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Halfway through the deadline: Ukraine scores 15% on the EU priority reforms plan

eurointegration.com.ua

Halfway through the deadline: Ukraine scores 15% on the EU priority reforms plan

In December 2025, the Ukrainian government made written commitments to the EU regarding key and urgent reforms in the areas of the rule of law and anti-corruption. The plan was signed on Ukraine’s behalf by Deputy Prime Minister for European Integration Taras Kachka, and the document also acquired an informal name: the "10 Kachka–Kos Points".

From the outset, Kyiv knew that this list carried special significance for Europeans. The issue is not only that all of its elements stem from EU accession criteria and other bilateral documents. For Brussels and the member-state capitals, this plan serves as an indicator of whether Ukraine’s declarations about its commitment to reform can be trusted. That is why it includes reforms that the EU considers particularly telling.

"You can change the laws however many times you want, but you can’t bring trust back overnight.... This is what we agreed in the paper – withing one year," European Commissioner Marta Kos explained, referring to the notorious events of July, when Ukraine undermined its own anti-corruption reforms.

Thus, this plan carries enormous political significance even without any formal legal status.

European officials now repeatedly emphasise that Ukraine itself set the implementation deadline at one year. Ukrainian officials, including Taras Kachka, continue to insist on this timeframe as well.

However, six months have passed, and progress on implementing the plan is far below expectations. Monitoring of implementation gives it a score of 15 out of 100. And again, this primarily reflects preparatory work rather than reforms that have actually begun.

Unless this situation is changed immediately, Ukraine will create serious obstacles on its own path towards EU membership. Failure to fulfil its own commitments, especially those regarded as a "test of trust", also significantly increases the risk that the EU may decide to separate the Ukraine-Moldova accession track ahead of schedule, something that officials in Brussels have hinted at.

If that happens, the government and parliament will have no one to blame but themselves.

EU compliance with legislation that Ukraine must adopt during the accession process is measured annually by the European Commission in the Enlargement Report. For assessing progress in the Fundamental Chapters 23 and 24, the EU uses a separate mechanism – the Interim Benchmark Assessment Report (IBAR).

The "Kachka–Kos plan" is more complicated. It is not part of the formal accession process, so there are no public EU tools to evaluate it. The European Commission prepares only internal documents, which it shares with member states but does not publish.

This raises the question: how can we determine whether Ukraine is actually succeeding in fulfilling these requirements, which are in reality key for continuing its path towards EU membership?

To answer this, Ukrainian think tanks have formed a coalition "Membership Check", led by the New Europe Center. It brings together eight expert organisations working on European integration, anti-corruption and judicial reform, including MEZHA, European Pravda, ANTS, DEJURE, the Centre of Policy and Legal Reform, the Anti-Corruption Action Center and Transparency International Ukraine.

In this article, the coalition presents its second report.

The first one, published in early April, was disappointing. After three months of work, the authorities achieved only 9% of the maximum score. At the time, the government said it expected to speed up later, as the first months were spent mainly on preparatory work. This explanation made sense. However, even less progress was achieved in the second quarter.

The result as of the end of June, according to the methodology, is 15 out of 100 points – only 15% complete.

It is important to emphasise: this does not mean that 100% completion is an absolute requirement.

Of course, that remains the desirable outcome, but reality is always more complex.

Even in formal accession requirements, Brussels often accepts imperfect results. For example, in the area of rule of law, the EU does not require literal compliance with all recommendations, but rather the creation of a system in which citizens and businesses trust court decisions and believe in their fairness.

The same applies here: if Ukraine demonstrates a genuine effort to implement all points, but the final decisions differ in detail from the EU’s (or the expert coalition’s) vision, the plan could still be considered fulfilled even if the numerical score is, let’s say, 80 points instead of 100.

However, the problem is that currently there is no meaningful progress in any of the 10 points.

Ukraine has implemented only one minor element of one of the points. At the same time, it has completely failed the main elements related to judicial reform. Within the coalition there were even discussions about whether a negative score should be assigned, since this is essentially a rollback in one of the reform areas.

At the same time, coalition interlocutors in the government remain optimistic.

They say that work is ongoing, a number of draft laws are being coordinated with the European Commission, and that this is one of the key reasons for the delay (meaning, in their view, the EU – not Ukraine – is responsible).

Well, Kyiv may still demonstrate rapid progress in implementing the plan during the remaining six months before the deadline set by Ukraine itself. However, this still does not explain how to fix the already mentioned dismantled reform of judicial integrity declarations.

Another reason for cautious optimism is that a group of MPs, including the head of the relevant anti-corruption committee, Anastasia Radina (from the Servant of the People faction), have started registering draft laws on their own, without waiting for the government, that aim to implement the plan’s points.

But will there be enough votes in parliament to go against the government? Even while understanding that Ukraine’s path towards EU membership is at stake? Especially given that the government is showing disagreement with certain pro-European parliamentary initiatives.

Now, more details on all 10 points.

This point of the "Kachka–Kos plan" formally reads: "Adopt comprehensive amendments to the Criminal Procedure Code and other legislation to ensure fast and high-quality justice."

This is the most important point of the entire plan and the largest in scope. In its detailed explanation, five elements are listed that are meant to solve several long-standing and highly important problems.

In particular, Ukraine committed to closing loopholes that currently allow some top-level corruption offenders to avoid responsibility. For example, by dragging out investigations and then closing cases due to statutes of limitation (this is a long-standing problem that Ukraine created for itself during a previous convocation of parliament, when it adopted and the president signed "Lozovyi amendments").

All attempts by parliament to fix these and similar provisions have failed, so the European Union has identified correcting these problems as one of the accession criteria.

In the coalition’s assessment, the first point carries the highest weight – 20 points. However, the current score is only 2.5 out of 20.

Ukraine is still only preparing to work on this reform.

The government has long promised to submit the relevant draft law and has indeed developed it, but issues arose during coordination. The document has now been sent back for revision together with the National Anti-Corruption Bureau (NABU) and the National Agency on Corruption Prevention (NACP).

Recently, apparently not expecting quick progress from the government, members of parliament registered two alternative draft laws: No. 15333 on improving the effectiveness of criminal proceedings after the expiration of pre-trial investigation deadlines and preventing procedural abuse, and No. 15334 on improving rules for determining jurisdiction and ensuring international cooperation. So far, there has been no movement on them in parliament.

Here too, everything is still at a very early stage. There are essentially only political statements expressing readiness to implement this point.

The Ministry of Justice has started drafting a bill, but NABU is dissatisfied with the proposals and criticizes the government’s concept for how the institution responsible for conducting forensic examinations would operate. After discussions of the ideas promoted by the Ministry of Justice, anti-corruption activists doubt that the new body would truly be independent. There is currently no draft suitable for expert analysis.

Experts’ assessment: 2 out of 10 points.

This point of the plan deserves special attention.

Normally, the European Union is very cautious not to interfere with national traditions and procedures, especially in areas where there are no common EU rules. The rules for appointing a Prosecutor General differ across European states, and this position is often filled according to political quotas, but with strict professional criteria.

However, an exception was made for Ukraine. Revising the procedure for selecting and dismissing the Prosecutor General was included in the EU accession criteria and also in the "Kachka–Kos plan".

The reason for this exceptional treatment is the role of Ukraine’s Prosecutor General, Ruslan Kravchenko, in the July last year attack on anti-corruption institutions. The EU is well aware that it was Kravchenko who prepared the draft of the controversial law that undermined the independence of NABU and the Specialized Anti-Corruption Prosecutor’s Office (SAPO).

However, the European Union cannot and will not demand his dismissal. The requirement is only that Ukraine introduces safeguards for the future, so that future Prosecutor Generals are selected based on professionalism rather than loyalty.

Even here, however, the government has done nothing so far. Moreover, there are not even political statements indi

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