Two judges have not been appointed. One law has not entered into force. Because of this, the European Commission has suspended payment of 680 million euros under the fourth and fifth tranches of the Ukraine Facility program — and for the first time in the program's history is genuinely considering a procedure for final funding cuts.
What exactly was not done
According to information provided to the Public Broadcasting Company by an European Commission official, the unfulfilled requirements concern two specific points. In the fourth tranche — increasing the number of personnel at the High Anti-Corruption Court. In the fifth — the entry into force of legislation on reviewing declarations of integrity of judges and the procedure for their verification. The deadlines for compliance are June 30 and September 29, 2026 respectively.
"There are two steps related to the fourth and fifth tranches that were not completed on time. The amounts associated with these tranches have been suspended".
European Commission official — to the Public Broadcasting Company, on condition of anonymity
If the conditions are not met by the specified dates, the Ukraine Facility regulation provides for a procedure for final payment cuts — the money simply is lost.
680 million — just the tip of the iceberg
The RRR4U consortium of independent analytical centers, which monitors the implementation of Ukraine's Plan, has released a more alarming figure: in the fourth quarter of 2025 alone, Ukraine failed to meet nine program indicators, putting another 2.3 billion euros at risk. In total for 2025, non-compliance reached 3.7 billion euros. The mechanism is simple: if a reform is not completed on time, the corresponding amount "hangs" for 12 months — during which it is still possible to catch up — and then is cancelled.
The Institute for Economic Research and Policy Consultation, which is part of RRR4U, records: the vast majority of blocked indicators are legislative initiatives, the adoption of which depends on the Verkhovna Rada. Moreover, most of them require not just a vote, but specifically entry into force — meaning you need to vote at least a month before the deadline.
The Rada is the bottleneck
The picture is complicated by the parliamentary situation. As Forbes was told by Andrii Motovilovets, first deputy head of the Servant of the People faction, gathering votes even for laws agreed with the IMF and the EU is currently "practically impossible". After the NABU case against a number of deputies — which includes the wording "voting on orders" precisely for Ukraine Facility bills — part of the faction refuses to support anything associated with donor pressure. In March 2026, the Rada already failed to pass a vote on one of the Ukraine Facility package bills.
The risk of failing to receive at least 1.4 billion euros in the first quarter of 2026 is assessed by RRR4U analysts as "extremely high" — and this is not counting the 680 million euros that are already suspended.
What it means for the budget
Ukraine needs to attract $46.5 billion in external budget financing in 2026. Of this, only $6.8 billion is guaranteed under the ERA loan. The rest is conditional on the implementation of reforms. Each unclosed indicator is not an abstract "European integration requirement," but a specific amount lacking for salary payments, pensions, and debt servicing under conditions of war.
If by the end of June 2026 the Rada does not vote to expand the staff of the High Anti-Corruption Court and the law on judges' declarations — 680 million euros will cease to be a matter of delay and will become a matter of permanent loss. Will the parliamentary majority have the political will to pass anti-corruption laws under conditions where voting for them has itself become part of a criminal case against deputies?
