bundle together reforms of democracy, rule of law and human rights. Two important caveats can be raised in relation to this approach. First, it could lead to a general underfunding of one of the three pillars if they are bundled together. As civil society organisations, independent media and oversight bodies often rely on EU funding as a safeguard against government pressure or cap­ture, this is particularly important. Secondly, it could also mean that governments could poten­tially gatekeep EU funding for independent over­sight bodies, civil society and free media, espe­cially when those governments are authoritari­an-leaning and do not want to fund critical voices and actors working to sustain checks and balanc­es to executive power. 20 Finally, the Ukraine Reserve Fund is set to pro­vide an additional€100 billion over 2028–2034, primarily targeting Ukraine’s accession, recon­struction and economic stability. While part of the Global Europe instrument, it has been taken out of the regular MFF budget line. Unlike previ­ous years, there are no democracy-specific ear­marks or spending markers within the Ukraine Reserve Fund. Instead, support for democracy will depend on priorities defined in action plans, government compliance and annual allocation, although this risks dilution among competing priorities(energy, security, reconstruction and so on). In view of the Ukrainian government’s crackdown on independent anti-corruption infra­structure and the general issues with the rule of law in the country(originating from before the Russian war of aggression), the lack of ring­fenced funding for democracy support is worri­some. 21 On a more positive note, the Ukraine Reserve Fund includes technical assistance not only to government authorities but also to civil society organisations at national, regional and local levels, although this technical assistance for civil society is contingent on the design and implementation of the relevant action plans. 9. The rule of law conditionality mechanism and governance reforms In the new MFF proposal, the rule of law condi­tionality mechanism is extended to include the entire EU budget. Member states will have to comply with the Charter of Fundamental Rights, gender equality and the rule of law. An ex ante horizontal condition will be fully integrated in the budget design of the new MFF before any funds are released, not just as a consequence of violations that may come to light subsequently. The Commission is therefore moving from a re­active to a more pro-active safeguarding of EU values. The linkage between the rule of law report, which now includes member state–specific rec­ommendations, and the release of funds under the NRPPs will reinforce the safeguards, as this means that there are clear guidelines to which the member states will have to adhere, and which will be benchmarks for the disbursement of EU funds. The Commission also clarified what will happen with the frozen funds:»They will be available for use in programmes in direct or indirect manage­ment, in particular those contributing to sup­porting Europe’s democracy, civil society, Union values or the fight against corruption.« 22 Hope­fully, this will help civil society, especially in countries affected by a shrinking civic space, to obtain sufficient funding from the EU to contin­ue their operations and defend democracy. In view, however, of the increased flexibility in the budget and the greater leverage for member states in the allocation of funding, especially within the NRPPs, the Commission will have to be particularly strict in monitoring and reviewing the use of funds. To this end, sufficient resources need to be allocated internally within Commis­20  Sam van der Staak(2025): Democracy assistance in the next MFF: a first impression, International IDEA(July). 21  Maria Alesina(ed.)(2023): Designed in Brussels, Made in Ukraine Future of EU-Ukraine Relations, European Liberal Forum. 22  European Commission(2025): A dynamic EU Budget for the priorities of the future – The Multiannual Financial Framework 2028–2034, Communication COM(2025) 570 final, 16 July. The rule of law conditionality mechanism and governance reforms 11