15 indicators of the Ukraine Facility plan that were not fulfilled by the end of 2025 could cost Ukraine around EUR 4 billion, according to a presentation by the RRR4U consortium (Resilience, Reconstruction and Relief for Ukraine).
According to the RRR4U presentation published on the organization’s website, the value of unfulfilled indicators for Q1–Q3 2025 exceeds EUR 1.3 billion. In particular, in the first quarter of 2025 Ukraine failed to meet the indicator on increasing staffing levels at the High Anti-Corruption Court (about EUR 0.3 billion). In the second quarter, indicators related to the review of judges’ integrity declarations and the digitalization of enforcement proceedings were not fulfilled (about EUR 0.7 billion). In the third quarter, Ukraine failed to meet the indicator on adopting legislation for the electricity integration package (about EUR 0.3 billion).
The largest volume of unmet commitments falls on the fourth quarter of 2025, during which Ukraine failed to fulfill 11 indicators with a total value exceeding EUR 2.6 billion. These include amendments to civil service legislation, lifting the suspension of the law on state aid, deregulation in certain sectors, improvement of permitting procedures for investments in renewable energy, defining a special status for the National Energy and Utilities Regulatory Commission (NEURC), appointing a nominated electricity market operator, and the entry into force of laws in the areas of housing policy, district heating, and railway transport.
At the same time, the presentation notes that the European Commission’s introduction of a partial assessment mechanism allows Ukraine to receive part of the funding for individual indicators. However, unfulfilled commitments may only be carried over for a limited period, after which the corresponding funds may be lost irreversibly.
RRR4U also points to risks in 2026. In particular, the indicator related to filling vacant positions at the High Anti-Corruption Court (HACC) has remained unfulfilled for nearly a year, creating a risk of an irreversible loss of about EUR 0.3 billion as early as the end of Q1 2026. In addition, as of early 2026, Ukraine has not fulfilled any indicators for Q1 2026, while a significant list of commitments remains for subsequent quarters.
The Ukraine Facility is a European Union financial support program for Ukraine totaling EUR 50 billion for 2024–2027. Funding under the program is provided in tranches following confirmation of compliance with agreed structural indicators of Ukraine’s Plan. The total amount of assistance allocated to Ukraine under the Ukraine Facility since March 2024 amounts to EUR 26.8 billion, representing nearly 70% of the funds available under the first pillar of the program. The latest tranche from the European Commission was disbursed on December 22, 2025, in the amount of EUR 2.3 billion.
