Ukraine’s record on reform during Russia’s war is stronger than much recent criticism suggests. By September, Kyiv had completed 84 of 95 milestones due under the Ukraine Plan. Yet progress on a smaller group of rule-of-law commitments has been strikingly weaker. The difference between the two tells Brussels much about where Ukraine’s European transformation is encountering resistance.
Ukraine’s reform record currently produces two figures that appear difficult to reconcile.
Under the Ukraine Plan, Kyiv had completed 84 of the 95 milestones due by late September — around 88 per cent. The result was strong enough for EU governments to approve another payment of almost €3 billion under the Ukraine Facility.
Three months earlier, however, a coalition of Ukrainian organisations monitoring ten rule-of-law and anti-corruption commitments agreed with Brussels had awarded progress just 15 points out of 100.
Neither figure is wrong. They measure different programmes.
The first covers a broad reform and investment agenda extending from the judiciary and financial markets to energy, agriculture, transport, human capital and the business environment. The second examines a deliberately narrow collection of reforms concerning prosecutors, criminal investigations, anti-corruption agencies and judicial governance.
Put together, they raise a more useful question than whether Ukraine is “reforming” or “not reforming”.
Why has a country capable of delivering most of a demanding EU programme during a major war found this particular group of reforms so much harder to complete?
Russia’s aggression provides part of the answer. Ukraine has been attempting an institutional transformation while mobilising its population, financing its armed forces, repairing infrastructure and keeping a functioning state under repeated Russian missile and drone attacks. No previous EU candidate has operated under comparable conditions.
But the ten reforms where progress has been weakest have something else in common. Most concern institutions that can investigate senior officials, prosecute corruption, scrutinise appointments or otherwise place limits on the exercise of political authority.
That is what makes the comparison important.
A strong overall record
The wider reform record should not be understated.
When the European Commission released €2.9 billion to Ukraine on 2 October, it specifically credited Kyiv with implementing reforms covering the judiciary, financial markets, human capital, the business environment, energy, transport, agriculture and the green transition.
Total EU support provided under the Ukraine Plan has now exceeded €32 billion. More than €17 billion in further budget support remains potentially available during 2026, provided Ukraine fulfils the corresponding conditions.
The money is particularly important because the Ukrainian state is directing such a large share of its own resources towards defence. European financing helps keep the civilian state operating while Ukraine fights Russia.
The Ukraine Facility has therefore become more than an aid mechanism. It gives Brussels a means of measuring reform against specific commitments and releasing money when they are met.
That system has generally worked.
It also makes the areas where progress is weaker much easier to identify.
The 15/100 assessment published in June concerned ten priorities agreed in December 2025 between Enlargement Commissioner Marta Kos and then deputy prime minister Taras Kachka. The score came from Ukrainian civil society, not the European Commission, and cannot legitimately be presented as Ukraine’s overall EU reform score.
It had nevertheless risen only six points from an assessment of nine out of 100 in April.
Among the unfinished commitments were changes to criminal procedure affecting high-level corruption cases, stronger guarantees for the independence and effectiveness of NABU and SAPO, reform of the State Bureau of Investigation, new arrangements surrounding the Prosecutor General, competitive recruitment within the prosecution service and further changes to judicial governance.
These are among the most difficult reforms Ukraine has undertaken since 2014 because they concern who has the authority to investigate whom.
The July 2025 episode changed the argument
The events surrounding NABU and SAPO in July 2025 remain central to understanding why Brussels is paying such close attention.
Ukraine had spent years building a specialised anti-corruption system intended to make investigations of senior political figures less vulnerable to interference from the conventional prosecutorial hierarchy.
NABU conducts investigations. SAPO provides specialised prosecution. The High Anti-Corruption Court hears the cases.
The system has never been free from political controversy, nor has its performance been beyond criticism. But its independence became an important part of Ukraine’s relationship with the EU and other international partners.
Then, in July 2025, parliament passed legislation placing NABU and SAPO under substantially greater authority of the politically appointed Prosecutor General. Zelenskyy signed it.
The decision produced an unusually sharp reaction inside Ukraine. Demonstrators took to the streets despite martial law, while European partners made clear that the legislation threatened reforms regarded as fundamental to the country’s European integration.
As EU Today reported during the crisis, the dispute went far beyond the technical division of powers between prosecutors and investigators.
Kyiv reversed course within days. Parliament restored the independence of the two bodies.
The reversal demonstrated that Ukraine’s political system still contained powerful corrective forces. Civil society mobilised, public opposition was visible and international pressure had an effect.
Yet the episode also established that the independence of institutions created specifically to investigate high-level corruption could still become the subject of direct political intervention.
That changed the context in which subsequent reform commitments are being judged.
The European Commission’s 2025 report on Ukraine recorded both sides of the episode. It acknowledged the restoration of NABU and SAPO independence, while warning that undue pressure on anti-corruption agencies remained a concern.
The Commission also identified practical weaknesses. NABU still required better access to timely and impartial forensic examinations, while SAPO needed stronger powers in cases involving members of parliament.
This is why simply retaining NABU and SAPO is no longer sufficient evidence that this part of the reform process is secure. Brussels is looking at whether they can operate when investigations become politically difficult.
Follow the institutions
The same issue appears elsewhere.
Ukraine agreed to review the procedure for appointing and dismissing the Prosecutor General, drawing on European standards and the Venice Commission. It also committed itself to transparent and competitive recruitment for senior positions throughout the prosecution service.
The significance is obvious. The Prosecutor General occupies a pivotal position in the Ukrainian criminal-justice system. The method by which that office is filled — and the circumstances in which its occupant can be removed — affect the credibility of every politically sensitive prosecution beneath it.
Progress has been slow.
There is a similar problem with the State Bureau of Investigation, which handles cases involving senior officials and law-enforcement personnel. Kyiv agreed to an independent assessment of the bureau followed by reform of its legal and institutional framework.
Again, the issue is not administrative tidiness. An agency responsible for investigating state officials has little value as a check on government if its own leadership or investigative decisions are susceptible to political influence.
Criminal procedure provides another example.
Ukraine committed itself to changing provisions under which corruption proceedings can eventually be closed because deadlines for pre-trial investigations have expired, as well as addressing limitation periods for corruption offences.
Draft legislation has appeared. Bills No. 15333 and 15334 were registered in parliament, and NABU and the Ministry of Justice have worked on amendments.
But the process has taken months.
For a simple criminal case, procedural deadlines may appear an obscure legal question. Top-level corruption investigations are different. They can involve offshore structures, large quantities of financial evidence, foreign jurisdictions and prolonged litigation. If the clock eventually disposes of a case that investigators and prosecutors cannot bring to judgment quickly enough, the anti-corruption architecture fails at the point where it is supposed to produce results.
The same pattern is visible in judicial reform and the new Anti-Corruption Strategy for 2026–2030. Work is taking place, legislation is being prepared and institutions are consulting one another. Some changes have been completed.
Others remain somewhere between agreement and implementation.
This is precisely the stage of accession at which that distinction begins to count.
When Ukraine and Moldova moved further into the EU accession process, the significance of the Fundamentals cluster was that progress would increasingly depend on the functioning of institutions rather than declarations of political intent.
Ukraine has no shortage of declarations of European intent. What the Commission needs to establish is whether the machinery beneath them works.
The limits of the wartime argument
Any assessment that ignores Russia’s war would be unserious.
Full-scale aggression has inevitably changed the Ukrainian state. Decisions that might take months in peacetime sometimes have to be taken within days. Military information cannot be handled according to ordinary transparency rules. Elections cannot proceed under normal conditions. The executive carries responsibilities that no Ukrainian government faced before 2022.
Reform is also competing for administrative capacity with mobilisation, defence procurement, reconstruction, energy emergencies and the daily consequences of Russian attacks.
This has to be taken into account when Brussels sets timetables and assesses progress.
It is less convincing when applied indiscriminately.
Competitive recruitment of prosecutors does not interfere with the defence of Ukraine. Neither does an independent procedure for selecting the Prosecutor General. NABU’s ability to investigate senior officials does not prevent the armed forces from conducting operations, while closing procedural loopholes in corruption cases has no obvious adverse effect on wartime decision-making.
There is therefore a boundary between powers required to fight Russia and powers that are simply easier for government to retain during wartime.
Finding that boundary is becoming one of the more difficult questions in Ukraine’s relationship with the EU.
This does not support the sweeping claim that every important Ukrainian institution has been placed under political control. The evidence does not justify it.
It does show why Brussels is concentrating increasingly on institutional independence.
The problem with wartime centralisation is rarely that it begins without justification. Governments fighting wars need authority. The longer an emergency lasts, however, the more important it becomes to distinguish measures required by national security from arrangements that have become politically convenient.
Ukraine has now lived under full-scale war for more than four years. Institutions created for the post-war European state are being shaped while the wartime state still exists.
That makes the current reform period unusually consequential.
Conditionality becomes Brussels’ leverage
The EU has one powerful instrument with which to influence the outcome: money.
The Commission is already using it.
The almost €3 billion approved in September followed the completion of agreed Ukraine Plan milestones. The next payments depend on further commitments being met.
As EU Today reported when the Ukraine Plan was amended, additional financing has come with additional rule-of-law and anti-corruption requirements.
There is a limit to how far Brussels can push this. Ukraine is fighting a Russian war of aggression that also poses a direct security threat to Europe. Destabilising the Ukrainian budget in order to demonstrate the rigour of EU conditionality would make little strategic sense.
Kyiv is well aware of that.
But Brussels cannot simply waive the conditions either. Doing so would weaken reformers inside Ukraine, reduce EU influence over the accession process and make it more difficult to explain enormous long-term transfers to European taxpayers.
The result is already visible: continued financial support accompanied by increasingly detailed scrutiny of how reforms are implemented.
That approach is likely to become tougher as accession advances.
There is another reason for it.
Ukraine will eventually have to manage reconstruction on a scale Europe has not seen for decades. European governments, international financial institutions and private investors will be asked to commit hundreds of billions of euros. Confidence in prosecutors, courts, public procurement and anti-corruption agencies will affect how much money arrives and on what terms.
Strong institutions are therefore not a concession Ukraine makes to Brussels in exchange for membership.
They are part of the infrastructure required for Ukraine’s recovery.
The same applies to the war itself. Corruption in defence procurement, reconstruction or public administration gives Russia opportunities to damage confidence in the Ukrainian state and strain relations between Kyiv and its partners. Moscow has every interest in amplifying genuine scandals alongside fabricated ones.
The most effective answer is not tighter political management of damaging information. It is institutions capable of investigating misconduct credibly.
That is also why the role of Ukrainian civil society deserves attention.
The organisations producing critical assessments of Kyiv’s reforms are operating in a country under attack. Many have supported Ukraine’s European integration for years. Their reports can be disputed and their scoring methodologies examined, but criticism of government performance is not evidence of disloyalty.
The ability to produce such criticism is itself one of the features separating the Ukrainian political system from the authoritarian model Russia represents.
Ukraine’s reform record consequently looks neither like the failure portrayed by some critics nor the uninterrupted success sometimes presented by its defenders.
The broader record is impressive. Completing 84 of 95 Ukraine Plan milestones while fighting a major war is not a trivial achievement, and the EU would not have continued releasing billions of euros if the reform programme existed only on paper.
The difficulty appears further down, where institutional reform begins to affect the ability of political authorities to influence prosecutors, investigators and judicial appointments.
The NABU-SAPO confrontation made that problem impossible to ignore. The subsequent reversal showed that Ukraine also possesses the political and civic capacity to correct course.
What happens next will matter more than either episode.
Bills that have remained in parliament will have to become law. Reviews of the SBI and prosecution service will have to produce institutional changes. Competitive appointment procedures will have to work when the preferred candidate of those in power does not win. Anti-corruption bodies will have to be allowed to pursue cases when their targets are politically connected.
These are less visible achievements than opening accession negotiations or announcing another EU funding package.
They are also much closer to what EU membership ultimately requires.
Russia has forced Ukraine to build an exceptionally powerful wartime state. European integration requires Kyiv to ensure that some of that power can eventually be constrained by institutions that do not depend on whoever occupies the presidential administration.
The figures that currently look contradictory — 84 out of 95 and 15 out of 100 — are therefore telling different parts of the same story.
Ukraine has shown that it can reform during the war.
The harder test is whether it can complete reforms precisely where doing so reduces political discretion.
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