How Ukraine is reforming the environmental sector and why there is no time to delay
On 4 November 2025, the European Commission published its 2025 Enlargement Package Report on Ukraine’s progress and this report turned out to be the most complimentary for Ukraine to date.
This year’s assessment of Ukraine under Chapter 27, "Environment and Climate Change," was marked as "good progress during the reporting period."
Read more about Ukraine’s environmental progress and what still needs to be done in the column by Nataliia Andrusevych of the Resource and Analysis Center: Society and environment: Finally not a ‘failing mark’! How Ukraine is meeting EU environmental requirements.
According to the author, several key events and adopted acts served as indicators for the "good progress" evaluation.
Most of them are in the field of climate policy: the resumption of monitoring, reporting and verification (MRV) of greenhouse gas emissions; the adoption of an implementation plan for the Emissions Trading System (ETS); the adoption of a framework Climate Law setting the goal of achieving climate neutrality by 2050.
"In the field of environmental protection, this includes the adoption of the National Waste Management Plan, the entry into force of the law on industrial pollution, the approval of river basin management plans and the strategy for reforming environmental control," Andrusevych adds.
At the same time, she emphasises that, according to the European Commission, no single area deserves the highest possible rating.
This is especially true in areas where Ukraine traditionally reports strong progress, such as environmental impact assessment (EIA), strategic environmental assessment (SEA), geospatial data, access to environmental information and public participation.
The column notes that a significant portion of the report’s analysis focuses precisely on EIA and SEA. The EU insists that general exemptions, even temporary ones, are unacceptable.
Meanwhile, according to the head of Society and Environment, government plans are currently aimed at deregulating environmental assessments, which would hinder the implementation of the European Commission’s recommendations.
In Andrushevych’s view, some of the report’s conclusions are puzzling due to their outdated or contradictory nature.
For example, it mentions the "underfunding of the Aarhus Centre," which is a relic of the past and no longer plays any role in facilitating access to environmental information.
On the other hand, the report fails to acknowledge the role of non-governmental environmental organisations, which, especially during wartime and institutional transition, play a major role in the European integration process – from their traditional watchdog and advocacy functions to assisting the government in negotiations.
The report’s recommendations, as usual, are particularly important. They are few but quite specific, the Chair of Society and Environment notes.
According to the European Commission, Ukraine’s key environmental priorities include aligning its Environmental Impact Assessment (EIA) and Strategic Environmental Assessment (SEA) procedures with EU standards, submitting its second nationally determined contribution under the Paris Agreement, and ratifying the Kigali Amendment to the Montreal Protocol. The country should also harmonise its national legislation with EU rules on fluorinated greenhouse gases and ozone-depleting substances, adopt a Strategy and Action Plan on the circular economy, and pass a law to implement the EU Regulation on deforestation-free products. In addition, Ukraine needs to continue preparing for the expansion of its Monitoring, Reporting and Verification (MRV) system and the implementation of an Emissions Trading System (ETS), while further strengthening the responsible institutions through clearly defined functions, adequate staffing, and sufficient technical expertise.
The author concludes that if Ukraine’s goal is to join the EU by 2030, environmental issues cannot be treated as secondary or residual.