Halfway to the deadline, Ukraine scores 15% on the EU’s priority reforms plan
In December 2025, the Ukrainian government made written commitments to the EU regarding urgent key reforms in the areas of the rule of law and anti-corruption. The plan was signed on Ukraine’s behalf by Taras Kachka, Deputy Prime Minister for European Integration, and became unofficially known as the "10 Kachka-Kos points".
Kyiv knew from the outset that this list has special significance for the Europeans. It’s not just that all of its elements stem from the EU accession criteria and other bilateral documents. For Brussels and the member states, this plan is 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 indicative.
"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 – within one year," European Enlargement Commissioner Marta Kos explained, referring to the notorious events of July 2025, when Ukraine undermined its own anti-corruption reforms.
The plan may not have formal legal status, but politically, it’s hugely significant.
EU officials are now repeatedly emphasising that Ukraine itself set the implementation deadline at one year. Ukrainian officials, including Taras Kachka, are continuing to insist on this timeframe as well.
Yet six months have gone by, and progress on implementing the plan is well below expectations. Expert monitoring of Ukraine’s progress gives it a score of 15 out of 100 – and most of that reflects preparatory work rather than reforms that have actually started.
Unless the situation changes immediately, Ukraine will create serious obstacles on its own path towards EU membership. Failure to fulfil the commitments it has undertaken, especially those regarded as a "test of trust", also significantly increases the risk of the EU deciding to decouple Ukraine and Moldova’s accession 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.
What this report is about and what counts as success
Alignment with the EU legislation that Ukraine must adopt during the accession process is measured annually by the European Commission in the Enlargement Report. To assess progress in the "Fundamentals" Chapters 23 and 24, the EU uses a separate mechanism – the Interim Benchmark Assessment Report (IBAR).
Things are more complicated with the Kachka-Kos plan. It is not part of the formal accession process, so there are no public EU tools to evaluate progress. 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 essential if it is to continue on its path towards EU membership?
To address this, Ukrainian think tanks formed a coalition known as Membership Check, led by the New Europe Center. It brings together eight expert organisations working on European integration, anti-corruption and judicial reform. The other members of the group are European Pravda, the Mezha Anti-Corruption Center, ANTS (the National Interests Advocacy Network), the DEJURE (Democracy, Justice, Reforms) Foundation, 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, revealed disappointing results. After three months of work, the authorities had achieved only 9% of the maximum score. At the time, the government said it expected to speed up later, as the first few months were mainly spent on preparatory work. This explanation made sense. But even less progress has been 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’s important to emphasise that 100% completion is not an absolute requirement.
Of course that remains the desired outcome, but reality is always more complex.
Even when it comes to formal accession requirements, Brussels often accepts less-than-perfect results. For example, in the area of the rule of law, the EU does not require literal compliance with all its recommendations, but rather the creation of a system in which citizens and businesses can trust court decisions and believe that they are fair.
The same applies here: if Ukraine can show that it has made a genuine effort to implement all the points, but details of the final decisions differ from the EU’s vision (or that of the expert coalition), the plan could still be considered fulfilled even if the numerical score were, say, 80 points instead of 100.
The problem is, however, that right now, no meaningful progress is being made on any of the 10 points.
Ukraine has implemented only one minor element of one of the points. It has also completely failed to address the main elements related to judicial reform. Within the coalition there were even discussions about whether a negative score should be given, since this is essentially a rollback in one of the reform areas.
Yet the coalition’s sources 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 main reasons for the delay (in other words, it’s the EU’s fault, not Ukraine’s).
It is true that Kyiv could still demonstrate rapid progress in implementing the plan in the remaining six months before the deadline Ukraine itself set. But that doesn’t explain how it will remedy the dismantling of the reform of judges’ declarations of integrity.
Another reason for cautious optimism is that a group of MPs, including the chair of the anti-corruption committee, Anastasiia Radina (from the Servant of the People faction), have started registering draft laws that aim to implement the plan’s points on their own, without waiting for the government.
But will there be enough votes in parliament to go against the government – even with the realisation that Ukraine’s path towards EU membership is at stake – especially given that the government has been showing that it disagrees with certain pro-European parliamentary initiatives?
Now for some more details on each of the 10 points.
Point 1: closing corruption loopholes in the Criminal Procedure Code (CPC)
This point of the Kachka-Kos plan 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 very important problems.
In particular, Ukraine has 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 the "Lozovyi amendments").
All attempts by parliament to fix these and similar provisions have failed, so the European Union has identified remedying these problems as one of the accession criteria.
In the coalition’s assessment, the first point carries the highest weight – 20 points. However, Ukraine’s current score is only 2.5 out of 20.
Ukraine is still only preparing to work on this reform.
The government promised long ago to submit a relevant draft law, and has actually drafted it, but issues arose during coordination. The draft has now been sent back for revision jointly with the National Anti-Corruption Bureau (NABU) and the National Agency on Corruption Prevention (NACP).
Recently – evidently not expecting rapid 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 the rules for determining jurisdiction and ensuring international cooperation. So far there has been no movement on them in parliament.
Point 2: independent forensic examinations for NABU
Here, too, everything is still at a very early stage. Essentially, there have only been political statements expressing readiness to implement this point.
The Ministry of Justice has started to draft a bill, but NABU is unhappy with the proposals and critical of the government’s concept of 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.
Expert score: 2 out of 10 points.
Point 3: changing the rules for the dismissal of the Prosecutor General and selection of candidates for the position
This point of the plan deserves particular 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 the position is often filled according to political quotas, but subject to strict professional criteria.
However, an exception has been made for Ukraine. A review of the procedure for selecting and dismissing the Prosecutor General has been included in the EU accession criteria, and in the Kachka-Kos plan as well.
The reason for this exceptional treatment is the role played by Ukraine’s Prosecutor General, Ruslan Kravchenko, in the attack on anti-corruption institutions in July last year. The EU is well aware that it was Kravchenko who drafted the controversial law that undermined the independence of NABU and the Specialised Anti-Corruption Prosecutor’s Office (SAPO).
However, the European Union cannot and will not demand his dismissal. The only requirement is that Ukraine introduce safeguards for the future, so that future Prosecutors General are selected based on professionalism rather than loyalty.
Even here, however, the government has done nothing so far. Moreover, there have not even been any political statements indicating an intention to carry out a meaningful reform.
The experts have awarded half a point only because of a parliamentary initiative: draft law No. 15343 on competitive selection for the position of Prosecutor General has been registered in the Verkhovna Rada.
Expert score: 0.5 out of 10.
Point 4: reinstating the competitive selection process for the appointment and transfer of prosecutors
This is another consequence of the notorious July 2025 law. As is well known, under pressure from the Ukrainian public and Western partners, the authorities rolled back restrictions on the independence of NABU and SAPO. However, the law also contained a provision concerning the prosecution service.
Parliament "forgot" to repeal it, and to this day Kyiv has ignored all reminders about this from the EU.
There have been political statements about the intention to implement this point, but no actual action.
The Office of the Prosecutor General has drafted a law (which the coalition has reviewed), but it does not reinstate competitive appointments of prosecutors to positions. The government says it intends to submit the draft law to the Venice Commission after further refinement, which could delay the process even more.
Expert score: 0.5 out of 10.
Point 5: reform of the State Bureau of Investigation (SBI)
Despite the fact that the Kachka-Kos plan is supposed to be implemented by the end of 2026, the government already appears to be planning to miss the deadline when it comes to the State Bureau of Investigation (SBI). Current government statements suggest an intention to submit a draft law "by the end of the year", which is quite late for such a complex reform.
The government says this is because the bill will only be drafted upon completion of an audit of the SBI.
However, the main problem is not missing the deadline, but the possible deliberate entrenchment of politically dependent leadership within the SBI.
The tenure of the current SBI director ends on 31 December 2026, and the competition commission to select his successor must be formed no later than 31 October 2026. Therefore there is a risk that the new director will be selected according to the existing procedure, the transparency and independence of which are questionable.
Expert score: 1 out of 10.
Point 6: appointment of judges to the Constitutional Court and members of the High Council of Justice
This point of the Kachka-Kos plan includes the requirement that only internationally vetted candidates should become judges of the Constitutional Court (CCU) and members of the High Council of Justice (HCJ) going forward.
Overall, there are no critical problems here, although the pace of implementation could be faster. A competitive selection process is underway for two vacant CCU judge positions under the parliamentary quota. Around late June/early July, the Advisory Group of Experts is expected to determine the candidates’ rankings and submit them to the parliamentary committee. The CCU judge positions that are under the quotas of the president and the congress of judges remain vacant.
As regards the High Council of Justice, the congress of judges has elected two members to the HCJ, but there are still vacancies under the quota of the congress of advocates (no competition has been announced since 2022, as the bar self-governance system, once controlled by Andrii Portnov, remains a systemic problem).
In August 2026, and again at the beginning of 2027, the terms of 13 more HCJ members will expire. Competitions to fill these vacancies have been announced.
Expert score: 1 out of 5, with hopes that the assessment may improve shortly.
Point 7: involving international experts in the selection commission of the High Qualification Commission of Judges (HQCJ)
Draft law No. 13382 has been registered in parliament, but its consideration has not progressed since June 2025.
The government claims it has prepared an alternative legislative initiative, which is currently at the stage of coordination with the European Commission.
Expert score: 1.5 out of 10.
Point 8: judges’ declarations of integrity and digitalisation of enforcement proceedings
This is a complex point consisting of three elements, so the experts agreed to roughly divide the maximum score (10 points) equally between them.
Let’s begin with the good news.
On 7 April, parliament adopted new legislation on the digitalisation of the enforcement of court decisions. The law received a positive assessment from the European Commission, and the experts also have no objections, so the coalition awarded the maximum score here – 3.5 points.
The other two elements concern the reform of judges’ declarations of integrity, which must include "improvement of the verification procedure", as well as the introduction of a separate mechanism for such declarations for Supreme Court judges, including "the temporary involvement of internationally nominated independent experts".
On both of these elements, there has been either zero progress or movement in the wrong direction.
It is important to explain that declarations of integrity are one of the few tools for cleaning out the judiciary. Or rather they were supposed to be – but the Ukrainian parliament has decided to protect dishonest judges. And this assessment is no exaggeration.
On 9 June 2026, parliament adopted draft law No. 13165-2 on judges’ declarations of integrity. Yet the law contradicts the plan’s requirements, does not improve the verification of existing declarations, and actually makes it easier for judges to exploit loopholes to avoid accountability. European Pravda has covered this in this article: A "European" reform in name only.
In addition, contrary to the plan’s requirements, the adopted bill does not provide for the temporary involvement of international experts in the verification of Supreme Court judges’ integrity declarations. Thus, parliament did not even attempt to simulate compliance with this element.
The controversial law is now awaiting the president’s signature.
Total expert score for the three elements of this point: 3.5 out of 10.
Point 9: the Anti-Corruption Strategy and Anti-Corruption Programme
Formally, this point has already been breached. It is the only one for which the Kachka-Kos plan has a separate deadline: both of these documents were supposed to have been adopted by the end of Q2 2026 – i.e. now.
Yet it was not until May, after a long delay by the government (which failed to approve the strategy developed by the NACP), that draft laws for the State Anti-Corruption Strategy (SAS) appeared in the Verkhovna Rada. The process was unlocked despite the Cabinet of Ministers’ position when MP Anastasiia Radina decided to submit the draft on behalf of the NACP herself.
Only then did the government submit its own draft law – but it removed several of Ukraine’s key commitments from the Strategy (as European Pravda has reported on in detail).
Later, a third, alternative parliamentary draft was also introduced. At present, all three remain stalled. It is unclear whether the government will agree to adopt a version that aligns with Ukraine’s obligations to the EU.
Work on the State Anti-Corruption Programme, which is to be based on the Strategy, will only begin after the Strategy is adopted.
Expert score: 1.5 out of 10.
Point 10: internal control systems against corruption
Here, according to the experts, work is still at a very early stage, although a number of measures have been implemented. The State Audit Service of Ukraine has added questions about the state of internal control to the audits it conducts. A whistleblower reporting portal is functioning, but it needs further improvement.
In May, updated Internal Audit Standards came into force which revised the requirements for organising internal audits in the public sector and strengthened requirements for the organisational and functional independence of internal audit units.
Expert score: 1 out of 10.
The full monitoring report is available at the following link.
By Sergiy Sydorenko, European Pravda
Assessment by the Membership Check coalition