Backing Ukraine above the 2028-2034 MFF ceiling poses political rather than financial risks

Brussels – One of the most striking features of the European Commission’s proposal for the 2028–2034 Multiannual Financial Framework (MFF) in the field of external relations is the decision to keep financial support for Ukraine outside the next EU budget. In technical terms, this places it “above the MFF ceiling”—an additional funding mechanism dedicated to Kyiv’s reconstruction and pre-accession assistance.

Under Article 6.2 of the new Global Europe Instrument—the €200-billion pillar for external action—€100 billion for Ukraine’s reconstruction and pre-accession process will be financed “in the form of loans” from the so-called ‘headroom’ of the MFF and implemented through the Global Europe Instrument, addressing “short-, medium- and long-term needs comprehensively,” including post-war reconstruction.

But does this approach risk undermining the predictability of EU support? “I would see the danger lying more in internal divisions among the member states than in the way the support is financed,” observes Amandine Sabourin, policy analyst at the European Centre for Development Policy Management (ECDPM), commenting on the Commission’s proposal in an interview with The New Union Post. While the proposed solution mirrors the mechanism the EU is currently using and raises no concerns over accountability, “the greater risk is political on discussions around Ukraine’s accession,” she notes.

At present, under the Regulation of the Ukraine Facility, implementing powers are “exceptionally conferred” to an ad hoc working party at Council level (AHWP RESUA). Unlike in the area of EU accession, “no serious deadlock has so far occurred regarding implementing decisions on macro-financial assistance,” Sabourin notes. Yet this does not mean that this policy could not also be threatened by veto stalemates. However, the Commission could have found a way out. According to the 2028–2034 MFF proposal, “the Council does not have to approve implementing decisions anymore, as the Ukraine Reserve is fully integrated into the Global Europe Instrument, and the same procedure—comitology—applies again.”

“Comitology” refers to the procedure by which the Commission adopts implementing decisions— for example, on the allocation of external funding—with the assistance of committees composed of representatives from EU Member States, though outside the formal Council set-up. Sticking to the usual procedure for external funding, “political discussions may remain, but even for Ukraine it becomes a technical allocation,” Sabourin stresses. At the same time, she reminds that—as this is only the Commission’s proposal—”nobody knows what will come out” of the negotiations, particularly given the presence of countries “less enthusiastic” about it, such as Orbán’s Hungary.

Alongside continuing the current form of assistance, her colleague Mariella Di Ciommo, a senior policy analyst at ECDPM, emphasises that another reason for placing Ukraine above the MMF ceiling is the sheer scale and unpredictability of the resources it requires. Were these funds included in the next EU budget, “either the MFF would become excessively large and immediately attract the attention of Member States, or too few resources would remain for anything else,” she explains. In this sense, the decision was also shaped by financial considerations of “what the EU budget can sustain.”

Flexibility, predictability, and adaptability in the next EU budget

Regarding the 2028–2034 MFF proposal, Di Ciommo describes it as “quite ambitious,” with €215 billion allocated to the external action pillar of the overall €1.9 trillion budget. According to ECDPM’s calculations, this represents an increase of around 75% compared to current external action funds. However, she warns that “the proposal still has to survive the negotiations,” and based on past experience, the likelihood of cuts “is very high.” For instance, the 2021–2027 MFF initially proposed a 12% real-term increase in external funds, but these were ultimately cut by 10%. “Future negotiations will be quite tough,” she adds.

Not only do the allocated funds have to pass through negotiations, but so does the new structure itself. A simpler and more flexible framework—”with the idea of giving the EU as a whole more capacity to respond to a very unstable and complex international environment”—has been realised in a single instrument that merges development and foreign policy (essentially the NDICI—Global Europe) with the pre-accession and humanitarian assistance, while retaining some of their specificities.

However, experts warn that this approach could create tensions between different EU policy areas, especially considering the shift from thematic to geographic pillars. The main concern relates particularly to humanitarian assistance: “How do you make sure that the humanitarian principles will be preserved?” asks Di Ciommo, pointing not only to how the regulation is drafted, but also to the political dynamics that shape its implementation. According to Article 14, programming would be driven by “mutual interests and shared priorities” rather than development concerns. While awaiting the guidelines, “it remains to be see how this alignment will work in practice.”

Another area of risk lies in the consequences of a more adaptable approach to programming. Under Article 17, multiannual indicative programmes can be reviewed “as necessary for effective implementation” if some degree of “urgency” justifies such flexibility. Legitimate questions arise about how partner countries will be involved, not only at the outset, but also throughout the implementation process and any subsequent review. Di Ciommo stresses that “predictability, historically one of the advantages brought by EU financing, is somewhat lost in this context of adaptability,” affecting not only responses to specific situations or global dynamics, but also “how the EU understands competitiveness, migration, and security issues.”

As noted, all discussions must take into account that negotiations between the Parliament and the Council could change any part of this Commission’s proposal, including its core pillars. Regarding Ukraine, “the first discussion will start progressively in 2026, based on the findings of the evaluation of the current Ukraine Facility,” anticipates ECDPM policy analyst Sabourin. With “a general understanding that this is a matter of survival for Europe,” negotiations on supporting Ukraine may focus on increasing grants, as “the debt burden on Ukraine’s shoulders is already very high.” And while considering how to compensate for the withdrawal of the US, “it should not be forgotten that they provided mostly grants,” Sabourin concludes.