One year of the Ukraine Facility Regulation: Civil society recommendations for improvement

Brussels
February 28, 2025

FOR THE ATTENTION OF:

Marta Kos,
European Commissioner for Enlargement

Gert Jan Koopman,
Director-General for Enlargement
and the Eastern Neighbourhood

Katarína Mathernová,
EU Ambassador and Head
of the EU Delegation to Ukraine

Dear Commissioner Kos, Director-General Koopman, and Ambassador Mathernová,

We, the undersigned Ukrainian and European civil society organisations, appeal to you concerning the implementation of the Ukraine Facility Regulation as it reaches its one-year mark.

In light of recent geopolitical developments, the Ukraine Facility now more than ever constitutes a vital support mechanism for Ukraine, providing EUR 50 billion over the 2024-2027 period. This funding is helping Ukraine in its efforts to maintain macro-financial stability, promote recovery, and strengthen governance on its path to EU accession.

However, we believe the Ukraine Facility could have a far greater impact. To this end, we urge the European Commission to consider the following recommendations:

Increase the quality of documents produced within the Ukraine Plan to be conducive to effective implementation and sustainable reforms.

Improve the visibility and transparency of the Ukraine Investment Framework for the public and civil society organisations.

Streamline climate and environmental objectives, including biodiversity conservation and the principle of ‘do no significant harm’, ensuring they apply to 20 per cent of total financing under the Ukraine Investment Framework and investments within the Ukraine Plan.

Establish a platform for civil society organisations to submit their opinions along with a procedure for transparently tracking and incorporating their opinions into official documents.

Ensure Ukrainian municipalities receive access to 20 per cent direct financial support from the Ukraine Plan through newly developed methodologies for submitting project concepts for public investment funding.

• Prioritise grant support for Ukrainian civil society organisations.

We hope these recommendations will also contribute to the Commission’s annual report to the European Parliament and Council on progress towards achieving the objectives of the Ukraine Facility Regulation.

More detailed recommendations are provided in the Annex.

Thank you in advance for your consideration and support.

Signatories:
CEE Bankwatch Network
T&E
Association for International Affairs (AMO)
Centre for Environmental Initiatives “Ecoaction”
NGO Ekoltava
NGO Ecoclub
SaveDnipro NGO
NGO Urban Reform
NGO CELA
International Charitable Organization “Environment - People - Law”
RePower Ukraine Foundation
Fund RcErBs
ForestCom
Eurogroup for Animals
WWF European Policy Office
Volonteurope
Agency for Sustainable Development of the Carpathian region “FORZA”
Institute for Development of National Economy
Zero Waste Alliance Ukraine
Greenpeace Ukraine
NGO Plato
Clean Air Action Group
Eastern Partnership Civil Society Forum
National Ecological Centre of Ukraine
Civic Union "Innovation Aarhus Network Of Ukraine Territorial Communities and the City of Kyiv"
Young European Federalists - JEF Europe
Zero Waste ZP NGO