Cluster 2 opens the Internal Market: homework in nine chapters
Together with the decision to open Cluster 2, "Internal Market", the EU published its Common Position. This is the document in which the 27 Member States set out what exactly they expect from Ukraine in nine negotiating chapters and on what conditions each of them can be closed. Ukraine, for its part, accepted the whole of the EU acquis under this cluster as of 7 October 2026 and formally requested transitional periods in only two chapters: land and financial services.
If Cluster 1, "Fundamentals", is about how the state is organised, Cluster 2 is about how the economy is organised. These are the rules by which Ukrainian goods, services, companies, money and workers will move across the European market. And the reverse: by the same rules, European companies, workers and investors will come to the Ukrainian market. This second side is discussed less often in Ukraine, yet it appears in almost every chapter of the document.
The nine chapters in brief
Here is the substance, as I see it, with one interesting detail from each chapter.
1. Goods (Chapter 1)
So that a Ukrainian producer can sell a product in Poland or Germany without repeat testing, and the buyer can be sure the product is safe. The EU welcomes that Ukraine has functioning standardisation and accreditation bodies, recognises a high level in accreditation and conformity assessment, considers some technical regulations fully aligned (electromagnetic compatibility, tractors, textile labelling) and most partially aligned (toys, lifts, gas appliances, machinery, radio equipment), while the rules for fertilisers and construction products still have to be written. The weak spot is market surveillance, that is, those who check that what lies on the shelves is safe. It is to be "significantly reinforced" with people and money. The EU also expects a transition to the European CE marking in place of our conformity mark. It separately mentions the Agreement on Conformity Assessment and Acceptance of Industrial Products (ACAA, known in Ukraine as the "industrial visa-free regime") for low-voltage equipment, electromagnetic compatibility and machinery. Ukraine has been working on it for a long time, and it is what will open the EU market for these goods before accession.
An interesting detail. The EU asks Ukraine to check whether road signs and markings need to change so that the safety systems in cars certified under European rules can read them correctly.
2. Workers (Chapter 2)
The most candid chapter. The EU assesses the level of alignment as low and reminds us that from the day of accession EU citizens must have free access to the Ukrainian labour market and the same working conditions, social and tax advantages as Ukrainians. Ukraine has to set up a body to support workers from the EU, introduce the European classification of skills and occupations, ESCO, learn to coordinate social security (so that years of service earned in Ukraine and, say, in Poland count together) and keep fighting undeclared work. At the same time, the EU warns that the current Member States will need transitional measures to restrict temporarily the access of Ukrainian workers to their labour markets after accession. Those already living and working legally in the EU will not be affected. The decision will come later, after an impact assessment by the Commission.
An interesting detail. Restrictions on foreigners in Ukraine's public service must follow the case law of the Court of Justice of the EU. Only posts involving the exercise of public authority can be closed to EU citizens, not the whole public sector.
3. Services and professions (Chapter 3)
This is about a Ukrainian doctor, architect or lawyer who wants to work in the EU on the strength of their diploma, and about a company that wants to provide services across the border without unnecessary permits. Here we are still far from European rules. Ukraine has to compile and send the Commission a list of regulated professions with a justification for every restriction, bring minimum training requirements and the curricula themselves into line with European ones, review all legislation for barriers to business, and make the "points of single contact" for entrepreneurs accessible online from abroad. Nationality requirements for access to professions have to go, except where justified.
An interesting detail. The EU separately mentions the Lawyers' Directive. After accession, a lawyer from the EU will be able to practise permanently in Ukraine under their home-country title, and a Ukrainian lawyer in any EU country.
4. Capital (Chapter 4)
The most sensitive point: land. The EU writes plainly that the ban on EU citizens buying agricultural land is not in line with EU law and must be repealed. Ukraine has requested a transitional period for land, including forests. The answer: first provide detailed information. Who owns land today and how much of it is leased by foreigners, what the farm structure is, what the plans for privatising state land are, what the timetable for full liberalisation is, and for exactly how long Ukraine is asking for a deferral. Without this, the EU will not form a position. The same chapter covers payment services (SEPA, instant payments, caps on card fees) and anti-money laundering, where not only laws but results are required.
An interesting detail. From the day of accession, Ukraine must terminate all bilateral investment treaties with EU Member States, including their "sunset clauses", which usually preserve investor protection for years after termination. Inside the EU, investment is protected by EU law, not by bilateral treaties.
5. Company law (Chapter 6)
The rules for setting up companies, mergers and divisions, disclosure and audit. The EU notes a high level of alignment on single-member companies; the rest has to be completed. Ukraine has to connect to the European system of interconnection of business registers, so that data on a Ukrainian company can be checked from any EU country, align the rules for public companies (shareholder rights, takeovers, reporting) and show that audit oversight really covers all the state-owned enterprises it applies to. It is also advised to keep implementing the OECD principles of corporate governance.
An interesting detail. After accession, a Ukrainian company will be able to merge with a company from another EU country or move its registered office there without liquidation, and European company forms, such as the Societas Europaea, will be available for registration in Ukraine.
6. Intellectual property (Chapter 7)
The EU notes a long-standing dialogue and the existence of basic institutions, and welcomes the intention to join the Unitary Patent System. Next, Ukraine has to complete work on copyright, including the rules for the digital environment, accede to the Marrakesh Treaty on access to books for people with visual impairments, and prepare for the fact that from the day of accession all European trade marks and designs will automatically have effect in Ukraine. The main thing is more real enforcement: court cases, inspections and sanctions, plus training for judges and prosecutors.
An interesting detail. The EU mentions the new rules on geographical indications for craft and industrial products. In principle, Kosiv ceramics or Petrykivka painting could get the same protection as Murano glass. And one small thing from everyday life: the right to carry online subscriptions across borders, so that your streaming service works on holiday in another EU country just as it does at home.
7. Competition (Chapter 8)
There is good news: the EU calls the Antimonopoly Committee a well-established and operationally independent authority. But the requirements that follow are serious: guarantees of the independence, resources and powers of the AMCU, completion of alignment of antitrust rules, rules for state monopolies and companies with special rights, and, above all, fully restoring State aid control. Yes, "restoring". The conditions for closing the chapter include a track record of deterrent sanctions for infringements, prior notification of State aid measures and recovery of aid granted unlawfully.
An interesting detail. One of the missing directives gives companies and individuals harmed by a cartel the right to recover damages from its participants in court. Fighting cartels becomes a matter not only for the state but for the victims themselves.
8. Financial services (Chapter 9)
Banks, insurance, the capital market, mortgages, crypto-assets. Ukraine has requested two exceptions: not to extend banking requirements to credit unions, and three years after accession to raise the deposit guarantee gradually to EUR 100,000. The EU answers as it did on land: more data are needed on the size of the sector, the share of EU-owned subsidiary banks, the amount of additional contributions to the Deposit Guarantee Fund, the expected growth of deposits and the timetable. In insurance and the securities market alignment is low; in digital finance it does not yet exist. The condition for closure is to demonstrate the resilience and independence of the regulators.
An interesting detail. The EU singles out the fact that Ukraine has no European rules at all on bank recovery and resolution, that is, the procedure by which a failing bank is rescued or wound down at the expense of shareholders and creditors, not taxpayers.
9. Consumer and health protection (Chapter 28)
A telling fact here: the consumer rights law written to European rules has already been adopted, but will only take effect after martial law ends. Next, the EU expects rules on general product safety, connection to the Safety Gate system (rapid alerts on dangerous goods), collective redress for consumers, the right to repair and protection from "green" deception in advertising. In health: rules for medicines, medical devices and cosmetics, tobacco control and patients' rights. Ukraine plans to move fully to European rules for the registration of medicines by 2032 (by 2031 for veterinary medicines). Here too the EU first asks for an assessment: how many medicines registered in Ukraine have no authorisation in the EU, what will happen to Ukrainian pharmaceuticals, and how to make sure that medicines with a long shelf life registered under the old rules do not remain on the market after accession.
An interesting detail. After accession, a Ukrainian will be able to get treatment in another EU country, with the cost reimbursed by the Ukrainian system up to Ukrainian tariffs. And the reverse.
What matters most
First. In Cluster 1 the EU set interim benchmarks. In Cluster 2 it wrote the closing conditions for each of the nine chapters straight away. So from day one we know exactly what has to be shown for a chapter to be provisionally closed. And one thing recurs across all nine: not only adopted laws, but "administrative capacity with high standards of integrity" and a track record. For competition that means sanctions and recovered aid, for intellectual property court cases, for financial monitoring real results.
Second. To every request for a transitional period the EU gave the same answer: give us the figures. Land, credit unions, deposit guarantees, medicines. The EU reminds us that transitional measures are an exception, must be limited in time and scope, and must come with a plan with clear stages. The homework now includes not only draft laws but calculations.
Third. The rules are fixed as of 7 October 2026, but new EU legislation will appear before the negotiations are concluded, and it will have to be caught up with as well. The Conference will return to this cluster, and Ukraine is asked to report regularly in writing to the Association Council on implementation.
Fourth. The Common Position says what to do, but not when. So it will be interesting to see the roadmap for Ukraine, which the Commission has announced for the end of October together with the Enlargement Package: it should make clear what time horizon the Commission has in mind for all of this. And for the government it is a good opportunity, now with the text of the Common Position on the table, to go through the National Programme for the Adoption of the Acquis (NPAA) once more and, during its scheduled update at the end of the year, check priorities and deadlines against what is now written in the nine chapters.
The bottom line
Cluster 2 makes European integration tangible for everyone: a product sold without repeat testing, a diploma that is recognised, a deposit guaranteed up to EUR 100,000, treatment in another EU country paid for by your own system. But the document is also a reminder of the other side: European companies, workers and investors will get the same rights in Ukraine, and we have to be ready for that, politically too.
The main test is the same as in Cluster 1. Not whether we can adopt the laws, but whether the institutions, from market surveillance to the Antimonopoly Committee, can enforce them and show results.