Nearly all reviewed countries have adopted national anti-corruption strategies and increased their engagement with civil society in the development and monitoring of these policy documents. However, only a few countries apply a risk-based approach to setting priorities. Although the use of diverse data sources is growing, reliance on business, employee, and household surveys remains low. Strategies primarily focus on prevention, awareness, and education, while law enforcement measures and objectives are less prominent. Stakeholder consultations in policy drafting are common, yet their inclusiveness requires improvement. Regular monitoring of anti-corruption policy implementation is widely practised, but only half of the countries use outcome-based indicators in their monitoring reports. A significant gap persists between policy design and effective implementation, too. The evaluation of the impact and effectiveness of implemented measures to inform the next policy document is still not a common practice.
Anti-Corruption Trends in Eastern Europe and Central Asia
Abstract
This chapter assesses the anti-corruption strategic frameworks of 21 ACN countries using Key Performance Indicators (KPIs) grouped into four areas: evidence-based problem analysis and diagnostic tools, inclusiveness and transparency of intergovernmental and public consultations, implementation rate, coordination, monitoring and evaluation. Of 24 ACN countries, 21 had adopted national anti-corruption strategies by mid-2024. Kosovo was in the process of finalising its draft Anti-Corruption Strategy in 2024.1 Seventeen countries had developed related action plans (see Annex C).
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024); Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
A key element for developing a quality anti-corruption strategy that addresses the country’s corruption challenges is a risk-based approach (OECD, 2017[15]). Such approach implies identifying sectors vulnerable to corruption, pinpointing specific risks and their roots, while using solid evidence to inform strategic objectives and setting realistic measures to mitigate identified risks (UNODC, 2015[16]). There is a growing commitment to evidence-based policymaking among ACN countries, as reflected in efforts to broaden data sources and enhance data quality. However, only a limited number of ACN countries applied a risk-based approach when setting strategic objectives and priorities in their policy documents (Figure 1.2).
Notes: OECD PII data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024); Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
KPI 1 focuses on the existence of an inter-institutional body2 tasked to prepare an analytical report on public integrity risks. Analytical reports should formulate recommendations and identify priorities for the public integrity system, forming a basis for national policy documents (OECD, 2017[15]).
While many countries conducted a robust analysis during the strategy development phase (see KPI 2), only North Macedonia and Serbia developed comprehensive analytical reports on broader public integrity risks. In the case of North Macedonia, the report was prepared using the Sectoral Integrity and Corruption Risk Assessment Methodology in close collaboration with various government bodies. This document allowed North Macedonia to understand corruption risks across different governmental sectors better, providing a solid foundation for crafting a targeted anti-corruption strategy (Box 1.1). Serbia also conducted a comprehensive risk analysis in 12 priority areas, based on the Methodology for Corruption Risk Assessment, which later informed its National Strategy for the Fight against Corruption.
Prior to developing the National Strategy for Prevention of Corruption and Conflict of Interest 2021-2025, the State Commission for Prevention of Corruption of North Macedonia undertook a comprehensive analysis of public integrity risks (2020[17]). The assessment aimed to analyse risk factors across the public integrity system, identify sectors with the highest corruption risks, and define strategic priorities for a new anti-corruption policy document. The analysis was built on the Sectoral Integrity and Corruption Risk Assessment Methodology. The scope of the assessment was two-fold: (i) an analysis of risks by “horizontal processes” that extend throughout the whole public sector, such as public procurement, public sector employment, inspections, issuing permits and licences, and (ii) sector-specific analysis (e.g., judiciary, police, public health, education, transport, economy, environmental protection). The report included an analysis of each selected area with a description of the following types of risk factors: (i) systemic or external, (ii) institutional or organisational, (iii) human, and (iv) factors related to operational processes. The report also provided information about the common forms of corruption and risks in the selected areas, their impact, a general risk rating (high, medium, low), and a level of urgency for addressing the threat of corruption. The drafting process led by the State Commission for Prevention of Corruption was conducted through the Working Group, comprised of representatives from state bodies, civil society organisations, the private sector, and the media.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; State Commission for Prevention of Corruption of North Macedonia (2020[17]), National Strategy for Prevention of Corruption and Conflict of Interest 2021-2025, https://dksk.mk/wp-content/uploads/2021/09/NACS-2021_25-and-Action-Plan-EN-final.pdf.
KPI 2 assesses the extent to which an anti-corruption strategy is based on a comprehensive assessment of public integrity risks. This indicator emphasises the importance of a thorough analysis, including the identification of relevant integrity breaches, pinpointing actors likely to be involved, and determining the expected likelihood of risk materialising and its potential impact. Thus, a strategy that is based on a robust risk analysis typically provides a description of high-risk sectors, insights into the nature of these risks, their roots, and obstacles to implementing anti-corruption measures.
Only a few countries have applied a risk-based approach to setting anti-corruption strategic objectives and priorities. Specifically, Estonia, Lithuania, North Macedonia, and Ukraine incorporated risk-based perspectives into their anti-corruption policy documents to varying extents. Most of these documents provide a comprehensive account of the country's experience in combating corruption, explain the rationale behind selecting specific priority areas, and describe corruption risks, their potential root causes, and possible impact (Box 1.2). The increasing quality of problem analysis among some of the assessed countries represents a significant step forward in developing impactful anti-corruption strategies. However, most countries have not yet fully adopted a risk-based approach, indicating the need for improvement in this area.
A quality anti-corruption policy depends on robust and diverse data. KPI 3 requires using at least four out of the following eight data sources: (i) indicators from international organisations or research institutions, (ii) employee surveys, (iii) household surveys, (iv) business surveys, (v) other survey data, such as user surveys, or polls from local research institutions, (vi) data from public registries, (vii) published research documents from national or international organisations or academia and (viii) commissioned research. In this context, the anti-corruption strategies of 13 countries explicitly reference a minimum of four sources of information. This suggests a growing recognition of the value of evidence-based policymaking in the fight against corruption among the ACN countries. Moving forward, countries should strive to incorporate a broader range of data and further enhance the quality of data to improve the effectiveness of their anti‑corruption efforts (Figure 1.3).
Notes: OECD PII data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD ACN (2024); Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
The measures of Lithuania’s National Anti-Corruption Programme were specifically designed to address the transparency and corruption concerns identified in surveys and analyses (2015[18]). For example, the following assessments revealed challenges in the Lithuanian judicial system: (i) the Map of Corruption indicated a negative anticorruption perception of the courts; (ii) Special Investigation Service (STT) monitoring showed the absence of a unified anti-corruption action plan in the judiciary, and (iii) STT's corruption risk analysis also highlighted a lack of transparency in the case allocation system. As a result, to improve the integrity and efficiency of the Lithuanian judicial system, the targeted measures were incorporated into its National Anti-Corruption Programme, among them: (i) implementation of the Sectoral Plan for the Prevention of Corruption in the Lithuanian Judicial System; (ii) modernisation of the information systems managed by courts; (iii) analysis of legal regulation and practical application of the institute of recusal; and (iv) development of a concept for the organisation and scheduling of court hearings.
Another example concerned STT’s anti-corruption intelligence results in the policymaking process. In particular, an analytical anti-corruption intelligence operation revealed significant corruption risks in the healthcare sector's public procurement processes. The analysis showed that large hospitals awarded the majority of contracts (over 70% of the total value of public procurement contracts) to a small number of contractors, often linked to sponsorship arrangements. The STT also uncovered indirect links between contracting authorities and contractors, as well as linkages through subsidiaries. As a result, legislative changes were initiated to enhance transparency and strengthen the accountability and control framework in the sponsorship mechanism.
Source: OECD ACN 2024, Regional Anti-Corruption Trends questionnaire responses, also additional information was provided at the Regional Dialogue Session organised within the ACN Steering Group Meeting on 19 September 2024; Seimas of the Republic of Lithuania (2015[18]), Resolution on the Approval of the National Anti-corruption Programme of the Republic of Lithuania for 2015-2025, https://e-seimas.lrs.lt/portal/legalAct/lt/TAD/e42b7360100211e5b0d3e1beb7dd5516?jfwid=-fxdp8swm.
The use of international indices, such as Transparency International’s Corruption Perceptions Index, Corruption Perception Barometer, and the World Bank’s Worldwide Governance Indicators, is a common trend in anti-corruption strategies. Most countries drew on published research documents produced by national and international organisations, as well as administrative data from law enforcement agencies and national statistics offices. Several countries also employed sectoral risk assessments, which contributed to their data pool. However, the use of business, employee, and household surveys, which provide valuable insights into corruption risks from the perspective of specific groups, has been less common in the region. Nine countries (Armenia, Croatia, Estonia, Latvia, Lithuania, Montenegro, Romania, Serbia, and Ukraine) have incorporated insights from at least one survey into their strategy (Box 1.3).
Croatia: The Ministry of Justice and Administration of Croatia utilised insights from both international and domestic data sources. Indices such as the Eurobarometer and Transparency International are complemented with a tailored online survey to assess perceptions of corruption and experiences among Croatian citizens. For example, key findings of the domestic surveys revealed that sectors with the highest reported incidence of corruption were healthcare, self-governance, entrepreneurship-related activities, and the judiciary. These results play a role in prioritising high-risk areas and developing targeted anti-corruption interventions. Besides, the survey data served a dual purpose in the Strategy for Prevention of Corruption 2021-2030; namely, it was used to establish the baseline data and provided result-level indicators to measure progress (2021[19]).
Lithuania: Lithuania’s National Anti-Corruption Agenda 2022-2033 incorporated findings from several sociological surveys focused on corruption within the country (2022[20]). In addition to external surveys that informed the policy document, the authorities also leveraged data from the Lithuanian Map of Corruption (2023[21]). Launched by the Special Investigation Service, it focuses on assessing the attitudes of target groups towards corruption and their anti-corruption potential, measuring the prevalence of corruption across various institutions, analysing respondents' experiences with corruption, and their perceptions of decision-making transparency in Lithuania. The 2022-2023 edition expanded its scope to include perceptions of the public image of specialised anti-corruption body, public procurement processes, municipal institutions, asset confiscation practices, and levels of trust in state institutions. The survey covered 1 001 Lithuanian residents, 500 business company managers, and 740 civil servants.
Mongolia: The Independent Authority Against Corruption of Mongolia (IAAC) plays an important role in assessing and monitoring corruption in the country as mandated by the Anti-Corruption Law. Its responsibilities include conducting bi-annual surveys on corruption’s scope, forms, and causes, including among individuals receiving public service, as well as establishing a corruption index (Independent Authority Against Corruption of Mongolia[22]). The used research and perception-based surveys included: (i) “Current situation of corruption” which illustrates corruption trends and attitudes incorporating data from both domestic and international surveys; (ii) “Integrity Assessment” survey that assesses the perception of integrity across three key groups (citizens, civil servants, and academia) towards ministries, agencies, and provincial Governors’ Offices, and (iii) “Corruption perception in political and law enforcement organisations” that specifically targets corruption perception of political parties and law enforcement institutions.
Source: OECD ACN 2024, Regional Anti-Corruption Trends questionnaire responses; Parliament of Croatia (2021[19]), Strategy for Prevention of Corruption 2021-2030, https://narodne-novine.nn.hr/clanci/sluzbeni/2021_11_120_2069.html; Seimas of the Republic of Lithuania (2022[20]), National Anti-Corruption Agenda 2022-2033, https://www.stt.lt/data/public/uploads/2022/08/stt_darbotvarke_en.pdf; Special Investigation Service of Lithuania (2023[21]), Map of Corruption in Lithuania 2022/2023, https://www.stt.lt/en/news/7481/_2023/map-of-corruption-in-lithuania-2022-2023-public-anti-corruption-stance-is-strengthening-though-the-willingness-to-report-cases-of-corruption-remains-a-challenge:3609; Independent Authority Against Corruption of Mongolia.
Reviewed anti-corruption strategies revealed several common priorities across ACN countries. Prevention of corruption emerges as the most prevalent focus featured in 91% of the strategies. Awareness and education initiatives aimed at fostering a culture of integrity are also widely included, referenced in 82% of anti-corruption policy documents. Strengthening the detection and prosecution of corruption offences as a strategic objective is less common, featured only in 61% of reviewed strategies. Frequently addressed areas include strengthening public servants' integrity, asset and interest disclosures, access to information, anti-corruption awareness raising, whistleblower protection, procurement and public finance management, judiciary, business sector, state-owned enterprises, and political party funding. Several strategies include sectors such as infrastructure and construction (Latvia, North Macedonia, Ukraine), sports (Croatia, Estonia, Latvia, North Macedonia), tax and customs (Armenia, Croatia, Serbia, Montenegro, Tajikistan, Ukraine), cultural heritage (Romania) and environmental protection (Croatia, Estonia, North Macedonia, Mongolia, and Romania).
While acknowledging the vital role of civil society in exposing corruption, some countries have incorporated specific objectives for enhancing cooperation with civil society organisations. For example, in its anti‑corruption policy document, North Macedonia outlines several measures to improve the criteria for granting state aid to media and increase transparency of civil society financing. Croatia's Anti-Corruption Strategy focuses on financing non-profit media, improving the normative framework, and increasing transparency of media ownership. Additionally, at least eight countries - Albania, Bosnia and Herzegovina, Croatia, Kazakhstan, Lithuania, Moldova, Montenegro, and Serbia - have defined detailed measures to increase accessibility to data.
The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Anti-Bribery Convention) and related measures are included in the strategies of the Working Group on Bribery members, such as Bulgaria, Croatia, Latvia, Lithuania, and Romania. Two ACN countries (Kazakhstan and Uzbekistan) included measures aimed at acceding to the OECD Anti-Bribery Convention. Albania, Azerbaijan, and Bulgaria used international organisations’ reports (e.g., OECD, UNODC) as sources for their strategies. Notably, Bosnia and Herzegovina included joining the IAP peer review as one of its strategic objectives.
Two countries have incorporated a gender perspective in their anti-corruption policy documents, demonstrating some level of awareness of the intersection between gender and corruption. For example, Latvia has taken a proactive approach by including a measure to analyse the potential relationship between gender and corrupt practices within the country, drawing from international experience. Bosnia and Herzegovina’s National Strategy for the Fight against Corruption not only underlines the importance of gender considerations but also requires responsible government agencies to use gender-sensitive language in their communication, classify statistical data by gender, prepare analysis on gender-specific manifestations of corruption, and implement regular educational activities on the gender dimension of corruption. The limited adoption of gender-sensitive anti-corruption measures suggests an area for additional consideration in future policy development.
Involving a wider group of stakeholders in the development of public policies promotes government accountability and improves the evidence base for policymaking (OECD, 2017[23]). Besides, a consultative, transparent, and inclusive strategy development process aims to increase its quality (UNODC, 2012[24]). Engaging governmental and non-governmental stakeholders in consultation is now recognised as an essential step in policy development. Thus, many countries in the region have made notable progress in improving governmental and public consultations in the development of anti-corruption policies. While some of these steps involve utilising various communication tools and publishing draft strategies online, additional efforts are necessary to effectively respond to received feedback and ensure more diverse and inclusive public consultations (Figure 1.4).
Notes: OECD PII data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024); Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
A legal framework defining the minimum conditions for public and intergovernmental consultations (KPI 4) plays a crucial role in creating an environment that enables the engagement of key stakeholders. In this context, a general legal requirement to conduct inter-governmental consultations on anti-corruption policy documents is foreseen by primary or secondary legislation of 16 countries, with a minimum duration of two weeks in 12 countries. On the other hand, the requirement to conduct public consultations is provided in the legislation of 18 countries, of which 15 countries established a minimum duration of two weeks. Two countries (Azerbaijan and Kazakhstan) have a shorter public consultation period of ten or fewer days.
The general legal framework for public consultations varies across the countries covered in this report. In addition to the requirement to hold public consultations, some jurisdictions have detailed provisions, for example, on the required types of consultations, their format and possible channels of communication, an explicit obligation to publish drafts online, provide public feedback to the received input or publish received comments (e.g., Albania, Armenia, Bosnia and Herzegovina, Croatia, Kosovo, Latvia, Moldova, and Ukraine). For example, Latvia’s Regulation on Procedures for Public Participation in the Development Planning Process establishes a mandatory minimum 30-day requirement for public consultation on policy planning documents (and at least 14 days for primary legal acts). It also obliges each state agency to publish on the Unified Portal for the Development of an Agreement upon Draft Legal Acts, or on their website, draft documents, as well as a summary of opinions, proposals, objections received, and explanations provided by the responsible institution.3 These findings underline the growing recognition of the importance of stakeholder engagement across the assessed countries. However, the variations in consultation requirements and durations across countries suggest room for improvement. Countries with shorter consultation periods may need to reassess their approach to ensure meaningful participation.
Draft anti-corruption policy documents and relevant supporting materials must be accessible in practice, as required by KPI 5. In this regard, 17 countries published their draft policy documents online. To enhance accessibility and involve a more diverse range of stakeholders, several countries have been progressively using and expanding the functionalities of their e-consultation platforms.4 Notably, seven countries (Albania, Armenia, Bulgaria, Croatia, Serbia, Kazakhstan, and Latvia) have government-wide platforms where draft anti-corruption policy documents were published during public consultations (Box 1.4). This approach represents an important step toward digital transparency and participatory governance. However, the effectiveness of these e-consultation platforms in ensuring a high-quality participatory process appears to be influenced by various factors, potentially including a lack of public awareness about these platforms or published draft documents. In at least five countries, the number of opinions shared on draft policy documents through dedicated platforms did not exceed ten comments. Thus, while implementing government-wide e-consultation platforms is a progressive approach to stakeholder engagement, the low number of comments in some cases suggests that these platforms alone may not be sufficient to ensure meaningful public participation.
Armenia: The Platform for the Publication of Legal Acts of Armenia serves as a centralised website for government agencies to upload draft legal acts and facilitate public discussions (Ministry of Justice of Armenia[25]). It offers a range of functionalities designed to engage stakeholders effectively. For example, users can access published drafts and their supporting materials, monitor the finalisation and adoption progress of the draft, review suggestions submitted by other stakeholders, and, upon registration, contribute their own opinions and receive information about accepted comments and explanations regarding not incorporated proposals.
Croatia: Croatia launched a comprehensive e-consultation platform as part of its commitment to the National Open Government Partnership (OGP) Action Plan (Ministry of Justice, Administration and Digital Transformation of Croatia[26]). The centralised platform offers several key features, such as a single point of entry for all public consultations initiated by the government, an opportunity to comment on specific sections of proposed legal acts, allowing more precise and relevant feedback, as well as the possibility to monitor how state bodies respond to submitted comments. To further support the system's effective operation, the government appointed dedicated coordinators within public bodies to oversee the consultation process, created standardised templates and practices for reporting on public consultation results, and published annual reports on public consultations providing an overview of citizens' engagement.
Latvia: The Unified Portal for the Development and Agreement upon Draft Legal Acts (TAP Portal) is a state information system used to ensure the Cabinet of Ministers' operation, inform the public, and participate in the drafting of legal acts (State Chancellery of Latvia[27]). The TAP portal is a single platform where all draft legal acts and policy planning documents to be reviewed by the Cabinet of Ministers are available to the public and where public consultation and inter-institutional coordination have been conducted since September 2021. In 2024, the TAP portal received the United Nations Public Service Award, recognising its contribution to fostering innovation and openness in Latvia.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; Ministry of Justice of Armenia (2025[25]), Platform for the Publication of Legal Acts of Armenia, https://www.e-draft.am/en; Ministry of Justice, Administration and Digital Transformation of Croatia (2025[26]), e-Consultation Platform, https://esavjetovanja.gov.hr/ECon/Dashboard; State Chancellery of Latvia (2025[27]), Portal for the Development and Agreement upon Draft Legal Acts, https://tapportals.mk.gov.lv/.
The actual implementation of the established mandatory intergovernmental and public consultations in practice is assessed by KPI 6. In total, 17 countries organised mandatory public consultation before adopting anti-corruption strategies and action plans (Figure 1.5). A noteworthy positive trend is that in 11 countries, drafts on e-consultation platforms or other websites were published by at least one additional type of consultation (KPI 7). These consultations took various forms, with the most frequently used instruments being working (operational) meetings and formal meetings with targeted groups of stakeholders. Several other countries conducted even more extended public consultations using social media outreach (Ukraine), leveraging institutional co-operation platforms (Romania), and opting for open public meetings rather than limiting the discussion to selected stakeholder groups (Latvia and Moldova) (Box 1.5).
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD ACN (2024), Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
These findings demonstrate countries’ understanding that a single approach may not be sufficient to capture all relevant inputs and perspectives, and, therefore, a combination of online platforms/websites with more traditional consultation methods (such as in-person meetings) represents a balanced approach that can potentially reach a broader audience. The IAP fifth round of monitoring also showed significant progress in enhancing transparency through the publication of draft strategies and efforts to organise public consultations in Armenia, Azerbaijan, Moldova, and Ukraine (OECD, 2024[28]). However, despite these positive developments, there is a need for further efforts to ensure that consultations are meaningful, effective, and reach diverse audiences. Some of these challenges include, for example, the need to further engage diverse stakeholders in public consultation (Azerbaijan) (OECD, 2024[7]), increase the uptake of proposals made by non-governmental organisations (Moldova) (OECD, 2024[8]), or provide more systematic feedback to the provided comments (Albania) (OECD, 2021[29]).
Public consultation on the draft Anti-Corruption Strategy 2021-2025 of Ukraine has been highly praised by the national non-governmental stakeholders (2022[30]). The consultation process was characterised by its inclusivity and the use of multiple communication channels. Notably, following the publication of the draft on the website, consultations involved a broad spectrum of participants through eight thematic virtual consultations, which were streamlined on the National Agency on Corruption Prevention’s social media channels. Besides, two sessions were co-organised in close coordination with Transparency International Ukraine. According to the NACP, 270 participants and 30 invited experts participated in virtual discussions, attracting attention from over 31 500 viewers on the NACP’s social network pages. The draft Anti-Corruption Action Plan underwent a similar process, with 11 consultations focusing on specific chapters of the strategic document.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; OECD (2024[9]), Review of Anti-Corruption Reforms in Ukraine under the Fifth Round of Monitoring, https://doi.org/10.1787/9e03ebb6-en; Parliament of Ukraine (2022[30]), Anti-Corruption Strategy 2021-2025, https://nazk.gov.ua/en/anti-corruption-strategy/.
According to KPI 8, at least one key integrity body5 should participate in regular intergovernmental or public consultation and provide its comments on the draft anti-corruption strategy. The data show that all countries reviewed in this report consulted with at least one integrity body, as evidenced by their inclusion in the working groups or participation throughout the intergovernmental consultations in the anti-corruption policy development process. These institutions primarily include specialised anti-corruption agencies, public prosecution offices, and court administration bodies. However, the data also reveals that consultations with certain other institutions, such as parliament, ombudsman, and local governments, have been significantly less frequent.
Establishing ad hoc working groups or using other mechanisms that ensure close engagement of civil society, such as organising consultation meetings or thematic public discussions, could foster regular cooperation, continuous communication, and meaningful dialogue with civil society (OECD, 2020[31]). At least one non-state actor should be a member of a working group mandated to develop or amend the strategy in force, as required by KPI 9. In total, 20 countries invited non-state actors to respective working groups responsible for elaborating anti-corruption strategies. The actors typically engaged were civil society organisations (in all 20 countries) and business associations (in nine countries) (Box 1.6). However, engaging different civil society sectors in these working groups while building on their diverse expertise and perspectives requires more effort across the assessed countries. Namely, the business sector, academia, and media were the least represented in the consultation processes. For example, a few countries engaged media representatives in the drafting process, including Bosnia and Herzegovina, Croatia, and North Macedonia. Thus, while there is a clear preference for engaging civil society organisations seen as key stakeholders in anti-corruption efforts, the underrepresentation of the business sector, academia, and media in the drafting process highlights a gap that potentially limits the comprehensiveness of anti-corruption strategies.
Romania’s National Anti-Corruption Strategy 2021-2025 demonstrates a comprehensive approach to stakeholder engagement using its five co‑operation platforms (2021[32]). Notably, five distinct platforms target a specific sector/group: (i) independent authorities and anti‑corruption institutions, (ii) central public administration, (iii) local public administration, (iv) the business sector, and (v) civil society. With the involvement of more than 100 participants, the platforms convene meetings biannually to contribute to developing, monitoring, and evaluating the anti-corruption strategy. The platforms are important channels for raising awareness of legislative and institutional changes or reforms and capturing sector‑specific insights, potentially leading to more targeted anti‑corruption measures.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; Government of Romania (2021[32]), National Anti-Corruption Strategy 2021-2025, https://sna.just.ro/en/c/sna-2021-2025; OECD (2024[33]), Implementing the OECD Anti-Bribery Convention Phase 2 Report: Romania, https://doi.org/10.1787/37adcf9a-en.
A high degree of transparency and meaningful feedback on comments on draft strategies significantly enhances the legitimacy of anti-corruption policies. To this end, KPI 10 requires that, following the public consultation process, a consultation portal or the responsible agency's website should contain a summary sheet for the draft strategy, including responses to all comments submitted during the public consultation. However, only seven countries assessed have published all comments received through public consultations. This conclusion demonstrates a significant gap in the feedback loop of the consultation process and, thus, suggests a need for improvement in responsiveness during public consultation.
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024), Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
KPI 11 looks at the implementation rate of activities in the anti-corruption action plan as presented in the monitoring reports provided by national authorities. It aims to promote effective implementation of the commitments made by state bodies and facilitate realistic planning at the beginning of the policy cycle. The percentage of implementation is drawn from the monitoring reports focusing on fully implemented activities only (ongoing, continuous, or only partially implemented activities are excluded). In total, nine out of eighteen countries that reported their implementation rates have implemented only over half of the planned activities, which underlines an important implementation gap. Future analysis could focus on factors contributing to successful implementation in countries with higher implementation rates, as well as the causes of low levels of policy implementation.
Since adopting the National Strategy for Prevention of Corruption and Conflict of Interest (2021-2025), the State Commission for Prevention of Corruption of North Macedonia has developed three annual monitoring reports. The reports demonstrate that the implementation rates have been consistently low, with only 20% of activities fully implemented in 2021, followed by a decline to 10% in 2022 and a slight increase to 13% in 2023. Significant progress was observed only in the healthcare and social policy sectors, while other areas experienced minimal improvements in implementation levels. The Commission has proposed a set of measures to address these challenges. These include intensifying data collection from competent institutions, adopting a systematic approach to impact measurement, facilitating open discussions with stakeholders, and organising frequent high-level co‑ordination meetings. Additionally, the Commission plans to strengthen its human, technical, and financial resources. Furthermore, an ongoing analysis is currently being conducted by independent experts to identify the root causes of the persistently low implementation levels over the past three years. The Commission also recognises that various factors may influence the implementation process, such as the quantity and quality of measures and activities, frequent changes in management structures, and insufficient resources. By leveraging the insights gained from the current strategy's implementation and the ongoing analysis, the Commission aims to develop and adopt a more effective next national strategy (2026-2030) that will drive meaningful changes and achieve higher implementation rates in the future.
Source: OECD ACN 2024, Regional Anti-Corruption Trends questionnaire responses, also additional information was provided at the Regional Dialogue Session organised within the ACN Steering Group Meeting on 19 September 2024; State Commission for Prevention of Corruption (2020[17]), National Strategy for Prevention of Corruption and Conflict of Interest, https://dksk.mk/wp-content/uploads/2021/09/NACS-2021_25-and-Action-Plan-EN-final.pdf.
All assessed countries have established a dedicated agency to co‑ordinate the implementation of their anti-corruption strategies, and monitoring mechanisms have been improved. However, countries still lack evaluation reports, resulting in an unclear picture of the effectiveness of their anti-corruption efforts and limiting their ability to identify lessons learned and address weaknesses in their next policy cycle (Figure 1.7).
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024), Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
The successful implementation of an anti-corruption strategy depends on multiple factors, including the close co-operation of government agencies and the central coordinating body (agency, unit, or dedicated staff). KPI 12 requires a central coordination function responsible for overseeing the strategy and action plan implementation, monitoring, and evaluation. In this regard, all analysed countries have reported an agency entrusted with such functions, thus demonstrating a common recognition of the importance of centralised co-ordination of anti-corruption efforts. Institutional arrangements of these functions vary across the countries assessed. Seven countries have embedded their coordinating functions within the existing institutional structures, such as ministries or government-created commissions. Six countries have assigned this function to law enforcement agencies, and in eight countries, this role was entrusted to specialised preventive agencies.
The IAP fifth Round of Monitoring Reports highlight the significant improvements in the quality of co-ordination, level of co-operation with stakeholders, and overall work of the dedicated anti-corruption agencies among nine ACN-member countries (Box 1.8). However, these reports also identified areas requiring further attention, for example, limited human resources allocated to co-ordination and monitoring functions (Armenia, Ukraine, Kyrgyzstan, and Uzbekistan), and the duplication of functions among agencies (Kyrgyzstan and Mongolia) (OECD, 2024[34]).
Through the legislative amendments introduced to the Law on Public Service in 2022, Armenia introduced and institutionalised the role of officials responsible for anti-corruption activities (anti‑corruption focal points). The changes aim to establish a clear mandate and define specific focal point responsibilities, ensuring effective intra-agency co‑ordination. According to the legislation, each state or local self-government body should appoint at least one person to co‑ordinate and implement anti‑corruption measures. The Law clearly outlines the responsibilities, such as supporting the implementation of anti-corruption measures outlined in strategic documents, conducting self-evaluation, participating in anti-corruption meetings, requesting and receiving information from relevant structural units, submitting required information to the central co‑ordinating body, etc. By embedding these responsibilities into the day-to-day functions within existing governmental structures, the legislative amendments could enhance accountability at the institutional level and contribute to the better implementation of anti-corruption strategic documents.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; OECD (2024[6]), Baseline Report of the Fifth Round of Monitoring of Anti-Corruption Reforms in Armenia, https://doi.org/10.1787/fb158bf9-en.
Regular monitoring of the implementation of strategic frameworks and evaluating their impact is a crucial element of an effective anti-corruption policy (UNODC, 2015[16]). KPI 14 encourages governments to prepare monitoring reports annually and publish them no later than three months after the defined reporting schedule. Conducting monitoring of the implementation is an increasingly common practice. Namely, two‑thirds (15 countries) have prepared and published monitoring reports illustrating progress in implementing their action plans.6
Despite the improvements in the frequency of the monitoring reports, the quality of the reports seems to require further improvements. Only 12 countries based their monitoring reports on progress against pre‑defined indicators and targets in their action plans as required by KPI 15. While most analysed action plans include objectives, measures, and responsible agencies, many lack clear deadlines, outcome-level indicators, and specific targets for each measure (Figure 1.8). Thus, while some have made progress in regularly producing monitoring reports (OECD, 2024[28]), there is a significant shortcoming in the quality of these reports across the countries assessed. The lack of indicators and targets in action plans indicates a potential weakness in anti-corruption strategies' initial analysis phase, and later significantly hinders effective monitoring and evaluation (Box 1.9).
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy.
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024), Regional Anti-Corruption Trends dataset built on the responses provided by countries.
Ukraine has developed an innovative information system to monitor the implementation of its National Anti-Corruption Strategy thoroughly. The key features of the information system include a visual representation of the implementation status for each measure, level of progress, implementation dates, funding sources, responsible agencies, implementation challenges, and a description of achieved strategic results. The portal offers an interactive and user-friendly design and structure, allowing users to easily filter information by specific measures, implementing agencies, or implementation status. Furthermore, each strategic objective is directly linked to publicly available supporting documents (e.g., risk assessments), demonstrating the clear connection between problem analysis and the measures included in the action plan. The system illustrates quarterly updates, providing stakeholders with up‑to‑date information on the progress of anti-corruption measures.
Source: OECD ACN 2024, Regional Anti-Corruption Trends questionnaire responses; Information was provided at the Regional Dialogue Session organised within the ACN Steering Group Meeting on 19 September 2024; National Agency for Corruption Prevention of Ukraine (2025[35]), Information system for monitoring the implementation of the state anti-corruption policy, https://dap.nazk.gov.ua/en/.
To increase public support for anti-corruption reforms and maintain a high level of accountability of governmental agencies, consultations with the general public and/or civil society organisations on its monitoring report should be initiated (UNODC, 2015[16]). The responsible agency should, at a minimum, update interested internal and external stakeholders or even the general public about the monitoring results (KPI 16). However, the fact that only thirteen countries have organised consultations with civil society highlights missing crucial opportunities, among them a potential to identify gaps and increase the credibility of anti-corruption efforts.
While monitoring the implementation is essential, it alone cannot reveal the extent to which the results were achieved or their impact on reducing corruption. Countries are encouraged to prepare and publish evaluation reports at the end of each policy cycle (KPI 17). Most reviewed countries have recognised the importance of an evaluation by explicitly establishing such obligations in their policy documents and entrusting the co‑ordinating institution with related powers. Nevertheless, only half of them evaluated the impact of their previous anti-corruption policy document (Figure 1.9). This suggests that the effectiveness and impact of previous anti-corruption strategies, or lessons learnt from their implementation, do not systematically feed into new strategic frameworks. As a result, these countries are missing important opportunities to enhance their future anti-corruption efforts. This finding also underlines a need for capacity building in evaluation methodologies and practices of anti-corruption agencies or responsible government bodies across the region. At the same time, some countries are already leveraging existing and tested methodologies to enhance their anti-corruption efforts (Box 1.10).
Notes: OECD PIIs data for Bulgaria, Croatia, Estonia, Lithuania, Latvia, Romania and Ukraine. PII data on Bulgaria is not comparable with Bulgaria’s compliance with KPI 9, 11 and 14, given that PII considers both the National Strategy for Preventing and Combating Corruption and the National Strategy for Preventing and Combating Irregularities and Fraud, while KPIs assess only the National Strategy for Preventing and Combating Corruption. PII data on Romania is not comparable with Romania’s compliance with KPI 3, 9, 11 and 16, given that PII considers both the National Anti-Corruption Strategy and the National Anti-Fraud Strategy, while KPIs assessed only the National Anti-Corruption Strategy
Source: OECD (2025[5]) Public Integrity Indicators Database. https://oecd-public-integrity-indicators.org/; OECD (2024), Regional Anti‑Corruption Trends dataset built on the responses provided by countries.
In developing comprehensive anti-corruption strategies and analysing the impact of their implementation, policymakers should access diverse data sources and established methodologies, each offering unique insights into the complex landscape of corruption. One example of such tools is the State Capture Assessment Diagnostics (SCAD) methodology developed by the Centre for the Study of Democracy (Centre for the Study of Democracy, 2019[36]). The SCAD is designed to assess state capture practices in given economic sectors and regulatory/enforcement institutions and suggest policy adjustments that could close the opportunities for special interests to use public governance institutions for private ends. This instrument could be a powerful tool for drafting an effective anti-corruption strategy while serving as a solid evidence-gathering mechanism that policymakers can use to verify the existence of state capture practices in various areas and, as a result, focus on the most problematic areas. The second helpful methodological tool could be the Monitoring Anticorruption Policy Implementation (MACPI) (Centre for the Study of Democracy, 2021[37]). It provides an instrument for assessing anti-corruption policies at the organisational level, identifying specific corruption vulnerabilities within public organisations and evaluating policies targeting them.
Source: Centre for the Study of Democracy (2019[36]), State Capture Assessment Diagnostics, https://csd.eu/publications/publication/state-capture-assessment-diagnostics/; Centre for the Study of Democracy (2021[37]), Monitoring Anti-Corruption Policy Implementation in High-Risk Sectors, https://csd.eu/publications/publication/monitoring-anti-corruption-policy-implementation-in-high-risk-sectors/.
The use of impact indicators for quality evaluation reports has been uncommon among the assessed countries (KPI 17). The countries mostly presented outputs or outcomes of the policy implementation, while the impact of the measures remained ambiguous. This significantly limits their ability to track progress and measure the achievement of set goals meaningfully. Besides, in rare cases where a few impact indicators were used in evaluation reports, they did not capture the complexity of the national anti-corruption landscape and the scale of set objectives and related measures (Box 1.11).
The UK’s Anti-Corruption Strategy foresees the so-called “indicator basket’’ approach. Impact indicators are grouped into five baskets reflecting five different measurement themes: (i) regulation and transparency that reduces corruption, (ii) the corruption threat to the national security, (iii) an increase in prosperity in the UK and abroad, (iv) public confidence in domestic and international institutions and (v) expert opinion of corruption. These baskets compose disaggregated indicators derived from diverse governance datasets and global composite indices. Going beyond single data points and incorporating multiple complementary indicators from various data sources ensures a holistic approach, facilitating a robust evaluation of the effectiveness and impact of anti-corruption measures over time.
Source: Government of the United Kingdom (2017[38]), United Kingdom Anti-Corruption Strategy 2017-2022; https://assets.publishing.service.gov.uk/media/5a829eb7e5274a2e87dc21f0/6_3323_Anti-Corruption_Strategy_WEB.pdf; Additional information was provided at the Regional Dialogue Session organised within the ACN Steering Group Meeting on 19 September 2024.
Non-state actors engaged in evaluating a predecessor strategy, either as evaluators or as part of a formal review or quality assurance mechanism, in only ten analysed countries (KPI 18). Some countries have taken further steps to benefit from external expertise and perspectives in the evaluation process. Notably, Armenia, North Macedonia, Moldova, and Ukraine invited non-state actors to develop alternative assessment reports. These initiatives facilitate effective access to information and contribute to an increase in trust and co‑operation levels with non-governmental partners (Box 1.12). While alternative reports can serve as a valuable source for governmental agencies and minimise the duplication of efforts, it is noteworthy that this practice is not yet widespread in the region.
Moldova’s National Integrity and Anti-Corruption Programme for 2024-2028 recognises the important role of civil society engagement by promoting the development of alternative monitoring and evaluation reports by civil society organisations. In this context, six civil society organisations developed alternative reports on diverse sectoral areas (covered by the previous strategic document), including customs, environmental protection, and local public administration. These reports focused on assessing the progress and challenges in implementing the anti-corruption strategy while providing recommendations to address identified gaps. All alternative reports were publicly presented and published. Another civil society organisation (Centre for the Analysis and Prevention of Corruption) presented a comprehensive assessment of the implementation and impact, showcasing the important role of external evaluations. This approach included diverse data sources from responsible government agencies, focus groups and interviews, impact assessment surveys, and alternative monitoring reports from civil society. As a result, the organisation noted the improvements in the level of implementation but concluded that these developments fell short of the expected impact.
Source: OECD (2024), Regional Anti-Corruption Trends questionnaire responses; OECD (2024[8]), Baseline Report of the Fifth Round of Monitoring of Anti-Corruption Reforms in Moldova, https://doi.org/10.1787/25fc47ac-en.
← 1. Kosovo did not have a national anti-corruption strategy in place at the time of this assessment, although anti-corruption objectives were reflected in the Strategy on Rule of Law 2021-2026.
← 2. An inter-institutional body - a public authority of a permanent or temporary nature that has members from at least three central government bodies and/or oversight institutions. An example can be a joint task force with members from different central government bodies and/or oversight institutions.
← 3. Latvian Cabinet Regulation No. 639, Procedures for the Public Participation in the Development Planning Process adopted on 15 October 2024.
← 4. More information is available on public consultation platforms and related country commitments on the use of e-consultation platforms (Open Government Partnership[45]).
← 5. For the purposes of this indicator and in line with the OECD Public Integrity Indicators, “key integrity body” includes (a) anti-corruption authority, (b) supreme audit institution, (c) public procurement authority, (d) central institution responsible for internal control; (e) ombudsperson institution, (f) ministry(ies) responsible for police, tax or customs authorities, or (g) prosecution or court administration.
← 6. Some of the provided monitoring reports were published before the assessment period of this report (2023-2024), but during the last year of their action plan in force.