What problems did the shadow report reveal about reforms in Ukraine?

In about two weeks, a landmark event will take place in Brussels. The European Commission will publish the most important annual document for countries seeking EU membership: the Enlargement Report. Increasingly, voices from EU member states are expressing the view that Kyiv’s pace of reforms is insufficient. The report will therefore provide arguments either for Ukraine’s supporters or for the sceptics.

Although the text of the report is being kept secret, its general tone can already be discerned – both from statements by European officials and from an interim document that was made public this week.

The tone of this shadow report is not optimistic.

Read more about what the shadow report has revealed, how the Ukrainian government plans to respond and whether the EU will make concessions to Ukraine in the article by Sergiy Sydorenko, European Pravda's editor: A year without reforms, but without punishment either: what the shadow report revealed about Ukraine’s EU accession.

According to European Pravda, the European Commission is currently facing a difficult choice.

Politically, Brussels would like to deliver good news for Ukraine. The EU’s highest-ranking officials repeatedly emphasise that Kyiv deserves special treatment because it is carrying out reforms during wartime. At last week’s summit, this point was reiterated by both European Commission President Ursula von der Leyen and European Council President António Costa.

The problem is that reforms in Ukraine have practically ground to a halt since last year.

At the same time, there is also a view within the European Union that Ukraine has been underestimated in recent years.

Sources indicate that, following this logic, a proposal is being discussed within the European Commission to upgrade Ukraine’s assessment in recognition of its "past achievements". However, no decision has yet been made.

What works against Ukraine is that, specifically in 2026, the country has done practically nothing – at least according to the experts’ assessment.

The Shadow Report is a report prepared by independent Ukrainian experts at the European Commission’s request. Brussels takes it into considerable account when formulating its official assessment. On 19 October, the report was published in Kyiv.

Shadow reports are generally more critical than the European Commission’s official assessments. The 2026 document is no exception.

Across a large number of policy areas, experts assessed Ukraine’s reform efforts as showing zero progress.

The report acknowledges that some positive developments have occurred, but they have not been systematic.

"During the reporting period, progress in the fight against corruption remained limited: positive developments were predominantly isolated and dependent on internal processes within institutions, while the systemic legislative changes envisaged in the Rule of Law Roadmap were largely not implemented," the document states.

The report covers only the period up to August and does not take the autumn developments into account, which significantly worsens Ukraine’s assessment. It was in September, following a prolonged escalation of tensions between institutions, that parliament resumed progress on reforms.

This may be one reason why the government disagrees with the experts’ assessment.

"We have reforms underway in the areas of the rule of law and law enforcement, not to mention the fight against corruption," Deputy Prime Minister Vsevolod Chentsov said on Monday at the report’s presentation.

Even under the most optimistic scenario, however, the European Commission’s report will speak of limited progress at best.

The amount of work that remains to be done is incomparably greater than what has been accomplished.

The government’s current objective is to fulfil all interim benchmarks as quickly as possible. In other words, it aims to secure EU approval for all reforms carried out in the areas of the rule of law and anti-corruption, and to submit for EU approval a report on Ukraine’s implementation of these interim benchmarks, known as the IBAR.

If this happens, it would represent a truly seismic shift in Ukraine’s progress towards EU membership. Approval of the IBAR would allow the candidate country to move on to the process of provisionally closing chapters in its accession negotiations.

For now, the main achievement of the past year is that there has been no reversal of reforms.