Ukraine has made significant strides in reforming its anti-corruption framework in the past decade. It has done so by enhancing transparency, accountability, and integrity through open data, digitalisation, and bolstering of the independence of anti-corruption bodies. However, corruption risks remain high in the context of Russia’s full-scale invasion of Ukraine, which makes having a robust public integrity system more critical than ever to ensure a transparent and effective reconstruction process. This review delivers recommendations to strengthen Ukraine’s legal and institutional framework, embed a culture of integrity in state bodies and society, enhance judicial accountability, and reinforce control and audit mechanisms. It also explores ways to reinforce whistleblower protection, implement lobbying regulations and promote business integrity – through awareness raising, adoption of company-level anti-corruption compliance programmes and incentivising good corporate behaviour through public advantages and criminal law measures. Together, these measures can help to promote trust, drive economic recovery and sustain international support for Ukraine now and in the future.
OECD Integrity and Anti-Corruption Review of Ukraine
Abstract
Executive Summary
Ukraine has shown the world that it is possible for a country to defend itself against a full-scale invasion and simultaneously improve its defences against corruption to a level that aligns closely with international benchmarks in OECD and EU countries. Since the 2013–2014 Euromaidan Revolution and Russia’s invasion of Crimea and Donbas, Ukraine has significantly reformed its anti‑corruption framework to fight what were then historically high corruption levels in the country. Perceptions of corruption remain very high but have improved since 2013 and self-reported citizens’ experiences with corruption have fallen drastically. Driven by public demand and aspirations for EU membership, Ukraine has enhanced transparency, strengthened accountability, and promoted integrity through open data, digitalised public services, independent anti‑corruption bodies, political finance reforms, and decentralisation. The OECD Public Integrity Indicators (PIIs) place Ukraine above the OECD average in many areas (strategy, conflict-of-interest management, political finance, corruption risk management); further progress is expected once the restrictions under Martial Law are no longer necessary or when relevant legislation (e.g. on lobbying) comes into effect.
Since Russia’s full-scale invasion on 24 February 2022, Ukraine has endured severe civilian harm and military casualties. The war has also caused widespread power outages, displacement and workforce shortages, affecting both public and private sectors. Security-related restrictions, market disruptions, and infrastructure damage amplify the hardships. Nevertheless, Ukraine has intensified efforts to fight corruption, recognising the need to have strong integrity safeguards in place for reconstruction efforts to succeed. Integrity mechanisms are essential for fostering trust among Ukrainians and international partners, reinforcing social cohesion, and attracting continued international support and foreign investment. Moreover, public integrity is essential for sustaining open and competitive markets, which drive economic resilience and safeguard against undue interference through strategic corruption.
Areas for progress and further improvement for Ukraine in integrity and anti-corruption are summarised below.
Ukraine has established a strong regulatory framework for anti‑corruption and public integrity. However, regulations must now be implemented to induce change in behaviours and a more resilient culture of integrity across the public administration, including at sub-national level, and in society at large. The National Agency on Corruption Prevention (NACP) is successfully leading and co-ordinating the development of the 2021-25 National Anti‑Corruption Strategy. However, broader engagement and ownership by all public bodies of both strategy development and implementation monitoring would be beneficial.
The Strategy is comprehensive and evidence based. Implementation is proceeding well but could focus more on outcomes than outputs and a key gap is the lack of plans for evaluation and lesson-learning. This would help ensure continuity and greater effectiveness of future strategies.
Ukraine has a comprehensive legal framework regulating conflicts of interest and asset declarations to detect and prevent corruption in the public sector.
To cultivate a culture of integrity, Ukraine could reinforce ethical standards and a values-based approach to complement its current rules-based approach. Codes of ethics can support appointed and elected officials in adopting higher standards of behaviour. The National Agency of Ukraine on Civil Service and the National Agency on Corruption Prevention could work together to mainstream integrity principles throughout civil service careers by fostering ethical leadership, incentivising ethical behaviour, and incorporating integrity-related performance indicators. Aligning actors and processes within the conflict-of-interest policy framework could support public integrity and enhance corruption prevention. Ukraine should also ensure the effective use of asset declarations for corruption detection and prevention beyond unjustified wealth, for example in conflict-of-interest situations.
Ukraine’s regulations for access to public information and political financing compare favourably to OECD countries. The regulations for lobbying have been well defined in law but are not yet in force.
Ukraine could ensure its new lobbying framework comes into effect as soon as possible, and, later, review its effectiveness. Clarifying how the public interest test in the Law on Access to Public Information should be applied under Martial Law and publishing ministers’ and government session agendas would enhance transparency. In the longer term, oversight and enforcement of public information regulations could be improved. Requiring recipients to verify donor eligibility and ensuring proper registration of private donations would enhance political financing accountability.
A judicial reform process that has been ongoing since 2016 has introduced integrity safeguards in judicial selection, appointment, promotion, and disciplinary procedures. More recently, Ukraine also adopted a revised code of judicial ethics and integrated judges into new systems for conflict-of-interest management and whistleblowing. However, many of these reforms remain incomplete.
Ukraine could complete the reform of judicial career progression in a manner that is efficient without compromising integrity standards. Strengthening judicial integrity also requires implementation of the new code of ethics, and further improving whistleblower protection in practice. Embedding integrity principles in legal education can reinforce ethical conduct among future legal professionals. To ensure fairness, impartiality, and timeliness of enforcement mechanisms in corruption cases, Ukraine could improve case allocation mechanisms and improve transparency.
Ukraine has gradually aligned with international standards by implementing public sector internal control requirements and assigning the Ministry of Finance a central harmonisation role in line with the EU’s public internal financial control framework. Legislative amendments have brought Ukraine’s supreme audit institution closer to international standards. However, implementation remains challenging due to resource constraints. The effectiveness of external audit could be improved through clearer institutional responsibilities, better audit planning, stronger uptake of recommendations by public bodies, and increased stakeholder engagement in the Accounting Chamber.
Ukraine could better integrate corruption risk management within the framework of organisational internal control and risk management. Strengthening internal audit units, particularly at the local government level, is also crucial.
Ukraine has been enhancing its whistleblower framework, including through a solid legislative basis for reporting corruption, establishing a web-based portal for whistleblower reports, and increasing institutional and public awareness of the whistleblower framework.
To further improve, Ukraine could broaden the material and personal scope of its whistleblower legislation and clarify legal provisions. Strengthening authorised units’ capacity to receive and act upon disclosures, improving the functionality of the whistleblower portal, and ensuring that data collected feed into policy making could enhance protection and support broader anti‑corruption efforts.
Ukraine has addressed business integrity in several key policy documents, including the National Anti-Corruption Strategy, the State Anti‑Corruption Programme and the Communication Strategy in the Area of Prevention and Countering of Corruption. Going forward, Ukraine should develop stronger outcome and impact indicators for the assessment of the effectiveness of these policies. Moreover, to ensure that the policies on business integrity are properly informed and based on relevant evidence, the authorities should improve the quality of the consultation process with businesses and better reflect their needs in these documents, along with the assessment of specific corruption risks that companies face. The National Agency on Corruption Prevention should also ensure broader inclusion of the private sector in its training activities.
Preventing and detecting solicitation and acceptance of bribes by public officials is an important part of ensuring integrity in business operations. Surveys have demonstrated that the willingness of Ukrainian companies to report bribe solicitation remains low. Ukraine should therefore work to increase the trust of businesses in the law enforcement system and address the concerns of companies over potential reprisals for reporting corruption.
Candidates for civil servant positions in Ukraine must pass a test on the knowledge of legislation, including anti-corruption legislation, but this has been suspended during the war. Ukraine should resume the testing and include additional bribery-related questions. The National Agency on Corruption Prevention or the National Anti-Corruption Bureau of Ukraine should consider preparing detailed guidance for public officials on how to act when undue benefits are provided, offered or promised.
Under Ukrainian law, certain large state-owned enterprises (SOEs) and companies bidding for high-value public procurement contracts are required to establish dedicated anti‑corruption programmes and appoint internal “integrity commissioners” responsible for their implementation. Ukraine should consider extending systemically this requirement to all important SOEs and a broader circle of public procurement participants, and strengthening the role of company boards in overseeing their implementation. Ukraine should ensure that the anti‑corruption programmes are effective and not merely a box-ticking exercise for companies.
Ukraine introduced a quasi-criminal corporate liability model in 2014 and reinforced it through legislative amendments in December 2024, but further steps are required to establish an effective regime covering corruption offences beyond foreign bribery.
Ukraine can further incentivise integrity in the private sector by considering compliance programmes a mitigating factor in criminal cases against legal entities, improving its provisions on non-trial resolutions, introducing verification of anti-corruption compliance programmes and eliminating the gaps in the current system of debarment of companies from public advantages over corruption convictions.
