Reform Index 266: Ukraine’s Integration into the EU Digital Market and Civil Service Pay Reform

“Law No. 4345-IX completes the core phase of aligning Ukrainian legislation with the European Union’s ‘Roam Like at Home’ (RLAH) roaming zone.

The law significantly strengthens the role and powers of the National Commission for the State Regulation of Electronic Communications, Radio Frequency Spectrum, and the Provision of Postal Services (NCEC). The NCEC is now equipped with instruments equivalent to those available to national regulators in EU member states under the European Electronic Communications Code. These include oversight of operators and enforcement of service access, monitoring of tariffs for regulated services, ensuring operator compliance with fair use policies, and more. Crucially, as the regulator’s powers expand, so too does the importance of ensuring its independence.

The European Commission has already issued a positive assessment of Ukraine’s legal framework. It proposed that the EU Council invite Ukraine to join the EU roaming zone starting January 1, 2026—a proposal the Council has since endorsed.

Implementing this legislation will impose substantial costs on Ukrainian mobile operators. They will need to invest heavily in upgrading their billing and IT systems to comply with RLAH requirements. Although the government, represented by the Ministry of Digital Transformation, has pledged to support operators, the primary financial burden will nonetheless fall on the private sector.

Joining the EU roaming network will allow Ukrainians to use their domestic mobile plans across EU countries without incurring additional charges. Likewise, EU citizens traveling in Ukraine will be able to use their home plans at no extra cost. This move will foster deeper integration into the EU digital market overall, as it will necessitate closer cooperation between Ukrainian and EU telecom operators.”

“In March 2025, the Verkhovna Rada of Ukraine passed Law No. 4282-IX ‘On Amendments to Certain Laws of Ukraine on Introducing Unified Approaches to Civil Service Remuneration Based on Job Classification.’ Adoption of this law in the first quarter of 2025 was one of the performance indicators under the Ukraine Facility Plan. However, the President did not sign it into law until June 2025.

The law contains several positive elements, including:

• A structured pay system, where the core component of remuneration consists of a clearly defined base salary, supplemented by bonuses for years of service and rank, while the variable part includes capped bonuses and compensation for access to state secrets.
• Preservation of the requirement to approve a unified Procedure for forming the payroll fund within public agencies—a norm introduced in the 2019 Civil Service Law but only recently implemented, and so far only formally, without real standardization. As a result, large amounts of budgetary funds—tens of billions of hryvnias annually—are allocated in a non-transparent manner and without uniform rules.
• An increase in the minimum base salary for local-level civil servants to no less than 2.5 times the subsistence minimum for non-disabled persons (up from the current 2 times).
• The stated intention to legally establish a mechanism for calculating and capping the number of civil servants.
• A mandate to compare remuneration levels for typical civil service positions with corresponding roles in the private sector.

However, the law is not without its shortcomings. First, the title of the law—which promises the introduction of unified approaches to civil service remuneration—does not correspond to its content, as it includes numerous exceptions and special provisions for certain public bodies. For example, a separate salary scale is defined for the State Audit Service and its regional branches, even though this provision was not part of the bill during its first reading. Similarly, the Apparatus of the Verkhovna Rada is granted its own salary scale and catalog of typical civil service positions. Separate pay rules are also introduced for bodies governed by special legislative acts (e.g., NABU, the Economic Security Bureau, the NACP). By legal status, these are central executive authorities, and their employees perform work as complex and responsible as that of staff in equivalent positions in other institutions—such as in legal support or international cooperation.

Moreover, all public bodies are divided into three groups with different base salary levels, but there are no transparent criteria for determining which body falls into which group. For example, the Court Security Service, Maritime Administration, and State Inspectorate for Architecture and Urban Planning are placed in the same category as ministries—even though their functions and levels of responsibility differ significantly. This can result in situations where a civil servant performing complex legal work earns less than someone with simpler duties, solely because they belong to different groups. The European Commission has also highlighted this issue.

Second, the mechanism for oversight of the job classification process is lost. The National Civil Service Agency (NCSA), which serves as the central executive body responsible for civil service, will no longer verify or approve job classifications in the Apparatus of the Verkhovna Rada, the Government Secretariat, the Office of the President, the Central Election Commission, the Constitutional Court, the Supreme Court, higher specialized courts, the High Council of Justice, the High Qualification Commission of Judges, the Office of the Prosecutor General, and others.

Another concern is a provision that allows the Cabinet of Ministers to unilaterally set additional adjustment coefficients for salaries across different public bodies during martial law and for six months after its conclusion. This grants the government excessive discretion in making such decisions and poses corruption risks in determining who receives which coefficients during this period.

So, despite the law’s positive aspects, it ultimately fails to establish genuinely unified approaches to civil service remuneration and does not ensure implementation of the European Commission’s recommendations.”