A list of obligations Ukraine must fulfill under its €90 billion loan agreement with the EU has been published. The conditions are included in the bill ratifying the memorandum with the European Union, submitted to parliament by Volodymyr Zelensky and already approved by the Verkhovna Rada.
The first tranche, worth €3.2 billion, requires the preparation of draft laws abolishing tax exemptions on international parcels—with the exception of goods intended for defense and security needs—as well as legislation taxing income earned through digital platforms. Ukraine also commits to extending the 5% military levy for another three years, updating its public finance management strategy, drafting a new Customs Code, and appointing a permanent head of the State Customs Service.
To receive the second tranche, Kyiv must adopt laws on the taxation of digital platforms, abolish exemptions for international parcels, and introduce a new property valuation system. Additional requirements include aligning corporate taxation with EU Directive 2016/1164 on anti-tax avoidance measures, preparing a roadmap for improving VAT administration, drafting the 2027-2029 budget declaration, and completing 2026 spending reviews. The memorandum also specifically requires parliament to appoint three experts to the commission selecting the leadership of the Accounting Chamber.
The third tranche, worth €1.45 billion, is tied to reforming the preferential tax regime, which under the memorandum must generate at least 70 billion hryvnias in additional annual budget revenue. The document also calls for further simplification of VAT administration and continued harmonization of corporate taxation with EU Directive 2016/1164, including the provisions of Articles 5-9.
Other Ukrainian obligations include preparing the draft 2027 state budget, developing a new public procurement strategy and a concept for reforming defense procurement, reforming the State Audit Service, creating ten new audit committees, and implementing updated internal audit standards.
The memorandum separately fixes the obligation to adopt a new Customs Code and implement technical requirements for customs IT systems.
The document also предусматривает reform of the simplified taxation system. Proposed measures include tackling business fragmentation used to preserve preferential tax status, introducing restrictions on companies repeatedly switching from the general taxation system back to the simplified regime, and implementing differentiated tax rates for third-group sole proprietors depending on their type of activity. Ukraine must also continue adapting its tax legislation to EU Directive 2006/112/EC.
Among the broader commitments fixed in the agreement are the preservation of democratic institutions, the multiparty system, human rights and minority rights, continuation of anti-corruption policies, and maintenance of all mechanisms introduced under EU and IMF programs. The document also requires safeguarding the independence of the National Bank of Ukraine, implementing modern corporate governance standards for state-owned enterprises and banks, and regularly providing the European Commission with macroeconomic and financial reporting.