Ukraine has not met any of the structural benchmarks it was required to implement by the end of March 2026 under the IMF’s Extended Fund Facility program.
This is evidenced by data from the RRR4U consortium.
Specifically, this concerns three key commitments: strengthening the selection procedure for supervisory boards of state-owned banks, adopting tax reforms, and appointing the head of the State Customs Service based on the results of a competition.
Although the government submitted some of the draft laws, the Verkhovna Rada did not adopt them, so these commitments are considered unfulfilled.
Other provisions of the memorandum have also not been implemented: the government has not submitted a number of draft laws, has not approved KPIs for the head of the customs service, has not published a report on the National Revenue Strategy, and has not filled vacancies on the NBU Council.
Furthermore, an international financial advisor has not been appointed to prepare for the privatization of state-owned banks.
At the same time, Ukraine is adhering to some of its commitments—in particular, it is not introducing new currency or import restrictions.
A new four-year IMF program worth $8.1 billion was approved in February 2026. The first tranche has already been disbursed, but to receive the next one, Ukraine must meet certain conditions, including tax reforms.