In 2025, Ukraine fails to fulfill 15 indicators of Ukraine Facility for almost EUR 4 bln – RRR4U consortium
The 15 indicators of the plan under the Ukraine Facility program that were not fulfilled by the end of 2025 could cost Ukraine about EUR 4 billion, according to the presentation of the RRR4U consortium (Resilience, Reconstruction and Relief for Ukraine).
According to an RRR4U presentation on the organization’s website, as of the first three quarters of 2025, the value of unmet indicators exceeds EUR 1.3 billion. In the first quarter, the target to increase staffing at the High Anti-Corruption Court was not met (about EUR 0.3 billion); in the second quarter, indicators related to reviewing judges’ integrity declarations and digitalizing enforcement proceedings were unmet (around EUR 0.7 billion); and in the third quarter, the target for adopting legislation on the electricity integration package was not achieved (about EUR 0.3 billion).
The largest volume of unmet obligations fell in the fourth quarter of 2025, when Ukraine failed to meet 11 indicators totaling more than EUR 2.6 billion. These include changes to civil service legislation, lifting the suspension of the state aid law, deregulation in certain sectors, improving permitting procedures for renewable energy investments, defining a special status for the National Energy and Utilities Regulatory Commission (NEURC), appointing the nominated electricity market operator, and enacting laws in housing policy, centralized heating, and railway transport.
The presentation also notes that the European Commission’s partial assessment mechanism allows Ukraine to receive funding for individual indicators. However, unmet obligations can only remain open for a limited period; after that, the corresponding funds may be permanently lost.
RRR4U also highlights risks for 2026. In particular, the indicator for filling vacant positions at the High Anti-Corruption Court (HACC) has remained unmet for almost a year, creating a risk of permanently losing about EUR 0.3 billion by the end of Q1 2026. In addition, as of early 2026, Ukraine has not met any indicators for Q1 2026, while a significant list of obligations remains for the coming quarters.
The Ukraine Facility is an EU financial support program for Ukraine totaling EUR 50 billion for 2024-2027, with funding disbursed in tranches upon confirmation of agreed structural indicators in the Ukraine Plan. As of March 2024, a total of EUR 26.8 billion has been allocated under the Ukraine Facility, representing nearly 70% of the funds available under the first pillar of the program. The most recent tranche from the European Commission, EUR 2.3 billion, was received on December 22, 2025.