An Investor’s Stress Test: How NHSU Rules Are Driving European Companies Away

The EU designed the Ukraine Facility to make reform, EU accession, and the mobilization of private capital work as parts of a single system. Ukraine’s healthcare sector, however, is sending the opposite signal: a European investor can commit capital, build infrastructure, and help patients, only to find itself operating under different economic conditions from those applied to state-run providers – facing rules that can change without its knowledge after an investment decision has already been made.JOIN US ON TELEGRAMFollow our coverage of the war on the @Kyivpost_official. Synevo is part of the Swedish Medicover Group, whose shares are listed on the Stockholm Stock Exchange. So when we talk about the conditions under which Synevo operates in Ukraine, we are also talking about how the Ukrainian state treats one of its European investors. This is where the paradox begins. Through the Ukraine Facility, the EU is providing Ukraine with up to €50 billion ($56 billion) for 2024-27. One of the instrument’s explicitly stated objectives is to mobilize investment in Ukraine’s private sector. Its investment framework includes €9.6 billion ($11 billion) in guarantees and grants, and is designed to attract up to €40 billion ($45 billion) in public and private investment. Now put yourself in the position of a company considering investing in Ukrainian healthcare. It sees that the legal framework for the Programme of Medical Guarantees (PMG) provides for healthcare providers to be contracted regardless of their ownership structure. The National Health Service of Ukraine (NHSU) states the same principle on its contracting webpage. Other Topics of Interest Russia’s New Filin Missile Uses US, Chinese Electronics Ukrainian intelligence has detailed Russia’s new Filin cruise missile, identifying foreign electronics in a weapon with a claimed range of 1,200 kilometers. Yet in practice, in 2026, private providers face downward adjustment coefficients, restrictions on increasing contract values, barriers to entry for new participants and, in our case, a failure to recognize that work has even been performed, despite the tests having already been carried out and used by doctors and patients. (Photo courtesy of Synevo Ukraine) During the first nine months of 2026, approximately 700,000 tests performed by Synevo were not recognized. That represents more than 20% of the work completed. An independent economic study presented at the Chamber of Commerce and Industry by Liliia Tymoshchyk, head of the Office of Forensic Examinations, found that the criterion of a sharp increase in laboratory records, which can trigger the application of a 0.6 coefficient, is by no means specific to private laboratories. Depending on the growth threshold applied, ranging from 70% to 120%, between 94% and 96% of providers that exceeded those thresholds were state-owned or municipally owned. Meanwhile, according to figures presented at a roundtable by Serhii Dzis, a partner at SDM Partners law firm, the 0.6 coefficient was applied to 58.7% of private providers, compared with just 21.1% of state and municipal providers. In other words, a rule that is formally neutral can have an unequal economic impact. And when it comes to EU accession, the impact is what matters. We have no intention of exaggerating the issue or resorting to legal alarmism. Equal access for private and municipal laboratories to the PMG is not explicitly listed as a separate benchmark under Chapter 28 of the EU accession negotiations, which covers Consumer and Health Protection. But, European integration does not end with Chapter 28. There is also Chapter 8, covering Competition Policy. The Ukrainian government’s official materials describe its underlying principles clearly: an open market economy, free competition, clear and fair rules, and the prevention of state intervention that could distort competition. It is therefore entirely legitimate to raise this issue. In May 2026, the Association of Private Medical Institutions of Ukraine, together with Synevo, CSD LAB, and other healthcare providers, filed a complaint with the Antimonopoly Committee of Ukraine concerning Cabinet of Ministers Resolution No. 1808. Representatives of the private sector are also challenging the resolution in administrative court proceedings. Separately, we have approached the European Commission, which has responded twice, that the matter is being considered at the European level. The remarks made by Andreas Giallourakis of Business Sweden were particularly telling. He spoke from an investor’s perspective, emphasising transparency, predictability, long-term stability, and dialogue between regulators and the private sector before a policy comes into force. Investment decisions are not made for the short term. Any investor committing money, people, and effort to a market does so with the intention of operating there for years to come. Private hospitals are not asking for protection or preferential treatment. They want the same requirements, the same quality standards, the same accountability, and a fair opportunity to provide care. That is the position of Oscar Gaspar, President of the European Union of Private Hospitals (UEHP), which represents more than 6,000 healthcare facilities. UEHP has already raised the issue with Ukraine’s Deputy Prime Minister responsible for European and Euro-Atlantic integration. Next month, the association will also discuss the unequal treatment of healthcare providers separately with the European Commissioner responsible for health. There is another stakeholder whose interest should not be overlooked – the World Bank. It is financing the THRIVE project, which is specifically designed to improve the efficiency of public healthcare spending, prioritization within the PMG and the institutional capacity of the NHSU. The program is worth $1.2 billion, of which Ukraine has already received $449 million. In other words, the rules governing Ukraine’s public healthcare purchaser are already a matter of concern for international partners investing their own resources in the reform. I do not want the European Commission or the World Bank to “protect Synevo.” Nor are we asking for special rules for a Swedish investor. Quite the opposite: to us, the European approach means precisely that there should be no special rules. Ukraine is currently presenting the world with a compelling investment proposition: come now, help rebuild the country, benefit from European guarantees, and operate in a market that will one day be part of the EU. This proposition could be worth tens of billions of euros. But that proposition is undergoing a stress test right now – and not at investment forums. The test is being faced by a company that has already invested in Ukraine and secured its first contract with the state. It comes when the company has to find out whether the rules on which it based its investment decision will remain in place, or whether they will be changed after the money has already been committed. If these two versions of Ukraine – the one asking the world to invest and the one changing the rules after the investment has been made – look different, that is a risk not only for investors, but also for Ukraine’s European integration. The views expressed in this opinion article are the author’s and not necessarily those of Kyiv Post.