How Ukraine should negotiate transitional periods with EU

, 10 November 2025, 14:00 - Anton Filippov

Ukraine will inevitably request transitional periods during accession negotiations with the European Union, especially in areas where reforms require significant investments and time. Requests for such transition periods are already being developed for each negotiation chapter as part of Ukraine’s official positions.

Ukraine risks, however, falling into the trap of its own ambitions, trying to demonstrate the fastest possible full harmonisation of national legislation with the EU acquis. It is discussed whether to request a transition period and how long it should last. It is important to remember that the issue is not only how much time is needed, but how that time will be used.

Read more about the importance of transition periods and how to make effective use of them is discussed in the column by Aliona Shulyma of the NGO Pragma: Not a "delay," but a reform plan: how Ukraine should negotiate transitional periods with EU.  

Requests for transitional periods are not exceptions but a well-established practice in EU enlargement. They are systematically applied when new states join the Union, depending on their level of readiness for full harmonisation with EU law.

The largest number of transition measures has traditionally been applied under Chapter 27, Environment and Climate Change. 

It involves complex infrastructure changes: wastewater treatment, extended producer responsibility systems, separate waste collection and recycling infrastructure. Ukraine is currently developing its negotiation position for this chapter.

The EU’s enlargement experience shows that transitional periods help new members gradually achieve full compliance with EU legislation without jeopardising economic stability or the quality of reform implementation.

Within EU institutions, there is a clear understanding that harmonisation is also about investment, technology, institutional capacity and human resources.

For Ukraine, this issue is even more sensitive. The country is simultaneously fighting a full-scale war, modernising and rebuilding its economy, and preparing for the most rapid and multi-dimensional integration process in its history.

In the context of Ukraine’s EU accession talks, time becomes not merely a calendar factor but also a political resource and a matter of accountability.

Therefore, when formulating requests for transitional periods, Ukraine must focus on ensuring that they are well-considered, justified, balanced, strategically sound and transparent.

The EU perceives transitional periods not as deferrals but as part of a roadmap toward full harmonisation.

Accordingly, such requests must be based on solid reasoning, include clear milestones and specify accountability mechanisms for their implementation.

To successfully defend these requests, Ukraine must demonstrate from the outset that it is not merely asking for extra time but proposing a plan, showing that it understands what needs to be done, how and within what realistic timeframe.

The goal of a transitional period is to allow the state to gradually adapt to EU requirements without undermining its economic capacity.

Achieving this requires coordination not only with the EU but also within Ukraine itself: the government must know exactly what position it is defending; businesses must understand what investments they are ready to make and when; the expert community must offer practical solutions and provide evidence-based justifications; and civil society must use its experience of cooperation with authorities to advocate for a united national position before the EU.

Above all, Ukraine must be honest about its own capabilities, not making unrealistic promises, but offering a consistent and credible plan.