The EU has mobilised €200 billion for Ukraine since February 2022 and built its most ambitious external financial instrument to date. Our research shows that the numbers only tell half the story. The Ukraine Facility’s genuine innovations – speed, reform conditionality, integrated financing, Ukrainian ownership – have each generated unresolved tensions. And its conditionality model ultimately depends not on disbursement mechanisms but on something harder to measure: whether the reforms it requires are seen as legitimate by the society that must implement them.
According to the fifth rapid damage and needs assessment, published in February 2026, Ukraine’s total reconstruction and recovery will cost $588 billion over the next decade. This represents nearly three times Ukraine’s GDP, with energy infrastructure damage worsened by 21% in a single year. That is an essential baseline. But numbers alone do not tell us whether the EU’s response is working, or what needs to change. For that, we need a different kind of analysis.
Our latest discussion paper on the Ukraine Facility offers exactly that. Drawn from over 35 interviews with EU institutions, member state officials, the EU delegation in Kyiv, financial institutions, civil society and the Ukrainian government, we asked not how much the EU has spent – since February 2022, the EU and its member states have mobilised approximately €200 billion – but whether the instrument it built is fit for the relationship Ukraine needs.
“Ukrainian ownership is not merely a design feature. It is a structural condition for conditionality to function.”
The Ukraine Facility is an innovative and strategic design
The Ukraine Facility, in force since March 2024, is innovative, combining macro-financial assistance, investment support and technical assistance under one framework linked to a reform agenda aligned with Ukraine’s accession path. Building on the lessons from preceding instruments, including the NDICI-Global Europe and its EFSD+, it aims at breaking the siloed approach of such tools. Its reform conditionality has proven real: quarterly disbursements linked to verified reform steps worked, including when it mattered most. The partial fourth tranche (€3.2 billion disbursed rather than €4.5 billion when three benchmarks were unmet) demonstrated that conditionality is not performative.
Critically, we found out that conditionality worked not only because of the disbursement mechanism, but because of what accompanied it: a co-designed reform agenda that Ukraine cannot frame as externally imposed; three ministries coordinating across a jointly drafted Ukraine Plan; an independent Audit Board (a first for an EU external instrument) assessing the adequacy of Ukraine’s public financial management systems. Ukrainian ownership is not merely a design feature. It is a structural condition for conditionality to function.
Some remaining tensions and challenges
Each of the Facility’s innovations has also generated unresolved tensions.
Governance vs. speed. The three pillars – budget support, investment support and technical assistance – operate under different Commission units, different oversight mechanisms and different Council working parties, with no single body holding a comprehensive view across all three. Between the Commission and member states, information flows are asymmetric and strategic steering capacity is constrained. This fragmentation reflects the complexity of building an instrument of this ambition at extraordinary speed, with so much political attention and resources, as well as a diverse set of stakeholders. But it has made coherent oversight quite difficult, and this will become more acute under the Global Europe instrument if not addressed now.
Three-pillar integration was designed but not fully operationalised. Investment and technical assistance pillars proceed in parallel rather than in tandem. The gap is felt most acutely at the local level, where all three pillars converge on the same municipalities without a shared operational overview. Initiatives like Ukraine FIRST and the EIB’s JASPERS advisory programme are meaningful steps, but primarily at the national infrastructure level, leaving sub-national actors without integrated support.
Conditionality is working and becoming more politically sensitive. As reforms move from tractable early benchmarks to structurally harder ones (i.e. judiciary independence, decentralisation, anti-corruption institutional reform), wartime constraints are widening the gap between benchmark design and delivery. The EU has inherited the ‘critical friend’ function the United States previously exercised, without yet having the institutional architecture to exercise it fully.
European economic interests remain more symbolic than real. The research shows that Article 11’s strategic procurement clause, which also inspired Article 20 of the proposed Global Europe Instrument, has been interpreted inconsistently across implementing partners, is non-trackable for the €33 billion in budget support, and lacks a precise enough definition of what ‘strategic European interest’ means in practice. Therefore, this does not require a more sophisticated regulatory clause but a more developed strategic framework: one that identifies priority sectors and combines regulatory reform with proactive demand-side instruments. The European private sector should be better accompanied by EU instruments when engaging in Ukraine, including an effective additional guarantee for European export credit agencies.
The financing cliff was real, and only partly resolved. The Facility was deliberately front-loaded, leaving limited resources for 2026-27, with nearly 75% of plan funding disbursed by end-2025, while Ukraine’s public debt reached approximately 110.5% of GDP, up from 48.9% before the invasion. The €90 billion Ukraine Support Loan agreed at the December 2025 European Council addresses this gap in design. At the same time, its delayed first disbursement, held up by a single member state using procedural leverage, illustrates a structural vulnerability: even a politically agreed and legally adopted instrument can be delayed by unanimity constraints.
“If the reforms that the EU requires and Ukraine has committed to are not seen as legitimate domestically, the model breaks down.”
A conversation about society, not just instruments
In April, ECDPM and CMI – Martti Ahtisaari Peace Foundation co-organised a closed-door roundtable examining a first-of-its-kind resilience risk assessment across five frontline oblasts, developed by Ukraine’s National Platform for Resilience and Social Cohesion with CMI’s support. One finding directly reinforces the paper’s argument: Ukrainian society is holding together horizontally – solidarity, civil society, and trust in the military remain high – but trust in political and judicial institutions is deteriorating sharply. It is the social condition on which the Facility’s conditionality model ultimately depends. If the reforms that the EU requires and Ukraine has committed to are not seen as legitimate domestically, the model breaks down. This will not be due to a design failure, but because of a deeper gap between instrument logic and social reality. The paper’s argument about local ownership, civil society monitoring, and decentralisation as structural conditions for reconstruction is the institutional expression of exactly this.
What comes next
The facility matters beyond Ukraine. It is the EU’s most significant test as a strategic external actor at scale, and its design choices are already shaping the Global Europe Instrument and the €100 billion Ukraine Reserve proposed for 2028-2034. ECDPM’s forthcoming publications will examine how reconstruction, accession and security must be managed as interlinked rather than sequential agendas; what the next MFF must address to make coherent support possible; how the multilayered coordination architecture around Ukraine can be further used to strengthen this already solid EU framework to support Ukraine; and how effective the international support to Ukraine has been to mobilise private investment.
The question running through all of it is whether the EU is willing to act as a whole, putting collective strategic interest ahead of the institutional and national dynamics that have kept it focused on the instrument, when what Ukraine needs, and what the EU needs to demonstrate, is a long-term strategic partnership.