Proposal for a COUNCIL DECISION authorising enhanced cooperation on the establishment of a Loan for Ukraine
Date: 2025-12-23
Institutions: European Commission, Secretariat-General
Subjects: EU aid, EU loan, Russia, Russo-Ukrainian issue, Ukraine, economic reconstruction, enhanced cooperation, financial aid, macro-financial assistance

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   EUROPEAN COMMISSION  Brussels, 23.12.2025  COM(2025) 806 final 2025/0431 (NLE)  Proposal for a COUNCIL DECISION authorising enhanced cooperation on the establishment of a Loan for Ukraine   
 
2025/0431 (NLE) 

Proposal for a 

COUNCIL DECISION 

authorising enhanced cooperation on the establishment of a Loan for Ukraine  

THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 329(1) thereof,  

Having  regard to  the  requests made by the Kingdom  of  Belgium, the Republic of Bulgaria, 
the  Kingdom  of  Denmark,  the  Federal  Republic  of  Germany,  the  Republic  of  Estonia,  the 
Republic  of  Croatia,  Ireland,  the  Hellenic  Republic,  the  French  Republic,  the  Republic  of 
Cyprus, the Republic of Latvia, the Republic of Lithuania, the Grand Duchy of Luxembourg, 
the Republic of Malta, the Kingdom of the Netherlands, the Republic of Austria, the Republic 
of  Poland,  the  Portuguese  Republic,  Romania,  the  Republic  of  Slovenia,  the  Republic  of 
Finland, the Kingdom of Spain, the Republic of Italy, the Kingdom of Sweden, 

Having regard to the proposal from the European Commission,  

Having regard to the consent of the European Parliament1,  

Whereas: 

(1) 

(2) 

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On  24  February  2022,  the  President  of  the  Russian  Federation  announced  a  military 
operation in Ukraine, and Russia’s armed forces began an unprovoked and unjustified 
military  aggression  against  Ukraine.  This  illegal  war  of  aggression  is  a  blatant 
violation of the territorial integrity, sovereignty and independence of Ukraine, as well 
as  a  violation  of  the  prohibition  on  the  use  of  force  enshrined  in  Article  2(4)  of  the 
United Nations (UN) Charter, which is a peremptory rule of international law, and of 
the other principles of the UN Charter. 

Since the beginning of Russia’s unprovoked and unjustified war of aggression against 
Ukraine,  the  Union,  its  Member  States  and  European  financial  institutions  have 
mobilised  unprecedented  support  for  Ukraine’s  economic,  social,  financial  and 
defence  resilience.  That  support  combines  support  from  the  Union  budget,  in 
particular  by  means  of  macro-financial  assistance  under  the  form  of  the  Macro-
Financial  Assistance+2,  the  Ukraine  Facility3  and  the  Ukraine  Loan  Cooperation 

Official Journal C […], […], p. […].  
Regulation  (EU)  2022/2463  of  the  European  Parliament  and  of  the  Council  of  14  December  2022 
establishing an instrument for providing support to Ukraine for 2023 (macro-financial assistance +) (OJ 
L 322, 16.12.2022, p. 1). 
Regulation  (EU)  2024/792  of  the  European  Parliament  and  of  the  Council  of  29 February  2024 
establishing the Ukraine Facility (OJ L, 2024/792, 29.2.2024). 

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(3) 

(4) 

(5) 

Mechanism  (ULCM)4,  and  support  from  the  European  Investment  Bank  and  the 
European Bank for Reconstruction and Development, fully or partially guaranteed by 
the Union budget, as well as further financial support by Member States. 

On  9  September  2025,  Ukraine  submitted  an  official  request  to  the  International 
Monetary Fund (IMF) for a new programme to cover additional financing needs from 
2026  to  2029.  That  programme  would  follow  the  successful  implementation  of  the 
existing  IMF  programme,  where  Ukraine  completed  eight  reviews,  but  takes  into 
consideration  that  Russia’s  war  of  aggression  has  continued.  The  IMF’s  ability  to 
proceed  with  this  programme  is  contingent  upon  receiving  sufficient  financing 
assurances from other partners, including the European Union.  

On  23  October  2025,  26  Member  States  committed  to  address  Ukraine’s  pressing 
financial  needs  for  2026-2027,  including  for  its  military  and  defence  efforts.  Those 
Member  States  also  underlined  the  critical  need  to  ensure  that  Ukraine  remains 
resilient and has the budgetary and military means to continue to exercise its inherent 
right  of  self-defence  and  counter  Russia’s  aggression,  and  reaffirmed  that  the 
European  Union  will  continue  to  provide,  in  coordination  with  like-minded  partners 
and  allies,  comprehensive  political,  financial,  economic,  humanitarian,  military  and 
diplomatic support to Ukraine and its people. Those Member States further concluded 
that all military support as well as security guarantees for Ukraine will be provided in 
full respect of the security and defence policy of certain Member States and taking into 
account  the  security  and  defence  interests  of  all  Member  States.  It  was  agreed  that, 
subject  to  Union law,  Russia’s assets should remain immobilised until Russia ceases 
its war of aggression against Ukraine and compensates it for the damage caused by its 
war, and invited the Commission to present options for financial support to Ukraine. 
On  the  same  date,  the  European  Council  concluded  that  Russia’s  war  of  aggression 
against Ukraine and its repercussions for European and global security in a changing 
environment constitute an existential challenge for the European Union.  

The  financial  situation  of  Ukraine  requires  that  disbursement  of  the  Union  financial 
assistance takes place in the second quarter of 2026 at the latest. To this purpose, on 3 
December 2025, the Commission adopted a package of different proposals including a 
proposal for a Regulation of the European Parliament and of the Council establishing 
the Reparations Loan5 and a proposal for a Regulation amending Council Regulation 
(EU,  Euratom)  2020/2093  of  17  December  2020  laying  down  the  multiannual 
financial  framework  (MFF)  for  the  years  2021  to  20276.  Taken  together,  these 
proposals offered two different options to  address Ukraine’s pressing financial needs 
for 2026-2027. In the package, the proposal on the amendment of the MFF was made 
to allow to mobilise the Union budget headroom guarantees for financial assistance to 
Ukraine  over  and  above  the  MFF  ceilings.  Absent  that  amendment,  the  contingent 
liability  of  the  Reparations  Loan  was  to  be  supported  by  guarantees  to  be  given  by 
Member States on a voluntary basis.  

(6) 

On 12 December 2025, the Council adopted Council Regulation (EU) 2025/2600 of 12 
December 2025 on emergency measures addressing the serious economic difficulties 

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Regulation  (EU)  2024/2773  of  the  European  Parliament  and  of  the  Council  of  24  October  2024 
establishing  the  Ukraine  Loan  Cooperation  Mechanism  and  providing  exceptional  macro-financial 
assistance to Ukraine (OJ L, 2024/2773, 28.10.2024 p.1-14.). 
COM(2025) 3502 final, 2025/3502 (COD). 
COM(2025) 3500 final, 2025/3500 (APP). 

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(7) 

(8) 

(9) 

caused  by  Russia’s  actions  in  the  context  of  the  war  of  aggression  against  Ukraine7 
which  was  part  of  the  package  of  the  proposals  made  by  the  Commission  on  3 
December 2025.  

Intensive consultations took place in the Council on the elements of the package and in 
particular  on  the  proposal  for  a  Regulation  establishing  a  Reparations  Loan,  and  the 
proposal to amend the multiannual financial framework Regulation for the years 2021 
to  2027  (MFF  Regulation).  It  appeared  that  the  amendment  of  the  MFF  Regulation 
allowing  to  back  the  contingent  liability  linked  to  support  to  Ukraine  by  the  Union 
budget over and above the MFF ceiling was an important  element for some Member 
States and a condition for their support to the Reparations Loan. However, some other 
Member  States  were  reluctant  to  support  the  possible  expenditure  and  contingent 
liability connected with the Reparations Loan.  

In  its  conclusions  of  18  December  2025,  the  European  Council  supported  the 
provision of a loan to Ukraine of EUR 90 billion for the years 2026-2027 based on EU 
borrowing  on  the  capital  markets  backed  by  the  Union’s  budget  headroom.  The 
European Council conclusions also reflected that, by means of enhanced cooperation 
(Article  20  TEU)  in  respect  of  the  instrument  based  on  Article  212  TFEU,  any 
mobilisation of resources of the Union’s budget  as a guarantee for this  loan will not 
have  an  impact  on  the  financial  obligations  of  the  Czech  Republic,  Hungary  and 
Slovakia. 

Since 3 December 2025, the preparatory bodies of the Council, including Coreper, had 
met on several occasions with the aim of agreeing on the set of acts proposed by the 
Commission, including on the proposal for a Regulation establishing the Reparations 
Loan  and  a  proposal  for  the  amendment  of  the  MFF  Regulation.  On  19  December 
2025, the preparatory bodies of the Council (Coreper) acknowledged the impossibility 
of achieving the objective of the loan within a reasonable period through the package 
of  acts  involving  the  Union  as  a  whole  within  a  reasonable  period.  The  assessment 
took  into  account  the  urgent  need  for  financial  assistance  for  Ukraine.  It  also 
established  that  the  instrument  providing  the  loan  to  Ukraine  and  the  necessary 
amendments  to  the MFF Regulation  can only  be agreed,  as  a last  resort, through the 
combination of unanimous agreements on the proposal for the amendment of the MFF 
Regulation  and  an  enhanced  cooperation  on  a  proposal  for  a  loan  to  Ukraine,  under 
Article  212  TFEU,  while  the  expenditure  resulting  from  the  implementation  of  that 
act,  other  than  administrative  costs  entailed  for  the  institutions,  is  borne  by  the 
participating Member States, in accordance with Article 332 TFEU.  

(10)  On  20  December  2025,  the  Kingdom  of  Belgium,  the  Republic  of  Bulgaria,  the 
Kingdom of Denmark, the Federal Republic of Germany, the Republic of Estonia, the 
Republic of Croatia, Ireland, the Hellenic Republic, the French Republic, the Republic 
of  Cyprus,  the  Republic  of  Latvia,  the  Republic  of  Lithuania,  the  Grand  Duchy  of 
Luxembourg, the Republic of Malta, the Kingdom of the Netherlands, the Republic of 
Austria,  the  Republic  of  Poland,  the Portuguese  Republic,  Romania,  the Republic  of 
Slovenia,  the  Republic  of  Finland,  the  Kingdom  of  Spain,  the  Republic  of  Italy,  the 
Kingdom  of  Sweden,  addressed  a  joint  letter  to  the  Commission  requesting  it  to 

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Council  Regulation  (EU)  2025/2600  of  12  December  2025  on  emergency  measures  addressing  the 
serious economic difficulties caused by Russia’s actions in the context of the war of aggression against 
Ukraine (OJ L, 2025/2600, 13.12.2025). 

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“submit a proposal to the Council for a decision authorising an enhanced cooperation 
that has as objective and scope to provide a loan to Ukraine of EUR 90 billion for the 
years  2026-2027  based  on  EU  borrowing  on  the  capital  markets  backed  by  the  EU 
budget  headroom  by  giving  effect  to  paragraphs  3  and  4  of  the  European  Council 
conclusions  (EUCO  24/25)  as  well  as  paragraph  8  of  the  text  on  Ukraine  firmly 
supported by 25 Head of States or Governments (EUCO 26/25)”.  

(11)  The  financial  assistance  to  third  countries,  as  set  out  by  Article  212  TFEU,  is  not 
included in the list of areas of exclusive competence of the Union referred to in Article 
3(1)  TFEU.  The  provision  of  a  financial  assistance  to  Ukraine  under  the  modalities 
envisaged  by  the  European  Council  in  its  conclusions  of  18  December  2025  (‘the 
envisaged enhanced cooperation’) therefore falls within the framework of the Union's 
non-exclusive competence. 

(12)  The envisaged enhanced cooperation supports different objectives which will reinforce 
the  integration  process  in  accordance  with  Article  20(1)  TEU.  Firstly,  providing 
financial assistance to Ukraine would contribute to the objectives of the Union as set 
out in Article 3 TEU, in particular to peace and security in the Union and in the world 
as  well  as  to  the  sustainable  development  of  Europe  based  inter  alia  on  balanced 
economic  growth  and  price  stability.  Indeed  such  an  assistance  would  allow  to 
mitigate  the  effects  of  Russian’s  actions  on  the  security  and  on  the  economy  of  the 
Union  and  of  its  neighbourhood.  A  defeat  by  Ukraine  would  be  associated  with  an 
increased risk of aggression by Russia against one of the Member States or a country 
in  the  neighbourhood  of  Ukraine,  including  candidate  countries,  having  direct  and 
indirect repercussions on the security and economic situation in the Union. It can also 
be expected that the repercussions on the Union’s economy due to Russia’s aggression 
would be even more severe in the case where Ukraine would not be able to support the 
fiscal  efforts  that  are  necessary  for  the  continuation  of  its  war  effort.  Secondly, 
considering that Ukraine is  also a candidate to accede to the Union, this support is a 
strategic investment of the Union in peace, security, stability and prosperity in Europe 
and  allows  the  Union  to  be  better  positioned  to  address  global  challenges  while 
contributing to the implementation of the Ukraine Facility Regulation (EU) 2024/792 
and its focus on rule of law reforms, public administration reform and the functioning 
of  democratic  institutions  as  key  fundamentals  for  accession.  Thirdly,  providing 
assistance  to  Ukraine  would  also  be  beneficial  for  the  internal  market  and  would 
provide increased economic and trade opportunities to the mutual benefit of the Union 
and  Ukraine,  while  supporting  a  gradual  transformation  of  the  country  including 
through the implementation of the Ukraine Plan as amended by Council Implementing 
Decision (EU) 2025/2157. Fourthly, the Union is confronted to a stark deterioration of 
its security context, linked not only to Russia’s persistent threat and its intensified shift 
to  a  war-time  economy  and  to  the  evolution  of  the  war  in  Ukraine,  but  also  to 
uncertainties stemming from the advent of a geopolitical situation in which the Union 
has to markedly step up its efforts to ensure its defence autonomously. In this context, 
providing  a  financial  assistance  to  Ukraine  should  also  allow  to  support  objectives 
which  would  be  beneficial  for  the  reinforcement  of  the  European  Defence  and 
Technological  Industrial  basis  (EDTIB),  in  a  context  where  several  instruments  and 
programmes  of  the  Union  promote  defence  industrial  cooperation  with  Ukraine,  in 
particular  Council  Regulation  (EU)  2025/1106  of  27  May  2025  establishing  the 
Security  Action  for  Europe  (SAFE)  through  the  Reinforcement  of  the  European 

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Defence  Industry  Instrument8  and  the  European  Defence  Industry  Programme 
(EDIP)9.  

(13)  The  envisaged  enhanced  cooperation,  which  consists  in  having  a  group  of  Member 
States  providing  a  financial  assistance  to  Ukraine,  complies  with  the  Treaties  and 
Union  law  and  is  to  be  organised  in  a  way  which  does  not  undermine  the  internal 
market  or  economic,  social  or  territorial  cohesion.  It  should  also  not  constitute  a 
barrier to, or a discrimination in, trade between Member States and does not distort the 
competition between them.  

(14)  The  implementation  of  the  envisaged  enhanced  cooperation  requires  expenditures, 
other than administrative costs entailed for the institutions ('expenditure of enhanced 
cooperation'),  and  contingent  liabilities  from  financial  assistance,  which  are  to  be 
guaranteed over and above the MFF ceiling ('guarantee for contingent liabilities').  

(15)  The envisaged enhanced cooperation respects the competences, rights and obligations 
of  non-participating  Member  States.  The  non-participating  Member  States  should 
contribute neither to the financing of the expenditure of the enhanced cooperation nor 
to  the  coverage  of  the  guarantee  for  the  contingent  liabilities.  For  this  purpose,  the 
Member States not participating in the enhanced cooperation on the establishment of 
the Reparations  Loan should  be entitled to an  adjustment in  accordance  with  Article 
11  of  Council  Regulation  (EU,  Euratom)  No  609/2014.10  That  adjustment  should 
cover  the  expenditure  of  enhanced  cooperation  and  any  call  on  the  guarantee  for 
contingent liabilities.  

(16)  The  envisaged  enhanced  cooperation  is  open  at  any  time  to  all  the  Member  States 
which  want  to  participate  in  it  under  the  terms  defined  in  this  Decision.  Any  newly 
participating  Member  State  in  the  enhanced  cooperation  should  contribute  to  the 
financing of the expenditure of the enhanced cooperation from the date on which the 
participation  of  that  Member  State  becomes  effective  pursuant  to  Article  331(1) 
TFEU.  Any  newly  participating  Member  State  should  also  ensure  coverage  of  the 
guarantee  for  contingent  liabilities  entered  into  from  the  start  of  the  enhanced 
cooperation by the Union, in view of its implementation. To that effect, that Member 
State  should  contribute,  as  of  the  date  on  which  its  participation  becomes  effective 
pursuant  to  Article  331(1)  TFEU,  with  its  proportionate  share,  to  any  call  on  the 
guarantee for contingent liabilities, including calls related to contingent liabilities into 
which the Union entered, in view of the implementation of this enhanced cooperation, 
before that date. 

HAS ADOPTED THIS DECISION:  

Article 1 

The Kingdom of Belgium, the Republic of Bulgaria, the Kingdom of Denmark, the Federal 
Republic of Germany, the Republic of Estonia, the Republic of Croatia, Ireland, the Hellenic 
Republic, the French Republic, the Republic of Cyprus, the Republic of Latvia, the Republic 

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Council  Regulation  (EU)  2025/1106  of  27  May  2025  establishing  the  Security  Action  for  Europe 
(SAFE)  through  the  Reinforcement  of  the  European  Defence  Industry  Instrument  (Text  with  EEA 
relevance), (OJ L, 2025/1106, 28.5.2025, p.39-52). 
COM(2024) 150 final. 
Council  Regulation  (EU,  Euratom)  No  609/2014  of  26  May  2014  on  the  methods  and  procedure  for 
making available the traditional, VAT and GNI-based own resources and on the measures to meet cash 
requirements (Recast) (OJ L 168, 7.6.2014, p. 39). 

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of Lithuania, the Grand Duchy of Luxembourg, the Republic of Malta, the Kingdom of the 
Netherlands,  the  Republic  of  Austria,  the  Republic  of  Poland,  the  Portuguese  Republic, 
Romania,  the  Republic  of  Slovenia,  the  Republic  of  Finland,  the  Kingdom  of  Spain,  the 
Republic  of  Italy,  the  Kingdom  of  Sweden,  are  hereby  authorised  to  establish  enhanced 
cooperation between themselves on the establishment of a Loan for Ukraine under the terms 
described in this Decision, by applying the relevant provisions of the Treaties.  

This Decision shall enter into force on the day of its adoption.  

Article 2 

Done at Brussels, 

For the Council 
The President 

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