From 2025 to 2026: PPP/Infrastructure in Ukraine

CEELM: How would you describe the current infrastructure and PPP environment in Ukraine?

Bondarchuk: From what we see across mandates advising both sponsors and contracting authorities, infrastructure activity in Ukraine is gradually returning, but in a far more selective and disciplined form than before the war. The market has moved away from ambitious, volume-driven launches toward a preparation-led approach, where project maturity and bankability determine whether a project moves forward at all.

The 2025 PPP reform package has undoubtedly improved the legal framework. Procedures are clearer, timelines are more realistic, and the rules are better aligned with the realities of reconstruction. That said, legislation is no longer the main constraint. In practice, outcomes depend less on formal reform and more on how consistently the framework is applied, particularly at the level of feasibility, procurement planning, and risk allocation.

We also see a noticeable change in approach on the public side. Authorities are increasingly cautious about launching tenders prematurely and are more focused on building pipelines that can actually attract financing. This reflects a broader shift in mindset. Investor confidence today is driven by execution quality, not by policy declarations.

Activity is therefore picking up, but at a controlled pace. Security risks, fiscal constraints, and institutional capacity still shape what is realistically deliverable. That pacing is not necessarily negative. In our view, the market is becoming more credible, even if it is moving more slowly.

CEELM: What types of projects or sectors are generating the most interest right now, and why?

Bondarchuk: We increasingly advise on projects in logistics and transport connectivity, energy resilience, and municipal infrastructure, which together form the core of current investor interest.

Logistics projects, including ports, rail links, and export corridors, remain central. They deliver immediate economic impact, support trade continuity, and align closely with EU integration priorities. These assets are also familiar to international sponsors, which makes them more suitable for concession or PPP delivery when the preparation is sound.

Energy infrastructure is another area of sustained focus. Projects aimed at strengthening energy security, such as grids, distributed generation, and critical energy assets, benefit from both strategic urgency and strong IFI engagement. In practice, these projects progress fastest where revenue mechanisms are clearly defined, whether through offtake arrangements, regulated tariffs, or availability-style payments.

Municipal and utility infrastructure is also gaining momentum. We see growing interest where water, heating, waste, or social infrastructure projects can be standardized, bundled, and supported by blended finance. This combination makes projects more scalable and reduces transaction risk for sponsors and lenders.

Across all sectors, interest is highly selective. Projects attract attention not because of their strategic label, but because they combine clear demand, credible revenue models, and some form of public or donor-backed risk mitigation.

CEELM: From a practical standpoint, what are the key hurdles in getting projects off the ground?

Bondarchuk: In our experience, the main hurdles are execution-related rather than driven by lack of capital or interest.

Bankability remains the first and most decisive issue. Sponsors and lenders need predictable cash flows and realistic risk allocation. Projects often stall where revenue models are unclear, state support mechanisms are underdeveloped, or financial assumptions are overly optimistic. As a result, we increasingly advise clients to focus on availability-based structures, phased delivery, and conservative modelling from the outset.

Risk management, particularly in relation to security and political risk, remains a central challenge. The availability of guarantees and insurance instruments has improved materially compared to earlier stages of the war, but these tools must be properly integrated into the overall project structure. IFI participation continues to be a key stabilizing factor in this regard.

Another recurring issue is insufficient project preparation. Delays are frequently caused by incomplete feasibility studies, unresolved land or permitting matters, or gaps in technical data. Both sponsors and authorities are responding by placing much greater emphasis on front-loaded preparation, often supported by dedicated project preparation facilities.

Finally, institutional coordination and procurement capacity remain uneven. Complex PPP processes require experience and continuity, which are not always available. Where authorities invest in early market engagement and realistic procurement strategies, results tend to improve significantly.

CEELM: Looking ahead, which developments are likely to shape infrastructure and PPP activity over the next year?

Bondarchuk: Over the next year, progress will be shaped less by new policy announcements and more by delivery.

The most important test will be whether the reformed PPP framework produces a limited number of well-prepared, lender-friendly transactions. Even a small pipeline of credible deals would have a strong signalling effect for the wider market.

Project preparation funding will also be critical. Projects that secure early-stage technical, legal, and financial structuring support are likely to move first. Underprepared projects, by contrast, will continue to struggle regardless of strategic importance.

We also expect continued alignment with EU and IFI standards to play a significant role. This is steadily reshaping how infrastructure projects are structured and procured in Ukraine, increasing predictability for international investors despite the challenging environment.

Overall, momentum is building, but scaling will depend on execution quality rather than reform volume. The next phase is likely to be defined by fewer projects, delivered better, and those projects will set the benchmark for the broader reconstruction effort.

Ivan Bondarchuk, Partner, Head of Energy&Projects, exclusively for CEE Legal Matters