Ukrainian civil society is both the main beneficiary and the driving force behind Ukraine’s reconstruction. The Ukraine Facility Regulation invites socio-economic partners and civil society representatives to submit ‘opinions’ to the European Commission on implementation of the Ukraine Plan. However, its influence remains limited.
Valeriya Izhyk, EU Policy Officer, Ukraine Reconstruction | 30 January 2025
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The Ukraine Donor Platform will engage with Ukrainian civil society organisations quarterly, yet political platforms must strengthen their role to ensure legitimate decision-making. In 2025, priority should be given to establishing detailed procedures for civil society participation, including submission timelines, follow-up processes, and improved communication.
The Ukraine Facility and Donor Platform
The European Union is providing EUR 50 billion in financial support from 2024 to 2027 to aid Ukraine’s recovery from brutal war. The objective is to address the social, economic, and environmental consequences of Russia’s war of aggression, ensuring long-term reconstruction, modernisation, and resilience. These funds are critical for rebuilding infrastructure, restoring essential services, and supporting vulnerable communities.
The Ukraine Donor Platform, established by the G7 in December 2022, coordinates financial support from international donors. Since its launch in January 2023, the Platform has brought together Ukraine, EU and G7 countries, international financial institutions, and 10 observer nations. Engaging civil society in this process is crucial for ensuring resources are allocated in a coherent, transparent, and inclusive manner.
Public participation in the Ukraine Facility
The Ukraine Facility operates similarly to other European funds such as the Recovery and Resilience Facility and the European Fund for Sustainable Development Plus. Given its alignment with Ukraine’s EU accession process, implementation of the Facility has significant long-term implications. For this reason, the process must be comprehensive and include robust public consultation mechanisms.
Since January 2023, Bankwatch has organised informal dialogues between the Ukraine Service of the Directorate-General for Neighbourhood and Enlargement Negotiations and civil society organisations. These meetings, held on seven occasions over two years, initially aimed to provide civil society organisations with a voice in shaping the Ukraine Facility Regulation. However, these informal dialogues have not evolved into formal consultation mechanisms.
At the national level, the Ministry of Economy has been overseeing the development and implementation of the Ukraine Plan under the Ukraine Facility. While the Ministry for Development is responsible for recovery and restoration, the State Recovery Agency and local self-government bodies handle reconstruction projects, serving as an intermediary for local governments lacking the capacity to implement projects independently. of the Ukraine Plan under the Ukraine Facility. While the Ministry for Development is responsible for recovery and restoration, the State Recovery Agency and local self-government bodies handle reconstruction projects, serving as an intermediary for local governments lacking the capacity to implement projects independently.
One positive aspect of the Ukraine Plan is its adherence to EU regulations on meaningful stakeholder engagement. This commitment to transparency, in line with EU funding best practices, requires authorities to co-design projects with affected communities. Implementation will be overseen by monitoring committees typically comprising socio-economic partners, managing authorities of EU Member States, regional and local bodies, and civil society organisations.
‘Opinions’ as an instrument for empowering civil society
Civil society and other socio-economic partners have the opportunity to submit opinions on implementation of the Ukraine Plan, as outlined in Article 4 of the Ukraine Facility Regulation. This provision allows organisations to report irregularities and provide feedback on government actions related to the execution of the Plan. However, despite this formal avenue of participation, the lack of clear procedures limits its effectiveness.
Some opinions have already been submitted to the Directorate-General, particularly regarding environmental concerns. For instance, Ukrainian non-governmental organisations have raised issues about deviations from environmental impact assessment and strategic environmental assessment requirements. However, these submissions have had minimal impact on decision-making structures, as no dedicated follow-up mechanisms currently exist. And while the European Commission acknowledges these inputs, there is no protocol for ensuring they are considered in funding assessments.
Recent updates indicate that a dedicated website and email will be introduced to facilitate submissions. However, this alone will not resolve the issue of accountability. Without specific guidelines on how opinions influence decision-making, organisations may be discouraged from investing time and resources in providing concrete recommendations.
Ukraine Donor Platform: Steps towards engagement
The Steering Committee of the Ukraine Donor Platform met with civil society organisations for the first time in April 2024. Held in Kyiv, the event brought together key stakeholders from civil society organisations as well as international partners and financial institutions to discuss economic growth. Discussions focused on reforms, economic challenges, and the most pressing areas of need, particularly regarding capacity limitations.
Following this initial dialogue, the Platform committed to holding regular meetings, including two Steering Committee dialogues and two expert-level dialogues on an annual basis. The second expert-level dialogue, held in November 2024, invited selected organisations to discuss regional recovery strategies. However, concerns persist about the selection process and the representativeness of the participants.
To improve future engagements, a more transparent and inclusive process should be established. Civil society organisations should have a clear pathway to propose discussion topics and drive the agenda. The Directorate-General, which steers the Platform’s Secretariat, should ensure that international donors consider the priorities of civil society when communicating with the Commission on future policies and funding allocations. A more structured approach in 2025 will be critical for streamlining the involvement of civil society going forward.
Local-level opportunities for civil society
Reconstruction efforts occur primarily at the local level, making municipal engagement crucial. The Ukraine Facility mandates consultations with local and regional stakeholders, including authorities, social partners and civil society organisations, yet implementation is inconsistent. While Ukraine has made progress in decentralisation, challenges remain in ensuring meaningful citizen participation.
The Ukrainian government has introduced legal frameworks to facilitate this engagement. For example, the 2023 amendments to the Cabinet of Ministers Resolution on Public Participation aim to improve consultation processes. However, according to the National Agency for Corruption Prevention, 30 per cent of regulatory decisions in 2023 bypassed public consultations, highlighting ongoing gaps in transparency and inclusivity.
Encouragingly, the Ukrainian Parliament recently adopted legislation to strengthen democratic processes at the local self-government level, providing additional engagement tools, including public hearings and citizen evaluations of authorities. It also grants the 6.5 million internally displaced persons in the country the right to participate in decision-making in their host communities.
Another progressive step is the pending local democracy law, which over 160 public organisations have urged the President to sign. The law would see the introduction of new mechanisms for public hearings, consultations, and participatory budgeting.
Partnership shows the way forward
Despite these advancements, practical challenges remain in institutionalising effective civic engagement in Ukraine’s public policymaking and stakeholder recovery partnerships. Inspiration can be drawn from how partnerships have been forged during the implementation of other EU funding instruments.
Importantly, the European partnership principle, which requires close cooperation between public authorities, economic and social partners, and civil society at all levels, offers valuable lessons for Ukraine’s reconstruction throughout the programming cycle.
However, while some civil society participation mechanisms exist, they remain incomplete and ineffective. In short, significant improvements are needed at the national level. Bringing about meaningful change will require amplifying the voices of civil society organisations in decision-making processes and ensuring robust consultations at all levels.
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