Ukrainian civil society is the main beneficiary and the driving force of Ukraine’s reconstruction. Ukraine Facility Regulation invites socio-economic partners and civil society to participate in the Ukraine Plan implementation assessment by sending the European Commission ‘opinions.’ However, there proves to be a limited space for influence. At the same time, the Ukraine Donor Platform will engage with Ukraine’s civil society four times a year at the Steering Committee and expert levels. However, given the profound importance of Ukraine’s reconstruction, political platforms should strengthen their role in ensuring legitimate decision-making. For 2025, the priority should be establishing detailed procedures for CSO (civil society organisation) ‘opinions,’ including clear submission timelines, follow-up processes, and improved communication about opportunities to influence the Ukraine Facility implementation and Ukraine Donor Platform.
Valeriya Izhyk, EU Policy Officer, Ukraine Reconstruction | 30 January 2025

The Ukraine Facility Regulation became the first European overarching document laying out the principles and requirements to provide predictable short-term macro-financial and medium-term financial support for Ukraine over 2024-2027. The Facility has a wide societal impact as it disburses 50 billion EUR to“address the social, economic and environmental consequences of Russia’s war of aggression, thereby contributing to the peaceful recovery, reconstruction, restoration and modernisation of the country and to the post-war recovery of Ukrainian society”, and particularly vulnerable groups created by the Russian full-scale invasion.
The Ukraine Donor Platform was established following a decision of G7 leaders taken on 12 December 2022. The platform’s mandate is to coordinate the support for Ukraine’s immediate financing needs and future economic recovery and reconstruction across different sources and established instruments for financing. Since its launch in January 2023, the Ukraine Donor Platform brought together Ukraine, the EU, G7 countries, IFIs, the Republic of Korea, the Netherlands, Norway, Sweden and 10 observers: Denmark, Estonia, Latvia, Lithuania, Poland, Spain, Belgium, Finland, Switzerland, and Luxembourg. It is another political platform for legitimate CSO engagement in Ukraine’s reconstruction, given that its aim is to direct resources coherently, transparently and inclusively.
Avenues for public participation within the Ukraine Facility
The Ukraine Facility operates similarly to other European Funds, such as the Recovery and Resilience Fund and European Fund for Sustainable Development Plus (EFSD+). As it aligns with Ukraine’s EU accession process, its implementation represents a strategic initiative with long-term implications. Given this significance, implementation should be comprehensive and include robust public consultation processes.
Since January 2023, CEE Bankwatch Network has organised informal meetings between the DG NEAR.E (Ukraine Service) and Ukrainian and International civil society. For 2 years, seven dialogues of this type were held. In the beginning, when the Ukraine Facility Regulation was still a draft, there was an expectation that this informal dialogue would transform into a formal one for both the EU’s and Ukraine’s civil society because co-design policies with the people affected by the rules and decisions arising from these policies are the backbone of evidence-based policy-making in the EU.
At the national level, the Ministry of Economy was involved in the development of the Ukraine Plan as part of the EU’s Ukraine Facility and continues coordinating the interagency working group on the plan’s implementation. The Ministry for Development (former restoration) is responsible for recovery and restoration; the State Recovery Agency and local self-government bodies are responsible for implementing the national recovery policy, with the State Recovery Agency overseeing reconstruction projects at the national level, acting as an agent for individual local governments that are unable to implement projects on their own fully.
The Ukraine Plan’s adherence to the regulations on meaningful stakeholder engagement is a reassuring sign of its commitment to transparency and inclusivity.
This is not only a wish of Ukrainian civil society; this is the best practice of evidence-based funding disbursement in the EU. It requires authorities to co-design projects with those affected by the projects and programmes. A monitoring committee is a body that oversees the implementation of a programme; in this context, it would be monitoring committees for the Ukraine Plan. The committee usually consists of socio-economic partners and representatives of Member State managing authorities, regional and local bodies, economic and social partners, and relevant civil society organisations.
‘Opinions’ as an instrument to influence the European Commission’s disbursements within Ukraine Facility
Civil society and other socio-economic partners were offered to submit their ‘opinions’ on Ukraine Plan implementation. In the General Principles (Article 4) of the Regulation, it is stated that: ‘the Commission shall ensure that civil society in Ukraine, including non-governmental organisations, can directly report any irregularities it may detect to the Commission via appropriate standing channels, as well as to send to the Commission opinions on the implementation of the Ukraine Plan and the evaluation of its measures by the Ukrainian government.’
So far, a few opinions have already been sent to the responsible DG NEAR.E. Among them – are appeals about the developed Concept note defining the scope of deviations from the Environmental Impact Assessment and Strategic Environmental Assessment submitted by Ukraine’s NGOs. However, it did not influence the concept of development either nationally or at the DG NEAR as there is no procedure on how these ‘opinions’ play out in the European Commission assessment for disbursement. They are ‘taken into consideration,’ as we heard from the desk officers, but no dedicated protocol was developed to follow up on them. As for now, CSOs who wish to submit opinions or reports are invited to send them to a dedicated Policy Officer and focal point for civil society engagement at DG NEAR until a more structured mechanism is implemented.
According to the latest updates, the mechanism will imply a dedicated website with an email address for sending ‘opinions.’ However, if it is only about a landing page with an email, it will not solve the problem of the European Commission’s accountability for the received inputs from CSOs. Why would an organisation dedicate its resources to developing a data-based analysis with recommendations without guaranteeing that it will be read and incorporated in the assessment report? The European Commission should develop specific guidelines on ‘opinions’ to ensure the Facility’s objective of ‘encouraging access to information and the participation of civil society in decision-making processes and public scrutiny’ (Article 3. Objectives of the Facility, part 2 (i)).
As to the Investment Framework, the investment part of the Ukraine Facility, and engagement on the programs that will be supported through it, the EU Commission expects civil society to exercise directly with the international financial institutions according to their information and safeguards policies.
Ukraine Donor Platform: baby steps to CSOs’ proper engagement
The Steering Committee for the Ukraine Donor Platform held its first engagement with civil society in April 2024 in Kyiv. The objective of this event was to bring together key stakeholders from a diverse range of civil society organisations, international partners, and international financial institutions to discuss the steps that could enable economic growth in Ukraine in a time of war and prolonged uncertainty. The discussion identified key enablers, including reforms carried out so far and envisaged in the near future (i.e. including those related to the Ukraine Plan); key challenges to economic growth and solutions to overcome them; and assistance needed the most from international partners, including to enhance Ukraine’s human capital capacities. The contact person in DG NEAR should be published on the website.
After that first dialogue, the Platform committed to regularly engaging with Ukraine’s civil society at both Steering Committee (two dialogues per year) and Experts levels (two additional dialogues per year). A second dialogue was organised at the experts’ level on 20 November 2024 with some civil society organisations invited by the Kyiv Secretariat of the Platform. The focus was on strategic perspectives towards a strong and sustainable economic recovery and a practical perspective to support the recovery and rebuilding of Ukraine at the regional level. It is hard to prove that the meeting was inclusive and representative.
The two iterations of civil society involvement in 2024 took place without a proper process for informing or selecting diverse groups of CSOs. Ukrainian civil society has been arguing for a wider representation of civil society organisations for this engagement and for dialogues to be focused on more specific topics to allow for deeper discussions. For a better CSO engagement, all the parties involved in the process should agree on the lines to take towards CSOs. Since the DG NEAR.E is steering the Secretariat for the Platform, any topics that civil society organisations believe should be prioritised by international donors can be shared with the Commission, which can suggest them for the agenda of the Ukraine Donor Platform. In 2025, a more structured, predictable and timely approach towards public participation in the Ukraine Facility Regulation/Ukraine Plan and Ukraine Donor Platform should be streamlined. The DG NEAR.E (Ukraine Service) and a Secretariat for the Ukraine Donor Platform, together with Ukrainian civil society organisations, can agree on the specifics and make sure they are transparently communicated to all the socio-economic partners.
Opportunities for civil society at the local level
All the reconstruction is local. Therefore, if one wants to understand how the reconstruction process is organised in a participatory way, one should look into local authorities’ real power within the process. Ukraine Facility manifests that ‘for the preparation and, where available, for the implementation of the Ukraine Plan, a summary of the consultation process, conducted in accordance with the national legal framework, of relevant stakeholders, including local and regional authorities, social partners and civil society organisations, and how the input of the stakeholders is reflected in the Ukraine Plan’ (Article 16, paragraph 2 (f)).
The increasing involvement of citizens in decision-making processes at the local level is enshrined in the Ukrainian Plan as part of the continuation of the decentralisation reform. Formally, ministries and regional state administrations are supposed to implement the Resolution of the Cabinet of Ministers of Ukraine, ‘On Public Participation,’ as amended on 27 June 2023. However, according to the National Agency for Corruption Prevention, in 2023, 30% of regulatory and legal acts didn’t go through public consultations. Alternatively, the law ‘On People’s Power and Local Self-Government’ (registration number 7283) allows citizens to engage in discussions about reconstruction at the local level. It also introduces procedures for public hearings, public evaluation of local authorities, and other tools. Finally, it enables 6.5 million IDPs (Internally Displaced Persons) to participate in decision-making in their resettlement communities.
Another progressive step, which will involve local authorities in reconstruction on the local level, is the law of Ukraine ‘On Democracy at the Local Level’ No. 3703-IX, which still requires the President’s signature. More than 160 public organisations appealed to the President of Ukraine with a request to sign the law. The law provides for the introduction of new opportunities for engaging residents in decision-making at the community level. Thus, they can participate in public consultations and public hearings and be involved in budget planning.
At the same time, there are still gaps in institutionalising the meaningful engagement and effective participation of citizens and civil society organisations in the national public policy-making and partnership of all interested stakeholders in Ukraine’s recovery. Inspiration can be taken from partnerships in the implementation of the EU Funds. Partnership implies close cooperation between public authorities, economic and social partners and bodies representing civil society at national, regional and local levels throughout the programming cycle, which consists of preparation, implementation, monitoring and evaluation.
Therefore, while some procedures and opportunities are in place, they remain incomplete and ineffective. There is significant potential for improvement at the national level. To foster meaningful change, it is imperative that we elevate the voices of Civil Society Organizations (CSOs) in decision-making processes and ensure robust consultations at both national and local levels.
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