Taxes, customs, and reforms: what Ukraine must fulfill to receive €90 billion from the EU
Kyiv • UNN
Zelenskyy submitted a memorandum to the Rada regarding a 90 billion euro loan. To receive the funds, Ukraine must amend its tax and customs legislation.
A draft law submitted by the President of Ukraine regarding the ratification of the Memorandum of Understanding between Ukraine and the European Union within the framework of the Ukraine Support Loan has appeared in the Verkhovna Rada. The document concerns macro-financial assistance to Ukraine as part of a broader EU loan of up to 90 billion euros for 2026-2027, which is to be repaid using reparations from Russia.
UNN examined what Ukraine needs to fulfill in order to receive these funds.
Details
The document does not provide for a one-time transfer of the entire 90 billion euro amount to Ukraine. It is part of the Ukraine Support Loan mechanism and defines the conditions for receiving EU macro-financial assistance in the amount of up to 8.35 billion euros.
The text states that EU Regulation 2026/467 introduces enhanced cooperation regarding the creation of a loan to support Ukraine for 2026 and 2027 in the amount of up to 90 billion euros. The loan is available until December 31, 2027. Its goal is to support Ukraine's macro-financial stability, ease external and internal financial constraints, and complement other programs of the EU, international financial institutions, and donors.
The specific macro-financial assistance provided for by the memorandum is to be paid in three tranches. The estimated size of the first tranche is 3.2 billion euros, the second is 3.7 billion euros, and the third is 1.45 billion euros. The first tranche can only be paid after the loan agreement becomes effective. The second and third tranches—no earlier than three months after the previous payment.
Each tranche can be transferred in one or several parts. The decision on the amount, timing, and number of parts will be made by the European Commission. All parts of the tranches must be paid to official Kyiv by December 31, 2028. If Ukraine's financing needs decrease significantly, the European Commission may reduce the unpaid amount of assistance or cancel it.
What conditions are stipulated in the draft memorandum with the EU
To receive all 3 tranches of assistance, Ukraine must adhere to effective democratic mechanisms, a multi-party parliamentary system, the rule of law, and human rights, including the rights of persons belonging to minorities. The document specifically noted that support for the rule of law includes the fight against corruption.
In addition, payments depend on a positive assessment by the European Commission regarding the implementation of macroeconomic and structural conditions defined in the annex to the memorandum. Another condition is the absence of a negative assessment in the field of Ukraine's anti-corruption obligations within other EU or IMF support programs.
Before each payment, the Ukrainian authorities must provide the European Commission with documents confirming the fulfillment of the conditions. The Commission will verify them, consult with international organizations if necessary, and may take into account the security situation and its impact on Ukraine.
Taxes, customs, and public finances: what conditions were set for Ukraine to receive the first tranche
For the first tranche, Ukraine must implement decisions in three blocks:
- mobilization of domestic revenues;
- efficiency of public expenditures;
- public financial management.
Among the conditions is the submission to the Verkhovna Rada of a draft law on the abolition of tax exemptions for international parcels, except for goods for security and defense needs. It is also necessary to submit a draft law on the introduction of taxation on income received through digital platforms.
Separately, the adoption by the Rada of a law on extending the military tax at a level of 5% for three years is envisaged. The document noted that this should ensure at least 140 billion UAH in additional revenue per year.
The Cabinet of Ministers, in turn, must approve the procedure for the development, monitoring, and evaluation of public investment strategies.
In addition, Ukraine must adopt and publish an updated Public Finance Management Strategy, submit a new Customs Code to the Cabinet of Ministers for alignment with the EU Customs Code, and appoint a new permanent head of the State Customs Service.
Second tranche: a broader package of reforms as a condition for receiving the loan from allies
For the second tranche, Ukraine must submit amendments regarding the alignment of corporate taxation with the EU Anti-Tax Avoidance Directive. The Rada must adopt amendments on the taxation of income through digital platforms and a law on the abolition of tax exemptions for international parcels.
Among the conditions are also the creation of a property valuation system, a State Tax Service roadmap for VAT risk management, and a plan to increase tax discipline. In the field of public investment, the creation of a unified information ecosystem with the integration of DREAM, state budget, LOGICA, Prozorro, and Treasury systems is planned.
The document also requires the adoption of the Budget Declaration for 2027-2029 with a baseline scenario, an active policy scenario, an assessment of macroeconomic assumptions, and an annex regarding public investment projects.
The Cabinet of Ministers must determine the areas for state budget expenditure reviews in 2026, including housing, regional, and veteran policies.
For customs, the draft agreement provides for an updated digital development plan until 2030, and the Verkhovna Rada must appoint the three missing experts to the commission for selecting members of the Accounting Chamber board.
Third tranche: preferential taxation, VAT, and procurement as main EU requirements
The largest list of conditions concerns the third tranche. Ukraine must submit a draft law on reforming the preferential tax regime, which should ensure at least 70 billion UAH in additional revenue per year. The document specifically mentioned measures against artificial business fragmentation, restrictions on re-entry into the simplified system, differentiated rates for single tax payers of the third group, and steps for alignment with EU VAT rules.
Also, the Rada must adopt a law on simplifying VAT administration for individual entrepreneurs (FOPs). This refers to quarterly reporting instead of monthly, monthly tax invoices instead of daily, a preliminary tax return for FOPs, and simplifying the unblocking of tax invoices.
Separately, the alignment of corporate taxation with European rules, the preparation of long-term pension expenditure forecasts together with the World Bank, the IMF, and European Commission services, as well as an explanation in the draft state budget for 2027 on how the results of expenditure reviews are taken into account in the budget, were provided for.
In the field of procurement, Ukraine must develop a new Public Procurement Strategy for 2027-2030 and a conceptual note regarding the law on defense procurement, which should bring the Ukrainian framework closer to EU law. In the field of audit, the separation of inspection and audit within the State Audit Service, the creation of 10 new audit committees, and a review of the national internal audit standard are planned.
Who will monitor Kyiv's fulfillment of the conditions
The memorandum provides for constant monitoring by the European Commission. Ukraine must provide information on the economic and financial situation and the progress of structural reforms. The Commission or authorized experts may conduct operational assessments of administrative procedures and financial schemes related to the management of EU assistance.
The Ministry of Finance and the NBU must regularly submit data on GDP, employment, unemployment, revenues and expenditures of the general government sector, budget deficit, public debt, the balance of funds in the single treasury account, inflation, balance of payments, reserves, and the exchange rate of the hryvnia to the euro and the dollar.
Memorandum with the EU: what you need to know about it
The document states that the Memorandum of Understanding regarding the macro-financial program for Ukraine was signed in Brussels on May 20, 2026, and in Kyiv on May 27, 2026. Minister of Finance Serhiy Marchenko signed on behalf of Ukraine, and European Commission member Valdis Dombrovskis signed on behalf of the EU. The National Bank of Ukraine acts as the borrower's agent, with NBU Governor Andriy Pyshnyi listed as the signatory for the NBU.
The memorandum enters into force after signing by all parties or after the creditor receives a legal opinion from the Ministry of Justice of Ukraine on the fulfillment of the necessary constitutional and legislative requirements.
In fact, the document defines not only the financial schedule but also a list of tax, customs, budgetary, and anti-corruption conditions on which Ukraine's access to funds within the European loan will depend.
As for the draft memorandum submitted to parliament by Volodymyr Zelenskyy, the document must now be considered by the VRU Committee on European Integration. After that, it will be sent to the session hall for a vote. For ratification, the draft memorandum needs to receive more than 226 votes from the people's deputies.