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20% progress: how Ukraine is meeting the EU's interim accession requirements

eurointegration.com.ua

20% progress: how Ukraine is meeting the EU's interim accession requirements

On 4 November, the European Commission will publish its annual enlargement report, presenting its assessment of Ukraine’s progress towards EU membership.

This year has been relatively successful for Kyiv’s European integration efforts in procedural terms: over the past five months, Ukraine and the EU have opened four of the six negotiating clusters.

However, opening clusters is only the initial stage of the negotiation process. Progress towards completing negotiations will be measured by the closure of negotiating chapters. Under the EU’s enlargement methodology, no negotiating chapter can be provisionally closed until Ukraine has met the interim benchmarks set under Chapter 23 "Judiciary and Fundamental Rights" and Chapter 24 "Justice, Freedom and Security", and received a positive assessment from the European Commission in its Interim Benchmark Assessment Report (IBAR).

This explains why Ukrainian officials refer so frequently to IBAR.

Achieving this goal and therefore determining the subsequent pace of negotiations will depend largely on Ukraine itself, particularly its ability to deliver tangible progress on the rule of law, judicial reform, the protection of fundamental rights, and the fight against corruption and organised crime.

Our monitoring indicates that Ukraine is around 20% of the way towards a positive IBAR.

The Ukrainian Centre for European Policy has presented the first findings of its independent expert monitoring of progress in meeting the interim benchmarks.

The findings of "EU Interim Benchmarks: Ukraine’s Progress under Chapters 23 and 24", also available as an interactive infographics called Accession Navigator monitoring system, show that the overall level of progress against the interim benchmark indicators stood at 20.9% at the end of the first half of 2026.

The fight against corruption, a field that attracts considerable public attention, recorded the highest score. This article examines why, which areas are lagging behind, and which tasks require the most urgent attention.

Ukraine’s progress under the two "fundamentals" chapters, 23 and 24, is almost identical: 20.3% and 21.4%, respectively.

First, however, it is important to avoid misinterpreting these figures. They do not mean that Ukraine has already met one fifth of all interim benchmarks, as the monitoring also captures intermediate steps towards their fulfilment.

Not all tasks involve adopting legislation. Some require Ukraine to demonstrate progress in institution-building or establish that reforms are sustainable. To take legislative tasks as a simple example, drafting a bill and submitting it to parliament generally accounts for around 10% of the work required to meet a particular benchmark.

At first glance, the results may appear relatively modest.

However, Ukraine received the official list of benchmarks only in June 2026. The monitoring findings should therefore be viewed primarily as a baseline for assessing further progress. At the same time, the overall figure masks substantial differences between individual areas of reform.

The fight against corruption recorded the highest level of progress, at 29.1%. Cooperation in the field of drugs and the fight against organised crime followed at 25% and 24.9%, respectively. The lowest scores were recorded in fundamental rights, at 11.9%, and migration, asylum, Schengen and external borders, at 11%.

What explains these differences?

One important finding of the study is that the pace at which EU requirements are met depends not only on the area of reform, but also on the nature of the tasks involved.

We identified three types: legislative and regulatory changes, institutional strengthening, and the demonstration of a sustained track record of results.

Progress has so far been stronger on institutional and organisational tasks. These include conducting competitive selection procedures, filling vacancies, establishing or strengthening specialised units, and building the capacity of public authorities.

Progress on legislative changes, the most common type of task, has been more difficult. Around three quarters of the interim benchmarks and their constituent elements require, among other measures, amendments to legislation.

The monitoring identified more than 30 bills pending before the Verkhovna Rada that are relevant to meeting the EU’s interim requirements. Only five have passed their first reading. A further three bills were automatically withdrawn following the government’s resignation in July 2026 and have not yet been resubmitted to parliament.

Particularly challenging, however, are tasks that require more than the adoption of legislation or institutional changes.

In the fight against corruption, for example, Ukraine must demonstrate a sustained track record of investigations, prosecutions and, in particular, final convictions in high-level corruption cases. The requirements also call for an increase in the number and total value of assets seized, frozen and confiscated.

For many of these indicators, the monitoring recorded little or no progress. However, this does not necessarily mean that the underlying situation is poor.

For some indicators, systematic collection of statistical data is only just beginning. It is therefore not yet always possible to assess trends reliably, simply because doing so takes time.

An institution can be established or a law adopted relatively quickly, and either step can be verified through a specific decision. Assessing practical results, by contrast, requires tracking the work of the relevant authorities over a period of time.

Tasks related to the fight against corruption recorded the highest level of progress. This is largely because these reforms have been a focus of Ukraine–EU relations for many years.

The core anti-corruption institutional framework is already largely in place. Current EU requirements therefore focus on the independence, capacity and practical results of the relevant bodies.

In the fight against organised crime, Ukraine is making progress in developing financial investigations, recovering and managing assets, reforming certain law enforcement agencies, and strengthening international cooperation. Progress has been weaker, however, in meeting requirements concerning effective investigations and final convictions.

The situation is different in the area of fundamental rights.

Many tasks require the establishment of new regulatory frameworks or the resolution of longstanding problems. These include personal data protection, reform of the penitentiary system, and reform of institutional care for children and persons with disabilities.

The low score in migration is largely linked to the state of the asylum system. Aligning it with EU requirements will require legislative changes, the development of a reception system for asylum seekers, and staff training. At the same time, Ukraine is making progress in aligning with the EU’s Schengen acquis and improving border management.

A lower score therefore does not necessarily indicate a lack of work.

Differences between scores may reflect both the state of reforms when work on meeting the requirements began and the scale and nature of the tasks involved.

The study’s findings point to several priorities.

First, parliament needs to accelerate its consideration of bills related to the interim benchmarks, while ensuring that they meet EU requirements and are subsequently implemented in practice.

Particular attention should be paid to tasks included in both the interim benchmarks and the 10-point reform plan on the rule of law and anti-corruption agreed by Ukraine and the European Commission in December 2025.

Most of the plan’s priorities overlap fully or partially with the requirements under Chapters 23 and 24. Delivering on them would therefore contribute to progress against the relevant benchmarks.

A telling example is the Anti-Corruption Strategy for 2026 – 2030. Its adoption is relevant to three processes at once: meeting the interim benchmarks, implementing the 10-point reform plan, and fulfilling commitments under the Ukraine Facility.

Yet despite its importance, the relevant bill has still not been placed on the Verkhovna Rada’s agenda.

It is also important to complete competitive selection procedures and appointments within the justice system, and to strengthen internal control and corruption risk management systems.

Systematic collection and publication of statistical data remain equally important. For many interim benchmarks, progress is measured through tangible results delivered by public institutions.

The initial findings of the independent monitoring show that Ukraine has already made some progress, although the pace of implementation remains uneven across different areas.

The 20.9% assessment is a baseline: it does not replace the EU’s official assessment and should be interpreted in light of limitations in data availability, particularly under martial law. Further progress will depend on the adoption of the necessary legislation, the completion of institutional changes, and the ability to demonstrate their effectiveness in practice.

To meet the EU’s interim requirements, Ukraine must go beyond showing which laws have been adopted and which institutions have been established. It is equally important to demonstrate that these changes are delivering tangible, measurable results.

Oleksandra Bulana, PhD in Economics, Analyst at the Ukrainian Centre for European Policy (UCEP)

Mariia Holubytska, Junior Analyst at UCEP

For European Pravda

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