A Two-Way Test for Ukraine’s EU Accession

The European Commission’s 2026 Enlargement Package sets a high bar.
November 09, 2026

One month after the European Commission set out a new policy in “Preparing for a Wider Union”, Enlargement Commissioner Marta Kos presented the 2026 Enlargement Package to the European Parliament. The November 4 report brings good news for Ukraine: Four of six clusters are now open, and the Commission has greenlighted the opening of the remaining two by the end of 2026. “Ukraine is a country at war, and it is delivering,” Kos stated.

That said, the analysis of Ukraine’s progress in the Enlargement Package goes beyond legal frameworks and technical readiness. The first message concerns the methodology of enlargement itself. For the first time, the Commission raises the question of how to make the process more predictable and beneficial for both sides, and the current solution is gradual integration. In addition to the report, the Commission published accession roadmaps that set a clear agenda for Kyiv. The Commission’s estimate that seven negotiating chapters could be closed in 2027 is ambitious. Since this is tied to meeting all interim benchmarks, it will require Kyiv to significantly accelerate reforms to reach its objective of closing all chapters by the end of 2028.

The second message has to do with security, which the report examines in detail. Enlargement is now seen as an investment in European defense capabilities, and although Ukraine still relies on external support, it already contributes a great deal through its defense industry, battle-tested innovations in drones and electronic warfare, cyber capabilities, and long experience countering hybrid threats. According to the report, Ukraine’s ties with the European Defense Technological and Industrial Base (EDTIB) need strengthening under the terms of the 2024 EU-Ukraine Joint Security Commitments.

The third message prominently featured in the report relates to corruption. Last year’s assessment showed that Ukraine’s specialized anti-corruption institutions—the National Anti-Corruption Bureau (NABU), the Specialized Anti-Corruption Prosecutor’s Office (SAPO) and the High Anti-Corruption Court—can function even during the wartime. The Commission recognized the significance of this work, including investigations, prosecutions, and convictions of current high-ranking officials. Operation “Midas” uncovered an alleged corruption and money-laundering scheme in the energy sector, demonstrating that state institutions can still deliver results under pressure. 

These positive steps also expose a political mismatch between Brussels and Kyiv. In the European Council, some member states continue to raise the possibility of decoupling Moldova’s and Ukraine’s accession journeys. The view of Moldova as farther along in the accession process should serve as a wake-up call for Kyiv to show the political readiness to proceed with the necessary reforms over the next six months. 

Under EU law, every accession milestone requires the absolute consensus of all 27 member states. Hungary’s latest block on Ukraine’s accession talks shows that the EU needs a different approach to enlargement. One member state should not be able to hold back a candidate for political reasons. If the enlargement process is merit-based, the principle must work both ways: Candidates that deliver should advance on their EU path. Sustaining public support for enlargement will also require EU capitals to make the case for it at home, explaining to their citizens the benefits it brings to them, too. 

The report, meanwhile, highlighted that in Kyiv, legislation is not keeping pace with the accession timeline. Even with NABU and SAPO delivering on their promises, the Verkhovna Rada did not pass significant new laws strengthening the anti-corruption framework during the reporting period. The ten priority reforms of the Kachka-Kos Plan, set out in December 2025, remain mostly incomplete, and the 2026–2030 anti-corruption strategy is still waiting for parliamentary approval. Anti-corruption agencies continue to report pressure from state and security agencies. The number of judges keeps falling, from 4,346 at the end of 2025 to 4,198 in August 2026. Ukraine’s continued progress during Russia’s full-scale war is widely acknowledged, but accession remains merit-based and no concessions will be made. The joint Commission-Ukraine Task Force will now serve as a timely instrument for streamlining coordination between Ukrainian and EU officials, initiating reform implementation and ensuring that Ukraine meets the EU’s interim benchmarks before their next assessment in the first half of 2027.

Kyiv’s homework includes safeguarding the autonomy of NABU and SAPO, for example by allowing the investigation of members of parliament without the prosecutor general’s approval; expanding NABU’s jurisdiction and ensuring access to independent forensic experts; operationalizing NABU’s independent wiretapping capacity; and passing a law to protect investigators from external interference. Kyiv must also fill the posts of SAPO head and deputy head as soon as possible. This will be an important indicator not only that Ukraine’s anti-corruption institutions can operate effectively in wartime, but also that the Verkhovna Rada is willing to back them with the necessary legislation establishing that no one is above the law.

The 2026 Enlargement package rightly sets a high bar. Ukraine must turn its institutional resilience into legislation to sustain its reform drive. EU member states, for their part, should not let their internal political interests outweigh candidate states’ merit. If Ukraine can implement anti-corruption reforms while at war, the EU has no grounds for holding up enlargement.

This publication was prepared with the support of the program “Strengthening Ukraine’s EU Alignment in the Rule of Law” (3*E4U), which is implemented by GIZ on behalf of the German Federal Foreign Office and the EU. It does not necessarily reflect the official position of the EU or its partners. 

The views expressed herein are those solely of the author(s). GMF as an institution does not take positions.