From the “OLX tax” and integrating tax and customs databases to repealing the so-called Lozovyi amendments and reforming state-owned companies’ supervisory boards: what “homework” from the IMF Ukraine was supposed to complete and where it failed.

This was reported by Maria Repko, Deputy Executive Director of the Centre for Economic Strategy, during the presentation of the Monitoring of the implementation of the IMF program conditions and EU assistance under the Ukraine Facility for September 2025, according to Espreso.

«The International Monetary Fund estimates Ukraine’s financing needs for the next two years at approximately $65 billion, which is a very, very large amount. Of this, according to rumors, $8 billion could be covered by a new program. What this program might look like will depend on how Ukraine has implemented the current one,» says Maria Repko.

In her opinion, the requirements that the IMF set for Ukraine in the current program were very easy, and the Fund was lenient about the implementation of structural benchmarks.

Ukraine was credited with completing 4 benchmarks

As of September, Ukraine has been credited with completing 4 benchmarks, although at least one of them has not been fully implemented.

«This is the so-called OLX tax (tax reporting requirements for digital platform operators). Indeed, it was initially implemented by submitting a bill to the Rada, then this bill was withdrawn and now the government has prepared a new bill. Nevertheless, the benchmark is considered completed,» says Maria Repko.

The second benchmark is the timely submission of the budget declaration for 2026-2028.

«It was submitted on time – which is great. We welcome that the government did this, and I think we will continue to move towards medium-term budget planning,» says the expert.

The third benchmark is the adoption by the Strategic Investment Council of the Single Project Pipeline. In September 2024, a pilot Single Project Pipeline (SPP) was formed very quickly. In accordance with the structural benchmark added during the 8th review of the Program, the Strategic Investment Council approved the Single Public Investment Project Portfolio for 2026.

«I know that some people smiled because projects worth as much as 11 trillion UAH were approved. So prioritization is still a problem, but nevertheless – the benchmark was met,» says Maria Repko.

The fourth completed benchmark is the publication of the external audit report of NABU.

Another structural benchmark is in the process of being implemented. It concerns the alignment of customs and tax service databases. Tax officials should have access to customs data and vice versa.

In addition, two structural benchmarks have the status of “completed with delay.” These concern the independent verification of the compliance and integrity of the members of the National Securities and Stock Market Commission and the appointment of the head of the Bureau of Economic Security (BEB). At the same time, the expert notes that no information on the results of such verification could be found.

«Another benchmark that was completed with a delay is the appointment of the head of the BEB. This was also very difficult and, without exaggeration, required a revolution with cardboard boxes,» says Maria Repko.

Which obligations Ukraine has not yet fulfilled

«The benchmark that has moved into the “not fulfilled” status is the new approaches to reforming the supervisory boards of state-owned enterprises, corporate governance in state-owned enterprises. This is a story that is hard to overestimate for Ukraine. It is probably what shapes the deep state in the worst sense of the term. And it is the hardest thing to fight,» says Maria Repko.

In her opinion, since this requirement was not met, it is very likely that it will be included in the preliminary measures of the new IMF program. That is, the requirements without which the implementation of the program will not begin.

«Another unfulfilled benchmark is the repeal of the “Lozovyi amendments.” This benchmark received a negative assessment from Ukrainian business, including even the white business,» the expert explains.

The deadline for this benchmark has already been postponed twice. The current Memorandum with the IMF stipulates that the parliament was supposed to adopt the relevant amendments to the Criminal Procedure Code by the end of July this year.

Source: ESPRESO.

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