Monitoring of the implementation of the IMF program and EU assistance (September 2025)
The government presented its vision of reforms for the next year and a half in the form of the CMU Activity Program, and a Priority Action Plan for 2025 was also developed. This is a fairly systematic attempt: operational goals, implementation steps, and performance indicators were defined. At the same time, the document did not undergo proper discussion (5 working days for proposals) and was submitted after the deadline. The political assessment should be given by the Parliament.
Discussions are ongoing on the terms of the new cooperation program with the IMF, but key parameters have not yet been determined. It is expected that unfulfilled obligations will be transferred to the new program, and the IMF itself may be more demanding. Meanwhile, by the end of September, 6 out of 9 structural benchmarks have been fulfilled until the next, 9th review.
The update of Ukraine’s Plan for the Ukraine Facility did not save from delays in reforms. The European Commission approved the changes, although they still need to be formally approved by the Council of EU. Therefore, in this presentation we move on to the new “calendar” of the Plan. Some of the reforms that were decided to be done faster have stalled: in particular, draft law No. 12087-d (electricity integration package) was not adopted in Q3 2025. Reporting on the implementation of indicators is significantly delayed (no report was submitted for the second quarter), which delays subsequent – even partial – payments. Restructuring due to the merger of a number of ministries is also not adding dynamics.
Ukraine is still looking for resources to cover the deficit. The government estimated the unmet need for international financing in 2025-2026 at $37.4 billion. The State Budget-2026 draft envisages an increase in external borrowing by +21.7% (to UAH 2.12 trillion), which should finance 42.3% of all expenditures.
