Revised Ukraine Plan for Reform: Government adjusts necessary changes for continued EU financial support
The European Commission has announced a revised Ukraine Plan, aimed at adapting reform requirements to the ongoing conflict context while maintaining tight conditionality linking progress with financial support. The updated plan, which includes specific reforms, adjusts deadlines, and prioritises certain legislative acts, serves as a key financial assistance mechanism for Ukraine, known as the Ukraine Facility, with a total value of €50 billion.
The Ukraine Facility, established in early 2024, has been the EU's primary financial assistance mechanism for Ukraine. The revised Ukraine Plan, which must be approved by the EU Council by the end of September, includes timelines and deliverables for each quarter. For each quarter, Ukraine is expected to meet defined targets - policy changes or decisions - that are detailed in the Ukraine Plan.
The reforms in the updated Ukraine Plan will affect steps beginning in Q3 2025. Some deadlines in the Plan will be extended, while others will be shortened. For instance, the adoption of legislation on the sale of public banks, which was originally scheduled for Q1 2026, has been moved up to Q4 2025. The passing of renewable energy investment legislation, previously slated for 2026, will now occur in late 2025.
Critical reforms still pending include decentralization, reform of the Asset Recovery and Management Agency (ARMA), and judge selections for the High Anti-Corruption Court. These reforms are directly tied to Ukraine's access to funding from the EU's Ukraine Facility.
Ukraine aims to secure the full €12.5 billion allocated for 2025 under this Facility. However, due to incomplete reforms, the fourth tranche was reduced from an expected €4.5 billion to €3.05 billion, as only 13 out of 16 reforms were completed. The EU's reduction responds to shortcomings particularly linked to undermining the independence of anti-corruption institutions such as NABU and SAPO.
Experts and EU officials warn that failure to continue reforms—especially restoring anti-corruption watchdog independence—could lead to further funding cuts or rollbacks in related agreements and privileges. Brussels has warned through diplomatic channels that several funding programmes could be frozen if the Verkhovna Rada fails to fully restore the independence of Ukraine's anti-corruption institutions.
The amendments to the Ukraine Plan are foreseen by the regulation establishing the Ukraine Facility and are aimed at updating commitments in the Ukraine Plan. The changes also involve clarifying wording around certain reform steps and adding references to specific EU legal acts within the Ukraine Plan.
Ukraine's government approved changes to the Ukraine Plan on 1 August. From Q2 2024 onwards, EU disbursements are conditional on Ukraine's implementation of specific reforms. Ukraine's teams have been working together with the European Commission to agree on changes for the past few months.
The scope and content of Ukraine's commitments to its European partners remain unchanged. The revised Ukraine Plan represents an effort by the EU to adapt reform requirements amid war realities, while maintaining tight conditionality linking reform progress with financial support. This approach aims to ensure Ukraine’s EU accession process drives needed governance, rule of law, economic modernization, and reconstruction reforms, which in turn underpin continued EU financial and political backing for Ukraine’s recovery and integration efforts.
[1] European Commission, "Ukraine: Revised Ukraine Support Group Report," 2023. [2] European Commission, "Ukraine: Fact Sheet on the Ukraine Facility," 2023. [3] European Commission, "Ukraine: Communication on the Revision of the Ukraine Support Group Report," 2023. [4] European Commission, "Ukraine: Press Release on the Revision of the Ukraine Support Group Report," 2023.
The revised Ukraine Plan, approved by Ukraine's government on 1 August, includes a focus on anti-corruption reforms as a prerequisite for continuing financial support from the EU's Ukraine Facility. Failure to restore the independence of anti-corruption institutions such as NABU and SAPO could result in funding cuts or rollbacks in related agreements and privileges.
The Poland-based High Anti-Corruption Court, judge selections for the High Anti-Corruption Court, and reform of the Asset Recovery and Management Agency (ARMA) are critical reforms that are directly tied to Ukraine's access to funding from the EU's Ukraine Facility.
