Systemic Delays in Reform: Missed Benchmarks and Financial Risks for Ukraine in 2025

Ukrainian Member of Parliament Yaroslav Zheleznyak prepared an analysis for on how the Government’s systemic delays in reform is failing to meet benchmarks and obligations – and what it might cost us in the Budget of Ukraine.

Below is a brief overview and a detailed video commentary from a Member of Parliament.

IMF:

• Ukraine is failing to meet at least two structural benchmarks — the director of the Bureau of Economic Security (BES) has not been appointed, and the “Lozovyi amendments”/strengthening of the SAPO have not been addressed.

• There is still a chance to meet at least one if Tsyvinskyi is appointed by July 31.

Some difficult benchmarks have been postponed by government agreement:

• Appointment of the Head of the State Customs Service — postponed from June 2025 to the end of December 2025.

• Audit of the National Securities and Stock Market Commission (NSSMC) — also postponed from June to August.

Ukraine Facility, linked to EU funding:

Q1 2025:

• 3 indicators not fulfilled:

1. Increase in the number of HACC staff — formally fulfilled, but most positions remain vacant.

2. Law on ARMA reform — was supposed to come into force by March but was only signed on July 27.

3. Law on prefects — passed the first reading but has been “stuck” in Parliament for over 2 months.

• This may cost the budget over €1.5 billion.

Q2 2025:

• Out of 11 indicators, 5 have not been fulfilled:

1. Law on the verification of judges’ asset declarations,

2. Digitalization of enforcement proceedings,

3. Law on vocational education – awaiting second reading,

4. Publication of investment projects related to critical raw materials,

5. Launch of tenders for subsoil (natural resource) allocations.

The World Bank:

There are still outstanding commitments from Spring 2025:

• Law on public procurement and reform of Ukrzaliznytsia,

• Launch of the selection process for the Head of the Customs Service.

And clearly, without resolving the situation around NABU and SAPO, no one will give us money at all.

We’ve never failed all programs at the same time – not even by half. And the reason lies entirely in the government’s/Presidential Office’s lack of will to get things done.

Here are the details.

EMPR