Bohdana Yefremova
Group Prime Services | Head of GPS Ukraine
Ukraine has made significant progress towards EU membership, particularly in harmonizing its financial services sector with EU standards. Despite the challenges posed by the ongoing war and the extensive legislative alignment required, the country is advancing through key reforms and regulatory roadmaps.
In its latest report within the 2025 Enlargement Package, released on 4 November 2025, the EU Commission recognized Ukraine for its remarkable resilience and steadfast commitment to its European aspirations, even amid the ongoing escalation of war.
Ukraine applied for EU membership on 28 February 2022, and the intergovernmental conference to initiate accession negotiations took place on 25 June 2024. The country has successfully completed the screening process and made significant strides in key reforms. Notably, Ukraine has adopted roadmaps addressing the rule of law, public administration, and the functioning of democratic institutions, along with an action plan for national minorities. As a result, the European Commission has confirmed that Ukraine is prepared to open the first, second, and sixth negotiating clusters.
The Ukrainian government's goal is to conclude accession negotiations by the end of 2028. While the Commission is committed to supporting this ambitious objective, it emphasizes that an acceleration of reforms is essential, particularly concerning foundational issues such as the rule of law. Consequently, the work ahead is tremendous. According to Ukrainian officials, implementing EU legislation involves harmonizing over 27,000 acts, with each ministry and agency receiving a specific “package” of regulatory acts that must align with EU standards and requirements.
In the area of financial services, relevant requirements fall under Chapter 9 of Cluster 2, which relates to the internal market. To advance harmonization in this sector, the National Securities and Stock Market Commission (NSSMC) approved a Roadmap and analysis titled “Regulatory Alignment of Capital Markets Legislation in View of Ukraine’s EU Accession” on 23 September 2025. This Roadmap, which can be accessed here, provides a comparative analysis of current Ukrainian legislation against European standards, identifies gaps, and outlines key areas for harmonization.
Key implementation areas include the regulation of investment services and investment firms, corporate governance and issuer transparency, the operation of stock exchanges, the development of collective investment and pension funds, and markets for derivative financial instruments and commodities, along with the protection of investor rights.
The report categorizes the legislative norms to be harmonized into four sections based on implementation priority:
As outlined in the report, immediate priorities for implementation include the UCITS and AIFMD directives, as well as the EuVECA, EuSEFs, ELTIFs, MiCA, and MAR regulations. These norms will be addressed through recently approved legislation — namely, laws on virtual assets and the regulation of capital markets and on organized commodity markets — although some additional regulations may be required to fully bridge existing gaps.
The next category encompasses the regulations on credit rating agencies, SFTR, prospectus regulation, and securitisation regulation, along with the directives IORP II, covered bonds directive, transparency directive, and the listing directive. While existing laws generally cover respective norms, their full implementation will necessitate the development and approval of some secondary acts. Therefore, these EU legal acts are expected to be implemented in the short term, by Q1 2026.
The directives SFD, FCD, the directive on investor-compensation schemes, BRRD, the directive on the prudential supervision of investment firms, MiFID II, and the regulations EMIR, CSDR, regulation on a framework for the recovery and resolution of central counterparties, the benchmark regulation, DLTR, MiFIR II, and IFR will be implemented in the medium term, with a deadline of Q1 2027, as they require creation of a secondary legal framework.
Lastly, the remaining directives — the financial conglomerates directive, CRD, together with the PRIIPs regulation, MMFs regulation, cross-border fund distribution regulation, and crowdfunding regulation — are designated for long-term implementation, with a target completion date of Q4 2027.
In summary, while Ukraine's path to EU membership is full of challenges, its strong commitment to reform and meeting EU standards is clear. However, to successfully integrate into the European Union, it is important to find a balance in regulatory frameworks. Many market experts have raised concerns about over-regulation in the local stock market, which can hinder innovation, reduce trading activity, and scare away foreign investors. Therefore, implementing the proposed roadmap and legislative priorities should not just focus on rules but also create a friendly environment for growth and investment. By tackling these regulatory issues, Ukraine can become a more attractive place for investors and make its integration into the EU smoother.
Group Prime Services | Head of GPS Ukraine