains  a  challenge,  in 
particular  for  persons  in  vulnerable  situations.  Ukraine  has  adopted  a  resolution  on  procurement  of 
social services for  comprehensive  development  and care  for  children  with  disabilities.  Furthermore, 

74 

 
 
Ukraine  approved  the  Strategy  for  Ensuring  the  Right  of  Every  Child  to  Grow  Up  in  a  Family 
Environment. Sustained progress on the implementation of the strategy is needed, including through 
strengthening local ownership and resources in child welfare, developing tailored action plans for all 
regions, investing  in  diversified  social  service  providers  at  community  level  and  enhancing  staffing 
and  expertise  of  social  service  workforce.  Following  an  invitation  by  the  European  Commission,  a 
national contact point for the European child guarantee has been nominated. 

On non-discrimination in employment and social policies, national legislation is not aligned with 
the  EU  acquis,  including  as  regards  the  Employment  Equality  Directive  and  the  Racial  Equality 
Directive. In January 2025, authorities adopted amendments to certain laws on ensuring the rights of 
persons  with  disabilities  to  work.  Support  for  access  to  employment  for  persons  with  disabilities  is 
progressively being addressed, but gaps remain. In 2024, the Ukrainian Parliament Commissioner for 
Human  Rights  received  12  notifications  of  discrimination  based  on  sexual  orientation  and  10 
notifications  based  on gender identity.  Legislation  is  not  fully  aligned  with  the  EU  acquis  on equal 
treatment in employment and occupation. 

On the equality between women and men in employment and social policy, Ukraine has in place a 
national  strategy  on  reducing  the  gender  pay  gap  but  needs  to  further  align  with  the  EU  acquis. 
Regarding  the  share  of  care  responsibilities,  33.4%  of  women and  19.1%  of men  care  for  children, 
older people or people with special needs on a daily basis. Ukraine has yet to align with directives on 
Work-life balance, Pay transparency and Women on Boards.  

The  level  of  preparation  for  the  participation  in  the  European  Social  Fund  Plus  is  low.  (See  also 
Chapter 22 - Regional policy and coordination of structural instruments). 

Chapter 20 - Enterprise and industrial policy 

EU  industrial  policy  strengthens  competitiveness,  facilitates  structural  change  and  encourages  a 
business-friendly environment that stimulates small and medium-sized enterprises (SMEs). 

On enterprise and industrial policy, Ukraine has undertaken strategic initiatives and implementation 
steps to improve industrial competitiveness and support to SMEs, as provided for in the SME Strategy 
until 2027, adopted in 2024. The strategy builds on the OECD findings and recommendations and is 
accompanied  by  an  action  plan  with  86  measures.  At  the  end  of  2024,  11  measures  were  fully  or 
partially implemented and 57 were in progress. 

The Digital Innovation Development Strategy until 2030 was adopted in January 2025, setting out key 
directions,  principles  and  goals  of  state  policy  in  the  field  of  innovation  and  creating  favourable 
conditions for business, startups, and investors. 

In  the  deregulation  field,  an  inter-ministerial  working  group  (IWG)  reviewed  1 323  instruments  of 
state  regulation  of  business  operations  and  recommended  to  abolish  456  instruments,  amend  or 
digitalise 584 tools and leave 283 regulations unchanged. As of August 2025, 352 instruments were 
already abolished. Most of the IWG’s recommendations on the abolition of instruments were included 
in the new version of 
the 
deregulation 
action plan.  

deregulation 
and 
of 

On 
efforts 
digitalisation 
permitting 
procedures,  in  three 
steps 
in 
September  2024  the 
government 
e-
launched 
permit 
to 
simplify the work of 

the 
system 

starting 

75 

 
 
entrepreneurs, reduce corruption risks and promote economic development by digitalising six initial 
permits and licences, as well as business appeal procedures in licensing (3 public services are already 
developed, 3 more are under development). The Law updating the approaches to regulating business 
activities and introducing changes to several other laws entered into force in February 2025, with the 
focus  on  succession  of  permits/licenses/certificates  between  an  enterprise  terminating  through 
transformation, merger, or acquisition, and its successor. 

On  enterprise  and  industrial  policy  instruments,  the  “Diia.Business”  portal  remains  key  in 
providing support to Ukrainian SMEs and underwent a major update in 2024. On SME digitalisation, 
considerable progress has been achieved through developing instruments such as digital vouchers for 
IT  solutions,  digital  maturity  assessments,  and  electronic  invoicing  platforms.  The  Ministry  of 
Economy has progressed in promoting the “Made in Ukraine” policy instruments to shift from a raw 
materials-based  economy  to  a  processing  economy  by  developing  production,  attracting  investment 
into the real sector, and promoting manufactured exports.  

Ukrainian  legislation  on  remedies  for  late  payment  is  still  not  aligned  with  the  Late  Payment 
Directive on combating late payment in commercial transactions. 

On  sectoral  policies,  Ukraine  has  intensified  its  focus  on  the  critical  raw  materials  sector. 
Institutional  and  regulatory  frameworks  have  significantly  evolved,  with  strengthened  roles  for  the 
responsible ministries. The State Service of Geology and Subsoil became an active participant in the 
European  Raw  Materials  Alliance  and  the  European  Battery  Alliance,  marking  Ukraine’s  deeper 
integration into EU CRM ecosystems.  

Chapter 25 – Science and research 

The EU provides significant support for research and innovation ecosystem. All Member States can 
participate in the EU’s research and innovation programmes and benefit from them, especially where 
there is scientific excellence and solid investment in research and innovation. 

Due  to  the  war,  the  continued  destruction  of  infrastructure  and  human  capital,  has  exacerbated  the 
long-term trend of underinvestment in research and innovation, with public investment in science and 
innovation kept at a minimum level. 

According  to  the  European  innovation  scoreboard  2025,  Ukraine  is  regarded  as  an  Emerging 
Innovator, performing at 29% of the EU average. The gap between Ukraine and EU is widening. 

Spending on research and development remains low standing at 0.37% of GDP in 2024. 

The  law  on  the  support  of  research  activity  in  higher  education  institutions  was  signed  on 
8 April 2025.  The  law  is  aimed  at  aligning  with  Art.  431  of  the  Association  Agreement  between 
Ukraine  and  EU,  improving  performance  of  research  activity  and  enhancing  quality  of  higher 
education. Ukraine introduced a new methodology for assessing research institutions in 2024, with the 
goal  of  building  an  effective  system  for  managing  a  network  of  research  and  higher  education 
institutions through performance-based funding. 

The  strategy  for  the  digital  development  of  innovation  in  Ukraine  until  2030  (WINWIN  Strategy), 
aiming  to  align  with  the  EU  policy  agenda  in  the  field  of  research  and  innovation,  was  adopted 
December 2024.  

Cooperation between science and business is underdeveloped, and the level of commercialisation of 
and spending on research results from private sources remains limited.  

As  regards  the  EU  framework  programmes,  Ukrainian representatives  are  engaged in  14  Horizon 
Europe  Programme  Committees  and  a  national  network  of  22  national  contact  points  covers  18 
thematic areas of the programme.  

In total, 225 Ukrainian institutions and organisations participate in Horizon Europe projects. 

The Ministry of Education and Science created a working group in January 2025 to gather input from 
the  scientific  community  to  the  development  of  an  updated  national  ERA  Roadmap  for  the  period 
2025 – 2027. To enable comprehensive integration in the ERA, inter-agency cooperation needs to be 

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further developed. 

Ukraine created a temporary advisory body for implementation of smart specialisation in November 
2024 and regional S3 teams have been created.   

Chapter 26 - Education and culture 

The  EU  supports  cooperation  in  education  and  culture  through  funding  programmes  and  the 
coordination  of  Member  State  policy  through  the  ‘open  method  of  coordination’.  The  EU  and  the 
Member States must also prevent discrimination and ensure quality education for children of migrant 
workers, including those from disadvantaged backgrounds. 

On  education  and  training,  Ukraine  needs  to  further  improve  the  collection  and  use  of  statistical 
data.  The  Ministry  of  Education  and  Science  (MOES)  published  in  2025  the  report  on  the 
implementation of its Annual Operational plan for 2024. In September 2024, the MOES adopted the 
Action Plan for Education Restoration (2024–2027), planning to rebuild educational institutions and 
prepare  human  resources  for  post-de-occupation  education.  Ensuring  quality  education  for  all 
children,  in  particular  near  the  front  line  and  in  temporary  occupied  territories,  including  inclusive 
education, remains challenging. 

On preschool education, the new law came into force in January 2025 and most of the implementing 
legislation has been adopted. This law introduces significant changes aimed at improving the quality, 
accessibility,  and  inclusivity  of  early  childcare  and  preschool  education  for  children  0-6,  including 
children with disabilities and other groups of children in need. 

In October 2024, Ukraine approved the conceptual framework for the reform of specialised secondary 
education  (Academic  Lyceums)  as  part  of  the  optimisation  process  for  the  general  secondary 
education. Ukraine should continue this process at national and local levels ensuring the sustainability 
and quality of education. 

On secondary education, the new Ukrainian school reform continued and in 2024 Ukraine extended 
the certification of primary school to mathematics, Ukrainian language and literature, and history. In 
2024,  the  State  Standard  for  Specialised  Secondary  Education  for  10th-12th  grades  was  approved, 
introducing flexibility in subject choices, educational trajectories, and the integration of disciplines. In 
February 2025, Ukraine amended the law on complete general secondary education allowing for the 
recognition  of  the  results  of  studies  of  Ukrainian  children  who  are  abroad  due  to  Russia’s  war  of 
aggression against Ukraine and had received education. Ukraine did not take part to the Teaching and 
Learning International Survey (TALIS 2024) yet it will join TALIS+, the 2026 administration of the 
survey. Ukraine is participating to PISA 2025. 

The issue of national minorities in education will continue to be monitored as part of Chapter 23 on 
judiciary and fundamental rights. 

In August 2025, Ukraine adopted a new law on vocational education and training (VET). Ukraine 
adopted the law on the national qualifications system and  continued with the referencing process of 
the  National  Qualifications  Framework  with  the  European  Qualifications  Framework.  Ukraine 
presented  a  state  of  play  in  referencing  in  2025.  As  of  October  2024,  dual  education  is  being 
implemented in 176 VET institutions across 87 working professions. In June 2025, Ukraine submitted 
the national commitment to become a member of the European Alliance for Apprenticeships (EAfA), 
through which Ukraine will implement measures that align with the 2018 Council Recommendation 
on a European Framework for Quality and Effective Apprenticeships. 

On higher education, in October 2024, Ukraine adopted a resolution on the awarding of professional 
qualifications  by  higher  education  institutions  if  professional  standards  are  absent.  Ukraine  has 
adopted  the  strategy  for  the  development  of  higher  education  but  has  yet  to  adopt  its  operational 
implementation  plan  for  2025-2028.  Currently,  35  higher  education  institutions  from  Ukraine 
participate  in  the  European  Universities  Alliances  as  associated  partners.  Ukraine  is  encouraged  to 
apply fully key commitments under the Bologna Process, notably in quality assurance. 

The rate of Roma children completion of compulsory education is significantly lower than that of the 

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general population. Particularly worrying is the situation of displaced children.  

On digital learning, as of January 2025, 306 digital learning centres had been set up in various regions 
of Ukraine. 

Ukraine  continued  to  benefit  from  the  international  dimension  of  the  2021-2027  Erasmus+ 
programme.  In  2024,  3 192  Ukrainian  students  and  staff  benefited  from  the  mobility  component  of 
Erasmus+. Ukraine is participating in all the European Education Area working groups 2021-2025. 

In order to fight corruption in education, an independent committee was created for the certification 
of textbooks, while online mechanisms for school enrolment were introduced. In 2025 a transitional 
model was introduced for the submission of investment projects on education infrastructure through 
the DREAM platform. 

On youth, on 5 June 2025, Ukraine adopted the law on the basic principles of youth policy. It has a 
National Youth Council and participates in the European Solidarity Corps. In April 2025, the city of 
Lviv inaugurated its nomination as European Youth Capital for 2025.  

On  sport,  Ukraine  continued  taking  part  in  the  European  Week  of  Sport.  In  May  2025,  Ukraine 
amended the law on physical culture and sports as far as adaptive sports are concerned.  

In March 2025, Ukraine approved the Strategy for the development of Ukrainian culture 2025-2030. 
Ukraine has ratified the 2005 UNESCO Convention on the Protection and Promotion of the Diversity 
of  Cultural  Expressions.  Since  December  2024,  Ukraine  has  participated  fully  in  both  culture  and 
media strands of the Creative Europe programme.  

Chapter 29 - Customs union 

All  EU  Member  States  are  part  of  the  EU  customs  union  and  follow  the  same  customs  rules  and 
procedures.  This  requires  legislative  alignment  as  well  as  adequate  implementing  and  enforcement 
capacity, and access to and interoperability with the EU electronic customs environment. 

As regards customs legislation, a new law which substantially aligns Ukrainian Customs Code with 
the  Union  Customs  Code,  entered  into  force  in  2025.  The  key  novelties  relate  to  customs 
representation,  authorisations,  placing  goods  under  a  customs  procedure,  presentation  of  goods, 
temporary storage, customs control (including post-clearance control), etc.  

In August 2025, the Cabinet of Ministers approved the new Mid-term Plan of measures to achieve the 
objectives of customs reform within the framework of the National Revenue Strategy for 2024-2030. 
The  Plan  covers  key  areas  including  alignment  of  Ukraine’s  customs  legislation  with  the  EU, 
strengthening  law  enforcement  and  anti-corruption  measures,  institutional  and  IT  development, 
international  cooperation,  and  support  for  business.  Overall,  it  reflects  EU  recommendations 
identified over the past year. 

The  use  of  the  common  transit  procedure  was  further  expanded.  Ukraine  continues  to  be  an  active 
Contracting Party of the Common Transit Convention and has made good progress in updating the IT 
system  to  the  latest  NCTS6  phase.  In  the  Q2  of  2025,  the  SCS  processed  nearly  34 000  transit 
declarations under the NCTS, compared to 25 500 in the Q2 of 2024. 

The number of authorised economic operators (AEO) increased to 100 by 31 August 2025 from 50 in 
the same period of 2024, with 5 operators granted both the AEO Security and Safety status and the 
Customs  Simplification  status.  Further  progress  is  required  at  the  national  level  to  start  proceeding 
with the negotiation on mutual recognition of AEO with the EU. 

On customs digitalisation, the technical specifications for the new Customs Clearance System were 
developed to align with EU standards. They also include enhanced functionalities such as export and 
import  systems,  centralised  clearance,  and  a  new  risk  management  system  compliant  with  EU 
requirements. 

A new automated customs clearance system for national use was deployed at all road border crossing 
points.  A  customs  decision  system,  equivalent  to  the  European  customs  decisions  system,  was 
introduced  to  process  applications  on  AEO  authorisations  and  authorisations  for  simplifications, 

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including transit. However, the processes are not supported with adequate human and IT resources. 

On administrative capacity building, in line with the provisions of the National Revenue Strategy 
for 2024-2030, the law reforming the SCS, which introduces a new procedure for the selection of its 
head,  a  re-certification  of  customs  employees  and  an  annual  performance  audit,  was  adopted  in 
September  2024.  However,  its  implementation  has  experienced  delays.  After  such  delays,  the 
selection process for the Head of the SCS has started, following the Cabinet of Ministers’ approval of 
the Advisory Group of Experts tasked with conducting the procedure. 

Ukraine needs to scale up efforts to address corruption within the customs administration. The number 
of disciplinary actions against customs officers increased in 2024, however their uneven geographic 
distribution shows a large disparity in enforcement efforts. The customs authority should be granted at 
the  national level  with  adequate enforcement  powers  and  have  a capacity  to  be  directly  engaged in 
intelligence  gathering  activities  and  contribute  to  pre-trial  investigation  in  cases  of  smuggling  of 
goods. 

CLUSTER 4: THE GREEN AGENDA AND SUSTAINABLE CONNECTIVITY 

This  cluster  covers:  transport  policy  (Chapter  14);  energy  (Chapter  15);  Trans-European  networks 
(Chapter 21); and environment and climate change (Chapter 27). 

Chapter 14 - Transport policy 

The EU has common rules on technical and safety standards, security, social standards, State aid and 
market liberalisation  in  road  transport,  railways,  inland  waterways,  multimodal  transport,  aviation 
and maritime transport. 

In the transport sector, the national transport strategy for the period until 2030 and the Strategy for 
developing and expanding the border infrastructure with the EU Member States and the Republic of 
Moldova until 2030 were adopted at the end of 2024. Ukraine needs to focus on the implementation 
to  make 
of 
progress  in  decarbonisation  of 
road  transport,  and  promote 
higher uptake of the alternative 
fuels and infrastructure. 

the  Strategies, 

In road transport, while some 
steps  toward  alignment  with 
EU standards have taken place, 
regulatory 
and 
legislative  enactments  need  to 
continue. 
prompt 
The 
alignment  with  social  and 
market rules for road transport, 
as well as with the road safety acquis, is key. Good progress has been made on the smart tachograph 
acquis. In April 2025, the road transport agreement to temporarily liberalise bilateral and transit road 
transport  between  the  EU  and  Ukraine  was  extended  until  31 December 2025.  In  December  2024, 
Parliament adopted the ratification of the Interbus Protocol on international regular and special regular 
carriage  of  passengers  by  coach  and  bus,  which  entered  into  force  for  Ukraine  on  1 May 2025  and 
aims  at  harmonising  the  conditions  for  the  performance  of  the  international  carriage  of  passengers 
with EU standards. 

reforms 

In  rail  transport,  Ukraine  needs  to  align  with  the  EU  rail  safety  and  interoperability  acquis  and 
prepare for the adoption of new legislation on railway transport to create legislative conditions for the 
functioning of a competitive market for passenger and freight transportation, including setting up the 
required institutional framework (independent regulatory body, independent national safety authority 
and  investigating  body,  and  separation of infrastructure management from rail transport  operations) 
that will enable the implementation of the future rail legislation. 

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In  maritime  transport, progress in  harmonising legislation  with  EU maritime principles,  including 
port  state  control  and  vessel  traffic  monitoring,  has  been  minimal.  The  sector  struggles  with 
regulatory  compliance  and  safety  standards.  Ukraine  is  partially  aligned  with  the  Port  Services 
Regulation.  

The development and implementation of  inland waterway transport regulations and directives are 
ongoing, aiming to increase navigation safety and market functionality. Ukraine’s engagement in the 
EU  Strategy  for  the  Danube  Region  and  bilateral  agreements  with  riparian  states  reflect  efforts  to 
facilitate inland navigation. The process of granting recognition of the certificates, record books and 
logbooks  in  inland  waterways  issued  by  Ukraine  is  ongoing  as  well  as  the  connection  to  European 
Crew  Database.  To reduce  security  risks, to  guarantee  sufficient capacity and  to  provide alternative 
transport  options  for  Ukraine’s  export  and  import,  a  contingency  plan  for  Danube  route  has  been 
adopted.  

Ukraine has not yet aligned with the Combined Transport Directive. 

On  passenger  transport,  Ukraine  has  to  make  efforts  to  align  its  legislation  with  EU  rules  on 
organisation  and  financing  the  public  service  obligations  (PSO)  in  transport  and  EU  rules  on 
passenger  rights,  notably  in  the  fields  of  rail,  bus  and  coach,  as  well  as  of  rights  of  persons  with 
disabilities and reduced mobility. 

Civil air transport remains grounded due to airspace closure. While regulatory alignment with EU 
aviation  rules  is  in  progress,  the  revision  of  the  EU-Ukraine  Common  Aviation  Area  Agreement 
transposition  list  has  not  yet  been  addressed.  Ukraine  is  partially  aligned  with  the  Air  Services 
Regulation,  as  well  as  the  Insurance  Regulation.  Regarding  the  EU  airport  acquis,  Ukraine  should 
make  efforts  to  align  its  legislation  with  EU  rules  on  slot  allocation  (notably  regarding  the 
establishment of an independent slot coordinator), as well as on airport charges and ground handling. 

The national railway company continued to struggle with several episodes of corruption, particularly 
in procurement. The government dismissed and appointment the company’s executives, despite new 
legislative measures attributing this power to the supervisory board. The publication of information on 
road  infrastructure  projects,  foreseen  under  the  State  Anti-Corruption  Programme,  is  facing  some 
delays. 

Chapter 15 – Energy 

EU  energy  policy  covers  energy  supply,  infrastructure,  the  internal  energy  market,  consumers, 
renewable energy, energy efficiency, nuclear energy, nuclear safety, radiation protection and nuclear 
safeguards.  

In terms of  security of supply, commercial electricity export capacity from the EU to Ukraine was 
increased  to  up  to  2.1  GW  from  December  2024  until  March  2025.  Together  with  250 MW  of 
emergency  capacity,  this  helped  balancing  Ukraine’s  energy  system  over  the  winter.  In  December 
2024, Ukraine adopted implementing legislation on oil stocks. Alignment with the risk preparedness 
Regulation  in  the  electricity  sector  and  gas  security  of  supply  Regulation  is  still  pending.  Ukraine 
signed agreements on firm capacity for gas with Poland (imports) and Moldova (import/exports) and 
increased its firm capacity for gas imports with Hungary and Slovakia. 

On the internal energy market, there has been little progress in aligning legislation with the EU’s 
third energy package as relates to the electricity sector. The electricity integration package, which is 
key for full electricity market coupling, is pending adoption by Parliament. Day-ahead, intraday and 
balancing  markets  continue  to  operate  under  price  caps.  The  energy  regulator,  the  National  Energy 
and Utilities Regulatory Commission (NEURC), increased day-ahead and intraday price-caps by more 
than 60% in July 2025. Ukraine needs to continue the gradual phase-out of wholesale electricity price 
caps  in  all  market  segments.  The  debts  on  the  balancing  market  remain  high.  In  December  2024, 
Ukraine increased network tariffs for the transmission of electricity for 2025 by 29%. However, tariffs 
are  still  insufficient  for  investments  and  maintenance  needed  for  energy  and  climate  reforms.  The 
implementation  of  the  network  codes for electricity is incomplete, in  particular  in  areas  of  capacity 
allocation and congestion management. In the coming period, Ukraine needs to adopt changes to the 

80 

 
 
indirect taxation of energy market participants. 

A  number  of  legislative  amendments  to  the  Law  on  the  natural  gas  market  and  Law  on  electricity 
market have been introduced to improve the requirements for wholesale energy players. These include 
stricter  obligations  regarding  the  publication  of  inside  information,  strengthened  mechanisms  to 
prevent market abuse and revised penalty structures for violations.  

The  tariff  for  gas  transmission  has  raised  nearly  four  times  during  the  reporting  period.  However, 
overall, gas market reforms including gradual phase-out of PSO and lifting the export ban on natural 
gas remain an important priority for Ukraine in view of alignment with EU rules and (re)establishing 
a competitive market. Phasing out of price caps and public service obligations should go hand in hand 
with setting up a financing mechanism for vulnerable customers. 

Ukraine  finalised  the  nomination  of  three  commissioners  of  the  energy  regulator  NEURC.  Despite 
certain progress, the independence of NEURC needs further strengthening. 

In the area of renewable energy, Ukraine started implementing its 2030 national energy and climate 
plan. However, most of Ukraine’s renewable energy auctions failed to attract investors, indicating a 
need to recalibrate auction design and address systemic issues in the Ukrainian electricity market. In 
June 2025, Ukraine adopted a roadmap for the separation of the renewable energy surcharge from the 
tariff  for  electricity  transmission  services,  and  an  action  plan  to  implement  it  in  2025  and  2026. 
Alignment  with  EU  sustainability  and  greenhouse  gas  emission  criteria  for  biofuels,  bioliquids  and 
biomass remains incomplete. Regulatory progress on biomethane enabled the first biomethane exports 
to the EU in February 2025. In the coming period, Ukraine needs to increase alignment with the EU’s 
renewable legislation including full alignment with RED II Directive, and address key gaps, such as 
resolving  the  debt  issue  and  simplifying  permitting  rules.  Ukraine  has  operationalised  an  electronic 
registry for guarantees of origin for electricity. 

Ukraine’s  energy  efficiency  legislation  is  broadly  aligned  with  the  EU’s  Energy  Efficiency  and 
Energy  Performance  of  Buildings  Directives.  During  the  reporting  period,  Ukraine  took  steps  to 
further  implement  the  Law  on  energy  efficiency  and  to  operationalise  its  framework.  Nevertheless, 
effective implementation requires further secondary legislation and better harmonisation with related 
policies  such  as  housing.  Strengthening  monitoring  systems,  enforcing  high  energy  efficiency 
standards,  and  embedding  the  “energy  efficiency  first”  principle  into  recovery  efforts  remain 
necessary. Institutional capacity and inter-agency coordination must be improved. Progress remained 
limited  on  mandatory  energy  efficiency  criteria  in  public  procurement  and  incentives  for  high-
efficiency  district  heating  and  cogeneration.  In  the  building  sector,  Ukraine  has  advanced  on  the 
alignment  with the  2018  Energy  Performance  of  Buildings  Directive  (EPBD).  However,  significant 
additional  work  will  be  required  to  transpose  the  2024  EPBD.  Limited  administrative  capacity 
remains  a  major  barrier  to  advance  on  legislation  and  ensure  adequate  enforcement.  The  Energy 
Efficiency  Fund  continued  to  support  renovations  but  will  require  sustained  state  funding  beyond 
2026.  Moreover,  the  government  still  needs  to  modernise  district  heating,  improve  energy  use  in 
public buildings, and strengthen public procurement standards. 

On governance, Ukraine has put in place a monitoring framework for its national energy and climate 
plan (NECP) and, on 15 March 2025, timely submitted its first implementation report. Key challenges 
for  implementing  the  NECP  are  limited  funding,  insufficient  administrative  and  human  resources, 
lack  of  data,  restricted  access  to  data,  and  weak  coordination  across  government  institutions.  An 
NECP revision taking due account of the recommendations of the Energy Community Secretariat is 
due at the end of 2025. On governance based on OECD standards in state-owned energy companies, 
challenges  remain.  The  supervisory  boards  of  the  gas  transmission  system  operator  (GTSOU)  and 
Ukrenergo have been completed, while Energoatom and Ukrhydroenergo remain with an incomplete 
supervisory  board.  The  CEOs  of  Naftogaz  and  Ukrenergo  were  appointed  based  on  competitive 
selection  processes,  however,  Energoatom,  Ukrhydroenergo  and  GTSOU  are  without  a  permanent 
CEO. Qualified majority voting mechanisms, which were introduced in  the charters of main energy 
companies,  including  Ukrenergo,  GTSOU,  Energoatom  and  Ukrhydroenergo  raised  concerns  about 
the  independent  decision-making  of  supervisory  boards  as  regards  CEO  appointments  and  strategic 
decisions.  In  June  2025,  Ukrenergo’s  charter  was  revised,  but  not  those  of  other  SOEs.  Political 

81 

 
 
influence over the management of energy SOEs should be addressed through effective separation of 
their management from policymaking. In 2024, energy was among the top three sectors in terms of 
high-level corruption cases, with several instances of procurement fraud, energy misappropriation and 
prices  manipulation  investigated  by  law  enforcement.  In  March  2025,  the  Ministry  of  Energy 
approved an Anti-Corruption Programme for 2025-2027. It includes measures in the areas of human 
resources, financial control, prevention of conflict of interest, public procurement and management of 
financial and material resources. 

There  has  been  no  progress  in  aligning  Ukraine’s  legislation  on  nuclear  safety,  radioactive  waste 
management  and  radiation  protection  with  the  Euratom  acquis,  and  both  regulatory  capacity  and 
harmonisation efforts need to be strengthened. Ukraine should accelerate its efforts to fully align with 
Euratom  legislation  and  strengthen  the  institutional  stability,  efficiency,  and  independence  of  the 
nuclear  regulatory  authority.  In  December  2024,  Ukraine  adopted  a  new  National  Targeted 
Environmental Programme for Radioactive Waste Management. Moreover, in 2025 Ukraine indicated 
its  readiness  and  took  further  steps  to  join  the  ECURIE  system.  Preparations  for  nuclear  unit 
decommissioning stalled, despite commitments in the NECP. Energoatom’s Supervisory Board needs 
to  be  completed  as  a  priority.  In  March  2025,  Ukraine  submitted  its  8th  National  Report  under  the 
Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste 
Management.  

Chapter 21 - Trans-European networks 

The EU promotes Trans-European networks (tens) in the areas of transport, telecommunications and 
energy to strengthen the internal market and contribute to growth and employment. 

With the adoption of the national transport strategy for the period until 2030, Ukraine has paved the 
way for the integration of its transport system into the trans-European transport network (TEN-T), 
including  on  the  TEN-T  corridors  which  have  been  extended  to  the  country.  While  continuing  on 
emergency repairs, restoring lifeline connections, and developing connections with Danube ports, EU 
Member States and Moldova under the EU-Ukraine Solidarity Lanes initiative, a comprehensive plan 
to introduce European standard gauge railway lines in Ukraine is in the making and the new 22 km 
European  standards  gauge  rail  between  Chop  and  Uzhhorod  are  operational  since  summer  2025. 
While Ukraine is progressing well with implementation of rail projects, more efforts should be done 
to ensure timely implementation of road border crossing points. Ukraine has started building upon the 
Single  Public  Investment  Projects  Portfolio  to  develop,  prioritise  and  submit  public  investment 
projects in transport. However, the administrative capacities and project preparation still need to be 
significantly  strengthened  to  speed  up  the  EU-backed  projects  and  encourage  smooth  and 
interoperable cross-border connectivity in alignment with EU TEN-T acquis, especially in technical 
standards,  decarbonisation  and  digitalisation,  which  still  remain  a  major  challenge.  In  December 
2024, Ukraine adopted the Strategy for developing and expanding the border infrastructure with the 
EU Member States and the Republic of Moldova until 2030.  

Ukraine  needs  to  prioritise  and  develop  the  future  investments,  focusing  on  the  TEN-T,  remove 
current bottlenecks, making sure that all investments are fully coordinated with relevant EU Member 
States  and  complemented  by  other  funding  sources.  These  priorities  should  be  also  reflected  in  the 
Single  Project  Pipeline.  It  is  very  important  that  Ukraine  develops  the  network  in  parallel  to  the 
implementation of reforms. 

As regards the trans-European energy network (TEN-E), Ukraine has not yet aligned its legislation 
with  the  revised  TEN-E  Regulation  2022/869.  Other  priorities  for  Ukraine  are  the  deployment  of 
energy  storage  capacities  and  smart  grids  as  well  as  the  development  of  hydrogen/biomethane 
infrastructure  including  reverse  flow  compressors,  to  integrate  greater  volumes  of  low-carbon  and 
renewable  gases.  Electricity  interconnection  projects  with  Slovakia  and  Romania,  which  aim  to 
enhance import/export potential, are advancing. Ukraine is at an early phase of developing hydrogen 
projects  including  the  generic  hydrogen  corridor  between  Ukraine,  Austria,  Czechia,  and  Germany, 
which is a priority corridor on the list of projects of common interest and projects of mutual interest 
(PCI/PMI). 

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Chapter 27 - Environment and climate change 

The EU promotes strong climate action, sustainable development and protection of the environment. 
EU rules contain provisions addressing horizontal environmental issues, climate change, water and 
air  quality,  waste  management,  nature  protection,  industrial  pollution,  chemicals,  noise  and  civil 
protection. 

Continued efforts are needed to fully align with EU environmental and climate acquis and gradually 
put in place a sound mid-term budgetary framework related to its implementation. This should be also 
accompanied  by  the  introduction  of  sustainable  finance  standards  (Environment  and  Social 
Governance).  Major  concerns  related  to  the  ability  of  Ukraine  to  follow  up  on  further  necessary 
alignment  and  proper  implementation  of  the  EU  acquis  in  environment  and  climate  are  limited 
administrative  capacity,  funding  constraints,  and  delayed  adoption  of  legislation.  Strengthening 
capacity, cross-sectoral integration and mobilisation of investments are essential for effective policy 
implementation  and  green  reconstruction.  Continuous  lack  of  administrative  capacity  is  putting 
further  strains  on  the  ability  of  Ukraine  to  follow  up  on  necessary  alignment  and  proper 
implementation  of  the  EU  acquis  in  environment  and  climate.  While  digitalisation  in  the 
environmental  sector  is  progressing,  further  efforts  are  required  to  improve  enforcement,  prevent 
corruption, and ensure accountability, particularly by enhancing environmental compliance assurance, 
monitoring and data collection, and governance structures. 

Ukraine’s horizontal environmental legislation remains only partially aligned with the EU  acquis. 
During the reporting period the main development was the ratification of amendments to the Aarhus 
Convention. Ukraine developed a concept note on the scope of deviations from environmental impact 
assessments  (EIAs)  and  Strategic  Environmental  Assessments  (SEAs).  However,  further  efforts  are 
needed to ensure full application of EIAs and SEAs across all relevant plans and projects, including 
reconstruction efforts, and to  ensure limited exemptions in line with the EU  acquis. Introduction of 
general  exemptions  and  exclusion  of  entire  project  categories  from  assessments,  in  particular  for 
forestry  and  agriculture,  should  be  avoided.  The  exclusion  of  EIA  requirements  from  the  amended 
administrative  procedure law  remains  problematic.  Although  electronic registries  exist,  civil  society 
continues  to  report  limited  access  to  EIA  and  SEA  documentation.  Transboundary  EIA  and  SEA 
procedures also require practical implementation. 

Environmental monitoring legislation is only partially aligned with the EU acquis. The martial law 
has delayed enforcement, although several implementing acts were approved between October 2024 
and February 2025, with postponed entry into force after the martial law ends. Progress was made in 
digitalising  environmental  services  and  databases.  The  Law  on  the  National  Register  of  Pollutant 
Emissions and Transfers has been implemented since 2023. However, supporting network such as the 
Aarhus  Centre  remains  underfunded,  undermining  its  potential  in  facilitating  public  access  to 
environmental information. Ukraine needs to further improve the quality of environmental data by 
improving  the  capacity  and  upgrading  the  monitoring  network,  including  via  improved  cooperation 
with relevant existing EU-wide information systems, and ensure broader access and transparency to 
meet EU standards. 

Alignment  on  environmental  liability,  crime,  and  control  legislation  is  incomplete.  Criteria  for 
environmental  inspections  were  updated  in  October  2024,  but  the  moratorium  on  inspections  under 
martial law hampers implementation. No progress was recorded in aligning with the EU acquis. The 
strategy until 2029 to reform environmental control and the action plan for 2025–2027 were adopted 
in  June  2025.  Anti-corruption  mechanisms,  including  Prozorro  procurement  (a  public  electronic 
procurement system) and a specialised environmental prosecutor’s office, are in place, but corruption 
risks  remain  high,  notably  in  land  use,  extraction  of  minerals,  illegal  logging,  waste  and  hazardous 
waste  management,  permits  and  tenders  for  concessions,  while  enforcement  remains  weak. 
Amendments to the Civil Code may further legalise ownership of lands that were privatised illegally, 
raising serious concerns. 

Air quality legislation remains partially aligned. The government adopted procedures in March 2025 
for  notifying  the  public  and  monitoring  air  quality.  Full  compliance  will  require  further  steps, 
including  national  emission  ceilings,  monitoring  of  volatile  organic  compounds  emissions,  better 

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sulphur content monitoring, and improvements in air quality data collection. 

On  waste  management,  progress  included  the  adoption  of  the  National  Waste  Management  Plan. 
Adoption of a circular economy strategy and action plan in 2026, as well as development of regional 
and  local  waste  management  plans  will  advance  strategic  prioritisation  and  planning.  Nevertheless, 
practical implementation and enforcement will require a framework and infrastructure to fully align 
with  the  provisions  of  the  waste  framework  Directive  and  other  relevant  legislation.  Ukraine  needs 
also to ensure proper management of construction and demolition waste, mining waste and hazardous 
waste,  address  extended  producer  responsibility,  packaging  waste,  single  use  plastics,  batteries  and 
electric and electronic equipment waste, and the compliance of existing landfills. The adopted waste 
management  legislation,  including  on  permitting,  must  comply  with  the  EU  acquis  and  avoid 
extensive use of derogations. 

On  water  quality,  legislation  remains  only  partially  aligned,  however  the  implementation  of  the 
Water  Framework  Directive  has  advanced.  All  river  basin  management  plans  were  adopted  and 
should be integrated into reconstruction programmes, such as the state programme for water sewage 
and  treatment  companies,  with  its  concept  adopted  in  February  2025.  However,  administrative 
capacity, lack of funding, and incomplete alignment with directives on nitrates, drinking water, and 
wastewater continue to impede implementation. Measures to ensure cost recovery while safeguarding 
access to water and sanitation rights are still needed. 

Alignment of nature protection legislation with the EU acquis is at an early stage. Ukraine started 
preparing a national biodiversity strategy during the reporting period, but it still needs to be finalised 
and  adopted.  Preparatory  work  started  on  a  strategy  for  ecosystem  services  and  invasive  species 
classification. Although a biodiversity monitoring procedure was adopted in January 2025, its entry 
into force is delayed until martial law is lifted. Further alignment is needed on EU rules on wild birds, 
habitats, Natura 2000, biosafety, zoos, and genetic resources. Stronger involvement from agriculture, 
forestry,  and  fisheries  sectors  is  essential.  Concerns  persist  about  construction  projects  encroaching 
into protected areas. Progress was made with pilot projects on timber certification and draft legislation 
to align with the EU Deforestation Regulation and amending the Forest Code. 

Industrial pollution and risk management legislation are only partially aligned. Parliament adopted 
a law on integrated industrial pollution prevention, and some implementing legislation was approved. 
Full  alignment  with  the  EU  Industrial  Emissions  Directive  still  requires  additional  secondary 
legislation and proper implementation. Efforts to adopt the EU Eco-Management and Audit Scheme 
and EU Ecolabel Regulations are needed. 

Chemical  safety  legislation  is  partially  aligned.  Several  implementing  decisions  to  the  Law  on 
chemical  safety  have  been  adopted,  such  as  procedures  for  documenting  environmental  checks  and 
criteria for risk assessments, but enforcement remains a challenge due to the war. Although legislation 
banning  asbestos  exists,  Ukraine  needs  to  implement  asbestos  management  rules,  set  up  certified 
laboratories and create a registry of landfills licensed to handle asbestos, as part of wider approach to 
hazardous waste management. 

No progress was made during the reporting period on aligning noise legislation with the EU acquis. 

On civil protection, Ukraine is an active participant in the EU Civil Protection Mechanism. Ukraine 
is  contributing  to  further  strengthening  the  European  Civil  Protection  Pool.  Crisis  coordination  has 
improved  and  nationwide  exercises  were  organised  to  prepare  for  regional  blackouts  during  the 
2024/2025 winter. As a member of UCPM, Ukraine has access to scientific partnerships through the 
Emergency  Response  Coordination  Centre  (ERCC),  as  well  as  to  early-warning  tools  and  is 
encouraged  to  make  use  of  them.  However,  further  strengthening  of  disaster  legislation  and  cross-
border cooperation is needed. 

Climate change  

Ukraine  made  good  progress  on  climate  change.  In October  2024, it  adopted  a  framework  law  for 
state  climate  policy  aligned  with  the  EU’s  2050  climate  neutrality  target.  A  draft  second  nationally 
determined contribution is in preparation ahead of the UNFCCC/COP30. Ukraine is yet to update its 

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long-term low-emission development strategy to reflect its 2050 climate neutrality goal and to submit 
its first  Biennial  Transparency  Report  under  the  Paris  Agreement.  Mandatory monitoring,  reporting 
and  verification  (MRV)  of  greenhouse  gas  emissions  at  installation  level  was  restored  in  February 
2025 (with some exceptions related to military operations). Ukraine’s MRV-system remains narrower 
than the EU Emissions Trading System (ETS) and further work is needed for full alignment with EU 
standards,  including  to  cover  aviation,  shipping,  road  transport  and  buildings.  Ukraine  approved  a 
national ETS action plan in February 2025 aiming to start operating a national ETS by 2028. The draft 
law  ratifying  the  Kigali  Amendment  has  been  pending  in  Parliament  since  February  2025.  Further 
efforts are also required to align with the EU standards on ozone-depleting substances and fluorinated 
gases and emission standards for road vehicles. 

The  NECP  needs  to  be  updated  by  end  of  2025.  Stronger  integration  of  the  NECP  into  national 
planning is necessary. Progress was made with the adoption of methodological guidelines on climate 
mainstreaming (October 2024), the strategy for agriculture and rural development promoting climate-
smart  agriculture  (November  2024),  ongoing  efforts  in  sustainability  reporting  and  SME  green 
transition and adoption of the action plan for environmental security and climate change adaptation 
(February 2025). 

CLUSTER 5: RESOURCES, AGRICULTURE AND COHESION 

This  cluster  covers:  agriculture  and  rural  development  (Chapter  11);  food  safety,  veterinary  and 
phytosanitary  policy  (Chapter  12);  fisheries  and  aquaculture  (Chapter  13);  regional  policy  and 
coordination of structural instruments (Chapter 22); and financial and budgetary provisions (Chapter 
33). 

Chapter 11 - Agriculture and rural development 

The EU’s common agricultural policy supports farmers and ensures Europe’s food security. It helps 
tackle  climate  change  and  the  sustainable  management  of  natural  resources;  preserves  rural  areas 
and landscapes; and supports the rural economy by promoting jobs in farming, agri-food industries 
and related sectors. This requires robust management and control systems. There are also common 
EU rules for marketing standards, quality policy and organic farming. 

On horizontal issues, the national strategy for agriculture and rural development to 2030 was adopted 
in  November  2024.  Its  detailed  operational  action  plan  was  updated  in  August  2025  to  ensure 
alignment of key priorities with the common agricultural policy. From 2025 registration in the State 
Agrarian Register (SAR) has become a mandatory requirement to access any form of state agricultural 
support.  SAR  will  support  the  development  of  the  integrated  administration  and  control  system 
(IACS) A law establishing the framework for the paying agency, the IACS and the farm sustainability 
data network (FSDN) is pending adoption by Parliament. 

The  implementation  of  the  FADN  is  piloted  in  the  Poltava  and  Zhytomyr  regions,  in  line  with  EU 
acquis.  Ukraine  should  proceed  with  the  establishment  of  an  IACS  including  the  land  parcel 
identification system (LPIS). Inter-operability of the various elements comprising the IACS should be 
ensured.  Preparatory  steps  for  creating  an  agricultural  knowledge  and  innovation  system  have  been 
taken. The advisory services will need to be strengthened. 

On  agricultural  markets  -  common  market  organisation,  legislative  alignment  has  continued,  in 
particular  for  marketing  standards.  A  law  on  hops  and  hop  products  was  adopted  in  March  2025 
aligning  to  the  EU  acquis.  Ukraine  continues  the  establishment  of  a  vineyard  register  and  the 
development of a new viticulture zoning. 

On rural development, the strategy for agriculture and rural development to 2030 and its 2025-2027 
operational plan sets out rural development priorities. The long-term plan for irrigation development 
to  2050  was  adopted  in  March  2025,  starting  with  the  implementation  of  the  pilot  projects  in  the 
Odesa,  Mykolaiv,  and  Zaporizhzhia  regions.  Grants  are  available  for  the  development  of  orchards, 
berry crops, vineyards and greenhouse construction. 

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On  quality  policy,  legislative  alignment  with  the  EU  acquis  needs  to  continue  and  administrative 
capacity further strengthened to ensure control and enforcement. 

On organic farming, legislative alignment with the EU acquis needs to continue. A draft law to align 
with EU standards on organic production and labelling remains to be adopted. The monitoring and the 
control of organic production should be further developed. 

On  the  fight  against  corruption,  public  support  to  the  sector,  land  allocation,  valuation,  lease, 
taxation  and  digital  cadastre  services  remain  key  risk  areas.  The  Land  Bank  was  launched  as  a 
transparent rental marketplace for state-owned agricultural land, while the implementation of the SAR 
is expected to increase transparency in the distribution and administration of state aid to agricultural 
producers. New measures were introduced to counter illegal grain export. 

Chapter 12 - Food safety, veterinary and phytosanitary policy 

The EU food acquis including hygiene rules for foodstuff production ensures a high level of food and 
feed safety, and a high level of protection of consumers’ interests. Animal health and welfare, and the 
safety of food of animal origin, are  safeguarded together with the quality of seeds, plant protection 
material, the protection against harmful organisms and animal nutrition. 

On  general  food  safety,  the  State  Service  on  Food  Safety  and  Consumer  Protection  continued  its 
functional  reform  process  to  further  align  with  EU  standards.  Ukraine  has  yet  to  update  the 
multiannual  control  plan  to  2026,  incorporating  changes  in  legislation,  institutional  structures,  and 
food and animal health risks. The transparency principle should apply to the official control systems, 
and these should receive adequate financial resources for effective operation. A new draft law to align 
with the EU acquis on official controls still needs to be adopted. 

On  veterinary  policy,  animal  health legislation  in  Ukraine is  not  yet  aligned  with  the  EU’s  animal 
health  policy.  Ukraine  continued  to  align  its  system  with  the  EU  acquis  through  a  comprehensive 
reform process, including to align with EU disease categorisation and related control measures. The 
list  of  notifiable  animal  diseases  has  been  updated.  On  animal  welfare,  Ukraine  is  partially  aligned 
with  the  EU  acquis.  Implementation,  the  resources  needed  and  the  administrative  capacity  need 
substantial strengthening, including clear timelines for alignment and implementation. 

In  the  reporting  period,  the  EU  trade  control  and  expert  system  (TRACES)  became  operational 
countrywide. It currently covers 24 commodities, with over 36 000 certificates issued from September 
2024  to  July  2025.  Ukraine  ensured  EU  cofinanced  programmes  for  African  swine  fever,  avian 
influenza and rabies for the period 2025-2027. 

For the placing of food, feed and animal by-products on the market, implementing legislation was 
adopted with rules for products of animal origin and improved risk management. An EU compliant 
system  of  collection,  storage  and  processing  of  animal  by-products  is  not  yet  in  place.  Further 
implementing  capacity  remains  needed.  Import  controls  remain  only  partially  aligned  with  the  EU 
acquis. 

On food safety rules and its specific rules for feed, EU-registered feed additives are now accepted 
without  national  registration.  Ukraine  updates  its  monitoring  plan  regularly  and  participates  in  the 
Rapid Alert System for Food and Feed without full membership. 

On  plant  health  and  phytosanitary  policy,  Ukraine  made  progress  toward  alignment  with  EU 
legislation through a new law on plant health, adopted in December 2024 and which will enter into 
force  in  January  2028.  Until  then,  about  80  implementing  acts  still  need  to  be  adopted. 
Implementation  began  with  the  review  of  inspection  procedures  and  the  e-Phyto  exchange  system. 
Since  official  use  began  in  February  2025,  over  73 500  e-phyto  certificates  have  been  transmitted, 
including  more  than  58 000  to  the  EU.  To  empower  phytosanitary  inspectors  with  full  control 
authority,  strengthen  risk  assessment  capacity,  integrate  laboratories  into  the  control  system,  and 
finalise alignment of border control posts remain crucial to fully align the EU acquis in this area.  

In  the  area  of  genetically  modified  organisms,  Ukraine  adopted  several  pieces  of  implementing 
legislation,  which  will  enter  into  force  together  with  the  primary  GMO  law  in  September  2026.  A 

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comprehensive  assessment  of  the  national  legislation  has  been  carried  out  in  spring  2025,  to  close 
remaining gaps before the national law enters into force in September 2026. 

Chapter 13 - Fisheries and aquaculture 

The  common  fisheries  policy lays  down  rules  on  fisheries  management, protects  living resources of 
the sea and limits the environmental impact of fisheries. This includes setting catch quotas, managing 
fleet  capacity,  rules  on  control  and  inspection,  rules  on  markets  and  aquaculture  and  support  for 
fisheries and coastal communities. Further, it promotes a sustainable aquaculture. 

The  introduction in  2024  of  the  e-Fish system made  it  possible  to  digitalise the  resource and  fleet 
management.  A  ‘one-stop  shop’  principle  for  servicing  business  entities  has  been  established  to 
simplify  administrative  services,  including  for  obtaining  fishing  permits.  A  list  of  permitted  and 
prohibited  fishing  gears  was  created  in  line  with  European  standards.  Ukraine  has  also  introduced 
mechanisms to further regulate fishing areas and minimise the impact of fishing activities on sensitive 
habitats. However, e-Fish requires significant additional developments, including greater automation 
and full compatibility with the EU data collection, monitoring and reporting requirements. 

The lack of effective inspection, control and monitoring hampers Ukraine’s capacity to efficiently 
address illegal, unreported and unregulated fishing. The mechanisms to introduce full traceability of 
fishery  products  and  improve  consumer  information  has  been  partially  aligned with  the  EU  acquis. 
Ukraine  needs  to  complement  its  legal  framework  with  legislation  to  modernise  its  state  control 
system, including expanding the powers of regulatory authorities, allowing the e-Fish system to track 
violators of fisheries legislation, introducing financial penalties and procedures to bring illegal fishing 
perpetrators to justice. 

On  market  policy,  legislation  on  traceability  and  market  measures  need  to  be  developed  and 
introduced to align national standards with the EU acquis. 

Ukraine needs to finalise legislation on the collection and management of data in the fisheries and 
aquaculture sector and to develop the legal framework required to provide structural support to the 
sector in line with the relevant EU acquis.  

In  the  aquaculture  sector,  Ukraine  has  adopted  legislation  to  develop  investments  in  commercial 
aquaculture  farms.  Further  efforts  are  required  to  align  the  legal  framework  with  the  acquis  on 
sustainable aquaculture and permits for the use of alien species. 

On international agreements, Ukraine became a member of the Port State Measures Agreement in 
March 2025. Ukraine remains committed to become a full-fledged member of the General Fisheries 
Commission  for  the  Mediterranean  (GFCM),  for  which  legislation  has  been  adopted  in  July  2025. 
Ukraine continues to participate at regional level with an active stance in the works of the GFCM and 
the Common Maritime Agenda.  

Ukraine needs to create the legal framework for maritime spatial planning. 

Chapter 22 – Regional policy and coordination of structural instruments 

Regional policy is the EU’s main tool for reducing regional disparities and investing in sustainable 
and  inclusive  socio-economic  growth.  It  is  operating  through  ‘shared  management’  between  the 
Commission  and  EU  Member  States.  The  implementation  of  cohesion  policy  programmes  requires 
appropriate administrative capacity on programme and project level, the establishment of systems of 
sound financial management and control and also the fulfilment of other EU acquis elements such as 
environmental or public procurement legislation.  

Some progress has been made on legislative framework in facilitation of the regional development 
policy implementation and its funding. Notable steps have been taken with the adoption of the 2025-
2027 action plan for the implementation of the updated State Regional Development  Strategy 2024-
2027, which was developed in a participatory manner with inclusive public consultation. The action 
plan cross-references the measures and actions from Ukraine’s commitments with donors. The action 
plan could further integrate actions related to the ongoing public investment management reform, and 
a  comprehensive  approach  to  strengthening  the  financial,  technical  and  administrative  capacities  of 

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the regional and local government authorities to respond to the requirements of project preparation, 
management and execution. 

The law on principles of state regional policy still needs to be fully implemented. While progress has 
been made with the local-level strategic planning process, further efforts should be taken to streamline 
and  clarify  the  content  and  structure  of  local  strategic  documents,  to  facilitate  their  digitalisation 
through the Geographic Information System and to link them with adequate financing lines. 

The efforts aimed at simplifying current planning system for regional and local development policy 
should be fully aligned with the ongoing Public Investment Management reform. There should be a 
clear path with defined milestones toward the establishment of a coordinated and coherent system of 
planning which considers strategic, spatial and budgetary planning. 

For the first time since the beginning of Russia’s war of aggression, Ukraine has allocated funding in 
the 2025 state budget for the reactivation of the State Fund for Regional Development. The Ministry 
for  Development  of  Communities  and  Territories  has  initiated  the  changes  to  the  Budget  Code, 
updating  the  Fund’s  financing  principles,  and  has  adopted  the  temporary  methodology  for  the 
financing  distribution.  The  Fund  should  be  made  operational,  with  a  fully  developed,  permanent 
allocation  methodology  that  is  transparent,  efficient  and  aligned  with  recovery,  multi-level 
governance, and regional policy principles. 

Progress has been made in development of urban planning at the local level. Relevant resolutions by 
the Cabinet of Ministers have been adopted related to the urban planning cadastre. 

In terms of the institutional framework Ukraine should intensify the effort to complete the legal and 
regulatory  process  to  consolidate  the  State  Agency  for  Restoration  (SARDI)  as  a  transparent,  and 
accountable institution with a well-defined mandate and an adequate implementation capacity, as well 
as  its  internal  administrative  reform.  The  role  of  SARDI  in  supporting  local  self-government 
authorities  during  the  preparation  and  implementation  of  infrastructure  projects  also  needs  to  be 
clarified. 

At  central  level,  efforts  are  needed  to  set  up  the  legal  framework  of  the  partnership  principle, 
requiring  the  involvement  of  relevant  regional  and  local  authorities,  public  authorities,  socio-
economic  partners  and  civil  society  in  all  programming  stages,  preparing  the  ground  for  future 
cohesion policy in line with the European Code of Conduct on Partnership. 

On  administrative  capacity,  Ukraine  has  appointed  the  Deputy  Prime  Minister  for  Restoration  of 
Ukraine  –  Minister  for  Development  of  Communities  and  Territories  as  the  chair  of  the  Inter-
ministerial Coordination Commission, taking a step to re-activating the regional policy coordination 
framework.  To  facilitate  fully  regional  development,  modernisation  and  inclusive  engagement  of 
regional  and  local  stakeholders,  capacity  building  is  needed  for  national,  regional  and  local 
administrations to conduct strategic planning and to prepare and implement projects. 

On  programming,  monitoring  and  evaluation,  the  Ukraine  Facility  requirement  for  allocation  of 
financing  to  the  recovery,  reconstruction  and  modernisation  needs  of  Ukraine’s  sub-national 
authorities, in particular local self-government, should be implemented in line with the principles of 
the cohesion policy, in particular subsidiarity, efficiency, accountability and decision-making role of 
sub-national authorities on the use of support. Ukraine should elaborate on the reporting approach for 
the  disbursement  of  these  funds.  On  financial  management,  control  and  audit,  the  internal  and 
external  audit  functions  are  in  place,  but  they  have  yet  to  deliver  audits  in  accordance  with 
international standards. Following the adopted amendments to the Law on the Accounting Chamber, 
the Accounting Chamber has been granted a mandate to audit local budgets, although the Accounting 
Chamber currently has both capacity and professional limitations. 

Ukraine  participates  in  seven  Interreg  cooperation  programmes  and  is  also  part  of  the  EU  Macro-
regional  Strategy  for  the  Danube  Region.  Ukraine  should  ensure  that  the  management  and  control 
systems of these programmes within the State Audit Service function effectively. 

On  the  fight  against corruption, a  system  of internal financial  audit and control,  including  for the 
future management of structural and cohesion funds, has been implemented at the national level, with 

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the establishment of internal audit and corruption prevention units in all state authorities. At the local 
level, however, implementation remains deficient. The practical effectiveness of such control systems 
to effectively prevent fraud and corruption remains uneven. 

Chapter 33 - Financial and budgetary provisions 

This  chapter  covers  the  rules  governing  the  funding  of  the  EU  budget  (‘own  resources’).  These 
resources mainly consist of: (i) contributions based on the gross national income of each Member 
State; (ii) customs duties; (iii) the non-recycled plastic resource and (iv) a resource based on value 
added  tax.  Member  States  must  have  the  appropriate  administrative  capacity  to  adequately 
coordinate and ensure the correct calculation, collection, payment and control of own resources. 

An EU budget unit was created as part of the Department of European and Euro-Atlantic Integration 
of the Ministry of Finance for the implementation of the own resources system. The unit coordinates 
activities  of  national  institutions  (State  Tax  Service,  State  Customs  Service,  State  Statistic  Service, 
State  Treasury  and  Ministry  of  Environmental  Protection)  included  in  the  system  of  EU  own 
resources. The interdepartmental working group was created on 10 September 2025, which main tasks 
will be to develop legislation to align with the EU acquis. 

Ukraine progressed in the underlying policy areas indirectly affecting the own resources system (see 
Chapters 16 - Taxation, 18 - Statistics, 29 - Customs union, and 32 - Financial control). 

On traditional own resources, Ukraine has implemented most of the fundamental principles in the 
policy areas that affect the own resources system. In the reporting period, substantial amendments to 
the Customs Code aligning to the Union Customs Code (UCC) entered into force and a draft of the 
new Customs Code aligned to the UCC was developed and, by the Protocol decision of the Cabinet of 
Ministers approved and transmitted to the EU for evaluation. 

Ukraine applies a single VAT system that is largely, but not fully, aligned with the European system. 
Amendments  to  the  Tax  Code  aligning  further  to  the  Council  Directive  on  the  common  system  of 
value  added tax  were adopted.  The system  of calculating  the  VAT based  own  resource  needs to be 
developed. 

Issues  related  to  national  accounts  and  gross  national  income  data  are  addressed  in  Chapter  18  - 
Statistics.  Before  adopting  necessary  legislation  and  implementing  the  Waste  management  system, 
calculation of the plastic-based own resource is not possible. 

CLUSTER 6: EXTERNAL RELATIONS 

This cluster covers: external relations (Chapter 30); and foreign, security and defence policy (Chapter 
31). 

Chapter 30 - External relations 

The EU has a common commercial policy towards third countries, based on multilateral and bilateral 
agreements  and  autonomous  measures.  There  are  also  EU  rules  on  humanitarian  aid  and 
development policy. 

On  the  common  commercial  policy,  Ukraine  continued  to  coordinate  its  positions  and  align  its 
policies closely with those of the EU, including within the WTO and its Dispute Settlement Body. In 
February  2025,  Ukraine  completed  the  second  review  of  its  trade  policies  and  practices  within  the 
WTO. 

On dual-use goods, Ukraine is yet to achieve full alignment with the latest EU  acquis in this area, 
namely  Regulation  (EU)  2021/821  and  its  annual  updates  as  regards  the  list  of  dual-use  items. 
Ukraine  is  a  member  of  the  Australia  group,  the  Nuclear  Suppliers  Group  and  the  Wassenaar 
Arrangement and has adopted and maintained a consolidated list of dual-use goods and technologies 
based on the EU acquis. 

On  bilateral  trade  agreements,  Ukraine  has  notified  to  the  WTO  preferential  bilateral  trade 
agreements with 17 partners, seven of which do not have a preferential trade agreement with the EU. 

89 

 
 
 
Ukraine is negotiating further preferential trade agreements with several partners and is also active in 
modernising existing agreements (e.g. The Digital Trade Agreement with UK and the modernisation 
of the Free Trade Agreement with EFTA). In the reporting period, Ukraine signed a preferential trade 
agreement with the United Arab Emirates, which is currently under ratification. Similarly, a free trade 
agreement signed with Türkiye in 2023 is awaiting ratification. Ukraine should continue to coordinate 
closely with the EU on international trade negotiations, in particular to ensure that, when it joins the 
EU,  its  commitments  are  compatible  with  those  of  the  EU  and  ensuring  the  integration  of  an  EU 
accession-linked expiration clause in the provisions of bilateral free trade and investment agreements. 

There are no developments to report on bilateral investment treaties. 

Ukraine has a legal framework in place to provide humanitarian aid to other countries. Ukraine has 
been  engaging  in  the  provision  of  development  aid  by  contributing  to  global  food  security  efforts, 
although  it  has  yet  to  develop  its  development  cooperation  policy  in  line  with  the  relevant  EU 
framework. 

Chapter 31 - Foreign, security and defence policy 

Member  States  must  be  able  to  conduct  political  dialogue  under  EU  foreign,  security  and  defence 
policy, align with EU statements, take part in EU actions, and apply agreed sanctions and restrictive 
measures. 

Ukraine continued intense political dialogue on foreign and security policy with the EU, confirming 
the alignment of Ukraine’s long-term strategic interests with those of the EU. Ukraine hosted an EU-
Ukraine Foreign Ministers meeting in May 2025. The EU and Ukraine last held a security and defence 
dialogue  on  18 February 2025.  The  10th  EU-Ukraine  Human  Rights  Dialogue  took  place  in  June 
2025.  

The EU-Ukraine joint security commitments signed in 2024 continue to be the guiding document for 
the  EU  and  Member  States’  support  to  Ukraine,  complementary  to  Member  States  bilateral 
commitments towards Ukraine. 

The institutional framework enabling Ukraine’s participation in common foreign and security policy 
(CFSP) and common security and defence policy (CSDP) is in place. 

In  2024,  Ukraine’s  alignment  with  statements  by  the  High  Representative  on  behalf  of  the  EU  and 
Council decisions on sanctions was at 95%. As of 24 October2025, its alignment rate was 99%. 

Ukraine  is  gradually  aligning  with  the  EU  acquis  on  EU  restrictive  measures.  Ukraine  has 
mechanisms  in  place  to  ensure  effective  implementation  of  EU  sanctions.  The  Criminal  Code  still 
needs to be amended, as sanctions evasion is still not a criminal offence in Ukraine. Ukraine should 
continue strengthening its sanctions implementation framework in line with the EU acquis. 

Ukraine’s cooperation with international organisations is strong and constructive, including with the 
UN,  the  Council  of  Europe,  the  Organization  for  Security  and  Co-operation  in  Europe  and 
Organisation for Black Sea Economic Cooperation. Ukraine continued to align with EU positions at 
the  United  Nations,  including  supporting  EU  initiatives  in  the  UN  Human  Rights  Council.  In  the 
context of Ukraine’s diplomatic engagement with global partners in support of just and lasting peace, 
Ukraine  initiated  at  the  UN  General  Assembly,  with  EU  support,  the  February  2025  Resolution 
‘Advancing  a  comprehensive,  just  and  lasting  peace  in  Ukraine’,  marking  the  third  anniversary  of 
Russia’s full-scale invasion of Ukraine. Ukraine also ran a successful campaign and was elected to the 
UN Economic and Social Council (ECOSOC) for the 2026-2028 term with 130 votes. 

Ukraine continues to increase its cooperation with the Office of the Prosecutor of the  International 
Criminal Court (ICC) to strengthen investigation of military and other international crimes. Ukraine 
became a full state party of the ICC on 1 January 2025 following the ratification of the Rome Statute; 
however,  Ukraine  has  to  further  align  its  legislative  framework  with  the  provisions  of  the  Rome 
Statute and its related instruments. 

As  regards  non-proliferation  and  disarmament  Ukraine  has  aligned  with  the  EU  in  most 
international fora dealing with non-proliferation over the reporting period. Ukraine complies with its 

90 

 
 
international  obligations  under international  export  control regimes.  Ukraine  is encouraged  to ratify 
the  Arms  Trade  Treaty  to  align  its  legal  framework  of  arms  control  with  the  Common  Position 
2008/944/CFSP  and  to  finalise  and  adopt  its  national  strategy  for  countering  and  preventing  illegal 
trafficking of small arms and light weapons. On 17 July 2025 Ukraine has informed the UN Secretary 
General of its decision to suspend the operation of the Anti-Personnel Mine Ban Convention. 

On  security  measures  (classified  information),  Ukraine  continued  to  implement  its  agreement  on 
security of information with the EU on procedures for the exchange of classified information. 

On the common security and defence policy (CSDP), cooperation on security and defence matters 
between Ukraine and the EU and its Member States was significantly increased, in particular within 
the  framework  of  the  European  Peace  Facility  (EPF).  Ukraine  closely  cooperated  with  EU  CSDP 
missions and benefitted from training provided by EUMAM, as well as advisory support of EUAM.  

Ukraine  should  keep  beyond  2025  the  measures  included  in  its  National  Action  Plan  for  the 
implementation of UN Security Council Resolution 1325 on Women, Peace and Security. 

Ukraine continued to cooperate with the EU in the area of countering cyber threats, including through 
the  regular  EU-Ukraine  Cyber  Dialogue.  In  March  2025,  the  European  Cybersecurity  Competence 
Centre (ECCC) signed a memorandum of cooperation with the  National Cybersecurity Coordination 
Centre  (NCSCC).  In  the  context  of  international  security,  Ukraine  has  actively  engaged  in  the 
negotiations of the final report of the UN Open-ended Working Group on security of and in the use of 
information  and  communications  technologies  2021–2025,  including  through  alignment  with  EU 
statements and submission of national positions. 

Ukraine  continued  to  cooperate  with  the  EU  in  the  area  of  countering  hybrid  threats  (including 
foreign information manipulation and interference) based on the bilateral security agreement of June 
2024. Ukraine has aligned with the July 2025 Statement by the High Representative on behalf of the 
EU condemning Russia’s persistent hybrid campaigns against the EU, its Member States and partners. 
The fight against FIMI and disinformation is especially crucial in rural and less developed regions that 
tend to be less resistant to such hybrid attacks. 

91 

 
 
 
 
ANNEX I - RELATIONS BETWEEN THE EU AND UKRAINE 

After the start of Russia’s war of aggression against Ukraine, Ukraine applied for EU membership on 
28 February 2022 and was granted European perspective and candidate country status in June 2022. 
In December 2023, the European Council decided to open negotiations with Ukraine. The first inter-
governmental conference opening the negotiations took place on 25 June 2024. 

The screening (or the analytical examination of Ukraine’s level of alignment with EU legislation and 
planned  reforms)  was  completed  in  September  2025.  The  work  is  ongoing  towards  the  opening  of 
negotiations on clusters, starting with the fundamentals, as soon as possible in 2025.  

The Association Agreement (AA) remains the basis for the cooperation between the EU and Ukraine 
in a broad range of areas. On 9 April 2025, the 10th meeting of the EU-Ukraine Association Council 
took place in Brussels. A wide range of political and bilateral issues were discussed, with a focus on 
the  military,  economic  and  social  situation  in  Ukraine  following  Russia’s  war  of  aggression.  The 
Association  Committee  in  Trade  Configuration  (ACTC),  which  oversees  trade  relations,  met  in 
November 2024 and started the work on the priority action plan for the implementation of the DCFTA 
2025-2026. The plan includes initiatives for gradual integration in the Single market. 

In July 2025 the ACTC decided to grant reciprocal internal market treatment in the sector of roaming, 
which will apply as of 1 January 2026. 

In July 2025, Ukraine and the EU concluded negotiations on the revision of the DCFTA, setting up a 
framework for long-term economic certainty and stable trade relations. The new trading regime  was 
agreed by a joint decision in the ACTC on 14 October 2025 and entered into force on 29 October. 

Despite growing trade integration, there remains unmet commitments breaching the DCFTA, such as 
wood ban, export duties on soybean and sunflower seed (and the recent adoption of additional export 
duties  on  soybeans  and  rapeseed  by  the  Ukrainian  Parliament)  and  discriminatory  rules  for  EU 
participation in public-private partnerships. The suspension of State aid control does not appear to be 
aligned  with  the  objectives  of  the  DCFTA.  These  irritants  have  negative  impact  on  EU  companies, 
which wish to invest in Ukraine. 

On  bilateral  financial  assistance,  since  start  of  Russia’s  war  of  aggression,  the  EU,  its  Member 
States  and  the  European  financial  institutions  have  stepped  up  their  support  in  a  Team  Europe 
approach,  mobilising  EUR  177.6  billion  for  Ukraine’s  overall  economic,  social  and  financial 
resilience in the form of emergency macro-financial assistance, budget support, emergency assistance, 
crisis response, humanitarian aid and military assistance as well as support for people fleeing the war. 

One core element of the EU’s response to Russia’s war of aggression against Ukraine and the latter’s 
recently acquired candidate status for EU membership is the Ukraine Facility (UF). The UF has been 
operational  since  1 March 2024  and  is  providing  up  to  EUR  50  billion  in  stable,  predictable  and 
flexible  support  for  the  period  2024-2027  by  combining  budgetary  support  (Pillar  I),  investment 
incentives (Pillar II) and EU accession-related technical assistance (Pillar III). The EUR 38.27 billion 
Ukraine  Plan  financed  under  Pillar  I  is  the  main  instrument  for  ensuring  Ukraine’s  recovery, 
reconstruction  and  modernisation,  while  implementing  reforms  designed  to  underpin  the  country’s 
accession  process.  The  plan  envisages  an  ambitious  growth-enhancing  reform  agenda  aimed  at 
facilitating  structural  transformation  while  supporting  Ukraine’s  path towards  EU  membership.  The 
plan  is  complementary  to  the  EU  accession  process  as  it  has  the  potential  to  accelerate  Ukraine’s 
economic convergence upon successful completion, while simultaneously increasing alignment with 
the EU acquis in key areas. EUR 22.7 billion has been disbursed in the form of budgetary support for 
the implementation of the plan, with EUR 6.5 billion paid in 2025. In addition, under Pillar II, EUR 
6.2  billion  have  been  committed  in  blended  finance  grants  and  guarantees;  this  will  allow  the 
beneficiary international financial institutions to provide support to financial intermediaries and final 
beneficiaries in Ukraine for an amount of EUR 18 billion. Furthermore, under Pillar III, the EU has so 
far  disbursed  EUR  649  million  in  subsidy  for  borrowing  costs  and  technical  assistance,  including 
EUR 10 million through the Ukraine2EU - EU Integration Support Programme for Ukraine, launched 

92 

 
 
 
in January 2025. This support aims to strengthen state mechanisms for the management of Ukraine's 
EU  accession  process  and  implementation  of  its  related  reforms.  In  a  Team  Europe  spirit,  the 
programme has mobilised financial contributions from Denmark, Lithuania and Sweden as well. 

Since  the  beginning  of  Russia’s  war  of  aggression  against  Ukraine,  the  EU  and  its  Member  States 
have  mobilised  approximately  EUR  4.2  billion  in  humanitarian  assistance  for  Ukraine.  The 
Commission alone has made available nearly EUR 1.2 billion, including an initial 2025 allocation of 
EUR 140 million.  

To  implement  the  commitment  by  G7  Leaders  to  provide  approximately  EUR  45  billion  worth  of 
loans to Ukraine to be serviced and repaid by future flows of extraordinary revenues stemming from 
the  immobilised  Russian  sovereign  assets,  Regulation  (EU)  2024/2773  creating  the  Ukraine  Loan 
Cooperation  Mechanism  and  providing  exceptional  macro-financial  assistance  to  Ukraine  in  the 
context of Russia’s war of aggression entered into force on 29 October 2024. In light of the confirmed 
contributions of G7 partners, ensuring fair burden sharing through a proportionate support to the size 
of  their  respective  economies,  the  EU  expects  to  provide  a  macro-financial  assistance  loan  of 
approximately EUR 18 billion as its contribution to the initiative. EUR 14 billion has been disbursed 
since the beginning of 2025. 

The EU and its Member States have also mobilised EUR 63.2 billion in military support for Ukraine, 
including EUR 6.1 billion under the EPF. 

Given the context, military and security cooperation between Ukraine and the EU and its Member 
States was significantly increased, in particular within the framework of the EPF and through the EU 
Military Assistance Mission in support of Ukraine (EUMAM Ukraine) and the EU Advisory Mission 
for Civilian Security Sector Reform in Ukraine (EUAM Ukraine). In line with the EU-Ukraine joint 
security  commitments,  EUMAM  Ukraine  has  completed  the  training  of  close  to  80 000  Ukrainian 
soldiers  on  the  territory  of  EU  Member  States,  covering  land,  maritime  and  air  domains.  EUAM 
Ukraine continued providing support to its Ukrainian partners in reforming the civilian security sector 
as  well  as  strengthening  their  capacity  to  address  war  related  challenges,  such  as  support  to 
accountability efforts and re-establishment of the rule of law in the liberated and adjacent territories. 

Ukraine  is  associated  to  14  Union  programmes  Horizon  Europe,  Euratom  Research  and  Training 
Programme,  Digital  Europe,  Fiscalis,  Customs,  Creative  Europe,  EU4Health,  LIFE,  Single  Market 
Programme,  Union  Civil  Protection  Mechanism,  Connecting  Europe  Facility,  Union  Anti-Fraud, 
Justice,  and  Citizens,  Equality,  Rights  and  Values.  In  2024,  Ukraine  became fully  associated to the 
Media strand of the Creative Europe programme, marking an important step towards the integration of 
the  Ukrainian  audiovisual  sector  into  the  European  ecosystem.  In  April  2025,  Ukraine  signed  the 
agreement on participation in the Copernicus component, the Space Weather Events and Near-Earth 
Objects  sub-components  of  the  Space  Situational  Awareness  component  of  the  Union  Space 
Programme. In July 2025, the agreement for Ukraine to join the Employment and Social Innovation 
(EaSI)  strand  of  the  European  Social  Fund+  was  signed.  Ukraine’s  financial  obligations  for  its 
participation in EU programmes have been suspended owing to Russia’s war of aggression.   

Participation in the EU programmes brings several tangible benefits and support to Ukraine beyond 
the Ukraine Facility. For example: i) Ukraine has been awarded approximately EUR 62.5 million in 
EU contributions from Horizon Europe through 336 participations. Under the EURATOM 2021-2025, 
Ukraine has been awarded EUR 9.8 million in EU contributions through 32 participations; ii) Under 
the Creative Europe programme, a special call for proposals of EUR 5 million was launched in 2024 
to  support  Ukrainian  artists  and  organisations;  iii)  Ukraine’s  association  to  the  Single  Market 
Programme has enabled Ukrainian businesses to benefit from funding under the programme. 

93 

 
 
 
 
 
 
94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II – STATISTICAL DATA  

STATISTICAL DATA (as of 11/09/2025) 

Basic data 
Population (thousand) 
Total area of the country (km²) 

National accounts 
Gross domestic product (GDP) (million national currency) 
Gross domestic product (GDP) (million euro) 
GDP per capita (euro) 
GDP per capita (in purchasing power standards (PPS)) 
GDP per capita (in PPS), relative to the EU average (EU-27 = 100) 
Real GDP growth rate: change on previous year of GDP volume (%) 
Employment growth (national accounts data), relative to the previous year (%) 
Labour productivity growth: growth in GDP (in volume) per person employed, relative to the 
previous year (%) 
Unit labour cost growth, relative to the previous year (%) 
*3 year change (T/T-3) in the nominal unit labour cost growth index (2015 = 100) 
Labour productivity per person employed: GDP (in PPS) per person employed relative to EU 
average (EU-27 = 100) 
Gross value added by main sectors 
Agriculture, forestry and fisheries (%) 
Industry (%) 
Construction (%) 
Services (%) 
Final consumption expenditure, as a share of GDP (%) 
Gross fixed capital formation, as a share of GDP (%) 
Exports of goods and services, relative to GDP (%) 
Imports of goods and services, relative to GDP (%) 
Gross fixed capital formation by the general government sector, as a percentage of GDP (%) 

Business 
Industrial production volume index (2015 = 100) 
Number of active enterprises (number) 
Birth rate: number of enterprise births in the reference period (t) divided by the number of 
enterprises active in t (%) 
Death rate: number of enterprise deaths in the reference period (t) divided by the number of 
enterprises active in t (%) 

95 

Note 

1) 

Note 

2) 3) 

2) 
2) 3) 

2) 3) 

Note 

2) 
2) 4) 

2012 
45 453 i 
603 549 w 

2020 
41 733 i 
603 549 w 

2021 
: 
603 549 w 

2022 
40 998 i 
603 549 w 

2023 
: 
603 549 w 

2024 
: 
603 549 w 

2012 
1 404 669 
136 750 
3 116 w 
: 
: 
0.2 
0 iw 
0 w 

2020 
4 222 026 
136 595 
3 285 w 
: 
: 
-  3.8 
-  4 iw 
0 w 

2021 
5 450 849 
168 960 
4 077 w 
: 
: 
3.4 
-  2 iw 
6 w 

2022 
5 239 114 
154 006 
: 
: 
: 
-  28.8 
: 
: 

2023 
6 627 961 
167 632 
: 
: 
: 
5.5 
: 
: 

: 
: 
: 

9.1 
25.2 
3.2 
62.5 i 
86.9 
19.0 
47.7 
56.4 
: 

: 
: 
: 

10.8 
20.9 
3.3 
64.9 i 
92.6 
13.4 
38.8 
40.3 
3 w 

: 
: 
: 

12.7 
23.7 
3.2 
60.5 i 
86.9 
13.2 
40.7 
42.0 
3 w 

: 
: 
: 

9.7 
18.9 
1.5 
69.9 i 
104.4 
11.9 
35.4 
52.0 
: 

: 
: 
: 

8.6 
19.9 
1.8 
69.7 i 
102.8 
19.9 
28.3 
49.2 
: 

2024 
: 
: 
: 
: 
: 
: 
: 
: 

: 
: 
: 

: 
: 
: 
: 
: 
: 
: 
: 
: 

2012 
134.0 w 
: 
: 

2020 
102.8 w 
1 729 058 w 
10.3 w 

2021 
105.0 w 
1 719 536 w 
9.4 w 

2022 
66.5 w 
1 532 287 w 
: 

2023 
71.0 w 
1 675 194 w 
: 

2024 
73.4 w 
: 
: 

2) 4) 

: 

10.8 w 

16.1 w 

: 

: 

: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
People employed in SMEs as a share of all persons employed (within the non-financial 
business economy) (%) 
Value added by SMEs (in the non-financial business economy) (EUR million) 
Total value added (in the non-financial business economy) (EUR million) 

Inflation rate and house prices 
Consumer price index (CPI), change relative to the previous year (%) 

Balance of payments 
Balance of payments: current account total (million euro) 
Balance of payments current account: trade balance (million euro) 
Balance of payments current account: net services (million euro) 
Balance of payments current account: net balance for primary income (million euro) 
Balance of payments current account: net balance for secondary income (million euro) 
Net balance for primary and secondary income: of which government transfers (million euro) 
*3 year backward moving average of the current account balance relative to GDP (%) 
*Five year change in share of world exports of goods and services (%) 
Net balance (inward - outward) of foreign direct investment (FDI) (million euro) 
Foreign direct investment (FDI) abroad (million euro) 
of which FDI of the reporting economy in the EU-27 countries (million euro) 
Foreign direct investment (FDI) in the reporting economy (million euro) 
of which FDI of the EU-27 countries in the reporting economy (million euro) 
*Net international investment position, relative to GDP (%) 
Year on year rate of change in gross inflow of remittances (in national currency) from migrant 
workers (%) 

Public finance 
General government deficit / surplus, relative to GDP (%) 
General government gross debt relative to GDP (%) 
Total  government revenues, as a percentage of GDP (%) 
Total government expenditure, as a percentage of GDP (%) 

Financial indicators 
Gross external debt of the whole economy, relative to GDP (%) 
Gross external debt of the whole economy, relative to total exports (%) 
Money supply: M1 (banknotes, coins, overnight deposits, million euro) 
Total credit by monetary financial institutions to residents (consolidated) (million euro) 
*Annual change in financial sector liabilities (%) 
*Private debt, consolidated, relative to GDP (%) 

2) 

2) 
2) 

Note 
2) 5) 

Note 
2) 
2) 
2) 
2) 
2) 

2) 

2) 
2) 
2) 
2) 
2) 

2) 

Note 
2) 6) 
2) 7) 
2) 6) 
2) 6) 

Note 
2) 
8) 
9) 

: 

: 
: 

64.0 iw 

64.3 iw 

63.9 iw 

67.0 iw 

48 221 iw 
86 283 w 

59 859 iw 
113 149 w 

57 871 iw 
93 313 w 

60 679 iw 
99 288 w 

: 

: 
: 

2012 
0.6 w 

2020 
2.7 w 

2021 
9.4 w 

2022 
20.2 w 

2023 
12.9 w 

2024 
6.5 w 

2012 
- 11 153.4 w 
- 16 997.3 w 
5 835.4 w 
- 2 306.9 w 
2 315.5 w 
-  464.5 w 
-  5.3 iw 
: 
5 598.1 w 
938.3 w 
100.4 w 
6 536.4 w 
4 225.4 w 
-  28.0 w 
1.0 iw 

2020 
4 735.0 w 
- 5 867.8 w 
3 845.7 w 
3 174.1 w 
3 583.0 w 
- 1 183.4 w 
-  1.4 iw 
20.2 w 
-  68.6 w 
13.5 w 
-  65.7 w 
-  55.1 w 
-  757.1 w 
-  14.1 w 
0.7 iw 

2021 
- 3 369.7 w 
- 5 689.0 w 
3 368.9 w 
- 4 961.0 w 
3 911.4 w 
- 1 278.8 w 
-  0.4 iw 
31.3 w 
6 391.6 w 
-  171.0 w 
-  165.3 w 
6 220.6 w 
4 609.4 w 
-  13.1 w 
1.0 iw 

2012 
-  3.7 w 
35.3 w 
42.9 w 
46.6 w 

2020 
-  5.4 w 
60.4 w 
39.6 w 
45.0 w 

2021 
-  3.3 w 
49.0 w 
37.0 w 
40.3 w 

2012 
71.9 iw 
151.7 w 
30 674.8 w 
: 
: 
: 

2020 
74.6 iw 
192.4 w 
30 226.3 w 
: 
: 
: 

2021 
67.8 iw 
165.6 w 
41 433.7 w 
: 
: 
: 

2022 
7 635.7 w 
- 14 130.5 w 
- 10 736.5 w 
8 138.9 w 
24 363.8 w 
15 843.7 w 
2.2 iw 
-  22.3 w 
249.9 w 
333.7 w 
-  100.7 w 
583.6 w 
-  8.3 w 
-  1.7 w 
1.0 iw 

2022 
-  15.3 w 
77.8 w 
50.1 w 
65.4 w 

2022 
79.7 iw 
225.8 w 
40 342.0 w 
: 
: 
: 

2023 
- 8 846.6 w 
- 26 932.5 w 
- 8 097.8 w 
4 688.5 w 
21 495.2 w 
11 835.4 w 
-  0.8 iw 
-  29.5 w 
4 102.8 w 
39.7 w 
20.3 w 
4 142.5 w 
3 343.8 w 
-  6.3 w 
1.0 iw 

2023 
-  19.5 w 
83.3 w 
54.0 w 
73.5 w 

2023 
86.8 iw 
306.5 w 
44 143.0 w 
: 
: 
: 

2024 
- 12 618.9 w 
- 28 140.2 w 
- 5 085.4 w 
304.1 w 
20 302.6 w 
9 993.7 w 
-  2.6 iw 
: 
3 227.7 w 
-  150.5 w 
-  64.5 w 
3 077.2 w 
2 364.9 w 
-  5.4 w 
: 

2024 
: 
91.8 ew 
: 
: 

2024 
: 
333.3 w 
48 473.6 w 
: 
: 
: 

96 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest rates: day-to-day money rate, per annum (%) 
Euro exchange rates: average of period (1 euro = … national currency) 
Trade-weighted effective exchange rate index, 42 countries (2015 = 100) 
*3 year change (T/T-3) in the trade-weighted effective exchange rate index, 42 countries 
(2015 = 100) 
Value of reserve assets (including gold) (million euro) 

8.58 w 
11.075 
142.1 w 
0.0 iw 

10) 
10) 

7.10 w 
30.910 
93.2 w 
0.1 iw 

6.78 w 
32.261 
91.5 w 
0.1 iw 

11.11 w 
34.019 
88.5 w 
- 0.1 iw 

12.29 w 
39.539 
78.5 w 
- 0.2 iw 

5.24 w 
43.469 
73.4 w 
- 0.2 iw 

8) 

18 619.4 w 

23 711.1 w 

27 294.4 w 

26 751.2 w 

36 459.0 w 

41 913.1 w 

External trade in goods 
Value of imports: all goods, all partners (million euro) 
Value of exports: all goods, all partners (million euro) 
Trade balance: all goods, all partners (million euro) 
Terms of trade (export price index / import price index * 100) (number) 
Share of exports to EU-27 countries in value of total exports (%) 
Share of imports from EU-27 countries in value of total imports (%) 

Demography 
Crude rate of natural change of population (natural growth rate): number of births minus 
deaths (per thousand inhabitants) 
Infant mortality rate deaths of children under one year of age (per thousand live births) 
Life expectancy at birth: male (years) 
Life expectancy at birth: female (years) 

Labour market 
Economic activity rate for persons aged 20–64: proportion of the population aged 20–64 that 
is economically active (%) 
Employment rate for persons aged 20–64: proportion of the population aged 20–64 that are 
in employment (%) 
Male employment rate for persons aged 20–64 (%) 
Female employment rate for persons aged 20–64 (%) 
Employment rate for persons aged 55–64: proportion of the population aged 55–64 that are 
in employment (%) 
Employment by main sectors 
Agriculture, forestry and fisheries (%) 

Industry (%) 

Construction (%) 

Services (%) 

Note 
2) 
2) 

2) 
11) 
2) 
2) 

Note 

Note 
2) 3) 
12) 
2) 3) 

2) 3) 
2) 3) 
2) 3) 

2) 3) 
13) 
2) 3) 
13) 
2) 3) 
13) 
2) 3) 
13) 

2012 
64 707 iw 
52 755 iw 
- 11 952 iw 
89.0 iw 
24.2 iw 
30.0 iw 

2020 
47 490 w 
43 053 w 
- 4 438 iw 
105.0 iw 
36.4 iw 
42.6 iw 

2021 
61 824 w 
57 718 w 
- 4 106 iw 
118.9 iw 
39.3 iw 
39.7 iw 

2022 
52 595 w 
41 752 w 
- 10 843 iw 
78.8 iw 
63.6 iw 
49.1 iw 

2023 
58 795 w 
33 481 w 
- 25 314 iw 
79.9 iw 
64.7 iw 
51.1 iw 

2024 
65 442 w 
38 573 w 
- 26 869 iw 
95.4 iw 
59.5 iw 
50.5 iw 

2012 
-  3.1 

8.4 
66.1 
76.1 

2020 
-  7.8 

6.8 
: 
: 

2021 
: 

7.2 
: 
: 

2022 
: 

2023 
: 

2024 
: 

: 
: 
: 

: 
: 
: 

: 
: 
: 

2012 
72.4 w 

2020 
72.0 w 

2021 
71.9 w 

2022 
: 

2023 
: 

2024 
: 

67.0 w 

65.2 w 

64.8 w 

72.8 w 
61.7 w 
40.0 w 

70.8 w 
60.0 w 
42.1 w 

70.8 w 
59.3 w 
41.1 w 

19.8 w 

14.1 w 

14.1 w 

19.4 w 

17.8 w 

18.2 w 

6.3 w 

7.0 w 

7.0 w 

54.5 w 

61.1 w 

60.7 w 

: 

: 
: 
: 

: 

: 

: 

: 

: 

: 
: 
: 

: 

: 

: 

: 

: 

: 
: 
: 

: 

: 

: 

: 

97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
People employed in the public sector as a share of total employment, persons aged 20–64 
(%) 
People employed in the private sector as a share of total employment, persons aged 20–64 
(%) 
Unemployment rate: proportion of the labour force that is unemployed (%) 

Male unemployment rate (%) 

Female unemployment rate (%) 

Youth unemployment rate: proportion of the labour force aged 15–24 that is unemployed (%) 
Long-term unemployment rate: proportion of the labour force that has been unemployed for 
12 months or more (%) 
Unemployment rate for persons (aged 25–64) having completed at most lower secondary 
education (ISCED levels 0-2) (%) 
Unemployment rate for persons (aged 25–64) having completed tertiary education (ISCED 
levels 5-8) (%) 

: 

: 

7.5 w 

8.5 w 

6.4 w 

17.3 w 
1.6 w 

: 

: 

9.5 w 

9.8 w 

: 

: 

9.8 w 

9.5 w 

9.1 w 

10.1 w 

19.3 w 
2.0 w 

19.1 w 
2.4 w 

7.1 w 

16.3 w 

15.3 w 

2) 3) 
13) 
2) 3) 
13) 
2) 3) 
13) 
2) 3) 
2) 3) 
13) 
2) 3) 

2) 3) 

5.6 w 

7.4 w 

8.5 w 

: 

: 

: 

: 

: 

: 
: 

: 

: 

: 

: 

: 

: 

: 

: 
: 

: 

: 

: 

: 

: 

: 

: 

: 
: 

: 

: 

2012 
3 026 w 

2020 
11 591 w 

2021 
14 014 w 

2022 
14 847 w 

2023 
17 442 w 

2024 
21 473 w 

Social cohesion 
Average nominal monthly wages and salaries (national currency) 

Index of real wages and salaries (index of nominal wages and salaries divided by the 
inflation index) (2016 = 100) 
Gini coefficient 

Poverty gap 

Standard of living 
Number of passenger cars relative to population size (number per thousand population) 
Number of mobile phone subscriptions relative to population size (number per thousand 
population) 
Mobile broadband penetration (per 100 inhabitants) 
Fixed broadband penetration (per 100 inhabitants) 

Note 
2) 3) 
14) 
3) 

2) 3) 
9) 
2) 3) 

Note 

2012 
: 
1 307.8 w 

: 
8 w 

Infrastructure 
Density of railway network (lines in operation per thousand km²) 

Length of motorways (kilometres) 

Education, Innovation and Research 
Percentage of persons aged 30-34 with a tertiary education level (ISCED 2011 levels 5 to 8) 
Percentage of persons aged 30-34 with a tertiary education level (ISCED 2011 levels 5 to 8), 
males 

Note 

2012 
35.8 iw 

2) 

15 w 

Note 
2) 3) 
2) 3) 

2012 
50.8 w 
44.1 w 

98 

: 

158 w 

175 w 

24 w 

25 w 

24 w 

20.5 w 

21.2 w 

21.7 w 

2020 
: 
: 

: 
: 

2020 
32.8 iw 

15 w 

2020 
57.1 w 
49.7 w 

2021 
: 
: 

: 
: 

2021 
: 

15 w 

2021 
58.0 w 
51.4 w 

: 

: 

: 

2022 
: 
: 

: 
: 

2022 
: 

15 pw 

2022 
: 
: 

: 

: 

: 

2023 
: 
: 

: 
: 

2023 
: 

15 pw 

2023 
: 
: 

: 

: 

: 

2024 
: 
: 

: 
: 

2024 
: 

: 

2024 
: 
: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2) 3) 

57.6 w 

64.8 w 

64.8 w 

: 

: 

Percentage of persons aged 30-34 with a tertiary education level (ISCED 2011 levels 5 to 8), 
females 
Participation in early childhood education (children aged 3 and over) 
Participation in early childhood education (children aged 3 and over), males 
Participation in early childhood education (children aged 3 and over), females 
Low achieving 15-year-olds in reading 
Low achieving 15-year-olds in mathematics 
Low achieving 15-year-olds in science 
Early leavers from education and training: proportion of persons aged 18-24 with at most 
lower secondary education (at most ISCED 2011 level 2) who are not in further education or 
training 
Early leavers from education and training: proportion of men aged 18-24 with at most lower 
secondary education (at most ISCED 2011 level 2) who are not in further education or 
training 
Early leavers from education and training: proportion of women aged 18-24 with at most 
lower secondary education (at most ISCED 2011 level 2) who are not in further education or 
training 
Proportion of persons aged 25-64 having participated in education and training (last 4 
weeks) 
Proportion of persons aged 25-64 having participated in education and training (last 4 
weeks), men 
Proportion of persons aged 25-64 having participated in education and training (last 4 
weeks), women 
Exposure of vocational education and training (VET) graduates to work-based learning (% of 
population aged 20-34) 
Share of individuals having at least basic digital skills (% of population aged 16-74) 
Share of individuals having at least basic digital skills (% of population aged 16-74), males 
Share of individuals having at least basic digital skills (% of population aged 16-74), females 
Public expenditure on education relative to GDP (%) 
Gross domestic expenditure on R&D relative to GDP (%) 
Government budget appropriations or outlays on R&D (GBAORD), as a percentage of GDP 
(%) 
Percentage of households who have internet access at home (%) 

Environment 
Index of greenhouse gas emissions,  CO2 equivalent (1990 = 100) 
Energy intensity of the economy (kg of oil equivalent per 1 000 euro GDP at 2015 constant 
prices) 
Electricity generated from renewable sources relative to gross electricity consumption (%) 
Road share of inland freight transport (based on tonne-km) (%) 

99 

2) 
2) 
2) 

83.9 w 
83.8 w 
84.0 w 
: 
: 
: 
: 

: 

: 

: 

: 

: 

: 

: 
: 
: 
6.4 iw 
0.72 iw 
0.30 w 

2) 
2) 
2) 
15) 
2) 3) 
16) 

Note 

2) 

2) 

86.7 w 
86.9 w 
86.6 w 
: 
: 
: 
: 

: 

: 

0.5 w 

0.5 w 

0.4 w 

: 

: 
: 
: 
5.4 iw 
0.40 iw 
0.20 w 

85.8 w 
86.0 w 
85.6 w 
: 
: 
: 
: 

: 

: 

0.5 w 

0.5 w 

0.4 w 

: 

: 
: 
: 
5.1 iw 
0.38 iw 
0.16 w 

88.5 w 
88.7 w 
88.4 w 
: 
: 
: 
: 

87.1 w 
87.3 w 
86.9 w 
: 
: 
: 
: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 

: 
: 
: 
: 
0.33 iw 
0.21 w 

: 
: 
: 
: 
0.32 iw 
0.12 w 

: 

: 
: 
: 
: 
: 
: 
: 

: 

: 

: 

: 

: 

: 

: 
: 
: 
: 
: 
: 

: 

34.6 w 

79.2 w 

82.7 w 

: 

: 

2012 
45.4 ew 
214.0 dw 

2020 
33.8 ew 
167.0 dw 

6.5 ew 
31.7 w 

11.5 w 
42.3 w 

2021 
35.8 ew 
: 

10.6 w 
39.3 w 

2022 
24.4 ew 
: 

: 
46.0 pw 

2023 
: 
: 

: 
47.8 pw 

2024 
: 
: 

: 
: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Energy 
Primary production of all energy products (thousand TOE) 
Primary production of crude oil (thousand TOE) 
Primary production of solid fuels (thousand TOE) 
Primary production of gas (thousand TOE) 
Net imports of all energy products (thousand TOE) 
Gross inland energy consumption (thousand TOE) 
Gross electricity generation (GWh) 

Agriculture 
Agricultural output volume index (at producer prices) (2015 = 100) 
Utilised agricultural area (thousand hectares) 
Livestock numbers: live bovine animals (thousand heads, end of period) 
Livestock numbers: live swine (thousand heads, end of period) 
Livestock numbers: live sheep and live goats (thousand heads, end of period) 
Raw milk available on farms (thousand tonnes) 
Harvested crop production: cereals (including rice) (thousand tonnes) 
Harvested crop production: sugar beet (thousand tonnes) 
Harvested crop production: vegetables (thousand tonnes) 

Source: Eurostat and/or the statistical authorities in Ukraine 

: = not available 
  d =  definition differs 
  e = estimated value 
  p = provisional 

i = Eurostat estimate 

Note 

2012 
84 441 
3 437 
39 052 
15 413 
38 499 i 
122 899 
198 878 

2020 
57 121 
2 476 
12 690 
15 856 
29 487 i 
86 583 
148 264 

2021 
: 
: 
: 
: 
: 
: 
: 

2022 
: 
: 
: 
: 
: 
: 
: 

2023 
: 
: 
: 
: 
: 
: 
: 

2024 
: 
: 
: 
: 
: 
: 
: 

Note 
2) 
1) 
2) 
2) 
2) 
2) 
2) 
2) 
2) 

2012 
90.6 w 
41 280.4 w 
4 645.9 w 
7 576.7 w 
1 738.2 iw 
11 377.6 w 
45 742.8 iw 
18 438.9 w 
10 162.3 w 

2020 
102.6 w 
41 144.2 w 
2 874.0 w 
5 876.2 w 
1 140.4 iw 
9 263.6 w 
64 333.4 iw 
9 150.2 w 
9 747.5 w 

2021 
119.4 w 
41 144.2 w 
2 644.0 w 
5 608.8 w 
1 094.3 iw 
8 713.9 w 
85 329.9 iw 
10 853.9 w 
10 038.3 w 

2022 
89.2 w 
41 144.2 w 
2 307.1 w 
4 948.3 w 
941.4 iw 
7 767.7 w 
53 529.6 iw 
9 941.5 w 
7 579.4 w 

2023 
99.1 w 
41 144.2 w 
2 156.2 w 
5 094.0 w 
906.3 iw 
7 430.4 w 
59 311.7 iw 
13 129.7 w 
8 356.0 w 

2024 
92.9 w 
41 144.2 w 
2 023.7 pw 
4 530.9 pw 
847.0 piw 
7 246.1 pw 
55 539.3 piw 
12 718.5 pw 
: 

  w= data supplied by and under the responsibility of the national statistical authority and published on an "as is" basis and without any assurance as regards their quality and 

adherence to EU statistical methodology 

  m =  missing value / data cannot exist 

* = Macroeconomic Imbalance Procedure (MIP) indicator 

  Footnotes: 

1)  Data of the State Service of Ukraine for Geodesy, Cartography and Cadastre and according to the new Classification of Land Types. 
2)  Since 2014, data for Ukraine generally excludes the illegally annexed Autonomous Republic of Crimea and the City of Sevastopol and the territories which are not under control of 

the Ukrainian government. 

3)  Data on Ukraine for the years 2021-2024 is limited due to exemption under the martial law from mandatory data submission to the State Statistics Service of Ukraine, effective as 

of 3 March 2022. 

4)  Excluding data on individual entrepreneurs. 
5)  Consumer price inflation. 
6)  Cash data (Government finance statistics manual 2014). 
7)  State and state guaranteed debt. 

100 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
8)  Assets and debt converted from US dollars to euro using cross rates at the end of the reporting year. 
9)  Monetary aggregate M1 includes: certain liabilities of resident deposit-taking corporations vis-a-vis resident sectors of the economy except general government and other deposit-

taking corporations; currency in circulation outside the deposit-taking corporations; and transferable deposits in national currency. 

10)  Nominal effective exchange rate index of the hryvnia (2015=100), 39 countries; from 2022: 37 countries. 
11)  Rolling index, based on ratio in the previous period. 
12)  From 2019 data for economically active population is based on the Labour Force Survey. 
13)  Persons aged 15 years and over. 
14)  Data refer to enterprises and their independent divisions with 10 or more employees. 
15)  The share of R&D expenditure from the government budget in GDP. 
16)  Share of persons who used the internet at home. 

101