Council Implementing Decision (EU) 2025/2157 of 17 October 2025 amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of the Ukraine Plan

Official Journal EN of the European Union L series 2025/2157 27.10.2025 COUNCIL IMPLEMENTING DECISION (EU) 2025/2157 of 17 October 2025 amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of the Ukraine Plan THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 establishing the Ukraine Facility(1), and in particular Article 20(2) thereof, Having regard to the proposal from the European Commission,

Whereas:

(1) Following the submission of the Ukraine Plan (the ‘Plan’) by Ukraine on 20 March 2024, the Commission proposed its positive assessment to the Council. The Council approved that positive assessment by Council Implementing Decision (EU) 2024/1447(2).

(2) Since the Council’s approval of the Plan, and in accordance with Articles 24 and 25 of Regulation (EU) 2024/792, a sum of EUR 6 000 000 000 has been disbursed to Ukraine as exceptional bridge financing, and a sum of EUR 1 890 000 000 has been disbursed to Ukraine in the form of pre-financing representing an advance payment of 7 % of the loan support that Ukraine is eligible to receive under the Plan. An additional sum of EUR 14 995 446 398 has been disbursed to Ukraine in the first four instalments under the Plan, pursuant to Article 26(4) of Regulation

(EU) 2024/792.

(3) The situation in Ukraine remains very challenging. Russia’s continued war of aggression is delaying Ukraine’s economic recovery and reconstruction and placing enormous pressure on its administrative capacities.

Consequently, some qualitative and quantitative steps under the Plan are no longer achievable by Ukraine, either partially or totally, particularly in terms of their timing.

(4) On 7 August 2025, after consulting the Verkhovna Rada, Ukraine proposed amendments to the Plan pursuant to Article 20(1) of Regulation (EU) 2024/792 (the ‘proposed amendments’), on grounds that the Plan is partially no longer achievable because of objective circumstances.

(5) The proposed amendments concern 46 out of the 146 qualitative and quantitative steps set out in Implementing Decision (EU) 2024/1447. The proposed amendments refer to steps due to be implemented between Q3 2025 and Q4 2027. For 10 of those steps, Ukraine proposed extending the initial deadline, and four steps were advanced. The description of 36 steps has been slightly amended, largely to correct clerical errors. Two steps were each split into two, two steps were merged into one, and one step linked to an interim target was deleted. Investment allocations have been lowered to reflect alternative donor sources for specific investments or a lower demand than initially expected, allowing the amounts to be re-allocated to general budget support. Such re-allocation reflects, and helps to address, the fiscal pressures created by the ongoing war. Consequently, the total number of steps in the Plan and the initial number of reforms and investments has not changed. Some amendments were proposed regarding arrangements for the implementation of, monitoring of and reporting on the Plan, without any impact on the Commission’s initial assessment of the Plan.

(1) OJ L, 2024/792, 29.2.2024, ELI: http://data.europa.eu/eli/reg/2024/792/oj.

(2) Council Implementing Decision (EU) 2024/1447 of 14 May 2024 on the approval of the assessment of the Ukraine Plan (OJ L, 2024/1447, 24.5.2024, ELI: http://data.europa.eu/eli/dec_impl/2024/1447/oj).

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 1/102EN OJ L, 27.10.2025

(6) In accordance with Article 18 of Regulation (EU) 2024/792, the Commission has assessed the relevance, comprehensiveness and appropriateness of the proposed amendments. In carrying out that assessment, the Commission acted, as much as possible, in cooperation with Ukraine. The Commission assessed in particular whether the proposed amendments represent a needs-based, comprehensive and adequately balanced response to the objectives of the Ukraine Facility, whether they contribute to and are consistent with addressing the relevant challenges identified in the context of Ukraine’s Union accession path, whether they are consistent with the general principles of the Ukraine Facility set out in Article 4 of Regulation (EU) 2024/792, and whether they meet Ukraine’s recovery, reconstruction and modernisation needs. The proposed amendments maintain the Plan’s ambition to contribute to climate change mitigation and adaptation, to the promotion of the rule of law, to social objectives and to gender equality and the empowerment of women and girls. The proposed amendments do not affect the current arrangements for the protection of the financial interests of the Union. Finally, the Commission has assessed whether the Verkhovna Rada has been duly consulted in accordance with Ukraine’s national legal framework, whether the proposed amendments take into consideration, where appropriate, the inputs of stakeholders, and whether the proposed amendments ensure that other donors are able to support the Plan’s objectives.

(7) The Commission considers that the proposed amendments do not affect the positive assessment of the Plan set out in Implementing Decision (EU) 2024/1447 as regards the Plan’s relevance, comprehensiveness and appropriateness.

In its assessment, the Commission took into account in particular the assessment criteria laid down in Article 18(3), points (a) to (l), of Regulation (EU) 2024/792.

(8) Pursuant to Article 20(3) of Regulation (EU) 2024/792, the Commission considers that the proposed amendments are justified.

(9) Pursuant to Article 7 of Regulation (EU) 2024/792, it is possible for Member States, third countries, international organisations, international financial institutions or other sources to provide additional contributions to the Ukraine Facility, including to the Plan.

(10) Pursuant to Article 7 of Regulation (EU) 2024/792, Sweden will provide SEK 750 000 000, which is the equivalent of approximatively EUR 67 000 000, as additional financial contribution to Pillar I of the Ukraine Facility in the form of non-repayable financial support. That contribution constitutes external assigned revenue. The Commission is responsible for managing that contribution in accordance with the procedures applicable to the expenditure of the Union, in particular the procedures under Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council(3) and Regulation (EU) 2024/792.

(11) The financial contribution from Sweden should be made available to Ukraine subject to the entry into force of a transfer agreement between Sweden and the Commission and the transfer of the related financial contribution.

That financial contribution is allocated to the seventh, eighth and ninth quarterly instalments of the Plan and is expected to be disbursed subject to the satisfactory fulfilment of the relevant qualitative and quantitative steps. The amounts of the seventh, eighth and ninth instalments of the Plan will be adjusted accordingly to take into account the final amount of that financial contribution expressed in euro resulting from the application of the official exchange rate at the time of the transfer.

(12) The Commission considers that the proposed amendments satisfactorily comply with the criteria for assessment set out in Article 18(3) of Regulation (EU) 2024/792, and the proposed amendments should be positively assessed.

Therefore the assessment should be approved and the qualitative and the quantitative steps necessary to implement the Ukraine Plan, as amended by this Council Implementing Decision, and the additional amount to be made available from the Union should be set out in this Decision in accordance with Article 19 of Regulation (EU) 2024/792.

(13) Implementing Decision (EU) 2024/1447 should therefore be amended accordingly,

HAS ADOPTED THIS DECISION:

Article 1 Implementing Decision (EU) 2024/1447 is amended as follows:

(3) Regulation (EU, Euratom) 2024/2509 of the European Parliament and of the Council of 23 September 2024 on the financial rules applicable to the general budget of the Union (OJ L, 2024/2509, 26.9.2024, ELI: http://data.europa.eu/eli/reg/2024/2509/oj).

2/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025

(1) Article 1 is replaced by the following: ‘Article 1 Approval of the assessment of the Ukraine Plan On the basis of the criteria set out in Article 18 of Regulation (EU) 2024/792, the Commission assessment of the Ukraine Plan, as amended by Council Implementing Decision (EU) 2025/2157(*), is approved. The reforms and investment projects described in the amended Ukraine Plan, the arrangements and timetable for monitoring and implementing the Ukraine Plan, including the qualitative and quantitative steps, and the arrangements for providing the Commission, the European Anti-Fraud Office, the European Court of Auditors and, where applicable, the European Public Prosecutor’s Office with full access to the underlying documents and data are set out in the Annex to this Decision.

(*) Council Implementing Decision (EU) 2025/2157 of 17 October 2025 amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of the Ukraine Plan (OJ L, 2025/2157, 27.10.2025, ELI: http:// data.europa.eu/eli/dec/2025/2157/oj).’;

(2) in Article 2, the following paragraph is added: ‘4. An additional financial contribution, in the form of non-repayable support amounting to the equivalent in EUR of SEK 750 000 000 at the official exchange rate at the time of the transfer of the contribution by Sweden to the Ukraine Facility, shall be made available to Ukraine pursuant to Article 7 of Regulation (EU) 2024/792.

The additional financial contribution referred to in the first subparagraph of this paragraph shall be implemented in accordance with the rules and conditions applicable to the amount referred to in paragraph 1 of this Article.’;

(3) the Annex is replaced by the text set out in the Annex to this Decision.

Article 2 This Decision shall enter into force on the date of its adoption.

Done at Luxembourg, 17 October 2025.

For the Council The President M. HEUNICKE

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 3/102EN OJ L, 27.10.2025 ANNEX FINANCIAL SUPPORT UNDER THE UKRAINE PLAN The instalments referred to in Article 19(.2), point (c) of Regulation (EU) 2024/792 shall be organised in the following manner, considering also the indicative maximum annual amounts as provided by the Regulation:

First instalment (Q2-2024)

Total amount: EUR 4 365 691 244 Non-repayable support: EUR 1 500 000 000

Loans: EUR 2 865 691 244

Total number of steps: 9 Sequential Reform/Investment Name of the step number

2.2 C2.R1 Improved revenue management Adoption of the strategic plan for the digitalisation of the State Customs Service

2.3 C2.R2 Improved public financial Approval of the Budget Declaration for 2025-2027 management

2.7 C2.R4 Improved public investment Adoption of the Action plan for the implementation of the management Roadmap for reforming public investment management

4.2 C4.R1 Developing the institutional Appointment of a new head of the National Agency on capacity of the anti-corruption Corruption Prevention infrastructure

6.2 C6.R2 Improved governance and Entry into force of the legislation on corporate governance of management of state-owned enterprises state-owned enterprises

8.3 C8.R2 Reform of the Economic Security Entry into force of the law on revising the legal basis of the Bureau of Ukraine Economic Security Bureau of Ukraine.

10.1 C10.R1 Integrated National Energy and Adoption of the Integrated National Energy and Climate Plan Climate Plan

10.15 C10.R7 Improved energy efficiency in Adoption of the Strategy for thermal modernisation of public buildings and improvement of buildings until 2050 and the Action Plan public procurement procedures

12.8 C12.R6 Demining of land and water areas Adoption of the strategic document on Mine Action for the period up to 2033 4/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Second instalment (Q3 2024)

Total amount: EUR 4 248 847 926 Non-repayable support: EUR 1 500 000 000

Loans: EUR 2 748 847 926

Total number of steps: 9 Sequential Reform/Investment Name of the step number

4.1 C4.R1 Developing the institutional Increased manpower for the Specialised Anti-Corruption capacity of the anti-corruption Prosecutor’s Office infrastructure

4.4 C4.R2 Improving the legal framework for Entry into force of the amended Criminal Code and of the a more effective fight against corruption Criminal Procedure Code

4.6 C4.R2 Improving the legal framework for Adoption of an Action Plan for the implementation of the a more effective fight against corruption Asset Recovery Strategy for 2023-2025

7.6 C7.R6 Improved functioning of the labour Adoption of the Demographic Development Strategy for the market period up to 2040

8.1 C8.R1 Improved regulatory environment Adoption of the Action Plan on deregulation

9.5 C9.R3 Development and implementation Adoption of resolutions to amend the State Strategy for of regional policy Regional Development for 2021-2027

10.8 C10.R3 Electricity market reform Entry into force of the secondary legislation on the Regulation on Wholesale Energy Market Integrity and Transparency

(REMIT) law

15.1 C15. R1 Prevention, reduction and control Entry into force of the legislation on prevention, reduction, of industrial pollution and control of industrial pollution with partial application of provisions

15.10 C15.R6 Environmental Impact Assessment Development of a concept note defining the scope of

(EIA) and Strategic Environmental deviations from the Environmental Impact Assessment (EIA) Assessment (SEA) and Strategic Environmental Assessment (SEA) rules Third instalment (Q4 2024)

Total amount: EUR 3 717 741 935 Non-repayable support: EUR 400 000 000

Loans: EUR 3 317 741 935

Total number of steps: 13 Sequential Reform/Investment Name of the step number

2.1 C2.R1 Improved revenue management Adoption of the strategic plan for digitalisation of the State Tax Service

3.6 C3.R2 Reforms of insolvency and Entry into force of the legislation on the improvement of enforcement of court decisions insolvency regime

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 5/102EN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

6.1 C6.R1 Adopting a state ownership policy Adoption of the state ownership policy and of the triage of state-owned enterprises

7.5 C7.R5 Improved social infrastructure and Adoption of the Strategy for reforming Psychoneurological, de-institutionalisation Other residential Institutions and De-institutionalisation of Care for Persons with Disabilities, and Older Persons and of the Strategy for Ensuring the Right of Every Child in Ukraine to Grow Up in a Family Environment for 2024-2028

8.7 C8.R5 Harmonisation of legislation and Adoption of the resolution for the resumption of market standards with the EU surveillance measures and control of non-food products, including product safety inspection

9.6 C9.R3 Development and implementation Adoption of resolutions for development of urban planning of regional policy at the local level

10.2 C10.R2 Improved regulatory framework Introduction of a market-based framework for renewable for increasing renewable energy and energy ensuring stable operation of the energy system

10.10 C10.R5 Ensuring independence of Entry into force of the legislation to ensure the independence National Energy and Utilities Regulatory of the National Energy Utilities Regulatory Commission Commission

11.1 C11.R1 Comprehensive planning of Adoption of the revised National Transport Strategy of transport sector Ukraine until 2030

11.2 C11.R2 Development of Ukraine’s export Adoption of the Strategy for developing and expanding the logistics potential border infrastructure with EU Member States and the Republic of Moldova until 2030

12.1 C12.R1 Aligning the institutional Adoption of the Strategy for Agriculture and Rural framework on agriculture and rural Development until 2030 development with the EU policy

12.5 C12.R4 Improvement of the official Entry into force of the legislation on the State Agrarian public electronic farm register Register

13.1 C13.R1 Strengthening strategic planning Entry into force of the legislation on revising the National and ensuring optimum framework for Programme for the Development of the Mineral Resource strategic investors Base of Ukraine to 2030 6/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Fourth instalment (Q1 2025)

Total amount: EUR 4 779 953 917 Non-repayable support: EUR 500 000 000

Loans: EUR 4 279 953 917

Total number of steps: 16 Sequential Reform/Investment Name of the step number

1.1 C1.R1 Civil service remuneration reform Entry into force of the legislative changes to the civil service remuneration reform

4.3 C4. R1 Developing the institutional Increased manpower for the High Anti-Corruption Court capacity of the anti-corruption infrastructure

4.7 C4.R2 Improving the legal framework for Entry into force of the law reforming the Asset Recovery and a more effective fight against corruption. Management Agency

6.6 C6.R3 Separation of accounts between Adoption of Roadmap on the separation of public service public service obligations (PSO) and obligations (PSO) and non-PSO activities non-PSO activities in state-owned enterprises

7.2 C7.R2 Improved preschool education Entry into force of the legislation on preschool education

7.11 C7.R9 Improved cultural development Adoption of the Strategy for the Development of Ukrainian Culture

9.1 C9.R1 Advancing decentralisation Entry into force of the legislation on reforming of territorial organisation of the executive authorities in Ukraine with delayed application

9.4 C9.R2 Increased involvement of citizens Entry into force of the legislation for public consultations on to decision making process at the local public policy with delayed application level

12.3 C12.R2 Ensuring a functional land Set up of an automated system for public monitoring of land market relations

12.7 C12.R5 Long-term development of the Adoption of the long-term plan on the irrigation system irrigation system to increase climate resilience of the sector

13.5 C13.R2 Improved administrative Set up of an upgraded e-cabinet of subsoil users procedures

14.1 C14.R1 Secure and efficient digital Adoption of a revised Plan for allocation and use of the radio infrastructure spectrum in Ukraine

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 7/102EN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

14.2 C14.R1 Secure and efficient digital Entry into force of the legislation on strengthening the cyber infrastructure security capabilities of state information resources and critical information infrastructure

14.3 C14.R2 Digitalisation of public services Adoption of the Action Plan for digitalisation of public services until 2026

15.2 C15.R2 Climate policy Entry into force of the legislation on the State Climate Policy

15.5 C15.R3 Market mechanisms of carbon Adoption of the Action Plan for the Establishment of pricing a National Greenhouse Gas Emissions Trading System Fifth instalment (Q2 2025)

Total amount: EUR 2 124 423 963 Non-repayable support: EUR 300 000 000

Loans: EUR 1 824 423 963

Total number of steps: 11 Sequential Reform/Investment Name of the step number

3.5 C3.R1 Enhancing the accountability, Entry into force of the legislation revising the declarations of integrity and professionalism of the integrity of judges and their verification process judiciary

3.8 C3.R2 Reforms of insolvency and Entry into force of the law on the enforcement of court enforcement of court decisions decisions related to monetary and non-monetary obligations and further digitalizing the enforcement proceedings.

5.4 C5.R3 Improved resolution of Adoption of the strategy for resolution of non-performing non-performing loans loans

7.1 C7.R1 Improved vocational education Entry into force of the legislation on vocational education

7.10 C7.R8 Improved social security Adoption of the resolution on the procurement of social services

8.4 C8.R3 Access to finance and markets Adoption of the Small and Medium Enterprises (SME) Strategy and Action Plan for its implementation

9.2 C9.R1 Advancing decentralisation Endorsement and publication on the website of the Ministry of Communities, Territories and Infrastructure Development of Ukraine of a study on the necessary measures to grant legal personality to municipalities

10.4 C10.R2 Improved regulatory framework Adoption of the Roadmap of the process of separation of the for increasing renewable energy and Renewable Energy Surcharge from the Transmission Tariff ensuring stable operation of the energy system 8/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

13.3 C13.R2 Improved administrative Publication of a pipeline of investment projects for extraction procedures of critical raw materials

13.4 C13. R2 Improved administrative Launch of Product Sharing Agreement (PSA) international procedures tenders ensuring their transparency

15.6 C15.R3 Market mechanisms of carbon Resumption of the compulsory monitoring, reporting and pricing verifying (MRV) system Sixth instalment (Q3 2025)

Total amount: EUR 2 655 529 954 Non-repayable support: EUR 300 000 000

Loans: EUR 2 355 529 954

Total number of steps: 10 Sequential Reform/Investment Name of the step number

2.8 C2.R4 Improved public investment Development and implementation of the digital management management tool for the reconstruction of Ukraine

3.1 C3.R1 Enhancing the accountability, Filling of at least 20 % of judicial vacancies integrity and professionalism of the judiciary

3.2 C3.R1 Enhancing the accountability, Entry into force of the law establishing a new court to hear integrity and professionalism of the administrative cases judiciary

5.2 C5.R2 Reducing state ownership in the Entry into force of the legislation on the principles for the sale banking sector of state-owned banks

8.8 C8.R5 Harmonisation of legislation and Adoption of harmonised standards for three groups of standards with the EU industrial products

10.5 C10.R3 Electricity market reform Adoption of the Law on the transposition of the electricity integration package

12.4 C12.R3 Improving the institutional and Entry into force of the legislation on the public support of administrative set up for managing agriculture of Ukraine investment programmes

13.2 C13.R1 Strengthening strategic planning Publishing of a report on the verification of Critical Raw and ensuring optimum framework for Materials’ reserves of Ukraine strategic investors

15.4 C.15.R2 Climate policy Adoption of the second Nationally Determined Contribution of Ukraine to the Paris Agreement

15.9 C15.R5 Increased circular economy Adoption of the National Waste Management Plan until 2033

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 9/102EN OJ L, 27.10.2025 Seventh instalment (Q4 2025)

Total amount: EUR 2 944 082 949(1) Non-repayable support: EUR 173 000 000

Loans: EUR 2 771 082 949

Total number of steps: 20 Sequential Reform/Investment Name of the step number

1.2 C1.R2 Merit-based recruitment and Entry into force of the legislative changes to improve the selection procedure for the civil service procedure for entering, passing, and terminating civil service

2.6 C2.R3 Improved public debt Adoption of the medium-term state debt management management strategy

2.9 C2.R5 Improved audit and financial Adoption of the amendments to the relevant legislation on control system state financial control

3.3 C3.R1 Enhancing the accountability, Settlement/adjudication of 20 % of old disciplinary cases not integrity and professionalism of the considered as of end of 2023 judiciary

3.4 C3.R2 Enhancing the accountability, Completion of the qualification evaluation (vetting) in respect integrity and professionalism of the of 50 % of judges who still had to undergo it as of judiciary 30 September 2016

3.9 C3.R2 Reforms of insolvency and A data collection system on the enforcement of court enforcement of court decisions decisions is operational

4.8 C4.R3 Anti-money laundering measures Conduct of the next National Risk Assessment

5.6 C5.R4 Improved capacity of the financial Entry into force of the law on the improvement of the state supervisory authority regulation for capital markets and organised commodity markets

6.7 C6.R3 Separation of accounts between Entry into force on legislation on the separation of public public service obligations (PSO) and service obligations (PSO) and non-PSO activities non-PSO activities in public service obligations

(1) The contribution from the Kingdom of Sweden to be received as external assigned revenue in 2025 makes up in total 750 million Swedish Krona (SEK), which represents approximately EUR 67 million (precise amount will be calculated based on the official exchange rate at the time of the transfer of the contribution). This contribution is intended to co-finance this instalment in the form of non-repayable financial support by an amount of 258 million Swedish Krona (SEK), which represents approximately EUR 23 million, subject to the satisfactory fulfilment of the relevant steps.

10/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

6.9 C6.R4 Improved state aid control Entry into force of the updated legislation on state aid and full framework unsuspension of the application of state aid control

7.8 C7.R7 Ensuring access to housing for Entry into force of the legislation on the Basic Principles of people in need Housing Policy

8.2 C8.R1 Improved regulatory environment Entry into force of the legislation in accordance with the Action Plan on deregulation in specific sectors

10.3 C10.R2 Improved regulatory framework Entry into force of the legislation to improve permitting for increasing renewable energy and procedures for renewable energy investments ensuring stable operation of the energy system

10.7 C10.R3 Electricity market reform Appointment of a new electricity market operator

10.11 C10.R5 Ensuring independence of Entry into force of the amendments to the Law of Ukraine National Energy and Utilities Regulatory ‘On the National Energy and Utilities Regulatory Commission’ Commission

10.13 C10.R6 Improved efficiency in the Adoption of the State targeted economic programme for the district heating energy modernisation of heat generating enterprises for the period up to 2030

10.14 C10.R6 Improved efficiency in the Entry into force of the legislation to support development of district heating the efficient and more sustainable district heating

11.3 C11.R3 Liberalisation in the railways Entry into force of the law on traffic safety and transport sector interoperability of railway transport of Ukrainewith application within three years from its adoption

13.6 C13.R3 Use of modern Extraction Publication of a study on the legislation on ESG reporting Technologies and Integration of Ukraine into Modern Processing Value Chains

15.3 C15.R2 Climate policy Adoption of the resolution on the Scientific and Expert Council on Climate Change and Preservation of the Ozone Layer

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 11/102EN OJ L, 27.10.2025 Eight instalment (Q1 2026)

Total amount: EUR 1 880 870 968(2) Non-repayable support: EUR 147 000 000

Loans: EUR 1 733 870 968

Total number of steps: 8 Sequential Reform/Investment Name of the step number

1.5 C1.R3 Digitalisation of civil service and The Human Resources Management Information System human resources management (HRMIS) is in operation

3.7 C3.R2 Reforms of insolvency and Entry into force of the legislation for simplified insolvency enforcement of court decisions procedures for Micro, Small, and Medium Enterprises

(MSMEs)

3.12 C3.R4 Reform of the Prosecution Service Entry into force of the legislation enabling transparent and merit-based selection of management-level prosecutors

5.1 C5.R1 Assessment of the banking sector Published Resilience assessment in the banking system

8.5 C8.R3 Access to finance and markets Entry into force of the legislation on the simplification of the accession of immovable property to external engineering networks and improvement of regulation in the field of pipeline transport

9.3 C9.R1 Advancing decentralisation Entry into force of the legislation to ensure a better distribution of powers between local governments and executive authorities

12.6 C12.R4 Improvement of the official Publication of report on the implementation of the state public electronic farm register support through the public Agricultural Register

15.8 C15.R5 Increased circular economy Adoption of the Strategy for implementing the principles of the circular economy and its Action Plan

(2) The contribution from the Kingdom of Sweden to be received as external assigned revenue in 2025 makes up in total 750 million Swedish Krona (SEK), which represents approximately EUR 67 million (precise amount will be calculated based on the official exchange rate at the time of the transfer of the contribution). This contribution is intended to co-financed this instalment in the form of non-repayable financial support by an amount of 246 million Swedish Krona (SEK), which represents approximately EUR 22 million, subject to the satisfactory fulfilment of the relevant steps.

12/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Ninth instalment (Q2 2026)

Total amount: EUR 2 411 976 959(3) Non-repayable support: EUR 172 000 000

Loans: EUR 2 239 976 959

Total number of steps: 16 Sequential Reform/Investment Name of the step number

1.4 C1.R3 Digitalisation of civil service and Modernisation of the Unified State Web Portal of Electronic human resources management Services

3.10 C3.R2 Reforms of insolvency and An upgraded IT system for enforcement of court decisions is enforcement of court decisions operational

4.5 C4.R2 Improving the legal framework for Adoption of a new Anti-Corruption Strategy and a State a more effective fight against corruption Anti-Corruption Program for the period after 2025

5.5 C5.R3 Improved resolution of Entry into force of the legal acts to improve resolution of non-performing loans non-performing loans

5.3 C5.R2 Reducing state ownership in the Adoption of the strategy for gradual reduction of state banking sector ownership in the banking sector

6.3 C6.R2 Improved governance and Appointment of Supervisory boards of state-owned management of state-owned enterprises enterprises with a majority of independent members

7.7 C7.R6 Improved functioning of the labour Adoption of the Population Employment Strategy market

7.12 C7.I1 Investments in education Investments of at least EUR 300 million in education

7.14 C7.I2 Investments in healthcare Investments of at least EUR 200 million in healthcare

7.18 C7 I5 Investment in providing housing for Investments of at least EUR 200 million for providing vulnerable groups of the population housing for veterans with disabilities of the I-II groups, family members of deceased veterans and internally displaced persons

9.7 C9.I1 Investments for the recovery, Allocation of at least 5 % of the overall non-repayable reconstruction and modernisation needs financial support for meeting recovery, reconstruction, and of Ukraine’s sub-national authorities modernisation needs of sub-national authorities

10.6 C10.R3 Electricity market reform Entry into force of the legislation on changing the conditions of taxation of participants in the electricity market

(3) The contribution from the Kingdom of Sweden to be received as external assigned revenue in 2025 makes up in total 750 million Swedish Krona (SEK), which represents approximately EUR 67 million (precise amount will be calculated based on the official exchange rate at the time of the transfer of the contribution). This contribution is intended to co-financed this instalment in the form of non-repayable financial support by an amount of 246 million Swedish Krona (SEK), which represents approximately EUR 22 million, subject to the satisfactory fulfilment of the relevant steps.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 13/102EN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

10.9 C10.R4 Liberalisation of electricity and Adoption of a Roadmap for gradual liberalisation of gas and natural gas prices electricity market, to be implemented after the expiration of the martial law

12.9 C12.I1 Investments in demining Investments of at least EUR 30 million in demining of agriculture land

14.4 C14.R2 Digitalisation of public services Entry into force of the legal act on the functioning of the Integrated Electronic Identification System, in line with the principles of Regulation (EU) 2024/1183

15.7 C15.R4 Restoration and conservation of Entry into force of the Law on reducing deforestation and natural resources forest degradation Tenth instalment (Q3 2026)

Total amount: EUR 531 105 991 Non-repayable support: EUR 75 000 000

Loans: EUR 456 105 991

Total number of steps: 5 Sequential Reform/Investment Name of the step number

1.3 C1.R2 Merit-based recruitment and Gradual restoration of merit-based recruitment in the civil selection procedure for the civil service service

3.13 C3.R4 Reform of the Prosecution Service Entry into force of the legislation improving the disciplinary system for prosecutors and increasing the capacity of the Qualification and Disciplinary Commission of Prosecutors

6.4 C6.R2 Improved governance and Corporatisation of key state-owned enterprises management of state-owned enterprises

7.4 C7.R4 Transition from military service to Entry into force of the legislation to implement a transition civilian life system from military service to civilian life

10.16 C10.R7 Improved energy efficiency in Adoption of legal acts on setting minimum energy efficiency public buildings and improvement of performance levels for buildings public procurement procedures 14/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Eleventh instalment (Q4 2026)

Total amount: EUR 531 105 991 Non-repayable support: EUR 100 000 000

Loans: EUR 431 105 991

Total number of steps: 9 Sequential Reform/Investment Name of the step number

2.4 C2.R2 Improved public financial Conduct of the spending review of the state budget management

2.5 C2.R2 Improved public financial Entry into force of the Law on Amendments to the Budget management Code of Ukraine to Define the Procedure for Managing Fiscal Risks of Local Budgets

3.15 C3.R1 Enhancing the accountability, A new court to hear administrative cases is operational integrity and professionalism of the judiciary

3.14 C3.R4 Reform of the Prosecution Service An e-Case Management System in the criminal justice is operational

7.9 C7.R7 Ensuring access to housing for people Entry into force of the legislation on the Social Housing in need Fund

7.3 C7.R3 Improved rehabilitation system for Entry into force of the legislation on rehabilitation of people with disabilities persons with disabilities

10.12 C10.R6 Improved efficiency in the district Cancelation of the moratorium on rising heat and hot heating water tariffs

11.8 C11 R3 Liberalisation in the railways Entry into force of the law on the railway transport market transport sector with a sequential application of its provisions

11.5 C11.R4 Improved shipping and ports Entry into force of the legislation on merchant shipping services and shipping on inland waterways

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 15/102EN OJ L, 27.10.2025 Twelfth instalment (Q1 2027)

Total amount: EUR 318 663 594 Non-repayable support: EUR 70 000 000

Loans: EUR 248 663 594

Total number of steps: 2 Sequential Reform/Investment Name of the step number

11.6 C11.R4 Improved shipping and ports Review and amend the existing national legislation in line services with the principles Regulation (EU) 2017/352 of the European Parliament and of the Council of 15 February 2017 establishing a framework for the provision of port services and common rules on the financial transparency of ports

12.2 C12. R1 Aligning the institutional Establishment of the Farm Sustainability Data Network framework on agriculture and rural (FSDN) system development to the EU policy Thirteenth instalment (Q2 2027)

Total amount: EUR 212 442 396 Non-repayable support: EUR 50 000 000

Loans: EUR 162 442 396

Total number of steps: 2 Sequential Reform/Investment Name of the step number

4.9 C4.R3 Anti-money laundering measures Entry into force of the legislation for the registry of bank accounts for individuals and personal bank deposit boxes, and the registry of bank accounts for legal entities

4.10 C4.R3 Anti money-laundering measures The necessary software and hardware for the the registry of bank accounts for individuals and personal bank deposit boxes, and the registry of bank accounts for legal entities is operational Fourteenth instalment (Q3 2027)

Total amount: EUR 212 442 396 Non-repayable support: EUR 50 000 000

Loans: EUR 162 442 396

Total number of steps: 2 Sequential Reform/Investment Name of the step number

6.8 C6.R3 Separation of accounts between Submission of an audit report confirming the separation of public service obligations (PSO) and public service obligations (PSO) and non-PSO activities non-PSO activities in state-owned enterprises

8.6 C8.R4 Improved public procurement Entry into force of the legislation on harmonising legislation in the field of public procurement with the EU acquis.

16/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Fifteenth instalment (Q4 2027)

Total amount: EUR 1 402 119 817 Non-repayable support: EUR 0

Loans: EUR 1 402 119 817

Total number of steps: 14 Sequential Reform/Investment Name of the step number

3.11 C3.R3 Digitalisation of the judicial Set up of IT solutions in the judicial system system

6.5 C6.R2 Improved governance and Submission of a report showing that the principles of management of state-owned enterprises corporate governance are duly followed

7.13 C7.I1 Investments in education Investments of at least EUR 650 million in education

7.15 C7.I2 Investments in healthcare Investments of at least EUR 400 million in healthcare

7.16 C7.I3 Investments in social infrastructure Investments of at least EUR 350 million in social infrastructure

7.17 C7.I4 Investments in compensation for Investments of at least EUR 600 million for financial damaged or destroyed housing compensations for damaged housing

7.19 C7.I5 Investments in providing housing Investments of at least EUR 450 million for providing for vulnerable groups of the population housing for veterans with disabilities of the I-II groups, family members of deceased veterans and internally displaced persons

8.9 C8.R6 Addressing late payments Entry into force of the legislation on combating late payments

8.10 C8.I1 Investments in financial support Investments of at least EUR 450 million for financial support for micro-enterprises and SMEs to micro-enterprises and SMEs and small and medium processing enterprises

9.8 C9.I1 Investments for the recovery, Allocation of at least 20 % of the overall non-repayable reconstruction and modernisation needs financial support for meeting recovery, reconstruction, and of Ukraine’s sub-national authorities modernisation needs of sub-national authorities

10.17 C10.I1 Investments in energy Investments of at least EUR 550 million in energy infrastructure infrastructure

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 17/102EN OJ L, 27.10.2025 Sequential Reform/Investment Name of the step number

11.4 C11.R3 Liberalisation in the railways Adoption of the by-laws for the implementation of the transport sector legislation on railway transport

11.7 C11.I1 Investments in transport Investments of at least EUR 350 million in transport infrastructure infrastructure

12.10 C12.I1 Investments in demining Investments of at least EUR 100 million in demining of agriculture land C.1. PUBLIC ADMINISTRATION REFORM

1. Description of Reforms and Investments The objective of this chapter is to strengthen the capacity and efficiency of the Ukrainian public administration and to gradually align the rules, standards, policies, and practices in the field of public administration with the EU acquis, policies and practices. Specifically, this chapter focuses on revising the civil service remuneration system, enhancing the merit-based recruitment and selection of the civil service, and on the digitalisation of civil service and human resources management systems.

Reform 1. Civil Service Remuneration Reform The objective of this reform is to introduce a transparent, fair and predictable labour remuneration system in line with relevant OECD/SIGMA principles of public administration(4).

The reform has one step. It entails the entry into force of new legislation introducing a new remuneration system based on functional classification of positions, a clear separation of wages into fixed and variable components, and reduction of the seniority supplement from 50 % to 30 %.

The reform is expected to be completed by Q1 2025.

Reform 2. Merit-based recruitment and selection procedure for the civil service The objective of this reform is to introduce a meritocratic recruitment and selection procedure for civil servants, so as to ensure public trust and attract highly professional staff to the civil service.

The reform has two steps. First, it entails the entry into force of legislation to improve the procedure for entering, passing, and terminating civil service. Second, it entails the gradual restoration of merit-based selection for vacant positions for civil servants of categories A, B, and C.

The reform is expected to be completed by Q3 2026.

Reform 3. Digitalisation of civil service and human resources management This reform is aimed at digitalising the civil service human resources management functions, focusing on the human resources management information system (HRMIS) and the Unified State Web Portal of Electronic Services.

The reform has two steps. First, a human resources management information system (HRMIS) shall be operational and used in all ministries and all operating /acting other central executive authorities and their territorial bodies. Second, the Unified State Web Portal of Electronic Services will be modernised.

The reform is expected to be completed by Q2 2026.

(4) OECD (2023), The Principles of Public Administration, OECD, Paris, https://www.sigmaweb.org/publications/Principles-of-Public- Administration-2023.pdf 18/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

1.1 Reform 1. Entry into force of the legislative Q1 2025 Entry into force of legislation (including the adoption of the necessary secondary legal and normative acts), changes to the civil service which complies with the relevant OECD SIGMA principles of public administration. The legislation focuses Civil service

remuneration reform on these main areas: remuneration reform — introduction of remuneration based on the functional classification of positions; — a clear separation of wages into fixed or guaranteed (not less than 70 % annually) and variable (not more than 30 % annually) parts;

— reduction of seniority supplement from 50 % to 30 %.

1.2 Reform 2. Entry into force of the legislative Q4 2025 Entry into force of legislation (including the adoption of the necessary secondary legal and normative acts) changes to improve the procedure to improve the procedure for entering, passing, and terminating civil service. The legislation complies with Merit-based for entering, passing, and the relevant OECD/SIGMA principles of public administration related to merit-based recruitment.

recruitment and terminating civil service selection procedure for The provisions relating to the resumption of merit-based selection for all civil servants’ positions in the the civil service territory controlled by Ukraine, where no hostilities are taking place, enter into force with its application as of 1 June 2026 (in accordance with the requirements of step 1.3).

1.3 Reform 2. Gradual restoration of merit-based Q3 2026 Restoration of merit-based selection for vacant positions for all civil servants will be implemented gradually

recruitment in the civil service in three stages:

Merit-based recruitment and 1) for civil service positions of category ‘A’; selection procedure for

2) for civil service positions of category ‘B’ (in the territory controlled by Ukraine where no hostilities are the civil service taking place);

3) for civil service positions of category ‘C’ (in the territory controlled by Ukraine where no hostilities are taking place).

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1.4 Reform 3. Modernisation of the Unified State Q2 2026 The Unified State Web Portal of Electronic Services is modernised. Functionality for publishing vacancies Web Portal of Electronic Services and submitting applications has been fully implemented and is operating in full.

Digitalisation of civil service and human resources management

1.5 Reform 3. The Human Resources Q1 2026 The Human Resources Management Information System (HRMIS) is in operation and used in all ministries Management Information System and all operating/acting other central executive authorities and their territorial bodies.

Digitalisation of civil

(HRMIS) is in operation service and human resources management 20/102

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1. Description of Reforms and Investments The objective of this chapter is to enhance Ukraine’s macro-economic and financial resilience, ensure efficient use of public funds, align with EU standards, and promote a sustainable growth.

Reform 1. Improved revenue management The objective of this reform is to enhance domestic revenue mobilisation through improved efficiency of the tax and customs administration.

The reform has two steps. First, the long-term national strategic plan for digital development, digital transformation and digitalisation of the State Customs Service shall be adopted. Second, the strategic plan for digital development, digital transformation and digitalisation of State Tax Service of Ukraine shall be adopted.

The reform is expected to be completed by Q4 2024.

Reform 2. Improved public financial management The objective of this reform is to build an efficient public finance management system and to ensure the financial stability of the state.

The reform has three steps. First, the Budget Declaration for 2025-2027 shall be approved to restore the medium-term budget planning and ensure the predictability of budget policy. Second, the reform shall introduce annual spending reviews of the state budget taking into account OECD practices in priority areas, including social protection, education, healthcare, energy, business support. Third, a law amending the Budget Code of Ukraine to define the procedure for managing fiscal risks of local budgets shall enter into force.

The reform is expected to be completed by Q4 2026.

Reform 3. Improved public debt management The objective of this reform is to increase the transparency of state debt management policy and the efficiency of state debt management.

The reform proposes one step, namely the adoption of the medium-term state debt management strategy for 2026-2028.

The strategy shall include an analysis of current public debt structure and trends, the establishment of targets to ensure debt sustainability, and the development of measures for the domestic government securities market.

The reform is expected to be completed by Q4 2025.

Reform 4. Improved public investment management The objective of this reform is to strengthen the institutional framework for public investment management in Ukraine, defining roles and responsibilities for participants at all stages of the investment project cycle, strategic priorities, transparency, and a digital project monitoring framework.

The reform has two steps. First, an action plan to implement a roadmap towards an improved public investment management shall be adopted. Second, the reform entails the development and implementation of a digital management tool for the reconstruction of Ukraine.

The reform is expected to be completed by Q3 2025.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 21/102EN OJ L, 27.10.2025 Reform 5. Improved audit systems The objective of this reform is to strengthen the audit and financial control system, in particular to achieve a high level of protection of the financial interests of the European Union regarding the funds used under Pillar I of the Ukraine Facility, in line with Article 35 of Regulation (EU) 2024/792.

The reform has one step. It entails the adoption and, where applicable, the entry into force of amendments to the resolutions or other legislation on state financial control, enabling the State Audit Service to to ensure that the institution is equipped with the necessary tools to ensure a high level of protection of the financial interest of the European Union, in particular for the funds used under Pillar I of the Ukraine Facility.

The reform is expected to be completed by Q4 2025.

22/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

2.1 Reform 1. Adoption of the strategic plan for Q4 2024 Adoption of the strategic plan for digital development, digital transformation and digitalisation of State Tax digitalisation of the State Tax Service of Ukraine, in line with the recommendations of the National Revenue Strategy for 2024-2030.

Improved revenue Service management

2.2 Reform 1. Adoption of the plan for the Q2 2024 Adoption of the long-term national strategic plan for digital development, digital transformation and digitalisation of the State Customs digitalisation of the State Customs Service.

Improved revenue Service management

2.3 Reform 2. Approval of the Budget Q2 2024 The Budget Declaration for 2025-2027 is approved and submitted to the Parliament. The Declaration Declaration for 2025-2027 focuses on these main areas:

Improved public financial management — key macroeconomic projections of economic and social development of the country; — key budget indicators (revenues, expenditures, budget deficit, public debt); — public policy priorities by spheres and expenditure ceilings for each key spending unit;

— relations between the state budget and local budgets, including necessary guidance for preparing medium-term forecasts of local budgets; — fiscal risks assessment.

2.4 Reform 2. Conduct of the spending review of Q4 2026 Spending reviews of the state budget are conducted annually based on the Government decision and the the state budget methodology taking into account best OECD practices in particular in the priority areas, such as social Improved public protection, education, healthcare, energy, business support.

financial management

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2.5 Reform 2. Entry into force of the Law on Q4 2026 Entry into force of the Law on Amendments to the Budget Code of Ukraine to Define the Procedure for Amendments to the Budget Code Managing Fiscal Risks of Local Budgets. The Law focuses on these main areas:

Improved public of Ukraine to Define the Procedure financial management — determining entities responsible for managing fiscal risks of local budgets; for Managing Fiscal Risks of Local Budgets — establishing the procedures for cooperation between various entities responsible for managing fiscal risks of local budgets;

— defining the methodological frameworks for managing fiscal risks of local budgets.

2.6 Reform 3. Adoption of the medium-term Q4 2025 Adoption of the medium-term state debt management strategy (MTDS) for 2026-2028. The MTDS focuses

state debt management strategy on these main areas:

Improved public debt management — analysis of current public debt structure and trends; — targets to ensure debt sustainability; — measures for the development of domestic government securities market.

2.7 Reform 4. Adoption of the Action plan for Q2 2024 Adoption of the Action plan for the implementation of the Roadmap for reforming public investment the implementation of the management. The action plan focuses on these main areas and includes the sequencing and timeframe:

Improved public Roadmap for reforming public investment — introduction of strategic planning for public investment in close connection with budget planning; investment management management — definition of the roles of all participants at all stages of the investment project cycle;

— establishment of unified approaches to the selection, evaluation and monitoring of investment projects, regardless of the sources of funding (budget revenues, international donors, state (local) guarantees, concessions, public-private partnerships) to enable the preparation of single project pipeline;

— definition of prioritisation criteria that capture defined needs, maturity of projects, and alignment with sectoral and/or regional strategies in the context of the public investment management; — introduction of an independent assessment of large public investment projects.

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2.8 Reform 4. Development and implementation Q3 2025 Development and implementation of the digital management tool for the reconstruction of Ukraine, which of the digital management tool for provides public access to data on reconstruction projects at all stages, including planning, financing, Improved public the reconstruction of Ukraine procurement, construction and commissioning, to enable a public and transparent monitoring of project investment implementation and better coordination of reconstruction efforts between sectors.

management

2.9 Reform 5. Adoption of the amendments to Q4 2025 Adoption of amendments to the resolutions of the Cabinet of Ministers and, if needed, entry into force of the relevant legislation on state other relevant legislation on state financial control. These changes focus on these main areas:

Improved audit and financial control financial control — provision of support to State Audit Services to ensure that the institution is equipped with the systems necessary tools to protect the financial interests of the Union, in particular for the funds used under Pillar I of the Ukraine Facility, in line with the principles of the international audit standards;

— strengthening measures for monitoring the procurement procedures.

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27.10.2025 ENEN OJ L, 27.10.2025 C.3. JUDICIAL SYSTEM

1. Description of Reforms and Investments The objective of this chapter is increasing the capacity, accountability, integrity, efficiency and transparency of the judicial system which is crucial for ensuring the rule of law and the protection of human rights in Ukraine as well as for a swift recovery, economic growth and attraction of investment.

Reform 1. Enhancing the accountability, integrity, and professionalism of the judiciary The objective of this reform is consolidating the results of the judicial reform and building public trust in the judiciary by resuming the transparent and meritocratic selection of judges, boosting the qualification evaluation of sitting judges, strengthening the disciplinary responsibility system, reinforcing existing judicial integrity tools, and establishing a new court to hear administrative cases involving state agencies.

The reform has six steps. First, 20 % of judicial vacancies are filled based on amended legislation, which includes streamlined stages of selection and shortened mandatory judicial training periods, consistent application of clear assessment criteria and scoring methodology, and the involvement of the Public Integrity Council in assessing the integrity of judicial candidates. Second, a new Specialised District Administrative Court and a new Specialised Administrative Court of Appeal are legally established and a transparent selection of judges in line with the adopted legislation is launched. Third, 20 % of pending disciplinary cases are resolved with the involvement of the Disciplinary Inspectors Service on the basis of the High Council of Justice’s methodology of prioritisation. Fourth, the qualification evaluation (vetting) is completed in respect of 50 % of outstanding cases. Fifth, laws and bylaws concerning revising and verification of the declarations of integrity enter into force. Sixth, a new Specialised District Administrative Court and a new Specialised Administrative Court of Appeal are operational.

The reform is expected to be completed by Q4 2026.

Reform 2. Reforms of insolvency and enforcement of court decisions The objective of this reform is the improvement of insolvency and enforcement procedures by aligning the relevant legislation with the EU acquis and building institutional and other capacities to properly apply it.

The reform has five steps. First, legislation on improving the insolvency regime, introducing insolvency prevention system and the early warning tool for legal entities and entrepreneurs in line with the EU acquis enters into force. Second, legislation for introducing simplified insolvency procedures for Micro, Small, And Medium Enterprises (MSMEs) in line with EU acquis enters into force. Third, the law on the enforcement of court decisions related to monetary and non-monetary obligations and further digitalisation of the enforcement proceedings enters into force. Fourth, an upgraded IT system for facilitating the enforcement process, debtor asset tracking, bank account freezing, and debt recovery becomes operational.

Fifth, a data collection system on the enforcement of court decisions becomes operational.

The reform is expected to be completed by Q2 2026.

Reform 3. Digitalisation of the judicial system The objective of this reform is to enhance access to justice, increase the transparency, efficiency, and effectiveness in the operation of courts, save operational costs, and enable an evidence-based policy making in the judiciary.

The reform has one step. It entails the introduction of the subsystem of the Electronic Document Management of the Unified Judicial Information and Telecommunication System (UJITS) in 15 pilot courts of general, commercial and administrative jurisdiction at the level of first and appellate instances.

The reform is expected to be completed by Q4 2027.

26/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Reform 4. Reform of the Prosecution Service The objective of this reform is to reinforce integrity, meritocracy and professionalism within the prosecutorial ranks and prevent corruption in the criminal justice chain.

The reform has three steps. First, legislation establishing a transparent and merit-based selection process of management-level prosecutors enters into force. Second, legislation improving the disciplinary system for prosecutors and increasing the capacity of the Qualification and Disciplinary Commission of Prosecutors enters into force. Third, three modules of an e-Case management system in the criminal justice chain are put in place to enable the digital processing of criminal cases.

The reform is expected to be completed by Q4 2026.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 27/1022. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

3.1 Reform 1. Filing of at least 20 % of judicial Q3 2025 At least 20 % of judicial vacancies available as of 16. October 2023 (a total number of 2 205 positions) is vacancies are filled in. filled on the basis of amended legislation, which includes the following elements:

Enhancing the accountability, integrity — streamlined stages of selection and shortened mandatory judicial training periods; and professionalism of — consistent application of clear and duly published assessment criteria and scoring methodology for the judiciary assessing professional competence and integrity of judicial candidates;

— involvement of the Public Integrity Council in assessing the integrity of judicial candidates whenever the law requires it.

3.2 Reform 1. Entry into force of the law Q3 2025 The law on the establishment of the Specialised District Administrative Court and the Specialised establishing a new court to hear Administrative Court of Appeal entered into force and a transparent selection of judges in line with the Enhancing the administrative cases adopted legislation is launched.

accountability, integrity and professionalism of the judiciary

3.15 Reform 1. A new court to hear Q4 2026 The Specialised District Administrative Court and the Specialised Administrative Court of Appeal become administrative cases is operational operational.

Enhancing the accountability, integrity and professionalism of the judiciary

3.3 Reform 1. Settlement/adjudication of 20 % of Q4 2025 20 % of old disciplinary proceedings (complaints) not considered as of 31 December 2023 are settled/ old disciplinary cases not adjudicated with the involvement of the Disciplinary Inspectors Service and on the basis of the criteria for Enhancing the considered as of end of 2023 prioritisation of disciplinary complaints consideration, provided for in clause 13.7 of the Rules of Procedure accountability, integrity of the High Council of Justice (as amended on 21 November 2023, No. 1068/0/15-23) that are published and professionalism of on the official website of the High Council of Justice.

the judiciary

3.4 Reform 1. Completion of the qualification Q4 2025 Qualification evaluation (vetting) is completed in respect of 50 % of judges who still had to undergo it as of evaluation (vetting) in respect of 30 September 2016 in line with the established procedures and with the involvement of the Public Integrity Enhancing the 50 % of judges who still had to Council.

accountability, integrity undergo it as of 30 September and professionalism of 2016 the judiciary 28/102

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3.5 Reform 1. Entry into force of the legislation Q2 2025 Entry into force of the laws and the bylaws of the High Qualification Commission of Judges of Ukraine revising the declarations of revising the declarations of integrity of judges and their verification process. The acts focus on these main Enhancing the

integrity of judges and their areas: accountability, integrity verification process and professionalism of — clarification of the content of the integrity declarations and the grounds for initiating the verification;

the judiciary — expansion of the time period covered by the verification; — improvement of the verification procedure by specifying the verification mechanisms and deadlines, defining the rights and obligations of the persons and entities involved in the verification process, clarifying the legal consequences of the verification.

3.6 Reform 2. Entry into force of the legislation Q4 2024 Entry into force of the law on the improvement of insolvency regime and the relevant secondary legislation, on the improvement of insolvency introducing insolvency prevention system and the early warning tool for legal entities and entrepreneurs in Reforms of insolvency regime line with the principles of Directive (EU) 2019/1023 of the European Parliament and of the Council of and enforcement of 20 June 2019 on preventive restructuring frameworks, on discharge of debt and disqualifications, and on court decisions measures to increase the efficiency of procedures concerning restructuring, insolvency and discharge of debt, and amending Directive (EU) 2017/1132. The new legislation focuses on these main areas:

— prevention of bankruptcy and restoration of solvency of debtors — early detection of signs of crisis in the company — identification of additional opportunities for restoring solvency of companies — availability of information for the companies about the mechanisms for preventing insolvency and early warning.

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3.7 Reform 2. Entry into force of the legislation Q1 2026 Entry into force of the legislation for simplified insolvency procedures for Micro, Small, and Medium for simplified insolvency Enterprises (MSMEs) in line with the principles of the Directive (EU) 2019/1023 of the European Parliament Reforms of insolvency procedures for Micro, Small, and and of the Council of 20 June 2019 on preventive restructuring frameworks, on discharge of debt and and enforcement of Medium Enterprises (MSMEs) disqualifications, and on measures to increase the efficiency of procedures concerning restructuring, court decisions insolvency and discharge of debt, and amending Directive (EU) 2017/1132. The legislation is drafted based on a regulatory impact assessment with the involvement of EU experts. The legislation focuses on these

main areas: — simplified out-of-court and bankruptcy procedures for MSMEs (including individual entrepreneurs); — availability of insolvency tools and services of insolvency practitioners for MSMEs; — prevention of abuse of insolvency procedures by MSMEs.

3.8 Reform 2. Entry into force of the legislation Q2 2025 Entry into force of the law on the enforcement of court decisions related to monetary and non-monetary on improving the enforcement of obligations and further digitalisation of the enforcement proceedings.

Reforms of insolvency court decisions related to and enforcement of monetary and non-monetary court decisions obligations and digitalisation

3.9 Reform 2. A data collection system on the Q4 2025 A data collection system on the enforcement of court decisions is operational. enforcement of court decisions is Reforms of insolvency operational and enforcement of court decisions

3.10 Reform 2. An upgraded IT system for Q2 2026 The upgraded IT system for enforcement facilitating enforcement process, debtor asset tracking, bank enforcement of court decisions is account freezing and debt recovery is operational.

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3.11 Reform 3. Set up of IT solutions in the Q4 2027 The introduction of the subsystem of the Electronic Document Management of the Unified Judicial judicial system Information and Communication System in 15 pilot courts of general, commercial and administrative Digitalisation of the jurisdiction at the level of first and appellate instances.

judicial system

3.12 Reform 4. Entry into force of the legislation Q1 2026 Entry into force of the legislation enabling transparent and merit-based selection of management-level enabling transparent and prosecutors. This legislation focuses on these main areas:

Reform of the merit-based selection of Prosecution Service — clear assessment criteria, including professional competence and integrity/ethics; management-level prosecutors — transparent, competitive and meritocratic selection procedure that includes a credible professionalism and integrity check;

— strengthening the institutional capacity and the powers of the Prosecutor's Office and the self government bodies, in particular the Council of Prosecutors, in terms of selecting prosecutors for senior positions.

3.13 Reform 4. Entry into force of the legislation Q3 2026 Entry into force of the legislation improving the disciplinary system for prosecutors and strengthening the improving the disciplinary system institutional capacity of the Qualification and Disciplinary Commission of Prosecutors (QDCP). The Reform of the for prosecutors and increasing the improved legal and institutional framework aimed at implementing GRECO recommendations focuses on Prosecution Service

capacity of the Qualification and these main areas:

Disciplinary Commission of — specification of disciplinary offences related to the conduct of prosecutors and their compliance with Prosecutors ethical standards, and expansion of the list of available disciplinary sanctions to increase their proportionality and effectiveness;

— amending the provisions on the composition of the QDCP to ensure that the majority of seats are held by prosecutors elected by their colleagues and conducting an independent and objective procedure for the pre-selection of all candidates for members of the QDCP, which includes verification of their integrity;

— increasing the efficiency of disciplinary proceedings by extending the statute of limitations.

3.14 Reform 4. An e-Case Management System in Q4 2026 The criminal justice e-Case Management System’s system-forming module, electronic criminal proceedings the criminal justice is operational module, and case analysis module are operational, enabling digital processing of criminal cases and Reform of the gradually replacing/significantly upgrading the outdated Unified Register of Pre-Trial Investigations.

Prosecution Service

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27.10.2025 ENEN OJ L, 27.10.2025 C.4. FIGHT AGAINST CORRUPTION AND MONEY LAUNDERING

1. Description of Reforms and Investment The objective of this chapter is to reinforce the key anti-corruption agencies and to update the legal framework to increase the overall effectiveness of the anti-corruption framework and the implementation of the state’s anti-corruption policy, which is essential for a favourable business and investment climate and sustainable recovery and economic growth. The

chapter also addresses the shortcomings related to asset recovery and management at institutional and procedural levels and on alignment of Ukrainian legislation with EU acquis and FATF standards in the field of anti-money laundering enabling to better tackle economic crime and to improve the overall business climate in Ukraine.

Reform 1. Developing the institutional capacity of the anti-corruption framework.

The objective of this reform is to increase the overall capacity of the anti-corruption infrastructure to fight corruption, including at the high level, via active and efficient investigation.

The reform has three steps. First, the Specialised Anti-Corruption Prosecutor’s Office (SAPO) is given the opportunity to increase its manpower from 10 % to 15 %. Second, a new head of the National Agency on Corruption Prevention (NACP) is appointed. Third, the number of judges and of the apparatus at the High Anti-Corruption Court (HACC) is increased by 60 % and by 40 % respectively.

The reform is expected to be completed by Q1 2025.

Reform 2. Improving the legal framework for a more effective fight against corruption The overall objective of the reform is to strengthen the key anti-corruption institutions and to streamline criminal procedure to increase their efficiency, including in high-level corruption cases, while preventing instances of procedural abuse and undue interferences. The reform also addresses the shortcomings related to asset recovery and management at institutional and procedural levels.

The reform has four steps. First, the amended Criminal Code and of the Criminal Procedure Code enters into force. The amended legislation improves the provisions regulating plea bargaining; cancels the pre-trial investigation period from the time of the registration of the criminal proceedings until the notification of the suspicion and allow the adjudication of certain cases by a single judge of the High Anti-Corruption Court. Second, a new Anti-Corruption Strategy and a State Anti-Corruption Program for the period after 2025 is adopted. Third, an action plan for the implementation of the Asset Recovery Strategy for 2023-2025 is adopted. Fourth, the law reforming the Asset Recovery and Management Agency

(ARMA) enters into force.

The reform is expected to be completed by Q2 2026.

Reform 3. Anti-money laundering measures The objective of this reform is to further align Ukraine’s legal framework with the EU acquis and FATF standards and to create an effective anti-money laundering system in Ukraine to better tackle economic crime and improve the overall business climate in Ukraine.

The reform has three steps. First, the next National Risk Assessment is conducted. Second, legislation for the registry of bank accounts for individuals and personal bank deposit boxes, and the registry of bank accounts for legal entities in line with the principles of EU acquis enters into force. Third, necessary software and hardware for the registry of bank accounts for individuals and personal bank deposit boxes, and the registry of bank accounts for legal entities is put in place.

The reform is expected to be completed by Q2 2027.

32/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

4.1 Reform 1. Increased manpower for the Q3 2024 The Specialised Anti-Corruption Prosecutor's Office is given the opportunity to increase its manpower Specialised Anti-Corruption from 10 % to 15 % of the manpower of the National Anti-Corruption Bureau.

Developing the Prosecutor’s Office institutional capacity of the anti-corruption framework

4.2 Reform 1. Appointment of a new head of Q2 2024 A new head of the National Agency on Corruption Prevention is appointed following a selection procedure the National Agency on in line with the Law on the Prevention of Corruption Developing the Corruption Prevention institutional capacity of the anti-corruption framework

4.3 Reform 1. Increased manpower for the Q1 2025 The personnel number of High Anti-Corruption Court (HACC) judges is increased by 60 %, and the HACC High Anti-Corruption Court apparatus number is increased by 40 %.

Developing the institutional capacity of the anti-corruption framework

4.4 Reform 2. Entry into force of the amended Q3 2024 Entry into force of the Laws of Ukraine on amending the Criminal Code of Ukraine and the Criminal Criminal Code and of the Procedure Code of Ukraine. The laws focus on these main areas:

Improving the legal Criminal Procedure Code framework for a more — improvement of the provisions regulating plea bargain; effective fight against — cancellation of the pre-trial investigation period from the time of the registration of the criminal corruption proceedings until the notification of the suspicion;

— allowing to adjudicate certain cases by a single-judge of the High Anti-Corruption Court.

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4.5 Reform 2. Adoption of a new Q2 2026 Adoption and publication by the Parliament and the Government respectively of an Anti-Corruption Anti-Corruption Strategy and Strategy and of a State Anti-Corruption Program for its implementation covering the period after 2025.

Improving the legal a State Anti-Corruption framework for a more Program for the period after effective fight against 2025 corruption

4.6 Reform 2. Adoption of an Action Plan for Q3 2024 Adoption and publication on the website of the Cabinet of Ministers of an Action Plan for the the implementation of the implementation of the Asset Recovery Strategy for 2023-2025.

Improving the legal Asset Recovery Strategy for framework for a more 2023-2025 effective fight against corruption.

4.7 Reform 2. Entry into force of the law Q1 2025 Entry into force of the Law reforming the Asset Recovery and Management Agency. The law focuses on

reforming the Asset Recovery these main areas:

Improving the legal and Management Agency framework for a more — a transparent and merit-based selection procedure for the head of the agency, including a credible effective fight against integrity and professionalism check;

corruption. — an independent external performance assessment system; — transparent procedure for the management and sale of seized assets under the agency’s control.

4.8 Reform 3. Conduct of the next National Q4 2025 Preparation and implementation of the next National Risk Assessment in accordance with the updated Risk Assessment Methodology for the National Assessment of money laundering and terrorist financing risks in Ukraine Anti-money laundering measures 34/102

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4.9 Reform 3. Entry into force of the Q2 2027 Entry into force of the necessary legal framework for the registry of bank accounts for individuals and legislation for the registry of personal bank deposit boxes, and the registry of bank accounts for legal entities in line with the principles Anti-money laundering bank accounts for individuals of Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the measures and personal bank deposit prevention of the use of the financial system for the purposes of money laundering or terrorist financing, boxes, and the registry of bank amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing accounts for legal entities Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC, Directive (EU) 2019/1153 of the European Parliament and of the Council of 20 June 2019 laying down rules facilitating the use of financial and other information for the prevention, detection, investigation or prosecution of certain criminal offences, and repealing Council Decision 2000/642/JHA, and Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 on the mechanisms to be put in place by Member States for the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Directive (EU) 2019/1937, and amending and repealing Directive (EU) 2015/849, amending the Tax, Banking, AML, capital market and payment services Ukrainian legislation.

4.10 Reform 3. The necessary software and Q2 2027 The necessary software and hardware for the registry of bank accounts for individuals and personal bank hardware for the registry of deposit boxes, and the registry of bank accounts for legal entities is operational.

Anti money-laundering bank accounts for individuals measures. and personal bank deposit boxes, and the registry of bank accounts for legal entities is operational

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27.10.2025 ENEN OJ L, 27.10.2025 C.5. FINANCIAL MARKETS

1. Description of Reforms and Investments The objective of this chapter is to leverage the potential of Ukraine’s financial sector to drive economic growth and support recovery, by monitoring the health of the banking sector to maintain financial stability, strengthening regulatory framework in aligning with EU standards, addressing non-performing loans, and improving the regulation of capital markets.

Reform 1. Assessment of the banking sector The objective of this reform is to return to the regular assessment process, identify potential vulnerabilities within major banks, and ensure the resilience of the banking system in Ukraine.

The reform has one step. The National Bank of Ukraine shall carry out a resilience assessment of the largest banks that includes stress testing under the adverse scenario as well as an independent Asset Quality Review.

The reform is expected to be completed by Q1 2026.

Reform 2. Reducing state ownership in the banking sector The objective of this reform is to lay down the principles for the sale of state-owned banks and the strategy for gradually reducing state ownership in the banking sector.

The reform has two steps. First, an updated legislation shall establish guiding principles for the sale of varying ownership stakes in SOBs, while also providing the flexibility for complete acquisition. Second, a strategy shall be adopted, preparing for a gradual reduction of state-ownership in SOBs.

The reform is expected to be completed by Q2 2026.

Reform 3. Improved resolution of non-performing loans The objective of this reform is to improve the resolution of non-performing loans (NPLs).

The reform has two steps. First, Ukraine shall adopt a strategy for the resolution of NPLs, focusing on prudential requirements and improving the framework for NPL restructuring and resolution. Second, the subsequent legislative amendments to the relevant laws shall be adopted, addressing the recommendations of the strategy.

The reform is expected to be completed by Q2 2026.

Reform 4. Improved capacity of the financial supervisory authority The objective of this reform is to improve the state regulation for capital markets and organised commodity markets.

The reform has one step. It entails the entry into force of the law on the improvement of state regulation for capital markets and organised commodity markets, aligned with International Organization of Securities Commissions (IOSCO) standards.

The reform is expected to be completed by Q4 2025.

36/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

5.1 Reform 1. Published Resilience assessment in Q1 2026 The National Bank of Ukraine (NBU) publishes the Resilience Assessment of the largest banks in the the banking system banking system (in terms of assets) that includes stress testing under the adverse scenario, and the results of Assessment of the an independent Asset Quality Review if conditions allow it to be carried out.

banking sector

5.2 Reform 2. Entry into force of the legislation Q3 2025 Entry into force of the updated legislation on the sale of state-owned banks, namely, the Law of Ukraine ‘On on the principles for the sale of Divesting State-Owned Shareholdings in the Charter Capital of Banks that Have Undergone Reducing state state-owned banks Recapitalisation by the State’ No. 4524-VI dated 2012. The revised legislation should facilitate the sale of ownership in the varying ownership stakes in State-owned banks (SOBs), while also providing the flexibility for complete banking sector acquisition. The fundamental principles guiding the sale of SOBs will be developed through collaborative discussions and in consensus with the international donors.

5.3 Reform 2. Adoption of the strategy for Q2 2026 Adoption of the resolution of the Government or other legal act of the Government adopting the reform gradual reduction of state strategy for the SOBs, which sets out a gradual reduction in state ownership in the banking sector. The Reducing state

ownership in the banking sector strategy focuses on these main areas: ownership in the banking sector — financial health and stability; — management of non-performing loans; — mitigation of fiscal risks;

— enhancement of bank governance and operational efficiency; — bank value enhancement, long-term viability, and steps towards privatisation (when relevant).

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5.4 Reform 3. Adoption of the strategy for Q2 2025 Adoption of the strategy for resolution of non-performing loans in line with the relevant EU practices. The resolution of non-performing strategy focuses on these main areas:

Improved resolution of loans non-performing loans — strengthening of the prudential requirements for the NPL recognition and resolution; — exchange of data on the NPLs and other relevant market data between the financial institutions and state agencies to improve NPL resolution;

— review of potential obstacles and development of measures to improve the framework for NPL restructuring and resolution.

5.5 Reform 3. Entry into force of the legal acts to Q2 2026 Entry into force of the legal acts implementing the recommendations of the strategy for resolution of improve resolution of non-performing loans improving the system of NPLs resolution.

Improved resolution of non-performing loans non-performing loans

5.6 Reform 4. Entry into force of the law on the Q4 2025 Entry into force of the Law on the improvement of state regulation for capital markets and organised improvement of the state commodity markets, aligning it with IOSCO standards. This refers to the ability of the National Improved capacity of regulation for capital markets and Commission on Securities and Stock Market (NSSMC) to operate free from external influence, particularly the financial organised commodity markets from political or industry pressures, make decisions based on the law and the best interests of market supervisory authority integrity and investor protection, rather than external interests, and have strong enforcement mechanisms and international cooperation.

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27.10.2025EN OJ L, 27.10.2025 C.6. MANAGEMENT OF PUBLIC ASSETS

1. Description of Reforms and Investments The objective of this chapter is to improve the state ownership policy, corporate governance and management of Ukraine’s state-owned enterprises (SOEs) as well as to harmonise the State Aid framework with the EU acquis. This serves to improve transparency and efficiency and supports strengthening the level playing field with the private sector.

Reform 1. Adopting a state ownership policy The objective of this reform is to adopt a state ownership policy that would reflect long-term and whole-of-government priorities of SOEs ownership. The triage of SOEs shall be renewed according to the principles laid out in the state ownership policy. The triage of SOEs shall result in a list of SOEs that will remain in state ownership as strategic, a list of SOEs that will be proposed for privatisation, also indicating all SOEs which are temporarily banned for privatisation during the martial law in a dedicated subsection, and a list of SOEs which will be liquidated.

The reform has one step. It entails entry into force of legislation introducing the state ownership policy, and the publication of the triage of SOEs.

The reform is expected to be completed by Q4 2024.

Reform 2. Improved governance and management of state-owned enterprises The objective of this reform is to facilitate the transition from the state unitary enterprise legal form into more commercially oriented forms, to foster a more efficient and transparent governance framework for state-owned enterprises

(SOEs) via enhancing corporate governance standards and implementation in top SOEs.

The reform has four steps. First, a new law enters into force that improves corporate governance of SOEs taking into account OECD guidelines(5), including by defining the powers of SOEs’ supervisory boards. Second, supervisory boards with a majority of independent members in at least 15 top key SOEs are appointed. Third, Ukraine corporatises at least 15 top key SOEs as either joint-stock companies or limited liability companies. Fourth, authorities submit the first annual report showing that the principles of corporate governance are duly followed.

The reform is expected to be completed by Q4 2027.

Reform 3. Separation of accounts between public service obligations (PSO) and non-PSO activities in state-owned enterprises The objective of this reform is to strengthen the level playing field with the private sector, as well as further convergence with the EU acquis via a separation of accounts between activities connected to Public Service Obligations (PSOs) from non-PSOs activities.

The reform has three steps. First, Ukraine shall adopt and publish a Roadmap defining the necessary steps for mandatory structural separation of accounts between PSO and non-PSO activities for all SOEs engaged in PSOs. Second, entry into force of the legislation to align with the Directive 2006/111 of the European Commission, which will ensure that mandatory structural separation of accounts between PSO and non-PSO activities is defined and implemented. Third, Ukraine shall publish an independent audit report on top SOEs engaged in the PSOs, including on the implementation of accounts separation and market compliance on cross-subsidisation.

The reform is expected to be completed by Q3 2027.

(5) OECD (2015), OECD Guidelines on Corporate Governance of State-Owned Enterprises, OECD, Paris, https://www.oecd.org/daf/ca/ guidelines-corporate-governance-soes.htm

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 39/102EN OJ L, 27.10.2025 Reform 4. Improved state aid control framework The objective of this reform is to lift the suspension of application of State aid control and align the State aid control framework with that of the EU, which would result in more transparency over the state funding to SOEs.

The reform has one step. It entails the updating of legislation on state aid, including provisions in relation to services of general economic interest, together with the full lifting of suspension of application of state aid control by the Antimonopoly Committee of Ukraine.

The reform is expected to be completed by Q4 2025.

40/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

6.1 Reform 1. Adoption of the state Q4 2024 Adoption and publication of the Resolution of the Cabinet of Ministers of Ukraine on Approving the General State ownership policy and of the Ownership Policy and the ‘triage’ of SOEs. The State Ownership Policy focuses on these main areas:

Adopting a state triage of state-owned ownership policy — listing the public policy objectives that SOEs are required to achieve; enterprises — describing the state’s role in the governance of SOEs; how the state will implement its ownership policy; and the respective roles and responsibilities of those government authorities involved in its implementation;

— defining the overall rationales for keeping SOEs under state ownership and subjects these rationales to regular reviews; — setting long-term and whole-of-government priorities of SOEs ownership; — defining dividend policy, remuneration policy for members of supervisory boards and managers.

The ownership policy allows for the implementation of OECD Corporate governance reforms in DSO companies to improve competition in natural gas markets.

The triage of SOEs leads to the following outcomes: — a list of SOEs that will remain in state ownership as strategic; — a list of SOEs that will be proposed for privatisation, also indicating all SOEs which are temporarily banned for privatisation during the martial law in a dedicated subsection;

— a list of SOEs which will be liquidated.

6.2 Reform 2. Entry into force of the Q2 2024 Entry into force of the new law on corporate governance of SOEs taking into account OECD guidelines on corporate legislation on corporate governance. The law focuses on these main areas:

Improved governance of state-owned governance and — defining the powers of SOEs’ supervisory boards to appoint and dismiss CEOs; enterprises management of — defining the powers of SOEs’ supervisory boards to approve the strategic, investment and financial plans state-owned documents of SOEs;

enterprises — establishing an annual evaluation procedure for the supervisory boards of SOEs.

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6.3 Reform 2. Appointment of Q2 2026 Supervisory boards with a majority of independent members are appointed for at least 15 SOEs from the list of top Supervisory boards of key SOEs approved by the Cabinet of Ministers protocol decision. The nomination of the Supervisory board members Improved state-owned enterprises with is conducted via competitive selection process, on the basis of procedures agreed and in place at the time of the start of governance and a majority of independent the selection.

management of members state-owned enterprises

6.4 Reform 2. Corporatisation of key Q3 2026 At least 15 SOEs from the list of top key SOEs approved by a Cabinet of Ministers protocol decision are corporatised as state-owned enterprises either joint-stock companies or limited liability companies.

Improved governance and management of state-owned enterprises

6.5 Reform 2. Submission of a report Q4 2027 The first annual report with the financial and operational results showing that the principles of corporate governance showing that the principles are duly followed is shared with the European Commission. The report also assesses the independence of Supervisory Improved of corporate governance are boards’ decision-making, in particular in at least 15 SOEs from the list of top key SOEs, including whether decisions on governance and duly followed strategic matters and managerial appointments require a de facto consent from the government.

management of state-owned Before the audit, the following key principles of corporate governance are put in place and enforced: enterprises — the roles of the Cabinet of Ministers, Ministry of Finance, the Ministry of Economy are clearly defined, and the Parliament oversight is enforced;

— the mandate and scope of the consolidated SOE management entities are clearly defined fully in line with the State Ownership Policy; — public finance management considerations are embedded in top SOEs’ charters (and, if needed in those of of the consolidated SOE management entities);

— top SOEs charters, when needed, are ameded in line with the corporate governance reform principles, including to ensure the independence of supervisory boards in decision making.

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6.6 Reform 3. Adoption of Roadmap on Q1 2025 Adoption and publication of the Roadmap defining the steps for mandatory structural separation of PSO and non-PSO the separation of public activities for all SOEs engaged in PSOs. The Roadmap is based on the identified current level of adoption of required Separation of service obligations (PSO) accounting approaches and include operational steps for the separation of accounts for companies on different stages accounts between and non-PSO activities of implementation of required changes. The Roadmap describes how the account separation between PSO and public service non-PSO activities will be performed in all top key SOEs approved by the Cabinet of Ministers protocol decision.

obligations (PSO) and non-PSO activities in state-owned enterprises

6.7 Reform 3. Entry into force on Q4 2025 Entry into force of the legislation identified in the Roadmap adopted under step 6.6 to align with the Directive legislation on the separation 2006/111 of the European Commission, which will ensure that mandatory structural separation of accounts between Separation of of public service obligations PSO and non-PSO activities is defined and implemented in all top key SOEs approved by the Cabinet of Ministers accounts between

(PSO) and non-PSO protocol decision which are engaged in PSOs. public service activities obligations (PSO) and non-PSO activities in state-owned enterprises

6.8 Reform 3. Submission of an audit Q3 2027 Submission of an independent audit report conducted by an audit company that is part of the international auditing report confirming the network and, according to national legislation, has the right to conduct a mandatory audit of the financial statements Separation of separation of public service of enterprises of public interest. Such a report contains a detailed assessment on the following areas for the top key accounts between obligations (PSO) and SOEs approved by the Cabinet of Ministers protocol decision, engaged in PSO:

public service non-PSO activities obligations (PSO) — implementation of accounts separation; and non-PSO — market compliance on cross-subsidisation; activities in state-owned — definition of public service obligations for each SOE;

enterprises — costs, financial flows and liabilities stemming from the Public Service obligations.

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6.9 Reform 4. Entry into force of the Q4 2025 Entry into force of the updated legislation on state aid, including provisions in relation to services of general economic updated legislation on state interest, together with the full unsuspension of the application of state aid control by the Antimonopoly Committee of Improved state aid aid and full unsuspension of Ukraine, with the exception of the recapitalization by the State of systemically important banks holding state secrecy control framework the application of state aid clearance for financing of the defence industry for the duration of martial law. The law will also allow for specific control appropriate aid schemes for support to SMEs provided under martial law.

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27.10.2025EN OJ L, 27.10.2025 C.7. HUMAN CAPITAL

1. Description of Reforms and Investments The objective of this chapter is to present reforms considered necessary to halt recent years’ erosion of human capital, while simultaneously laying a foundation for a sustainable recovery, reconstruction and modernisation process.

Reform 1. Improved vocational education The objective of this reform is to ensure that education meets the needs of the labour market and the country’s recovery via expanding the institutional capacity of educational entities to provide formal and non-formal vocational education, and regulating the relations between vocational education institutions, national/local and international stakeholders for the sustainable development of human capital in Ukraine.

The reform has one step. It entails the entry into force of the law on vocational education.

The reform is expected to be completed by Q2 2025.

Reform 2. Improved preschool education The objective of this reform is to ensure access to quality preschool education with the aim to increase the involvement of women with preschool children into the labour market.

The reform has one step. It entails the entry into force of the law on preschool education.

The reform is expected to be completed by Q1 2025.

Reform 3. Improved rehabilitation system for people with disabilities The objective of this reform is to improve the rehabilitation system and to allow for a broader assessment of people’s needs through a new electronic system.

The reform has one step. It entails the entry into force of legislation for aligning with international standards for measuring functioning, disability and health, and introducing an electronic system containing information about the needs of the individual and automatically offering services in accordance with the identified needs.

The reform is expected to be completed by Q4 2026.

Reform 4. Transition from military service to civilian life The objective of this reform is to facilitate the transition from military service to civilian life, including active participation in social and economic life.

The reform has one step, namely the entry into force of the legislative measures required for the implementation of the transition system and associated services.

The reform is expected to be completed by Q3 2026.

Reform 5. Improved social infrastructure and de-institutionalisation The objective of this reform is to improve the well-being of children, persons with disabilities, and the elderly in the public care system.

The reform has one step. It entails the adoption of two strategies for reforming psychoneurological and other residential institutions and de-institutionalisation of care for children, persons with disabilities and the elderly.

The reform is expected to be completed by Q4 2024.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 45/102EN OJ L, 27.10.2025 Reform 6. Improved functioning of the labour market The objective of this reform is to contribute to the improved functioning of the labour market.

The reform has two steps. First, a strategy shall be adopted aiming to improve the demographic situation of Ukraine up to 2040, including reducing premature mortality, and overcoming negative migration trends. Second, a population employment strategy shall be adopted that proposes measures to update the conditions of Ukraine’s labour market, such as simplified access to the labour market, and a reformed state employment service.

The reform is expected to be completed by Q2 2026.

Reform 7. Ensuring access to housing for people in need The objective of this reform is to develop the framework for a social housing system.

The reform has two steps. First, legislation shall enter into force that that establishes key priorities for Ukraine’s housing policy, such as the need for transparency, accessibility for most vulnerable groups, or the creation of support schemes.

Second, legislation establishing a social housing shall enter into force.

The reform is expected to be completed by Q4 2026.

Reform 8. Improved social security The objective of this reform is to improve the provision of public social services, through the introduction of mechanisms for procuring certain social services from registered providers.

The reform has one step. It entails the adoption of a resolution that reforms the social procurement system for social services, changes the financing model to a result-oriented purchasing model of social services, and incentivises the provision of social services usually not financed by the community.

The reform is expected to be completed by Q2 2025.

Reform 9. Improved cultural development The objective of this reform is to promote Ukraine’s cultural heritage.

The reform has one step. It entails the adoption of a strategy that establishes priority goals such as improving the quality and accessibility of Ukraine’s cultural offer, as well as capacity building for Ukraine’s cultural institutions.

The reform is expected to be completed by Q1 2025.

Investment 1. Investments in education The objective of this investment is to improve access to safe and quality public education.

The investment has two steps. First, it entails the budgeting of at least EUR 300 million in current prices (in UAH equivalent) for improving access to safe and quality education for the years 2024 and 2025. Second, it entails the budgeting of at least EUR 650 million in (UAH equivalent) for improving the access to safe and quality education for the years 2024, 2025, 2026, and 2027.

The investment is expected to be completed by Q4 2027.

Investment 2. Investments in healthcare The objective of this investment is to improve Ukraine’s public healthcare system.

46/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 The investment has two steps. First, it entails budgeting at least EUR 200 million in current prices (in UAH equivalent) for strengthening of the healthcare infrastructure and facilities, digitalisation of healthcare services, and the provision of equipment for medical analysis, surgery, and patient care for the years 2024 and 2025. Second, it entails budgeting at least EUR 400 million (in UAH equivalent) for strengthening the healthcare infrastructure and facilities, digitalisation of healthcare services, and the provision of equipment for medical analysis, surgery, and patient care for the years 2024, 2025, 2026 and 2027.

The investment is expected to be completed by Q4 2027.

Investment 3. Investments in social infrastructure The objective of this investment is to strengthen Ukraine’s social infrastructure.

The investment has one step. It entails the budgeting of at least EUR 350 million in current prices (in UAH equivalent) for the restoration, construction (new construction, reconstruction, overhaul, restoration) of damaged/destroyed social infrastructure.

The investment is expected to be completed by Q4 2027.

Investment 4. Investments in compensation for damaged or destroyed housing The objective of this investment is to improve access to affordable housing and improve the quality and accessibility of housing.

The investment has one step. It entails the budgeting of at least EUR 600 million in current prices (in UAH equivalent) for the compensations paid to persons whose housing was damaged or destroyed as a result of Russia’s war of aggression.

The investment is expected to be completed by Q4 2027.

Investment 5. Investments in housing provision for vulnerable groups of the population The objective of this investment is to improve access to affordable housing and improve the quality and accessibility of housing with particular focus on veterans, with disabilities, their family members and internally displaced persons (IDPs).

The investment has two steps. First, it entails the budgeting of at least EUR 200 million in current prices (in UAH equivalent) for the provision of housing for persons with disabilities of group I-II for the years 2024 and 2025. Second, it entails the budgeting of at least EUR 450 million (in UAH equivalent) for the provision of housing for persons with disabilities of group I-II for the years 2024, 2025, 2026 and 2027.

The investment is expected to be completed by Q4 2027.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 47/1022. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

7.1 Reform 1. Entry into force of the legislation on Q2 2025 Entry into force of the Law of Ukraine ‘On Vocational Education.’ The law focuses on these main

vocational education areas:

Improved vocational education — fair rules for the functioning of educational entities in the market of educational services in the field of vocational education are defined; — the institutional capacity of educational entities to provide formal and non-formal vocational education is expanded;

— relations between vocational education institutions, national/local and international stakeholders for the sustainable development of human capital in Ukraine are clearly defined.

7.2 Reform 2. Entry into force of the legislation on Q1 2025 Entry into force of the Law of Ukraine ‘On Preschool Education’ in alignment with the Council preschool education Recommendation of 22 May 2019 on High-Quality Early Childhood Education. The law focuses Improved preschool

on these main areas: education — guarantees of access to preschool education for children of early and preschool age; — fair rules for the functioning of educational entities in the market of educational services in the field of preschool education;

— decent working conditions for employees in the field of preschool education; — the rules for the functioning of a flexible and efficient network of preschool education providers.

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7.3 Reform 3. Entry into force of the legislation on Q4 2026 Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine ‘On Rehabilitation rehabilitation of persons with disabilities of Persons with Disabilities in Ukraine’.

Improved

rehabilitation system The law focuses on these main areas: for people with — use of the International Classification of Functioning Disability and Health; disabilities — introduction of an electronic system that contains information about the needs of the individual and automatically offers services in accordance with the identified needs (social, medical, and other).

7.4 Reform 4. Entry into force of the legislation to Q3 2026 Entry into force of the Law of Ukraine on the State Veterans Policy, including the introduction of implement a transition system from military a system from transitioningfrom military service to civil life. The law will focus on these main Transition from

service to civilian life areas: military service to civilian life — rehabilitation and medical care, including psychological assistance; — training, retraining and professional development programmes; — the necessary conditions for employment of veterans as a separate category;

— measures to support veteran businesses.

7.5 Reform 5. Adoption of the Strategy for reforming Q4 2024 Adoption of the Order of the Cabinet of Ministers ‘On Approval of the Strategy for Reforming Psychoneurological, Other residential Psychoneurological, Other Residential Institutions and De-institutionalisation of Care for Persons Improved social in- Institutions and De-institutionalisation of with Disabilities and Older Persons’ and of the Order of the Cabinet of Ministers ‘On Approval of frastructure and Care for Persons with Disabilities, and Older the Strategy for ensuring the right of every child in Ukraine to grow up in a family environment de-institutionalisa- Persons and of the Strategy for Ensuring the for 2024-2028’. The strategies focus on these main areas:

tion Right of Every Child in Ukraine to Grow Up — development of social services to support families with children, people with disabilities and in a Family Environment for 2024-2028 older persons to live independently in the community and prevent institutionalisation;

— development of assisted living services for people with disabilities and older people who need additional support; — providing family-based forms of upbringing (e.g. foster care, guardianship, and adoption) for children left without parental care.

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7.6 Reform 6. Adoption of the Demographic Development Q3 2024 Adoption of the Order of the Cabinet of Ministers of Ukraine ‘On Approval of the Demographic Strategy for the period up to 2040 Strategy of Ukraine for the Period up to 2040’. The Strategy focuses on these main areas:

Improved functioning of the — improving the situation in the field of fertility; labour market — reducing premature mortality, especially among men of working age; — overcoming negative migration trends, through the return of forced migrants, attracting representatives of the foreign diaspora to Ukraine, etc.;

— promoting active longevity; — creating infrastructure and security preconditions for improving the demographic situation.

7.7 Reform 6. Adoption of the Population Employment Q2 2026 Adoption of the Order of the Cabinet of Ministers of Ukraine on approving the Population Strategy Employment Strategy. The strategy focuses on these main areas:

Improved functioning of the — creation of favourable conditions for employment, including through entrepreneurship and labour market with a particular focus on women; — simplification of access to the labour market;

— retraining and re-qualification; — reform the state employment service; — reform the labour market forecasting; — incentives to attract foreign talent to the Ukrainian labour market foreign entrepreneurs, highly skilled and working personnel and students.

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7.8 Reform 7. Entry into force of the legislation on the Q4 2025 Entry into force of the Law of Ukraine ‘On Basic Principles of Housing Policy’. The Law focuses on

Basic Principles of Housing Policy these main areas:

Ensuring access to housing for people — accessibility of housing for the most vulnerable categories of citizens should become the main in need principle in the provision of housing; — creation of various support mechanisms for citizens with different financial capacities and determination of criteria for access to them;

— regulating the legal basis for the introduction of lease of communal housing, lease of communal housing with the right to buy; — creating a transparent system for registering the housing needs of citizens to ensure prompt response at the local level;

— creating a transparent framework for monitoring by the public, civil society and the international community.

7.9 Reform 7. Entry into force of the legislation on the Q4 2026 Entry into force the Law of Ukraine on Amendments to the Law of Ukraine ‘On Social Housing Social Housing Fund Fund’ (or the new version of this Law). The Law focuses on these main areas:

Ensuring access to housing for people — establishing an institutional framework to ensure a sufficient supply of social housing projects; in need — establishing a transparent system for monitoring the needs of citizens to ensure prompt response at the local level;

— establishing a transparent framework for monitoring by the public, civil society and the international community; — improving the capacity of the institutional framework to ensure a sufficient supply of social housing projects;

— improving the rules for the establishment and operation of social housing, including ensuring compliance with energy efficiency, safety, and other standards.

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7.10 Reform 8. Adoption of the resolution on the Q2 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on purchasing social services at procurement of social services the expense of the state budget. The Resolution is fiscally neutral and does not impact in any way Improved social

the debt sustainability of Ukraine and focuses on these main areas: security — transition from financing institutions to a result-oriented purchasing model of social services; — introducing a mechanism for purchasing certain social services from registered public and private social service providers based on established social service standards and criteria for providers.

7.11 Reform 9. Adoption of the Strategy for the Q1 2025 Adoption of an Order by the Cabinet of Ministers approving the Strategy for the Development of Development of Ukrainian Culture Ukrainian Culture. The strategy focuses on these main areas:

Improved cultural development — preservation, safeguarding and promotion of cultural heritage and properties of Ukrainian people as an integral part of common European cultural area, preservation of national remembrance;

— rendering of high-quality and accessible cultural services and opportunities for creative self-realisation of people; — capacity building of Ukrainian cultural institutions to enhance accessibility, share the best practices of cultural participation, and strengthen international cultural relations;

— support to creative industries sector as a driver of social innovation and employment, enhancement of institutional capacities of creative industries.

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7.12 Investment 1. Investments of at least EUR 300 million in Q2 2026 Interim report of the government (or State Treasury report) showing that in the State Budgets for Investments in education 2024 and 2025 the general government budgeted in particular, to the regional and local levels (as education part of step 9.7), at least EUR 300 million (in UAH equivalent) for improving the access to safe and quality education, including preschool education in line with the new legislation on preschool education, among others for the following:

— shelters and safe conditions in educational establishments; — school buses; — modern teaching method, including through digitalisation; — materials and equipment for educational establishments; — quality nutrition;

— establishment of workshops and laboratories in educational institutions; — improvement of the energy efficiency of educational buildings.

7.13 Investment 1. Investments of at least EUR 650 million in Q4 2027 Final report of the government (or State Treasury report) showing that in the State Budgets for Investments in education 2024, 2025, 2026, and 2027, the general government budgeted in particular, to the regional and education local levels (as part of the step 9.8) at least EUR 650 million (in UAH equivalent) for improving the access to safe and quality education, including preschool education in line with the new legislation on preschool education, among others for the following:

— shelters and safe conditions in educational establishments; — school buses; — modern teaching method, including through digitalisation; — materials and equipment for educational establishments; — quality nutrition;

— establishment of workshops and laboratories in educational institutions; — improvement of the energy efficiency of educational buildings.

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7.14 Investment 2. Investments of at least EUR 200 million in Q2 2026 Interim report of the government (or Treasury report) showing that in the State Budgets for 2024 healthcare and 2025 the general government budgeted, part of which will be budgeted to the regional level Investments in (as a part of step 9.7), at least EUR 200 million (in UAH equivalent) for strengthening healthcare, healthcare

among others for the following: — laboratory equipment for micro-biological, chemical, and physical analysis; — shelters and safety measures for healthcare facilities; — hospital equipment for medical analysis, surgery, and patient care;

— healthcare infrastructure and facilities; — IT systems s to improve efficiency and effectiveness of healthcare services.

7.15 Investment 2. Investments of at least EUR 400 million in Q4 2027 Final report of the government (or Treasury report) showing that in the State Budgets for 2024, healthcare 2025, 2026, and 2027, the general government budgeted, part of which will be budgeted to the Investments in regional level (as part of step 9.8), at least EUR 400 million (in UAH equivalent) for strengthening healthcare healthcare, among others for the following:

— laboratory equipment for micro-biological, chemical, and physical analysis; — shelters and safety measures for healthcare facilities; — hospital equipment for medical analysis, surgery, and patient care;

— healthcare infrastructure and facilities; — IT systems to improve efficiency and effectiveness of healthcare services.

7.16 Investment 3. Investments of at least EUR 350 million in Q4 2027 Final report of the government (or State Treasury report) showing that in the State Budgets for social infrastructure 2026 and 2027 the general government budgeted at least EUR 350 million (in UAH equivalent) Investments in social for the restoration, construction (new construction, reconstruction, overhaul, restoration) of infrastructure damaged/destroyed social infrastructure, part of which will be budgeted to the regional level (as a part of step 9.8), to eliminate the social, economic and environmental consequences caused by the armed aggression of the Russian Federation against Ukraine, in particular to the regional level.

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7.17 Investment 4. Investments of at least EUR 600 million for Q4 2027 Final report of the government (or State Treasury report) showing that in the State Budgets for financial compensations for damaged 2026, and 2027, the general government budgeted at least EUR 600 million (in UAH equivalent) Investments in housing for the compensations paid to persons whose housing was damaged or destroyed as a result of compensation for hostilities, terrorist acts, sabotage caused by the military aggression of the Russian Federation damaged or based on verified data from the State Register of Damaged and Destroyed Property.

destroyed housing

7.18 Investment 5. Investments of at least EUR 200 million for Q2 2026 Interim report of the government (or State Treasury report) showing that in the State Budgets for Investments in providing housing to veterans with 2024 and 2025 the general Government budgeted at least EUR 200 million (in UAH equivalent) providing housing disabilities of the I-II groups, family for providing housing for:

for vulnerable members of deceased veterans and internally — persons with disabilities of I-II groups who defended the independence, sovereignty and groups of displaced persons territorial integrity of Ukraine;

population — family members of the deceased defenders; — internally displaced persons who defended the independence, sovereignty and territorial integrity of Ukraine and their family members.

7.19 Investment 5. Investments of at least EUR 450 million for Q4 2027 Final report of the government (or State Treasury report) showing that in the State Budgets for Investments in providing housing to veterans with 2024, 2025, 2026, and 2027, the general Government budgeted at least EUR 450 million (in providing housing disabilities of the I-II groups, family UAH equivalent) for providing housing for:

for vulnerable members of deceased veterans and internally — persons with disabilities of I-II groups who defended the independence, sovereignty and groups of the displaced persons territorial integrity of Ukraine;

population — family members of the deceased defenders; — Internally displaced persons who defended the independence, sovereignty and territorial integrity of Ukraine and their family members.

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27.10.2025 ENEN OJ L, 27.10.2025 C.8. BUSINESS ENVIRONMENT

1. Description of Reforms and Investments The objective of this chapter is to improve the business environment in Ukraine, recognising the role of the private sector in a sustainable recovery of the country. The reforms within this chapter are targeted towards reducing costs of doing business, inter alia, by cutting red tape, increasing digitalisation, and facilitating access to finance.

Reform 1. Improved Regulatory Environment The objective of this reform is to improve the regulatory environment by abolishing overlapping regulations, and by simplifying and digitising administrative procedures.

The reform has two steps. First, an Action Plan on the optimisation and digitalisation of regulation of economic activities in various sectors shall be adopted. Second, legislation on deregulation and simplification of business conditions shall enter into force.

The reform is expected to be completed by Q4 2025.

Reform 2. Reform of the Economic Security Bureau The objective of this reform is to relaunch and reinvigorate the Economic Security Bureau through the provision of a clearer mandate and an open, transparent and competitive process for selection of management and staff.

The reform has one step. It entails entry into force of new legislation to establish an open, transparent and competitive (merit-based) process for selection of management and staff, strengthened requirements for the selection commission, a contract system for employees, a clear scope and mandate definition, and a mechanism of attestation of staff.

The reform is expected to be completed by Q2 2024.

Reform 3. Access to finance and markets The objective of this reform is to help the private sector via different tools.

The reform has two steps. First, Ukraine shall adopt the Small and Medium Enterprises (SME) Strategy and Action Plan for its implementation to improve access to markets, finance and other resources and access to knowledge for SMEs. Second, legislative amendments on the simplification of access to utility networks shall enter into force.

The reform is expected to be completed by Q1 2026.

Reform 4. Improved public procurement The objective of this reform is to strengthen Ukraine’s public procurement system via a legislative framework aligned with the EU acquis.

The reform has one step. It entails the alignment of public procurement legislation with the EU acquis, focussing primarily on classic and utilities public procurement directives, on concessions and Public-Private Partnerships, the application of requirements for energy labelling and eco-design as mandatory minimum criteria during public procurement, and the enhancement of the e-procurement system.

The reform is expected to be completed by Q3 2027.

Reform 5. Harmonisation of legislation and standards with the EU The objective of this reform is to resume market surveillance measures and facilitate the adoption of EU norms and standards in Ukraine, particularly in the areas of industrial products.

56/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 The reform has two steps. First, legislation on the resumption of market surveillance measures and control for non-food products shall be adopted. Second, harmonised standards for three groups of industrial products (machines, electromagnetic compatibility of equipment, low-voltage electrical equipment) shall be translated into national standards.

The reform is expected to be completed by Q3 2025.

Reform 6. Addressing late payments The objective of this reform is to ensure that late payments do not impede business activity.

The reform has one step. It entails the alignment of relevant legislation with Directive 2011/7/EU (also known as the EU’s ‘Late Payment Directive’).

The reform is expected to be completed by Q4 2027.

Investment 1. Investments in financial support for micro-enterprises and SMEs The objective of this investment is to ensure entrepreneurs have access to finance.

The investment has one step. It entails budgeting of at least EUR 450 million in current prices (in UAH equivalent) for improving access to financial support for microenterprises, SMEs, small and medium farmers, and especially small to medium processing enterprises for the years 2024,2025, 2026, 2027 that can include both corporate lending and grants that will be allocated based on transparent criteria.

The investment is expected to be completed by Q4 2027.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 57/1022. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

8.1 Reform 1. Adoption of the Action Plan Q3 2024 Adoption of the Order of the Cabinet of Ministers of Ukraine regarding the approval of the Action Plan on on deregulation deregulation. The Action Plan focuses on these main areas:

Improved regulatory environment — reduction and digitisation of market access regulations; — changing the punitive and repressive model of state supervision (control) to a preventive one (risk-oriented approach);

— reducing the number of supervisory and control functions.

8.2 Reform 1. Entry into force of the Q4 2025 Entry into force of the legislation on deregulation and simplification of business conditions. The legislation focuses

legislation in accordance with on these main areas:

Improved regulatory the Action Plan on environment — digitisation of permit and license procedures through the implementation of an experimental project on the deregulation in specific introduction of the Unified State Electronic System of Permit Documents;

sectors — reduction of business inspections by introducing voluntary insurance and audit; — settlement of the issue of legal succession of permit documents and licenses in case of change in the organisational and legal form of a business entity.

8.3 Reform 2. Entry into force of the law on Q2 2024 Entry into force of the law on revising the legal basis of the activity of the Economic Security Bureau of Ukraine. The

revising the legal basis of the new legislation focuses on these main areas:

Reform of the Economic Security Bureau of Economic Security — developing an open, transparent and competitive process for selection of management and staff, selection of the Ukraine Bureau of Ukraine new head on merit-based procedure defined by law — strengthening requirements for the selection commission;

— introducing a contract system for employees; — defining a clearer scope and a mandate; — developing a mechanism of attestation of staff.

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8.4 Reform 3. Adoption of the Small and Q2 2025 Adoption of the resolution of the Cabinet of Ministers of Ukraine on approving the SME Strategy and Action Plan Medium Enterprises (SME) for its implementation. The strategy focuses on these main areas:

Access to finance and Strategy and Action Plan for markets. — access to markets; its implementation — access to finance and other resources; — access to knowledge.

8.5 Reform 3. Entry into force of the Q1 2026 Entry into force of the Law on Amendments to Legislative Acts on Simplification of the Accession of Immovable legislation on the Property to External Engineering Networks and Improvement of Legal Regulation in the Field of Pipeline Transport.

Access to finance and

simplification of the accession The law focuses on these main areas: markets. of immovable property to — open access to information about external engineering networks through public electronic registers, if the external engineering networks security situation allows, which will be determined in the relevant provisions of the amendments to the law, as and improvement of well as a unified procedure for connecting to external engineering networks;

regulation in the field of pipeline transport — inclusion of information about external engineering networks in public electronic registers of state ownership, if the security situation allows, which will be determined in the relevant provisions of the amendment to the law;

— inclusion of information on protection zones of external engineering networks in public electronic registers of state property.

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8.6 Reform 4. Entry into force of the Q3 2027 Entry into force of the Laws of Ukraine aligning legislation in the field of public procurement, with: legislation on harmonising Improved public — Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public legislation in the field of procurement procurement and repealing Directive 2004/18/EC;

public procurement with the EU acquis. — Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities operating in the water, energy, transport and postal services sectors and repealing Directive 2004/17/EC;

— Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award of concession contracts; — Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of procedures for the award of certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, and amending Directives 2004/17/EC and 2004/18/EC;

— Council Directive 89/665/EEC of 21 December 1989 on the coordination of the laws, regulations and administrative provisions relating to the application of review procedures to the award of public supply and public works contracts;

— Council Directive 92/13/EEC of 25 February 1992 coordinating the laws, regulations and administrative provisions relating to the application of Community rules on the procurement procedures of entities operating in the water, energy, transport and telecommunications sectors;

— Directive 2007/66/EC of the European Parliament and of the Council of 11 December 2007 amending Council Directives 89/665/EEC and 92/13/EEC with regard to improving the effectiveness of review procedures concerning the award of public contracts;

— Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on electronic invoicing in public procurement

These laws focus on these main areas: — further alignment of national legislation with the classic and utilities public procurement directives, especially with respect to the material scope of the Public Procurement Law and exemptions thereof, delimitation of procurement regulation that is not directly related to military needs carried out by customers in the sphere of security and defence;

— further alignment of national legislation on concessions and PPPs with the EU acquis; — application of the requirements for energy labelling and eco-design as mandatory minimum criteria during public procurement;

— enhancement of the e-procurement system, that includes development of e-contracting in the Prozorro system, and operational interoperability with DREAM system and other state IT systems if applicable.

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8.7 Reform 5. Adoption of the resolution for Q4 2024 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on Amendments to the Resolution of 13 March the resumption of market 2022 no. 303 ‘On the Termination of Measures of State Surveillance (Control) and State Market Surveillance under Harmonisation of surveillance measures and the Conditions of Martial Law’ with regard to the exclusion of state market surveillance from its scope and to repeal legislation and control of non-food products, Resolution of 3 May 2022 no. 550 ‘On the Termination of the Carrying Out of State Control of Non-Food Products standards with the EU including product safety under the Conditions of Martial Law’ in order to resume market surveillance measures and control of non-food inspection products, including product safety inspections

8.8 Reform 5. Adoption of harmonised Q3 2025 Harmonised standards for 3 groups of industrial products (machinery, electromagnetic compatibility of equipment, standards for three groups of low-voltage electrical equipment) are adopted as national ones by translation method Harmonisation of industrial products legislation and standards with the EU

8.9 Reform 6. Entry into force of the Q4 2027 Entry into force of the amendments to the legislation in line with the principles of the Directive 2011/7/EU of the legislation on combating late European Parliament and of the Council of 16 February 2011 on combating late payment in commercial Addressing late payments transactions (recast) payments

8.10 Investment 1. Investment of at least EUR Q4 2027 Report of the government (or State Treasury report) showing that in the State Budgets for 2024, 2025, 2026, 2027 Investments in 450 million for financial the general government budgeted at least EUR 450 million (in UAH equivalent) for financial support for financial support for support to microenterprises, microenterprises, SMEs, small and medium farmers, and especially small and medium processing enterprises, also in micro-enterprises and SMEs and small and medium line with the new SME Strategy and Action Plan when adopted and where relevant, that can include both corporate SMEs processing enterprises lending and grants that will be allocated based on transparent criteria. The corporate lending is channelled through financial intermediaries. The grants are channelled through dedicated entities with appropriate resources and capacity and through financial intermediaries.

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27.10.2025 ENEN OJ L, 27.10.2025 C.9. DECENTRALISATION AND REGIONAL POLICY

1. Description of Reforms and Investments The objective of this chapter is to advance the process of decentralisation on institutional and legislative level and to strengthen the development of regional policy. This contributes to a higher level of participation in the decision-making process at the local level and empowers regional and local government entities to participate in the recovery and reconstruction process. The reform also strengthens the capacity of entities, structures and systems that will be used for identification, implementation and evaluation of recovery and reconstruction projects.

Reform 1. Advancing decentralisation The objective of this reform is to put into place a framework for transforming local state administration into prefecture-type authorities and to ensure a better distribution of powers between local governments and executive authorities.

The reform has three steps. First, the legislation on transforming local state administration into prefecture-type authorities enters into force and is applied within 12 months from the date of termination or abolition of martial law in Ukraine.

Second, a study on the necessary measures to grant legal personality to municipalities is endorsed and published. Third, the legislation to ensure a better distribution of powers between local governments and executive authorities enters into force with an application in 12 months after the end of the martial law and from the start of the new budget period.

The reform is expected to be completed by Q1 2026.

Reform 2. Increased involvement of citizens to decision making process at the local level The objective of this reform is to increase citizen involvement and active participation into local decision-making processes.

The reform has one step. The law for public consultations on public policy enters into force and is applied within 12 months from the date of termination or abolition of martial law in Ukraine. The legislation launches a legal mechanism for public consultations during the formation and implementation of public policy, addressing issues of local importance.

The reform is expected to be completed by Q1 2025.

Reform 3. Development and implementation of regional policy The objective of this reform is to align regional policy with recovery and reconstruction efforts, by amending the strategy for regional development and development of urban planning at the local level.

The reform has two steps. First, adoption of resolutions to amend the State Strategy for Regional Development for 2021-2027. Second, the resolution for development of urban planning at the local level to foster the digitalisation of urban planning documentation is adopted.

The reform is expected to be completed by Q4 2024.

Investment 1. Investments for the recovery, reconstruction and modernisation needs of Ukraine’s sub-national authorities The objective of the investment is to support the recovery, reconstruction and modernisation needs of Ukraine’s sub-national authorities, in particular local self-government.

62/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 The investment has two steps. First, it entails providing an interim report showing that at least 5 % of the non-repayable financing support under Pillar I of the Ukraine Facility have been allocated to the recovery, reconstruction, and modernisation needs of Ukraine’s sub-national authorities, in particular local self-government for the years 2024 and 2025.

Second, it entails providing a report showing that at least 20 % of the non-repayable financing support under Pillar I of the Ukraine Facility have been allocated to the recovery, reconstruction, and modernisation needs of Ukraine’s sub-national authorities, in particular local self-government for the years 2024, 2025, 2026, and 2027.

This investment is expected to be completed by Q4 2027

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 63/1022. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

9.1 Reform 1. Entry into force of the legislation Q1 2025 Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine ‘On Local State on reforming of territorial Administrations’ and Some Other Legislative Acts of Ukraine as Regards the Reforming of Territorial Advancing organisation of the executive Organisation of the Executive Authorities in Ukraine’ with its application within 12 months from the date of decentralisation authorities in Ukraine with termination or abolition of martial law in Ukraine. Subordinate legal acts for the implementation of the law delayed application shall be adopted after it enters into force.

The law focuses on these main areas: — transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;

— ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.

9.2 Reform 1. Endorsement and publication on Q2 2025 Publication of the results of the study on the possibility of granting territorial communities the status of the website of the Ministry of a legal entity on the official web portal of the Ministry of Communities, Territories and Infrastructure Advancing Communities, Territories and Development of Ukraine decentralisation Infrastructure Development of Ukraine of a study on the necessary measures to grant legal personality to municipalities

9.3 Reform 1. Entry into force of the legislation Q1 2026 Entry into force of the amendments to the Law of Ukraine ‘On Local Self-Government in Ukraine’ and to ensure a better distribution of sector-specific laws with an application in 12 months after the end of the martial law but not earlier than the Advancing powers between local start of the new budget period. These legislative amendments are expected to focus on these main areas:

decentralisation governments and executive — lead to an improved distribution of powers between local governments and executive authorities based on authorities the principles of subsidiarity and decentralisation;

— help to eliminate conflicts of competence between different tiers of central, regional, district and local authorities, as well as within bodies of local self-government; — encourage a proper quality of public services at the local level and an efficient use of budget funds.

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9.4. Reform 2. Entry into force of the legislation Q1 2025 Entry into force of the Law of Ukraine ‘On Public Consultations’ with its application within 12 months from for public consultations on public the date of termination or abolition of martial law in Ukraine. The Law will launch legal mechanism for Increased involvement policy with delayed application public consultations during the formation and implementation of public policy, addressing issues of local of citizens to decision importance, which will establish preconditions for coherent, effective and efficient policy- and making process at the decision-making.

local level

9.5 Reform 3. Adoption of resolutions to amend Q3 2024 Adoption of the Resolution of the Cabinet of Ministers of Ukraine ‘On Amendments to the State Strategy for the State Strategy for Regional Regional Development for 2021-2027, approved by the Resolution of the Cabinet of Ministers of Ukraine Development and Development for 2021-2027 No. 695 dated 5 August 2020’. The resolution focuses on these main areas:

implementation of regional policy — development of multi-level governance, approximation of the regional development management system to EU procedures and best practices; — promoting partnerships, inter-municipal, interregional and cross-border cooperation;

— developing the institutional capacity of territorial communities and regions in terms of project management, digitalisation, anti-corruption and strategic planning.

9.6 Reform 3. Adoption of resolutions for Q4 2024 Adoption of the Resolutions by the Cabinet of Ministers of Ukraine approving the Procedure for maintaining development of urban planning at the state-level urban planning cadastre, the Unified State Address Register, the Unified State Register of Development and the local level Buildings and Structures, the Unified State Register of Administrative Units, amending resolutions of the implementation of Cabinet of Ministers of Ukraine regulating the development of urban planning documentation in the form of regional policy electronic documents, maintaining the Unified State Electronic System in the field of construction, integration and information interaction of registers and cadastres of the state.

9.7 Investment 1. Allocation of at least 5 % of the Q2 2026 Interim report showing that at least 5 % of the non-repayable financial support has been allocated to the Investments for the overall non-repayable financial recovery, reconstruction and modernisation needs of Ukraine’s sub-national authorities, in particular local recovery, support for meeting recovery, self-government.

reconstruction and reconstruction, and modernisation modernisation needs needs of sub-national authorities of Ukraine’s sub-national authorities

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9.8 Investment 1. Allocation of at least 20 % of the Q4 2027 Final report proving that at least 20 % of the non-repayable financing support has been allocated to the Investments for the overall non-repayable financial recovery, reconstruction and modernisation needs of Ukraine’s sub-national authorities, in particular local recovery, support for meeting recovery, self-government.

reconstruction and reconstruction, and modernisation modernisation needs needs of sub-national authorities of Ukraine’s sub-national authorities 66/102

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27.10.2025EN OJ L, 27.10.2025 C.10. ENERGY SECTOR

1. Description of Reforms and Investments The objective of this chapter is to strengthen the resilience and security of the energy sector in Ukraine, with a particular view to facilitate a clean energy transition, including via focusing on the energy efficiency measures, supporting private sector investments in renewable energy, advancing structural reforms, and easing integration of the energy system of Ukraine with that of the EU.

Reform 1. Integrated National Energy and Climate Plan The objective of this reform is to approve the Integrated National Energy and Climate Plan (INECP) which will set out national climate neutrality objectives, with an overarching goal to reduce greenhouse gas emissions.

The reform has one step. It entails the adoption of the Integrated National Energy and Climate Plan.

The reform is expected to be completed by Q2 2024.

Reform 2. Improved regulatory framework for increasing renewable energy and ensuring stable operation of the energy system.

The objective of this reform is to increase the share of renewable energy in the energy mix of Ukraine. This will be done via improving the conditions for the development of renewable energy on a market basis.

The reform has three steps. First, it entails the introduction of a market-based renewable energy framework in line with EU rules, defining necessary procedures and documents for competitive auctions. Second, legislation on streamlining and shortening the permitting procedures for renewable energy investments in line with EU rules enters into force. Third, it entails the development and approval of a Roadmap for the separation of the Renewable Energy Surcharge from the Transmission Tariff.

The reform is expected to be completed by Q4 2025.

Reform 3. Electricity market reform The objective of this reform is to improve the regulatory framework for the energy sector in Ukraine, including to support integration of the Ukrainian and European markets.

The reform has four steps. First, legislation enters into force that transposes the electricity integration package. Second, legislation changing the regime of indirect taxation of participants in the electricity market enters into force facilitating the market coupling of day-ahead and intraday markets of neighbouring states and export and import of electric energy. Third, a new electricity market operator designated by the regulator is appointed. Fourth, the secondary legislation on the wholesale energy market integrity and transparency (REMIT) law enters into force.

The reform is expected to be completed by Q2 2026.

Reform 4. Liberalisation of electricity and natural gas prices The objective of this reform is to set the grounds for a gradual liberalisation of prices once conditions allow, ensuring sufficient measures to protect vulnerable households.

The reform has one step. It entails the adoption of a Roadmap for gradual liberalisation of gas and electricity markets, which shall include a set of specific steps to take and the timeline to be implemented after the martial law is lifted.

The reform is expected to be completed by Q2 2026.

Reform 5. Ensuring independence of National Energy and Utilities Regulatory Commission The objective of this reform is to strengthen the independence of the energy regulator and ensure the effective functioning and development of markets in the energy and utilities sectors.

The reform has two steps. First, the legislative amendments exempting the decisions of the energy regulator from the state registration procedure, according to the requirements of the relevant EU directives, will enter into force. Second, legislative amendments to provide for the specification of special status of the regulator, as per the relevant EU directives, enter into force.

The reform is expected to be completed by Q4 2025.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 67/102EN OJ L, 27.10.2025 Reform 6. Improved efficiency in the district heating The objective of this reform is to improve the district heating sector and aim to strengthen the resilience of the integrated energy system, including by improving the regulatory framework, and supporting modernisation of the heating companies.

The reform has three steps. First, the State targeted economic programme for the modernisation of heat generating enterprises for the period up to 2030 will be adopted to improve heat supply services, support the green transition of the energy sector, and strengthen governance. Second, entry into force of legislation to support the development of efficient and sustainable district heating via clear rules for network connection and disconnection, and on improving procedures for individual heat substations installation in multi-apartment buildings. Third, Ukraine will cancel the moratorium on rising heat and hot water tariffs.

The reform is expected to be completed by Q4 2026.

Reform 7. Improved energy efficiency in public buildings and improvement of public procurement procedures The objective of this reform is to improve energy sustainability and support the reduction of energy consumption by rolling out energy efficiency measures.

The reform has two steps. First, Ukraine shall adopt a Strategy for Thermal Modernisation of Buildings until 2050 and an accompanying Action plan aimed at improved the energy efficiency of the buildings. Second, Ukraine shall adopt legal acts on setting minimum energy efficiency performance levels for buildings and also for products covered by the EU energy labelling legislation, and on setting classes of energy efficiency performance levels for products covered by the EU energy labelling legislation. .

The reform is expected to be completed by Q3 2026.

Investment 1. Investments in energy infrastructure The objective of this investment is to finance critical energy infrastructure to ensure energy security, with a strong focus on energy efficiency and development of renewable sources.

The investment has one step. It entails budgeting of at least EUR 550 million in current prices (in UAH equivalent) for energy investments in 2026 and 2027, for strengthening the energy infrastructure of Ukraine, including at the regional level, with a focus on improving energy efficiency in district heating, public buildings, and the residential sector, physical protection of Ukraine’s infrastructure, and development of renewable energy sources.

The investment is expected to be completed by Q4 2027.

68/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

10.1 Reform 1. Adoption of the Integrated National Q2 2024 Adoption of the Ordinance of the Cabinet of Ministers of Ukraine on approving the Energy and Climate Plan Integrated National Energy and Climate Plan to establish national climate neutrality Integrated National Energy and objectives and ensure appropriate planning after duly taking into account the Climate Plan recommendations from the Energy Community. The plan defines targets to be achieved by 2030 on:

— GHG reductions, including through market-based carbon pricing mechanisms; — the share of renewable sources in gross final consumption of energy; — the energy saving in final energy consumption.

10.2 Reform 2. Introduction of a market-based Q4 2024 Entry into force of market-based legislative and regulatory framework for investments in framework for renewable energy renewable energy sources in line with EU rules, namely necessary procedures and Improved regulatory framework for documents for competitive auctions. The following legislative act is increasing renewable energy and introduced/amended: The Resolution of the Cabinet of Ministers ‘On Amendments to ensuring stable operation of the the Resolution of the Cabinet of Ministers dated 29 December 2019 № 1175 on energy system Improving the Procedure for Holding Auctions for the Distribution of Support Quotas’

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10.3 Reform 2. Entry into force of the legislation to Q4 2025 Entry into force of the legislation on shortening the permitting procedures for improve permitting procedures for renewable investments in line with EU rules transposed in the Energy Community as Improved regulatory framework for renewable energy investments Ministerial Council Recommendation 2024/1/MC-EnC of 11 December 2024 on increasing renewable energy and accelerating the deployment of renewable energy projects and implementing the energy ensuring stable operation of the efficiency first principle (‘Recommendation 2024/1/MC-EnC’).

energy system

10.4 Reform 2. Adoption of the Roadmap of the process Q2 2025 Adoption of the Roadmap of the process of separation of the Renewable Energy of separation of the Renewable Energy Surcharge from the Transmission Tariff with identifying legislative needed acts and Improved regulatory framework for Surcharge from the Transmission Tariff terms of implementation.

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10.5 Reform 3. Entry into force of the Law on the Q3 2025 Entry into force of the Law on the transposition of the electricity integration package, transposition of the electricity integration aligning Ukrainian national legislation with the electricity integration package, as Electricity market reform package incorporated in the Energy Community acquis in December 2022. The electricity integration package approximates legislation in line with the following acts and network

codes and guidelines: — Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast) — Regulation (EU) 2019/943 of the European Parliament and of the Council of 5 June 2019 on the internal market for electricity (recast);

— Regulation (EU) 2019/941 of the European Parliament and of the Council of 5 June 2019 on risk-preparedness in the electricity sector and repealing Directive 2005/89/EC; — Regulation (EU) 2019/942 of the European Parliament and of the Council of 5 June 2019 establishing a European Union Agency for the Cooperation of Energy Regulators (recast).

— the five Network Codes and Guidelines establish detailed rules related to different

market segments and system operation: — Commission Regulation (EU) 2016/1719 of 26 September 2016 establishing a guideline on forward capacity allocation; — Commission Regulation (EU) 2015/1222 of 24 July 2015 establishing a guideline on capacity allocation and congestion management;

— Commission Regulation (EU) 2017/2195 of 23 November 2017 establishing a guideline on electricity balancing; — Commission Regulation (EU) 2017/1485 of 2 August 2017 establishing a guideline on electricity transmission system operation;

— Commission Regulation (EU) 2017/2196 of 24 November 2017 establishing a network code on electricity emergency and restoration.

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10.6 Reform 3. Entry into force of the legislation on Q2 2026 Entry into force of the legislation changing the regime of indirect taxation of changing the conditions of taxation of participants in the electricity market, in order to facilitate the market coupling of Electricity market reform participants in the electricity market day-ahead and intraday markets with day-ahead markets and intraday markets of neighbouring states and operations related to exports and import of electric energy within the framework of the implementation of the legislation of the Energy Community introduced by the decision of the Council of Ministers of the EU dated

15.12.2022 № D/2022/03/MC–EnС, namely to amend the Tax Code of Ukraine and to amend the Customs Code of Ukraine to enable market integration and market coupling.

The list of specific laws will be finalised after the adoption of the basic law on the transposition of the Electricity Integration Package.

10.7 Reform 3. Appointment of a new electricity market Q4 2025 Appointment of a nominated electricity market operator designated by National Energy operator and Utilities Regulatory Commission (NEURC).

Electricity market reform

10.8 Reform 3. Entry into force of the secondary Q3 2024 Entry into force of the secondary legislation on REMIT law. The NEURC approves these

legislation on the Regulation on procedures and requirements:

Electricity market reform Wholesale Energy Market Integrity and — the procedure for acquiring, suspending and terminating the status of a data transfer Transparency (REMIT) law administrator; — the procedure for the functioning of insider information platforms;

— requirements for ensuring integrity and transparency in the wholesale energy market; — procedure for Submission of Information on Economic and Trade Transactions with Wholesale Energy Products Preparation of the Terms of Reference for the development of an information system

defining the following functions of the NEURC: — the system will be integrated with the systems of market operators, insider information platforms, data transfer administrators and will detect information indicating the presence of abuse.

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10.9 Reform 4. Adoption of a Roadmap for gradual Q2 2026 Adoption of a Roadmap for gradual liberalisation of gas and electricity market by the liberalisation of gas and electricity market, Cabinet of Ministers of Ukraine with steps to take and the associated timeline, to be Liberalisation of electricity and to be implemented after the expiration of implemented after the expiration of the martial law. The Roadmap is based on the natural gas prices the martial law technical analysis to understand the financial condition of the sector. The Roadmap

focuses on these main areas: — steps needed to reform the PSOs in order to gradually liberalise the market prices, once the martial law is lifted; — steps to take to ensure vulnerable consumers are adequately protected once the prices for households are liberalised, including the new design of the subsidy system for vulnerable consumers which improve the targeting and ensures adequate levels of protection, as well as preparatory steps to be implemented before the end of the martial law, such as identification of vulnerable population and the associated digital solution.

10.10 Reform 5. Entry into force of the legislation to Q4 2024 Entry into force of the amendments Law dated 24 August 2023 № 3354–IX ‘On ensure the independence of the National law-making activity’, which exempt the decisions of the National Energy and Utilities Ensuring independence of National Energy Utilities Regulatory Commission Regulatory Commission, which are regulatory legal acts, from the state registration Energy and Utilities Regulatory procedure provided for by law. These amendments focus on these main areas:

Commission — ensuring the independence of the Regulator as provided for by Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast)and Directive 2009/73/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in natural gas and repealing Directive 2003/55/EC;

— implementation of Article 5 of the Law of Ukraine ‘On the National Energy and Utilities Regulatory Commission’ on the prohibition of state bodies to interfere in the activities of the Regulator.

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10.11 Reform 5. Entry into force of the amendments to the Q4 2025 Entry into force of the amendments to the Law of Ukraine ‘On the National Energy and Law of Ukraine ‘On the National Energy Utilities Regulatory Commission’ and other acts, which provide for the specification of Ensuring independence of National and Utilities Regulatory Commission’ the special status for ensuring the independence of the Regulator as provided for by Energy and Utilities Regulatory Directive (EU) 2019/944 of the European Parliament and of the Council of 5 June 2019 Commission on common rules for the internal market for electricity and amending Directive 2012/27/EU (recast)and Directive 2009/73/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in natural gas and repealing Directive 2003/55/EC.

10.12 Reform 6. Cancelation of the moratorium on rising Q4 2026 Cancelation of the moratorium introduced by Law No. 2479-IX ‘On the peculiarities of heat and hot water tariffs regulating relations in the natural gas market and in the field of heat supply during Improved efficiency in the district martial law and the subsequent restoration of their functioning’ followed by an increase heating in heat tariffs in order to reach cost-reflectiveness of heat and hot water tariffs.

10.13 Reform 6. Adoption of the State targeted economic Q4 2025 Adoption of the State targeted economic program for the energy modernisation of heat programme for the energy modernisation generating enterprises for the period up to 2030 by the Cabinet of Ministers. The Improved efficiency in the district

of heat generating enterprises for the Strategy focuses on these main areas: heating period up to 2030 — identifying measures to improve resilience, quality and availability of heat supply services; — identifying measures to support decarbonisation, reduction of greenhouse gas emissions and expansion of renewable energy sources;

— providing measures to strengthen governance and management skills for local authorities in district heating sector.

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10.14 Reform 6. Entry into force of the legislation to Q4 2025 Entry into force of the Law of Ukraine ‘On amendments to some Laws of Ukraine to support development of the efficient and support development of the efficient and more sustainable district heating’. The law Improved efficiency in the district more sustainable district heating’ focuses on these main areas:

heating — setting clear rules for network connection/ disconnection, zones of priority development of district heating systems; — improvement of procedures for individual heat substations (IHS) installation in multi-apartment buildings to ensure proper remote control and demand management.

10.15 Reform 7. Adoption of the Strategy for thermal Q2 2024 Adoption of the act ‘On Approval of the Strategy for Thermal Modernisation of modernisation of buildings until 2050 Buildings until 2050’ and Action plan for the Strategy by the Cabinet of Ministers of Improved energy efficiency in public and the Action Plan Ukraine, aimed at introducing market-based financial instruments and incentives, buildings and improvement of public containing a roadmap with policy measures, including those aimed to support the procurement procedures introduction of nearly-zero energy building.

10.16 Reform 7. Adoption of legal acts on setting Q3 2026 Adoption by the Cabinet of Ministers of Ukraine of legal acts on setting minimum minimum energy efficiency performance energy efficiency performance levels for buildings and also for products covered by the Improved energy efficiency in public levels for buildings EU ecodesign legislation and the Ministry for Communities, Territories and buildings and improvement of public Infrastructure Development adopted acts on setting classes of energy efficiency procurement procedures performance levels for products covered by the EU energy labelling legislation.

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10.17 Investment 1. Investments of at least EUR 550 million in Q4 2027 Report of the Government (or State Treasury report) showing that in the State Budgets energy infrastructure for 2026 and 2027 the general Government budgeted at least EUR 550 million (in UAH Investments in energy infrastructure equivalent) for strengthening the energy infrastructure of Ukraine, including at the regional level (as part of step 9.8), among others for the following:

— improving energy efficiency in district heating, in line with the State targeted economic program for the energy modernisation of heat generating enterprises for the period up to 2030; — financial contribution to the Energy Efficiency Fund to support improved energy efficiency in the residential sector;

— improving energy efficiency in public buildings, in line with the Strategy for Thermal Modernisation of Buildings until 2050; — physical protection of Ukraine’s energy infrastructure; — supporting the development of renewable energy sources, in line with the new market-based framework for renewable energy, and for the construction of highly flexible capacities.

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27.10.2025EN OJ L, 27.10.2025 C.11. TRANSPORT

1. Description of Reforms and Investments The objective of this chapter is to modernise and reform Ukraine’s transport sector. It aims to enhance connectivity with the EU and the Republic of Moldova and support development of a competitive and efficient transport system in line with EU policies and standards.

Reform 1. Comprehensive planning of transport sector The objective of this reform is to revise the key strategic document for the transport sector.

The reform has one step. It entails the adoption of the revised National Transport Strategy of Ukraine until 2030.

The reform is expected to be completed by Q4 2024.

Reform 2. Development of Ukraine’s export logistics potential The objective of this reform is to support modernisation and increase capacity of the existing network of Border Crossing Points to facilitate the needs for transportation across the border of Ukraine with the EU and the Republic of Moldova.

The reform has one step. It entails the adoption of the Strategy for developing and expanding the border infrastructure with EU Member States and the Republic of Moldova until 2030.

The reform is expected to be completed by Q4 2024.

Reform 3. Liberalisation in the railways transport sector The objective of this reform is the creation of a competitive rail market in line with EU standards based.

The reform has three steps. First, the law on traffic safety and interoparability of railway transport of Ukraine enters into force, with application within three years from its adoption. Second, the law on the railway transport market will enter into force with a sequential application of its provisions. Third, the main by-laws for the implementation of the law shall be adopted.

The reform is expected to be completed by Q4 2027.

Reform 4. Improved shipping and port services The objective of this reform is to ensure improvements in Ukraine's performance of its obligations under international treaties in the field of merchant shipping as well as enhance competition in port services.

The reform has two steps. First, legislation on merchant shipping and shipping on inland waterways shall enter into force.

Second, the existing national legislation to ensure full compliance with the provisions of EU Regulation 2017/352 on Port Service Regulation shall be amended.

The reform is expected to be completed by Q1 2027.

Investment 1. Investments in transport infrastructure The objective of this investment is to restore the damaged and destroyed transport infrastructure.

ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj 77/102EN OJ L, 27.10.2025 The investment has one step. It entails budgeting of at least EUR 350 million in current prices (in UAH equivalent) in 2026-2027 for the construction, reconstruction, restoration, modernisation and upgrade of transport infrastructure facilities amongst others in the following sectors, railways, maritime and inland shipping, roads, aviation and border crossing points.

The investment is expected to be completed by Q4 2027.

78/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj2. List of steps and timetable for implementation No. Reform / Investment Name of the step Timeline Step description

11.1 Reform 1. Adoption of the revised National Q4 2024 Adoption of an Order of the Cabinet of Ministers on updating the National Transport Strategy of Ukraine for Transport Strategy of Ukraine the period up to 2030.

Comprehensive until 2030

planning of transport The Strategy focuses on these main areas: sector — reconstruction and development of a competitive and efficient transport system in line with EU policies and standards in particular relating to trans-European transport networks and the decarbonisation targets of the transport sector set out at international and European level (including through the development of railway, road and inland waterway routes, included in indicative maps of the TEN-T network, digitisation of transport system management, etc.);

— high-quality passenger transportation and unimpeded mobility; — safe for people and the environment, sustainable, energy-efficient transport.

11.2 Reform 2. Adoption of the Strategy for Q4 2024 Adoption of the Strategy for Developing and Expanding the Border Infrastructure with EU Member States developing and expanding the and the Republic of Moldova until 2030. The Strategy focuses on these main areas:

Development of border infrastructure with EU Ukraine’s export — reconstruction of border crossing points on the border with Poland, Slovakia, Hungary, and Romania;

Member States and the Republic of logistics potential Moldova until 2030 — creation of a network of service areas; — simplification of border crossing procedures (digitalisation and introduction of joint control) in line with EU standards.

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11.3 Reform 3. Entry into force of the law on Q4 2025 Entry into force of the Law of Ukraine ‘On Traffic Safety and Interoperability of Railway Transport of traffic safety and interoperability Ukraine’ with application within three years from its adoption. The law ensures technical integration of Liberalisation in the of railway transport of Ukraine railway transport in line with the principles of Directives 2016/798, 2016/797, and Regulation 2016/796 railways transport

with application within three years and focuses on these main areas: sector from its adoption — establishing a national rail safety authority and vesting it with the powers and functions assigned to it by EU legislation;

— introducing a legal framework for the safety certification of railway undertakings and the safety authorisation of infrastructure managers; — establishing a national investigating body and introducing the technical investigation of railway accidents;

— establishing the legal framework for vehicle and infrastructure authorization based on technical specifications for interoperability; — establishing a legal framework for train driver certification, based on the EU model.

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11.8 Reform 3. Entry into force of the law on the Q4 2026 Entry into force of the Law of Ukraine ‘On the Railway Transport Market’ with a sequential application of its railway transport market with provisions. The law will implement key elements of EU legislation on the single European railway area and Liberalisation in the a sequential application of its on the provision of public passenger transport services by rail (PSO) in line with the principles of Directive railways transport provisions 2012/34/EC as amended and Regulation (EC)1370/07 read in conjunction with its 2023 Interpretative sector Guidelines. The Law will apply sequentially as follows:

within three years from its entry into force in the part concerning these main areas: — ensuring the functional separation of the infrastructure manager and railway undertakings, including the independence of the infrastructure manager as regards essential functions and the rules on financial relations/transactions, including a separation of accounts within the railway undertakings;

— setting up an independent Regulatory Body and defining its functions and powers; — licensing of railway undertakings by an independent Licencing Authority. within five years from its entry into force, which include a transition period of at least 2 years in the part

concerning these main areas: — creating a comprehensive legislative framework for the functioning of a competitive passenger and freight market, including ensuring equitable, non-discriminatory and transparent access to railway infrastructure for railway undertakings;

— introducing non-discriminatory charging for use of infrastructure and service facilities; — establishing of competent authorities for the award of public service contracts — defining the content of public service contracts in the railway sector;

— establishing mechanisms to control contract performance and rule out overcompensation for the provision of public services.

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11.4 Reform 3. Adoption of the by-laws for the Q4 2027 Adoption of the main legislative acts (by-laws) for the implementation of the Law of Ukraine ‘On Railway implementation of the legislation Transport of Ukraine’. The by-laws introduce mechanisms for the functioning of the rail transportation Liberalisation in the on railway transport market and, in particular, focus on: equal access to the rail infrastructure, licensing of railway operators, railways transport safety management systems, the procedure for the organisation of socially important passenger sector transportation (PSO).

11.5 Reform 4. Entry into force of the legislation Q4 2026 Entry into force of the Law of Ukraine ‘On Amendments to Certain Legislative Acts of Ukraine Concerning on merchant shipping and Merchant Shipping and Shipping on Inland Waterways’. The Law focuses on these main areas:

Improved shipping and shipping on inland waterways ports services — defining and regulating the principles of ensuring the safety of navigation in the territorial sea, inland sea waters, seaports, and inland waterways;

— improvement of the mechanism for implementing the international regime for the protection of ships and seaports; — defining a detailed mechanism for controlling ships in a seaport; — review of the functions of the central executive body implementing state policy in the areas of maritime and inland waterway transport and shipping in the Merchant Shipping Code, the Laws of Ukraine ‘On Transport’, ‘On Inland Waterway Transport’ and ‘On Seaports of Ukraine’ in order to eliminate duplication of legislative norms and clarify the division of competence, in particular with the central executive body that ensures the formation and implementation of state policy in the areas of maritime and inland waterway transport;

— simplification of administrative procedures, a clear list of powers of state bodies, elimination of administrative barriers.

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11.6 Reform 4. Review and amend the existing Q1 2027 Review and amend the existing national legislation (including relevant subordinate legal acts) in line with the national legislation in line with the principles of Regulation (EU) 2017/352 of the European Parliament and of the Council of 15 February 2017 Improved shipping and principles Regulation (EU) establishing a framework for the provision of port services and common rules on the financial transparency ports services 2017/352 of the European of ports.

Parliament and of the Council of 15 February 2017 establishing a framework for the provision of port services and common rules on the financial transparency of ports

11.7 Investment 1. Investments of at least EUR Q4 2027 Report of the government (or State Treasury report) showing that in the State Budgets for 2026 and 2027 350 million in transport the general government budgeted at least EUR 350 million (in UAH equivalent) for the reconstruction, Investments in infrastructure restoration, modernisation and upgrade of damaged and destroyed transport infrastructure facilities, in line transport infrastructure with the National Transport Strategy of Ukraine until 2030, including some of the funds to be directed to the regional level (as part of step 9.8), among others in the following sectors:

— railways (in line with the new legislation on railway transport of Ukraine); — maritime and inland shipping (in line with the new legislation on merchant shipping and shipping on inland waterways); — roads;

— aviation; — and border crossing points (in line with the Strategy for developing and expanding the border infrastructure with EU Member States and the Republic of Moldova until 2030).

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27.10.2025 ENEN OJ L, 27.10.2025 C.12 AGRI-FOOD SECTOR

1. Description of Reforms and Investments The objective of this chapter is to support strengthening of the Ukraine’s agri-food sector in parallel with further aligning its regulatory framework with the EU acquis.

Reform 1. Aligning the institutional framework on agriculture and rural development with the EU The objective of this reform is to develop strategic national priorities including to further alignment with EU practices, norms and rules.

The reform has two steps. First, Ukraine shall adopt the Strategy for Agriculture and Rural Development until 2030.

Second, a Farm Accountancy Data Network System shall be put in place in selected pilot regions to allow tracking the situation in the agricultural sector.

The reform is expected to be completed by Q1 2027.

Reform 2. Ensuring a functional land market The objective of this reform is to improve the functional land market.

The reform has one step. An automated system for public monitoring of land relations and a geoinformation system for mass land assessment shall be put in place.

The reform is expected to be completed by Q1 2025.

Reform 3. Improving the institutional and administrative set up for managing investment programmes The objective of this reform is to improve the set up for managing public financial support schemes to the agri-food sector.

The reform has one step. It entails the entry into force of legislation that focuses on the design of public support measures, including for small scale farms, future financial instruments, as well as digitalisation of the system via electronic document management systems, and ensures that state support can only be channelled to beneficiaries registered in the State Agrarian Register (SAR).

The reform is expected to be completed by Q3 2025.

Reform 4. Improvement of the official public electronic farm register The objective of this reform is to formalise and improve the official public electronic farm register (i.e. State Agrarian Register).

The reform has two steps. First, a law that recognises the State Agrarian Register (SAR) as an official public electronic register in the field of agrarian policy and food security enters into force. Second, a report is published detailing the implementation of state support by central government institutions through the SAR.

The reform is expected to be completed by Q1 2026.

Reform 5. Long-term development of the irrigation system to increase climate resilience of the sector The objective of this reform is to ensure long-term planning of irrigation infrastructure in a sustainable way, in order to foster resilience of the agri-food sector in the context of climate change.

The reform has one step. It entails the adoption of a long-term plan setting out the key areas and principles for developing Ukraine’s water irrigation systems.

The reform is expected to be completed by Q1 2025.

84/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 Reform 6. Demining of land and water areas The objective of this reform is to develop a national strategy to outlining key components of Ukraine’s de-mining efforts.

The reform has one step. It entails the adoption of the Strategy on Mine Action.

The reform is expected to be completed by Q2 2024.

Investment 1. Investments in demining The objective of this investment is to support owners or users of agricultural land undertaking de-mining efforts.

The investment has two steps. First, it entails budgeting of at least EUR 30 million in current prices (in UAH equivalent) for the funds paid to owners or users of agricultural land for costs of demining in 2024-2025. Second, it entails budgeting of at least EUR 100 million in current prices (in UAH equivalent) for the funds paid to owners or users of agricultural land for costs of demining in 2024-2027.

The investment is expected to be completed by Q4 2027.

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12.1 Reform 1. Adoption of the Strategy for Q4 2024 Adoption of the Strategy for Agriculture and Rural Development until 2030. The strategy focuses on these main

Agriculture and Rural areas:

Aligning the Development until 2030 institutional — adapting Ukrainian Agriculture and Rural Development policies to the EU pre-accession context and areas of framework on special Ukrainian concern, such as land reform, irrigation, war recovery and development support;

agriculture and rural — institutional strengthening and capacity building to develop necessary systems; development to the EU policy — acceleration of the process to approximate legal acts and capacities for agri-food agriculture and sanitary and phytosanitary measures (SPS) to EU standards;

— promoting the development to small producers and rural communities; — defining of environmental and climate action baselines and targets, building up evidence-based programming and sound financial management and control capacities.

12.2 Reform 1. Establishment of the Farm Q1 2027 The Farm Sustainability Data Network (FSDN) system with data from selected pilot regions, to be created under Sustainability Data Network the Ministry of Agrarian Policy, is established and is operational in line with the principles of the EU aqcuis in Aligning the

(FSDN) system this area. The system allows tracking the situation in the agricultural sector and making informed decisions institutional regarding the allocation of state support to agricultural producers framework on agriculture and rural development to the EU policy

12.3 Reform 2. Set up of an automated system Q1 2025 An automated system for public monitoring of land relations has been put into operation, functioning within for public monitoring of land the framework of maintaining the State Land Cadastre. A geoinformation system for mass land assessment has Ensuring a functional relations been put into operation as part of the software of the State Land Cadastre.

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12.4 Reform 3. Entry into force of the Q3 2025 Entry into force of the Law on Amendments to the Law of Ukraine ‘On State Support of Agriculture of Ukraine’.

legislation on the public The Law focuses on these main areas:

Improving the support of agriculture of institutional and — design future public support measures in line with the principles of the EU acquis in this area. The selection Ukraine administrative set up of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and for managing Threats (SWOT);

investment — design measures to support agricultural production for small scale farms to undertake private investments programmes (physical assets of agricultural holdings producers, for processing and marketing);

— design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions; — digitalisation through electronic document management systems;

— state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.

12.5 Reform 4. Entry into force of the Q4 2024 Entry into force of the Law of Ukraine ‘On the State Agrarian Register’. The law focuses on these main areas: legislation on the State Improvement of the — the State Agrarian Register (SAR) is recognised as an official public electronic register in the field of agrarian Agrarian Register (SAR) official public policy and food security with the regulation of its mandatory elements, such as the procedure for its electronic farm administration, the definition of its data, access by the third parties;

register — SAR coverage is expanded to register and include information on stakeholders throughout the entire agricultural value chains such as agricultural producers, food processors, water users; — SAR functionality is expanded, serving as a pre-condition for financial assistance and enabling targeted channelling of technical assistance, other administrative services, the introduction of analytical information;

— registration in SAR is a precondition for receiving any type of public support in agri-food sector; — mandatory publication of the register of beneficiaries of any state support programmes in the sector implemented through SAR.

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12.6 Reform 4. Publication of report on the Q1 2026 Submission of the report on the implementation of state support through SAR showing that minimum 80 implementation of the state percent of public support in the agricultural sector provided in 2025 by central government institutions was Improvement of the support through the public provided through the State Agricultural Register (SAR).

official public Agricultural Register electronic farm register

12.7 Reform 5. Adoption of the long-term Q1 2025 Adoption of the ‘Long-term plan for the development of the irrigation system’. The plan focuses on these main

plan on the irrigation system areas:

Long-term development of the — priorities in the irrigation sector based on an analysis of full economic benefits; irrigation system to — alignment with the water sector strategy and the water basin-based water management principles;

increase climate resilience of the sector — indication of needed public and other investments and the need for further privatisation; — governance/management dimension of the sector; — environmental assessment to be carried out for any rehabilitation or construction project in line with EU recommendation on environmental impact assessment, environmental strategic assessment and Ukraine legislation in this area.

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12.8 Reform 6. Adoption of the strategic Q2 2024 Adoption of the legislative act on the approval of the strategic document on Mine Action for the period up to document on Mine Action for 2033 (the Act of the Cabinet of Ministers of Ukraine or the President of Ukraine). The legislative act focuses on Demining of land and the period up to 2033 these main areas:

water areas — management in the field of Mine Action; — support of the efficiency of Mine Action operators; — prevention of accidents; — comprehensive assistance to victims; — innovations; — gender balance and representation;

— development of the private market; — effective and transparent coordination with donors; — forming the system of prioritisation of tasks in mine action.

12.9 Investment 1. Investments of at least EUR Q2 2026 Interim report of the Government (or State Treasury report) showing that in the State Budgets for 2024 and 30 million in demining of 2025 the general Government budgeted at least EUR 30 million (in UAH equivalent) for the funds paid to Investments in agriculture land owners or users of agricultural land for the costs of demining.

demining

12.10 Investment 1. Investments of at least EUR Q4 2027 Final report of the Government (or State Treasury report) showing that in the State Budgets for 2024, 2025, 100 million in demining of 2026, 2027 the general Government budgeted at least EUR 100 million (in UAH equivalent) for the funds paid Investments in agriculture land to owners or users of agricultural land for the costs of demining demining

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27.10.2025 ENEN OJ L, 27.10.2025 C.13. MANAGEMENT OF CRITICAL RAW MATERIALS

1. Description of Reforms and Investments The objective of this chapter is to support further development of the critical raw materials sector in Ukraine in line with both economic and sustainability objectives. It will focus on improving strategic planning and administrative procedures.

Reform 1. Strengthening strategic planning and ensuring optimum framework for strategic investors.

The objective of this reform is to attract investments in the extraction and processing of critical raw materials.

The reform has two steps. First, a law on amendments to the National Programme for the Development of the Mineral Resource Base of Ukraine for the Period up to 2030 shall enter into force, introducing the State Compensatory Fund for geological area and setting strategic directions for the sector. Second, a report on the verification of critical raw materials reserves of Ukraine using international classification shall be published and made available to investors.

The reform is expected to be completed by Q3 2025.

Reform 2. Improved administrative procedures.

The objective of this reform is to optimise the procedure and reduce the administrative burden for potential investors. The main goal is to improve transparency, speed, and cost efficiency for new investment decisions.

The reform has three steps. First, a pipeline of investment projects for extraction of critical raw materials shall be published.

Second, Product Sharing Agreement (PSA) international tenders using the model agreement terms as agreed by the Government and made public shall be launched. Third, the development and launch of an e-cabinet of subsoil users with additional functionalities.

The reform is expected to be completed by Q2 2025.

Reform 3. Use of Modern Extraction Technologies and Integration of Ukraine into Modern Processing Value Chains The objective of this reform is to enhance transparency as regards environmental, social and corporate governance practices in the critical raw materials sector.

The reform has one step. It entails the publication of a study assessing current legislation on Environmental, Social and Governance reporting (ESG) in the mining and extractive sector.

The reform is expected to be completed by Q4 2025.

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13.1 Reform 1. Entry into force of the Q4 2024 Entry into force of the Law of Ukraine on Amendments to the National Program for the Development of the legislation on revising the Mineral Resource Base of Ukraine for the Period up to 2030. The law focuses on these main areas:

Strengthening strategic National Programme for the planning and ensuring — introduction of State Compensatory Fund for geological area;

Development of the Mineral optimum framework for Resource Base of Ukraine to — prioritisation of the goals of extraction area in line with the EU Strategies; strategic investors 2030 — definition of the terms of strategic and critical raw materials, the need for regular methodological risk assessment of the level of security of their supply, and the definition of a group of partner countries.

13.2 Reform 1. Publishing of a report on the Q3 2025 Publication of a report on the verification of Critical Raw Materials reserves of Ukraine using international verification of Critical Raw classification system and results are made available to investors.

Strengthening strategic Materials’ reserves of Ukraine planning and ensuring optimum framework for strategic investors

13.3 Reform 2. Publication of a pipeline of Q2 2025 Publication of the pipeline of investment projects for extraction of critical raw materials. investment projects for Improved administrative extraction of critical raw procedures materials

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13.4 Reform 2. Launching of Product Sharing Q2 2025 Launch and publication of the Product Sharing Agreement (PSA) international tenders, using the model Agreement (PSA) international agreement terms as agreed by the Government. Transparency of PSA tenders and Agreements ensured Improved administrative tenders ensuring their through the open access to its terms.

procedures transparency

13.5 Reform 2. Set up of an upgraded e-cabinet Q1 2025 An upgraded e-cabinet of subsoil users with additional functionalities of access to state register of special of subsoil users permits for subsoil use allowing requesting and obtaining e-licences (extract from the Register) and providing Improved administrative access to digital geological data is operational.

procedures

13.6 Reform 3. Publication of a study on the Q4 2025 Endorsement and publication of study assessing the current legislation on Environmental, Social and legislation on ESG reporting Governance (ESG) reporting in the mining and extractive sector, proposing recommendations on what Use of Modern Extraction legislative gaps need to be covered.

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27.10.2025EN OJ L, 27.10.2025 C.14. DIGITAL TRANSFORMATION

1. Description of Reforms and Investments The objective of this chapter is to bolster the digital transformation of Ukraine. It will also focus on strengthening cybersecurity.

Reform 1. Secure and efficient digital infrastructure The objective of this reform is to strengthen cybersecurity in the process of digital transformation.

The reform has two steps. First, a resolution that defines the radio technologies that are allowed for use in Ukraine shall be adopted. Second, a number of cybersecurity legislative acts shall enter into force to align with the NIS and NIS2 framework, also paving the way towards the implementation of the EU’s 5G Security Toolbox.

The reform is expected to be completed by Q1 2025.

Reform 2. Digitalisation of public services The objective of this reform is to simplify the interaction between the state and citizens via digitalisation.

The reform has two steps. First, an Action Plan until 2026 for digitalisation of most common public services in a number of areas shall be adopted. Second, a legal act on the functioning of the Integrated Electronic Identification System in line with the principles of Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework shall enter into force.

The reform is expected to be completed by Q2 2026.

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14.1 Reform 1. Adoption of a revised Plan for Q1 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine on amending the Resolution of the Cabinet of allocation and use of the radio Ministers of Ukraine ‘On Approving the Plan for Allocation and Use of the Radio Spectrum in Ukraine’. The Resolution Secure and efficient spectrum in Ukraine defines the radio technologies that are allowed for use in Ukraine, with the definition of the radio frequency bands and digital radio services to which they correspond, as well as the terms of termination of their development and use, as well as infrastructure the list of promising radio technologies for implementation in Ukraine with the definition of the radio frequency bands and radio services to which they correspond, as well as the terms of their implementation in line with the EU acquis.

14.2 Reform 1. Entry into force of the Q1 2025 Entry into force of the respective legislative acts to align with the NIS and NIS2 framework (namely the Directive (EU) legislation on strengthening 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures for a high common Secure and efficient the cyber security capabilities level of cybersecurity across the Union, amending Regulation (EU) No 910/2014 and Directive (EU) 2018/1972, and digital of state information resources repealing Directive (EU) 2016/1148). The acts focus on these main areas:

infrastructure and critical information — regulate the mandatory implementation of measures aimed at creating an appropriate legal framework for the infrastructure implementation of measures to prevent, detect and suppress acts of aggression in cyberspace in the context of the Russian Federation’s war against Ukraine;

— increase the level of protection of state information resources and critical information infrastructure against cyberattacks; — improve the regulatory framework in the field of cybersecurity and information protection to strengthen the capabilities of the national cybersecurity system to counter cyber threats.

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14.3 Reform 2. Adoption of the Action Plan Q1 2025 Adoption of the Ordinance of the Cabinet of Ministers of Ukraine on approving the action plan for digitalisation of for digitalisation of public public services until 2026. The action plan focuses on these main areas:

Digitalisation of services until 2026 public services — recovery; — education; — health care; — services for veterans; — military serviceman; — customs; — e-social sphere.

14.4 Reform 2. Entry into force of the legal Q2 2026 Entry into force of a legal act on the functioning of the Integrated Electronic Identification System in Ukraine as a key act on the functioning of the component of the national electronic identity infrastructure, in line with the principles of Regulation (EU) 2024/1183.

Digitalisation of

Integrated Electronic The legal act focuses on these main areas:: public services Identification System, in line — establishment of a modern electronic identification system in Ukraine and ensuring its sustainable development;

with the principles of Regulation (EU) 2024/1183 — ensuring interoperability (technological compatibility) of electronic identification means, intermediate electronic identification nodes (hubs) and electronic identification schemes;

— protection of information resources processed in the system.

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27.10.2025 ENEN OJ L, 27.10.2025 C.15. GREEN TRANSITION AND ENVIRONMENTAL PROTECTION

1. Description of Reforms and Investments The objective of this chapter is to foster Ukraine’s green transition, by supporting decarbonisation and strengthening environmental and climate resilience.

Reform 1. Prevention, reduction and control of industrial pollution The objective of this reform is to address environmental pollution, ensuring the constitutional right of citizens to a safe environment.

The reform has one step. It entails the entry into force of the legislation aimed at preventing, reducing and controlling industrial pollution, with a partial application of provisions. The step introduces integrated approaches to permitting and control of industrial pollution based on the application of best available technologies and management methods in accordance with relevant EU legislation.

The reform is expected to be completed by Q3 2024.

Reform 2. Climate policy The objective of this reform is to create an architecture for climate governance as well as an appropriate mechanism for the development and implementation of state policy in the field of climate change in Ukraine.

The reform has three steps. First, new legislation shall enter into force that establishes basic principles of Ukraine’s state climate policy. Second, resolution on the scientific and expert council on the preservation of the ozone layer shall be adopted. Third, the second Nationally Determined Contribution of Ukraine to the Paris Climate Agreement shall be adopted.

The reform is expected to be completed by Q4 2025.

Reform 3. Market mechanisms of carbon pricing The objective of this reform is to foster the development of market mechanisms of carbon pricing.

The reform has two steps. First, an action plan for the development of a National Greenhouse Gas Emissions Trading System shall be adopted. Second, Ukraine shall resume its mandatory monitoring, reporting, and verification (MRV) system, with certain exceptions.

The reform is expected to be completed by Q2 2025.

Reform 4. Restoration and conservation of natural resources The objective of this reform is to reduce deforestation and forest degradation.

96/102 ELI: http://data.europa.eu/eli/dec_impl/2025/2157/ojEN OJ L, 27.10.2025 The reform has one step. It entails the entry into force of legislation that will regulate the issue of confirming the sustainability of the origin of wood and other goods that may lead to deforestation and forest degradation.

The reform is expected to be completed by Q2 2026.

Reform 5. Increased circular economy The objective of this reform is to implement the principles of circular economy and waste management.

The reform has two steps. First, a national waste management plan shall be adopted.. Second, Ukraine shall adopt a strategy for implementing the principles of the circular economy and an action plan for its implementation.

The reform is expected to be completed by Q1 2026.

Reform 6. Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) The objective of this reform is to foster environmental protection by enhancing clarity on the Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) rules.

The reform has one step. It entails the publication of a concept note that shall define the scope of derogations from the EIA and SEA rules.

The reform is expected to be completed by Q3 2024.

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15.1 Reform 1 Entry into force of the legislation on Q3 2024 Entry into force of the Law of Ukraine on Ensuring the Constitutional Rights of citizens to a safe prevention, reduction, and control of environment for life and health with a partial application of the provisions. Bylaws are to be Prevention, reduction industrial pollution with partial adopted within 12 months and some provisions on applying of the findings of the best available and control of application of provisions technologies and management methods within 4 years after termination of the martial law, except industrial pollution for the installations that are put into operation for the first time.

The law is aimed at preventing, reducing and controlling industrial pollution and introduces integrated approaches to permitting and control of industrial pollution based on the application of the best available technologies and management methods in accordance with Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions (integrated pollution prevention and control) (recast)

15.2 Reform 2. Entry into force of the legislation on the Q1 2025 Entry into force of the Law of Ukraine ‘On the Basic Principles of State Climate Policy’. The law

State Climate Policy focuses on these main areas:

Climate policy — goals and basic principles of the state climate policy; — governing bodies in the field of climate change; — strategic planning in the field of climate change; — mechanisms and tools for achieving climate goals;

— national framework for tracking the implementation of policies and measures and forecasting in the field of climate change; — scientific and expert council on climate change and preservation of the ozone layer;

— national system of inventory of anthropogenic emissions by sources and absorption by sinks of greenhouse gases; — international cooperation in the field of climate change.

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15.3 Reform 2. Adoption of the resolution on the Q4 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine ‘On Approval of the Regulation Scientific and Expert Council on Climate on the Scientific and Expert Council on Climate Change and Preservation of the Ozone Layer’. The Climate policy

Change and Preservation of the Ozone Regulation focuses on these main areas:

Layer — consideration of scientific conclusions of the Intergovernmental Panel on Climate Change

(IPCC) reports and scientific climate data and information, in particular, concerning Ukraine; — providing scientific and expert support and proposals, including preparation of reports, on climate goals, policies and measures, monitoring their implementation and forecasting in the field of climate change, as well as compliance of goals, policies and measures with Ukraine's international obligations;

— promoting the exchange of scientific achievements in the field of modelling, monitoring, advanced research and innovation aimed at reducing greenhouse gas emissions and increasing absorption by sinks;

— scientific substantiation of ways and means to achieve climate goals; — informing, raising awareness and educating on climate change and its consequences, as well as developing dialogue and cooperation between scientific institutions on climate change issues;

— guarantees of independence for said Council in all its proceedings; — diverse, scientifically relevant composition of said Council.

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15.4 Reform 2. Adoption of the second Nationally Q3 2025 Adoption of the Order of the Cabinet of Ministers of Ukraine ‘On Approval of the Second Determined Contribution of Ukraine to Nationally Determined Contribution (NDC) of Ukraine to the Paris Agreement’. The NDC focuses Climate policy

the Paris Agreement on these main areas: — higher emission reduction target than in the current NDC of Ukraine; — establishing a base year for calculating emissions from sources and sinks of greenhouse gases;

— duration of implementation and/or time periods of the proposed measures; — scope and coverage of economic sectors and greenhouse gases; — process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;

— justification of the equity and ambition of the NDC in the light of national circumstances; — contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.

The Second NDC of Ukraine to the Paris Agreement will be more ambitious than the current Updated NDC.

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15.5 Reform 3. Adoption of the Action Plan for the Q1 2025 Adoption of the Resolution of the Cabinet of Ministers of Ukraine "On Approval of the Action Plan Establishment of a National Greenhouse for the Establishment of a National Greenhouse Gas Emissions Trading System. Adoption of the Market mechanisms of

Gas Emissions Trading System Action Plan will ensure the definition of: carbon pricing — stages of the ETS implementation; — timeframes of the stages; — the necessary infrastructure; — organisational measures.

15.6 Reform 3. Resumption of the compulsory Q2 2025 The resumption of a mandatory monitoring, reporting and verification (MRV) system for facilities monitoring, reporting and verifying covered by the scope of the existing legislation, except for those that are not controlled, destroyed Market mechanisms of

(MRV) system or located in the temporarily occupied territory, or have officially announced the suspension of carbon pricing operations in terms of production.

15.7 Reform 4. Entry into force of the Law on reducing Q2 2026 Entry into force of the Law of Ukraine that will regulate the issue of confirming the sustainability of deforestation and forest degradation the origin of wood and other goods that may lead to deforestation and forest degradation. The Law Restoration and

focuses on these main areas: conservation of natural resources — expanding the use of electronic timber accounting, which will ensure the tracking of timber movement and confirmation of the legitimacy of the origin of timber and timber products;

— ensuring that the certification system for wood products was introduced and the existing certification system for manufactured wood was extended to cover all wood trading operations; — establishing requirements for confirming the origin of wood, including wood products in trade.

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15.8 Reform 5. Adoption of the Strategy for Q1 2026 Adoption of the strategy for implementing the principles of the circular economy and of an action implementing the principles of the plan for its implementation by the Cabinet of Ministers of Ukraine. The strategy identifies potential Increased circular

circular economy and its Action Plan opportunities and impacts of the transition to a circular economy in Ukraine for 5-10 pre-selected economy priority sectors and value chains, such as waste, textiles, plastics, batteries, electronics, agriculture, construction and repair, and metals and minerals.

15.9 Reform 5. Adoption of the National Waste Q3 2025 Adoption of the Order of the Cabinet of Ministers of Ukraine ‘On Approval of the National Waste Management Plan until 2033 Management Plan until 2033’. The National Waste Management Plan focuses on these main areas:

Increased circular economy — household waste management; — hazardous waste management; — infrastructure needs; — economic and financial sustainability analyses of the action plan; — implementation of economic instruments to improve waste management;

— monitoring and control of waste management; — strategic planning of waste management in Ukraine; — implementation of waste management at the regional level.

15.10 Reform 6. Development of a concept note defining Q3 2024 Preparation and publication on the official website of the Ministry of Environmental Protection and the scope of deviations from the Natural Resources of aa concept note following public consultations with stakeholders defining the Environmental Impact Environmental Impact Assessment (EIA) scope of derogations from the EIA and SEA rules.

Assessment (EIA) and and Strategic Environmental Assessment

Strategic The concept note includes the following information:

(SEA) rules Environmental — on the body that determines the scope of derogations from EIA and SEA obligations;

Assessment (SEA) — description of the objects and explanation of why they are included in the scope of derogation in each specific case; — justification of the scope of derogations; — time limits for the derogations granted.

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