This chapter outlines the public integrity and anti‑corruption legislative and institutional framework in Ukraine. The chapter provides recommendations to balance Ukraine’s robust regulatory framework for anti‑corruption and public integrity with values-based standards that strengthen corruption prevention. The creation of specialised anti‑corruption agencies has been instrumental in preventing and detecting corruption, but they require increased resources and accountability measures to enhance their effectiveness. The chapter emphasises that evaluating the impact of the 2021–25 National Anti-Corruption Strategy will be crucial for shaping the next Strategy to move from ad hoc integrity policies to a unified system where all stakeholders are responsible for public integrity.
OECD Integrity and Anti‑Corruption Review of Ukraine
Abstract
The OECD Recommendation on Public Integrity defines public integrity as the “consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector” (OECD, 2017[1]). In other words, public integrity means prioritising public interest over private interests and fulfilling duties in a manner that would endure public scrutiny. Corruption occurs from loopholes in the public integrity system and harms society in numerous ways. It exacerbates social inequalities and undermines economic growth. It erodes the resilience and proper functioning of democracies. Corruption lowers trust in government. Corruption also exacerbates security risks as a tool of foreign interference.
When Ukraine proclaimed its independence from the Soviet Union in 1991, the country was exposed to high levels of political corruption and everyday administrative corruption Several factors contributed to that. State institutions were disrupted in the transition period of the 1990s and society operated with high instability and opaque competition for economic resources and political influence. This facilitated the evolution of the so-called oligarchic system, in which several financial-industrial groups held economic monopolies, owned major media outlets and influenced politics through political finance disproportional to citizens’ support of political parties (Dalton, 2023[2]; Pleines, 2016[3]). Furthermore, the widespread everyday corruption was a continuation of the Soviet-era shadow economy and informal practices. This system, while essential for people to survive at the time, fostered a high tolerance of corruption (Karklins, 2005[4]). The combination of these corruption patterns undermined the country’s economic growth, democratic development and social well-being (Havrylyshyn, 2017[5]). Internationally, Ukraine remained associated with widespread corruption, and loopholes in the integrity and decision-making systems enabled foreign interference in Russia’s full-scale invasion of Ukraine.
Since 2013-2014 – the years of the Euromaidan Revolution and the Russian invasion of Crimea and Donbas – the patterns of corruption and the dynamics of anti‑corruption significantly changed in Ukraine. Due to the strong societal demand, combined with the incentive to join the European Union (EU), Ukraine advanced on several systemic reforms aimed at increasing transparency through open data and digitalisation of public services; tackling impunity for high-level corruption through the newly established system of independent bodies for the detection, investigation and adjudication of corruption; ensuring integrity in the judiciary through reformed selection procedures; reform of political finance; ensuring citizens' proximity to decision-making through the reform of decentralisation and open government mechanisms.
There has been steady and significant progress since those years in controlling corruption. The positive dynamic is especially notable against the background of the reported decline in controlling corruption in several EU countries and negative trends globally (Transparency International, 2023[6]).
The assessments of corruption in Ukraine indicate that the issue of everyday corruption has been addressed more effectively since 2014. Despite the permanently high perceptions of corruption among citizens, there has been a historic drop in the experience of corruption reported by citizens, from over 70% in 2015 to 15% after 2021 (Figure 1.1). The National Agency on Corruption Prevention’s (Національне агентство з питань запобігання корупції, herein “NACP”) index of corruption-prone sectors shows that public social services and activities of the Administrative Service Centres (ASC, ЦНАП) along with primary and secondary education are the least corrupt (NACP, 2024[7]). Major corruption issues remain with the law enforcement activities, customs and regulatory control of the private sector.
Under war conditions since 24 February 2022, Ukraine is not only fighting the external aggressor but is also continuing the fight against corruption. Corruption risks increased due to protracted crises triggered by the war. Disruption of the markets, massive displacement, and the need to close some public information due to security risks are only a few factors exacerbating corruption risks. In addition, the country faces the challenge of maintaining democratic resilience, especially due to halted elections – an essential accountability mechanism. At the same time, public demand for justice has reached historic levels, with 92% of citizens viewing corruption as a severe national issue, intolerance of corruption (referring to the view among Ukrainians that corruption is unacceptable) rising to 54% in 2024 (compared to 37% in 2015), and readiness to resist corruption (the self-reported willingness to take action against corruption) increasing to 49% in 2024 (compared to 26% in 2021) (ENGAGE, 2024[8]).
Note: The latest poll is part of the eighth Corruption Perception and Experience series (since 2007) and was conducted from June to August 2024 by the Kyiv International Institute of Sociology (KIIS). It surveyed 13 151 respondents across 3 groups: the general population, internally displaced Ukrainians (IDPs), and externally displaced Ukrainians (EDPs). Methodologies included stratified random sampling for the general population, in-person interviews for IDPs, and a mix of online and phone surveys for EDPs. The margin of error is ±1.5% at a 95% confidence level.
Source: ENGAGE (2024[8]), National Corruption Perceptions and Experience Poll, https://engage.org.ua/eng/national-corruption-perceptions-and-experience-poll-2024/.
Building a coherent system of public integrity is even more critical in the context of war. Integrity mechanisms are essential for building trust both among Ukrainians and with international partners. This trust underpins social cohesion and justifies ongoing external support. Moreover, public integrity is vital for sustaining open and competitive markets, which are necessary for the country's economic resilience. Finally, a resilient integrity system also helps prevent foreign interference through strategic corruption.
The OECD Integrity and Anti‑Corruption Review of Ukraine provides tailored recommendations on how to improve the integrity framework in the country. The Review addresses three issues, common to all chapters:
There has been significant progress in criminalising, detecting and adjudicating corruption, but the prevention of corruption in Ukraine could be improved.
The regulatory framework for public integrity in Ukraine is considerably strong, however fostering a culture of integrity requires to balance the legalistic approach to public integrity with applying the principle-based approach in daily practice. The latter incentivises individual responsibility for managing corruption risks and conflict of interest.
An effective system of specialised anti‑corruption bodies has been established in Ukraine, however the whole-of-government commitment and responsibilities for public integrity by other public bodies could be strengthened through mainstreaming functioning integrity principles across the sectors and levels of governance.
The analysis of the legal and institutional frameworks for integrity has been conducted in line with the 2017 OECD Recommendation on Public Integrity. Establishing a coherent integrity system requires balanced attention to three equally important pillars: (1) the system of public integrity is based on political commitment and encompasses clear institutional responsibilities, strategic and evidence-based approach to anti‑corruption policies, as well as high standards of conduct of public officials. (2) Effectively countering and fostering integrity also requires a whole-of-society approach, involving partnerships with the private sector and civil society. This pillar emphasises investing in integrity leadership and professional public sector, especially through sufficient training and guidance. It also includes cultivating an open organisational culture. (3) The third pillar safeguards the framework by incorporating a robust control and risk management system, enforcement mechanisms, external oversight, as well as transparency and stakeholders’ engagement in policymaking (Figure 1.2).
Source: OECD (2017[1]), Recommendation of the Council on Public Integrity, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
This Review has three objectives. First, it provides an overview of all components of the public integrity framework in Ukraine, examining how its components, such as anti‑corruption systems, judiciary or public administration, are interconnected – or disconnected – within the integrity framework. Second, while most conditionality mechanisms focus on individual outputs, this Review formulates recommendations on the level of outcomes while reflecting on their purpose. Third, the Review analyses Ukraine’s integrity framework in the international context, which allows benchmarking Ukraine against OECD and EU averages and suggests examples of international good practices in places where Ukraine requires improvement.
Methodologically, the assessment of Ukraine using the Public Integrity Indicators (PIIs) (see Box 1.1) serves as a foundation for identifying and prioritising issues. Alongside primary data obtained from the government in response to the PIIs, the analysis considers the latest assessments and reports on Ukraine from international organisations and academics. To gather stakeholder inputs, three fact-finding missions and online interviews were conducted with representatives from the government, civil society and business.
The OECD Recommendation on Public Integrity provides policy makers with a vision for a public integrity and anti-corruption strategy. It shifts the focus from ad hoc integrity policies to a context dependent, behavioural, risk-based approach with an emphasis on cultivating a culture of integrity across the whole of society.
The Public Integrity Indicators (PIIs) are designed to measure the successful implementation of the OECD Recommendation on Public Integrity. The indicator framework establishes standard indicators for the preparedness and resilience of the public integrity system at the national level to prevent corruption, mismanagement and waste of public funds, and to assess the likelihood of detecting and mitigating various corruption risks by different actors in the system.
The PIIs combine sub-indicators establishing minimum legal, procedural and institutional safeguards for the independence, mandate and operational capability of essential actors in the integrity system with outcome-oriented sub-indicators drawing on administrative data and surveys. The PIIs apply a mixed methods approach, drawing on both administrative data and big data provided directly by governments and surveys.
The PIIs:
provide objective and credible measures of different elements of a public integrity system
are meaningful for governments because they are co-created by the OECD with governments and do not rely on subjective expert assessments. The aim is not to provide country rankings, but a tool for learning and informing better policies
are the first-ever comprehensive set of indicators based on an agreed international legal instrument from the OECD and beyond, adhering to the same high statistical standards as other OECD indicators and are validated by OECD member countries
provide a better alternative to existing measures, enabling an analysis of the impacts of anti‑corruption efforts, linking the disaggregated data to a range of economic and social outcomes. The PIIs could also provide the basis for establishing cost-effectiveness and cost-benefit ratios.
To date, the OECD developed the indicators and sub-indicators for six principles of the OECD Recommendation, and a first measurement has taken place for Principles 3, 10 and 13, including the strategic framework for integrity policies. The first overall analysis of integrity frameworks based on the PIIs was published in the 2024 OECD Anti‑Corruption and Integrity Outlook. The PIIs cover 38 OECD countries and 26 non-OECD countries, including Ukraine.
Source: OECD (2024[9]), Anti‑Corruption and Integrity Outlook 2024, https://doi.org/10.1787/968587cd-en.
The Review is composed of ten chapters. The first chapter provides an overview of the normative and institutional frameworks for public integrity and analyses the quality of the strategic framework for anti‑corruption. Chapter 2 examines how ethical standards, conflict-of-interest management and an interest disclosure system can contribute to the culture of integrity in public organisations. Chapter 3 addresses accountability in decision-making, including issues of lobbying and influence, access to public information, and political finance. Chapter 4 looks into the ways of improving judicial integrity. Chapter 5 deals with corruption risk assessments as well as with the internal and external audit frameworks. Chapter 6 provides recommendations for improving whistleblower protection. Chapter 7 is devoted to the development of business integrity policy and awareness raising on business integrity. Chapter 8 explores the measures to prevent and detect the solicitation of bribes from companies by public officials. Chapter 9 assesses the state of affairs in terms of the adoption of anti‑corruption programmes and controls at company level. Chapter 10 examines the use of law enforcement measures and public advantages to incentivise integrity in the private sector.
1.2.1. Ukraine could further strengthen its robust regulatory framework by fostering a value-based culture extending beyond compliance
A practical translation of commitment into practice requires, among other things, clear, harmonised and up-to-date legislation and standards at the criminal, civil and administrative level. This ensures legal certainty for public officials and the general public to know which behaviour is allowed and prohibited. The legislation should be supplemented by clear standards to build a culture of integrity in public organisations (OECD, 2020[10]).
Since 2014, significant reform efforts have been undertaken to develop the legal framework for public integrity in Ukraine. There have been anti‑corruption laws and strategies in place since 1995, but only after 2014 they have been subject to numerous consultations and strongly influenced by civil society for Ukraine to reach international standards.
Thus, in most areas measured by the Public Integrity Indicators, Ukraine’s public integrity regulations show high compliance with OECD standards (Figure 1.3).
Source: OECD (2024[11]), OECD Public Integrity Indicators Database, https://data-explorer.oecd.org/ (accessed on 5 November 2024).
The Law on Prevention of Corruption (LPC) sets the definitions, regulates the institutional and policy framework for corruption prevention, and provides for the key mechanisms of corruption prevention (Box 1.2). In addition to the LPC regulating the mandate and functioning of the NACP, several other laws regulate the functioning of the additional specialised anti‑corruption bodies, including the 2014 Law on the National Anti‑Corruption Bureau of Ukraine (NABU), the 2016 Law on the National Agency of Ukraine for Finding, Tracing and Management of Assets Derived from Corruption and Other Crimes (ARMA), and the 2018 Law on the High Anti‑Corruption Court. The work of the Specialised Prosecutor’s Office of Ukraine (SAPO) is based on the Law on the Prosecutor’s Office and SAPO’s internal regulations, which are approved by Order No. 9 of the Deputy Prosecutor General – Head of SAPO dated 29 February 2024 (as amended on 27 March 2024).
In October 2014, Ukraine passed the Law on Prevention of Corruption (LPC), which established a comprehensive legislative framework to combat corruption and contained a wide range of integrity elements in both the public and private sectors. Several key elements include:
Key definitions (Article 1), such as corruption, unlawful benefit, real and potential conflict of interest, private interest, gift and others, and a broad scope of persons covered by the Law (Article 3).
Development and implementation of the anti‑corruption policy under the responsibility of the NACP (Articles 18-21), as well as the mandate and main functioning provisions of NACP (Articles 4-17).
Prevention and management of conflict of interest (Articles 28-26) and outlines corruption-related offences (Articles 22-27).
Rules of ethical conduct.
Asset disclosure requirements for public officials under financial control provisions (Articles 45‑522).
State protection of persons assisting in the prevention and combating of corruption (whistleblower protection) (Articles 53-539).
Follow-up mechanisms of prevention and combatting corruption, such as provisions for the local self-government bodies, anti‑corruption expertise of legislation, special inspections for candidates, the Register of persons who committed corruption or corruption-related offences.
Note: Anti‑corruption initiatives must be carried out by all state agencies, organisations, quasi-government bodies, and public servants in accordance with their specific roles and responsibilities. The Law applies to high-level government officials, local government officials, civil servants and military officials, members of public collegial bodies and to officials of state-owned enterprises and banks.
Source: Verkhovna Rada of Ukraine (2015[12]), Law on Prevention of Corruption, https://zakon.rada.gov.ua/laws/show/en/1700-18#top.
Further legislation is important for different elements of the integrity systems. For accountability in decision-making (Chapter 3), the Law on Access to Public Information (2015) establishes the foundations for transparency. The Law on Lobbying (2024) marks a milestone in regulating interest representation. However, the Law on Preventing Threats to National Security associated with the Strong Influence of Persons who have Significant Economic or Political Weight in Public Life (Oligarchs), also known as the “de-oligarchisation law” has faced criticism. Its effectiveness has been questioned, and the Venice Commission has criticised it for taking an individualistic rather than a systemic approach. Some integrity standards in the judiciary are set in the Law on the Judiciary and the Status of Judges (Chapter 4). The external audit is regulated by the Budget Code of Ukraine, the Law on Accounting Chamber and the Law on Public Financial Control (Chapter 5).
The Criminal Code (CC) and the Code on Administrative Offences (CAO) provide for liability for criminal and administrative corruption and corruption-related offences in the public and private sectors. According to the CC, most internationally stipulated forms of corruption in the public sector are criminalised, including active and passive bribery, misappropriation and embezzlement, active and passive trading in influence, abuse of functions, obstruction of justice, and enrichment from corruption offences. According to the CAO, there is an administrative liability for corruption-related offences such as violations of restrictions on part-time work and combination with other types of activities; receiving gifts; and violation of the requirements for prevention and settlement of the conflict of interest. Criminal and Administrative Procedures Codes regulate institutional responsibilities and processes of enforcement. The Civil Code and Civil Procedure Code of Ukraine are relevant, especially regarding the civil forfeiture procedure in cases of unexplained wealth. In addition to the sanctions listed above, the LPC provides for disciplinary liability for corruption and corruption-related offences.
While a clearly defined and strict sanctioning regime for corruption is critical to avoid impunity and enforce legislation, the primary goal of the enforcement logic is to deter corrupt behaviour through control, detection and punishment. As a complementary approach, codes of conduct and codes of ethics guide and incentivise behaviour in line with integrity standards. Codes of conduct clarify expected standards and prohibited situations, whereas codes of ethics identify the principles that guide behaviour and decision-making (OECD, 2020[10]).
Although Ukraine’s legal framework for anti‑corruption and integrity is well established through various codes and laws, principle-based standards – such as those outlined in codes of ethics and codes of conduct – are neither widespread nor sufficiently valued. Legislative measures have tended to take precedence, but Ukraine is encouraged to complement its system with stronger ethical codes. There are four examples on the national level, all of which were adopted or updated recently, in 2023 or 2024. This suggests that the development and implementation of ethical principles is a relatively new dynamic in Ukraine. Examples include:
General Rules of Ethical Behaviour of Civil Servants and Officials of Local Self-Government, adopted in 2016 and updated in 2023, outline principles and standards similar to the Rules of Ethical Conduct. All civil servants must familiarise themselves with the General Rules upon entering the civil service (see Chapter 2).
NABU Director’s Order No. 242 of 1 September 2016, "On the Approval of the Code of Professional Ethics for Employees of the National Anti‑Corruption Bureau of Ukraine" (as amended).
Code of Professional Ethics and Conduct of Prosecutors, approved by the All-Ukrainian Conference of Public Prosecutors on 27 April 2017 (with relative amendments). On 23 November 2022, the Council of Prosecutors of Ukraine approved the Commentary to the Code, which contains, among others, explanations of its provisions, case studies and the results of its practical application.
Code of Judicial Ethics (Decision of the Congress of Judges, 18 September 2024) outlines the conduct expected of judges both inside and outside of official duties (see Chapter 4).
Code of Ethics of Internal Audit Unit Employees was approved by Ministry of Finance Order No. 1217 of 29 September 2011 and provides guidance for internal auditors in public organisations (see Chapter 5).
Rules of Ethical Conduct of Lobbying Entities (as stipulated in Article 6.1 of the Law on Lobbying 3606-IX) outline general rules of ethical conduct for lobbying entities, and provisions for lobbying ‘subjects’ who interact with lobbying ‘entities’, clients, and beneficiaries and other lobbying entities) (see Chapter 3).
1.2.2. Ukraine has a well-developed institutional system that covers all integrity functions. However, specialised anti‑corruption bodies require more resources, regular law-enforcement system needs improved accountability, and external oversight bodies should be more strongly integrated into the overall system
Complementing a clear legal framework, promoting public integrity also requires clear institutional arrangement. A public integrity system typically involves many different official actors in the public sector that cover the various functions of an integrity system (Table 1.1). The 2017 OECD Recommendation on Public Integrity recommends that adherents “clarify institutional responsibilities across the public sector to strengthen the effectiveness of the public integrity system”, in particular through clear responsibilities, appropriate capacities, and sufficient coordination (OECD, 2017[1]).
Sources: Adapted from OECD (2009[13]), “Towards a sound integrity framework: Instruments, processes, structures and conditions for implementation”, https://www.researchgate.net/publication/281280788_Towards_a_sound_integrity_framework_instruments_processes_structures_and_conditions_for_implementation; OECD (2017[1]), Recommendation of the Council on Public Integrity, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
Ukraine has a comprehensive system of specialised anti‑corruption bodies, complemented by other bodies with anti‑corruption competencies (Figure 1.5), which covers all integrity functions in the public sector (Table 1.1). The functions under the “System” pillar are mainly covered by the NACP, which is responsible for the development and monitoring of the implementation of integrity policies and ensuring horizontal and vertical coordination. The NACP sets and officially interprets integrity standards (e.g. regarding conflict-of-interest regulations).
The functions under the “Culture” pillar are shared between the NACP and the National Agency of Ukraine on Civil Service (NAUCS). The NACP covers such functions as awareness raising through civic education and capacity building for authorised persons for corruption prevention and is also responsible for ensuring whistleblower protection and guiding integrity-related work in the private sector. NAUCS is responsible for Human Resources Management in the Civil Service, including competitions for civil service positions, evaluation and career promotion standards, organisational culture, including openness mechanisms, and methodological support to Human Resource managers in the public sector.
The functions under the “Accountability” pillar are widely distributed in Ukraine. The NACP is responsible for strategic, sectoral corruption risk assessments (CRA), as well as the methodology for CRA in public organisations. The NACP leads the work on conflict of interest and lobbying, and implements integrity measures in political financing, a function it shares with the Central Electoral Commission. Additional external oversight bodies critical for the integrity system include the Accounting Chamber of Ukraine (ACU), which conducts external audits, and the Ukrainian Parliament Commissioner for Human Rights.
To implement enforcement mechanisms, Ukraine has a strong core of specialised anti‑corruption bodies. NABU is responsible for investigation of corruption cases involving high-ranking officials or large amounts of public funds. SAPO is an independent unit of the Prosecutor General’s Office (Regulation on the Specialised Anti‑Corruption Prosecutor's Office of the Prosecutor General's Office", approved by the Order of the Prosecutor General no. 125 of 5 March 2020), which provides procedural guidance and supports public prosecution in the High Anti‑Corruption Court in proceedings falling within the jurisdiction of NABU.
The High Anti‑Corruption Court (HACC) is the highest specialised court in the Ukrainian judicial system, functioning since 2020 based on the Law on the High Anti‑Corruption Court. HACC tasks include reviewing proceedings on corruption crimes investigated by the NABU; and passing judgment as a court of first instance and appeal.
The National Agency of Ukraine for Finding, Tracing and Management of Assets Derived from Corruption and Other Crimes (ARMA) is a central executive body with a special status and task for finding, tracing and management of assets derived from corruption.
Sustaining positive development of specialised anti‑corruption bodies by ensuring required resources
The five specialised anti‑corruption bodies were developed as a priority measure in the anti‑corruption reform after the 2013-14 Revolution. They started operating as a coherent system only after 2019, when the judges of the HACC assumed their work, and the NACP was re-booted. This system shows the results in the increasing numbers of detected, investigated, and adjudicated corruption cases on the high political level, which addressed the longstanding issue of impunity for grand corruption in Ukraine (NACP, n.d.[14]). In 2024 alone, NABU and SAPO started 658 new criminal cases, including 95 in the defence sector, 37 in the energy sector, and 101 related to law enforcement and oversight bodies. Among the high-profile cases were investigations involving former members of parliament, ministers, customs, and tax officials linked to a multimillion-dollar graft. Assets worth UAH 6.8 billion (approx. EUR 150 million) were seized.1 Furthermore, the policymaking and prevention functions have been institutionalised through the central role of the NACP, which has made good progress in delivering results and has shown strong political independence (European Commission, 2023[15]). Civil society has recognised the improvement of the NACP’s capacity, governance, and coordination between 2020 and 2023, despite the escalation of war from 2022 (Figure 1.5).
Note: Scores assess agencies’ capacity, governance, and coordination on a five-point scale with five being the best score.
Source: TI Ukraine (2023[16]), “Capable, effective and independent: Analysis of anti‑corruption agencies”, https://ti-ukraine.org/en/research/capable-effective-and-independent-analysis-of-anti‑corruption-agencies/.
The specialised anti‑corruption bodies have several mechanisms preventing political or executive interference and ensuring their independence and accountability. These safeguards are entrenched in the relevant laws, and in the case of SAPO, in specific regulations. These mechanisms include transparent and competitive, merit-based procedures for the selection and appointment, as well as special procedures for termination of powers of the Heads and special procedures for financing and logistics. In addition, the operation of the public councils at NACP, NABU and ARMA ensure societal accountability. In addition, NACP (Cabinet of Ministers of Ukraine, 2023[17]) and NABU (Cabinet of Ministers of Ukraine, n.d.[18]) undergo independent external evaluations, which is also to be conducted for SAPO. ARMA is the subject to an external audit by the Accounting Chamber of Ukraine (ACU) (Accounting Chamber of Ukraine, 2024[19]). SAPO’s independence guarantees under the Prosecutor General’s Office (PGO) were strengthened by the Law on Amendments to the Criminal Procedure Code of Ukraine and Other Legislative Acts of Ukraine on Strengthening the Independence of the Specialised Anti‑Corruption Prosecutor's Office 3509-IX of 8 December 2023, which provides for SAPO as a separate legal entity. The procedure of ensuring merit- and integrity-based selection of HACC judges is considered effective and should serve as an example to follow in other areas of judicial reform (U4, 2020[20]) (see Chapter 4).
The sustainable development of the specialised anti‑corruption bodies requires sufficient human, technical and financial resources, in addition to the specific technical issues identified in their external assessments.
The NACP is entitled to have up to 408 employees with around 12% of positions vacant as of 31 December 2024, due in part to comparatively low salaries. Since 2023, the Parliament has increased the number of NABU’s staff from 700 to 1000 employees, that will be hired until 2026 through an open competitive process (Verkhovna Rada of Ukraine, 2023[21]). SAPO is entitled to the number of employees equivalent to 15% of NABU’s staff (Verkhovna Rada of Ukraine, 2014[22]). The number of HACC judges has also increased from 39 to 63 positions, and from 12 to 21 positions in the Appeal Chamber (High Council of Justice, 2023[23]). In addition to the complex, ongoing selection process, the Court struggles to ensure reasonable working conditions, such as office space and technical support for the new staff (see Chapter 4).
Improving effectiveness of corruption investigations by following assigned responsibilities in practice
Besides the specialised anti‑corruption bodies, other law enforcement agencies have selected competencies regarding corruption offences. The National Police (NP) investigates most crimes, including corruption, that do not fall within the competence of NABU and the State Bureau of Investigation (SBI) and draws up most of the administrative reports on corruption-related offences. The Economic Security Bureau (ESBU) investigates economic crimes, which can overlap with corruption. SBI investigates crimes which can also overlap with corruption, committed mainly by top officials, law enforcement officers, and organised crime groups. The Security Service of Ukraine (SSU) conducts operational and investigative activities against national security and public safety that may coincide with corruption offences. The General Prosecutor’s Office (GPO) provides procedural guidance and support to the prosecution in general courts in cases of NP, SBI, and SBU. Their cases fall under the jurisdiction of regular local and appeal courts.
The OECD Recommendation on Public Integrity stresses the importance of clearly defined institutional responsibilities to ensure an effective and coordinated integrity system in which well-defined roles and mandates help prevent overlaps, fragmentation, and gaps (OECD, 2017[1]). This recommendation is relevant for pre-trial investigations in Ukraine, where the competences in the investigation process among the five bodies are delineated in Art. 216 of the Criminal Procedural Code of Ukraine (Verkhovna Rada of Ukraine, 2012[24]). NABU has primary responsibility to investigate corruption offences committed by high-level public officials or pre-defined monetary value.2 In such cases, other investigative bodies should redirect their cases to NABU. However, the SBI report from 2023 indicates that the Bureau referred to court 353 indictments of corruption against 468 persons with the estimated damage of UAH 695 million (ca. EUR 16 million) (SBI, 2023[25]). The report of the SBI Public Council indicates that among the indictments were two Members of Parliament, four former Members of the Cabinet of Ministers and two “A” category public officials (State Bureau of Investigation Public Council, 2024[26]). Furthermore, the SBI and SSU often engage in investigations that fall under NABU’s mandate. Such actions blur the legal boundaries between law enforcement agencies and underscore the need for stronger legal safeguards to protect NABU’s investigative mandate (European Commission, 2023[15]). The joint civil society shadow report on EU accession raises concerns about parallel or joint pre-trial investigations of NABU with ESBU or SBI, and public exposure of corruption cases by SSU (TI Ukraine, 2024[27]). Failure to comply with the rules of jurisdiction could result in pre-investigation evidence deemed inadmissible in court or violate the principles of presumption of innocence and double jeopardy.
Ensuring the accountability of regular law enforcement agencies through a competition- and integrity-based selection process for leadership positions along with public oversight
A further challenge for Ukraine to tackle in the public integrity system is the lack of accountability mechanisms in the regular law enforcement system, especially in the appointment process for leadership positions, along with public oversight. Unlike in specialised anti‑corruption bodies, the selection of the Head of the National Police does not follow a similar competitive and integrity-based procedure (Verkhovna Rada of Ukraine, 2015[28]). Currently, the Prosecutor General (PG) is appointed by the President and confirmed by the Verkhovna Rada. The Verkhovna Rada may also remove the PG through a vote of no confidence. There are no transparent, merit-based procedures for the selection (or dismissal) of the PG, nor for other managerial-level prosecutors. The selection procedures of SBI and ESBU are based on merit-based competition, but a civil society coalition questions the impartiality of the selection commissions and the lack of integrity requirements for the candidates in the selection process (TI Ukraine, 2024[27]). The changes to the selection procedures for the head of ESBU have been adopted by law but are yet to be implemented (Verkhovna Rada of Ukraine, 2024[29]). These changes align with the selection model used for the heads of specialised anti‑corruption bodies, involving international representatives. Both SBI and ESBU have operating Public Councils to ensure public scrutiny (SBI, n.d.[30]; Economic Security Bureau of Ukraine, n.d.[31]), while the public oversight of the National Police has been limited under martial law, according to the civil society coalition (TI Ukraine, 2024[27]).
Integrating external oversight functions into the public integrity system
The public integrity system also includes “complementary” actors whose primary role is to indirectly support the integrity framework. Without these actors, the system could not function effectively. Institutions responsible for education and capacity building, freedom of speech and vital civil society, human resource management, as well as supreme audit institutions (SAI), regulatory agencies, and the electoral commission, all play a role in upholding integrity functions (Table 1.2). Regardless of where the responsibilities are assigned, governments should ensure that these actors have the appropriate level of authority to carry out the functions effectively (OECD, 2020[10]).
Ukraine should consider re-assessing the role of external oversight bodies and integrating them into the public integrity system. Ukraine’s system of public integrity has primarily evolved around specialised anti‑corruption bodies, while other key bodies remained either weak in their powers and capacities, or unreformed. For example, while the Parliamentary Commissioner for Human Rights is among the most trusted public bodies in Ukraine, the Office does not have sufficient powers to fully implement and monitor access to public information (see Chapter 3). Ukraine’s Supreme Audit Institution, the Accounting Chamber of Ukraine (ACU), has only recently begun its systemic reform towards achieving meaningful institutional independence and impartiality in external audits with the passage of the law in October 2024 (see Chapter 5). In the judiciary system, the main Administrative Court in Ukraine is yet to be formed, as the former Kyiv District Administrative Court has been resolved because of major systemic corruption cases revealed by NABU (Chapter Judiciary). Regulatory enforcement agencies are crucial actors in the public integrity system, that ensure compliance with the rules and regulations among public and private organisations. Although not the focus of this Integrity Review, the broader view of public integrity in Ukraine highlights the need to ensure the integrity of these institutions. Similarly, the regulatory bodies in Ukraine did not undergo a systemic reform. The NACP index of corruption-prone sectors indicates high levels of corruption in regulatory activities (NACP, n.d.[32]). Furthermore, the reports of the Business Ombudsman in Ukraine raise major integrity concerns regarding the private sector towards the regulatory enforcement agencies (Business Ombudsman Council, 2023[33]). Thus, while some external oversight bodies require reform to ensure their own integrity, others need a revision of their powers and capacities.
The 2017 OECD Recommendation on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks (OECD, 2017[1]). A strategic approach, usually developed through strategic documents, can shift a country’s focus from ad hoc integrity policies to a coherent and comprehensive integrity system (OECD, 2024[9]). A strategy design should follow the whole-of-society principle to ensure public interest and prevent policy capture.
The OECD PIIs show that Ukraine’s 2021-2025 strategic framework for integrity has high quality and meets most of the OECD baseline criteria (Figure 1.6). The National Anti‑Corruption Strategy (herein NACS or Strategy) 2021-2025 has a broad coverage, addressing most areas traditionally prone to corruption, including human resource management, public procurement, reducing fraud and other types of corruption in the public sector. However, it does not include strategic objectives for mitigating public integrity risks in public financial management or in internal control. The NACS is evidence-based and grounded in an assessment of public integrity risks, including a detailed situation and problem analysis (NACP, 2022[34]). The outcome level indicators and their target values are defined for all expected strategic results. Ukraine demonstrated a high level of inclusiveness and transparency in designing the current Strategy and State Anti‑Corruption Programme (SACP). The NACP conducted inter-institutional and public consultations which is published and accessible on their website (NACP, n.d.[35]). The published working materials show which actors provided suggestions and whether they were considered or declined with explanations (NACP, 2020[36]).
Source: OECD (2024[11]), OECD Public Integrity Indicators Database, https://data-explorer.oecd.org/ (accessed on 5 November 2024).
To implement the NACS 2021-2025, the SACP has been launched for 2023-2025, with some delay due to the late adoption of the Strategy and the war in Ukraine. The NACS comprises 3 chapters, 16 areas, 73 problems, 271 expected strategic results and 1146 measures to be implemented by 109 public bodies. The NACP is responsible for monitoring the implementation of the NACS and uses the online interactive Information System for Monitoring the Implementation of the State Anti‑Corruption Programme (ISM SACP) to manage public and internal communication with implementing bodies (Box 1.1). The system allows for transparent public monitoring of allocated responsibilities with deadlines for outputs and benchmarks to measure outcomes. Non-governmental actors can provide their own assessments regarding implementation.
Despite the overall high quality of the NACS, its broad consultative process among institutional stakeholders and relatively high adequacy of the implementation structures and reporting, three interlinked issues undermine its full effectiveness:
First, some unfulfilled PII criteria indicate the insufficient inter-institutional ownership of the NACS. For instance, while the NACP spearheads and coordinates the development of the Strategy, OECD good practice highlights the need for an inter-institutional body, representing diverse sectors across government, as well as the NACP, to take full ownership of both the Strategy’s development and its implementation monitoring. Such a body would enhance engagement and political commitment, ensuring that public integrity risks – both country-wide and sector-specific – are effectively considered. It would enable well-informed decision-making and distribute genuine responsibility for implementing reforms, rather than merely ensuring compliance with assigned tasks. Additionally, the inter-institutional body could develop an analytical report on public integrity risks, issuing specific recommendations and setting clear priorities for the entire public integrity system. This approach would hold all stakeholders accountable, ensuring they actively contribute to and take responsibility for the success of integrity reforms. Besides that, inter-institutional consultations could be conducted to discuss monitoring reports of individual sectors and administrations, as required by the LPC.
Second, the de facto implementation rate of the SACP is quite low compared to the OECD average. Just over 500 measures are planned for the final quarter alone of 2025. Notwithstanding the external factor of the war, which has undermined effective implementation, the design of the anti‑corruption programme’s implementation rate suggests it is unlikely that all measures will be implemented by the end of the implementation year.
Third, limited evaluation practice of previous strategies and the inadequate integration of lessons learned to inform new strategies indicates a lack of continuity of the strategic framework. The overlapping policy cycles between strategies disrupts a sequential monitoring of implementation and fails to fulfil the gap. Although the current Strategy foresees such an evaluation, no systemic outcome and impact assessments were conducted for the NACS 2014-2017. Annual monitoring reports assessed the outputs of the activities (NACP, 2017[37]) and an analytical study was conducted by external experts and issued by the EUACI (EUACI, 2019[38]); however, these efforts remain fragmented. It is critical that such assessment is conducted by the national authorities through an inter-institutional mechanism and ensures a systematic transfer of knowledge, capacity and strategic aims. Each approved and implemented strategy should build on the lessons learned from its predecessor. Addressing the ‘continuity gap’ from 2021-2025 to 2026-2030 remains crucial. This section provides recommendations to address these three issues.
1.3.1. Ukraine could reinforce an inter-institutional working approach in the anti‑corruption policy cycle to ensure the commitment and engagement of key stakeholders for an effective and continuous public integrity strategy
Effective implementation and sustainability of integrity strategies requires commitment at the highest political and management levels. To gather the necessary support for the strategy and the suggested reforms throughout the administration, it is key to ensure the appropriate participation of representatives of relevant government agencies, departments or units affected by the strategy in the initial drafting phase (OECD, 2020[10]). While many countries develop integrity frameworks in individual ministries or agencies, it is only when adopted at the highest levels, following a discussion by and among various ministries or ministers and members of the government, that strategies achieve greater recognition of corruption risks and policy solutions across the political spectrum and the public administration (OECD, 2024[9]). An advantage of involving key actors (responsible for implementation, enforcement and monitoring) in the strategy design process can improve their cooperation, which is critical to the effectiveness of the integrity system (OECD, 2020[10]).
The Law on Prevention of Corruption (LPC), Section 3 provides for the anti‑corruption policy cycle to be ongoing and inclusive, with the NACP leading the process. The NACS, developed by NACP is grounded in a statutory framework – a key difference from previous strategies since 2014 – ensuring political commitment and a high legal status for the Strategy. The SACP, designed by the NACP, is adopted by the Cabinet of Ministers within six months after the adoption of the Strategy. During the policy design phase, the NACP developed the ongoing 2025 Strategy and Programme through transparent public and inter-governmental consultations, a model that can be considered a good practice for other countries (Box 1.3).3
The National Anti‑Corruption Strategy:
Designed by the NACP (1 August of the year in which the previous Strategy expires), based on the analysis of corruption issues and the implementation results of the previous Strategy, approved by law by the Parliament of Ukraine (Art. 18).
Implemented through the State Anti‑Corruption Programme (SACP), designed by the NACP, and approved by the Cabinet of Ministers (6 months from the entry into force of the law approving the Strategy). Measures are mandatory for implementation (Art. 181).
Coordinated by the NACP. The Coordination Working Group on Anti‑Corruption Policy (CWG) shall be established under the NACP as an advisory body, consisting of implementors of the SACP and voluntary members of the Parliament, co-chaired by the Head of the NACP and the Minister of the Cabinet of Ministers of Ukraine (Art. 182).
Public information about the implementation results should be provided by the NACP to the Cabinet of Ministers annually by 1 April based on the updates provided by implementing bodies to NACP twice a year on 15 February and 15 July (Art. 183).
Monitoring and evaluation of the effectiveness of the implementation is conducted by the NACP and is publicly accessible through the Information System for Monitoring the Implementation of the State Anti‑Corruption Programme (ISM SACP) (Art. 183-4).
Amendments can be initiated by the NACP based on the results of monitoring and evaluation of the effectiveness of the implementation, and with public consultations (Art. 18, 18 (1)).
Effectiveness assessment of the Anti‑Corruption Policy is published in the National Report, prepared by the NACP based on the impact analysis in the year of completion of the Strategy, no later than 1 April (Art. 20).
Source: Verkhovna Rada of Ukraine (2015[12]), Law on Corruption Prevention 1700-VII, https://zakon.rada.gov.ua/laws/show/en/1700-18#top.
The NACP reports they held numerous consultations, both written and in person, with various state and implementing authorities in developing the SACP, in line with the decision of the Government Committee on National Security and Defence and Law Enforcement on 9 January 2023. The NACP received 127 approvals/statements during the SACP consultation, 80 without comments and 47 with comments and/or suggestions. Additional suggestions from 24 other bodies were partially considered.
Despite the strong legal status of the Strategy and broad consultation, the inter-institutional ownership of the Strategy is lacking both in its design and further monitoring of its implementation. Active engagement and participation of stakeholders is critical for co-ownership of integrity reforms, without which implementation of the SACP cannot be sustainable. According to the NACP monitoring system, most public organisations did not implement the required measures foreseen in the SACP (NACP, n.d.[39]).
The NACP’s regulations foresee three coordination mechanisms for the implementation of the SACP to ensure continuity of the NACS and increase whole-of-government ownership in the design of the new Strategy: the NACP coordination unit, sectoral coordination-monitoring groups, and the Coordination Working Group on Anti‑Corruption Policy (CWG).
An additional coordination instrument for the involvement of key ministries in the implementation of the SACP is establishing inter-governmental sectoral coordination and monitoring groups. For example, such a group has been established to address the challenge of financial shortfalls with regards to digitalisation tools under the SACP, which informs and supports SACP implementors in acquiring finance to develop new or modernise existing IT tools. This practice can be applied to other priority spheres, such as judiciary, taxation and customs, construction, land and infrastructure (Box 1.4).
Digital transformation is one of the five principles of the 2021-2025 National Anti‑Corruption Strategy in Ukraine. Accordingly, development and integration of digital tools is foreseen as one of the cross-cutting solutions in all high-risk areas. The SACP includes 123 measures aimed at design of new or modernisation of existing 63 digital tools. Implementation of these measures is often delayed or challenged by budget short-cuts, according to information provided by the NACP for the PII assessment.
To address this implementation challenge, the coordination-monitoring group for implementation of digitalisation-related measures is functioning since August 2023. The group is chaired by the Minister of Digital Transformation of Ukraine and the Head of NACP. Members of the group include representatives of the Ministries of Finance, Justice, but also representatives of the major technical assistance projects. Participants of the meetings include SACP implementing bodies dealing with digital tools.
The meetings of the group serve to:
exchange about the challenges related to digitalisation measures that can be addressed by the responsible Ministry
provide overview of financial instruments available by technical assistance projects to overcome public budget gaps
raise awareness among the implementing bodies about the economic and social effects of the foreseen IT tools to support political will.
Source: NACP (2023[40]), Regulation about the Sectoral Working Group on Digitalisation, National Agency on Corruption Prevention, Kyiv, Ukraine.
To ensure a whole-of-government commitment and approach to anti‑corruption policy, the NACP could initiate the work of the CWG in the implementation process of the current Strategy and ensure the continuity of the established cooperation in designing the new Strategy. The NACP reports the Group is scheduled to hold its inaugural meeting in April 2025. The tasks of the group, outlined in the NACP regulation of 21 May 2024, are twofold: first, to support the implementation of the Strategy and the Programme, and second, to work towards proposals for the development and implementation of the anti‑corruption policies (NACP, 2024[41]). This includes discussing the first evaluation of the effectiveness of the implementation of the NACS and SACP, as well as preparing a report on the effectiveness of the implementation of the state anti‑corruption policy. Thus, based on the NACP’s evaluation of implementation, the group will identify the reasons for delays and support proper implementation. In addition, the CWG moderates and considers proposals by the sectoral coordination groups to improve overall implementation. The CWG can provide recommendations for the NACP to improve the design and implementation of anti‑corruption policies. The Group also informs the public and supports cooperation between the implementors of the anti‑corruption program and representatives of the international technical assistance projects.
While the CWG and sectoral groups described above were originally designed to coordinate implementation of the 2023-2025 SACP, they could also be used as a mechanism to ensure whole-of-government engagement in the design of the upcoming 2026-2030 Strategy. The NACP Regulation provides for the interaction between the CWG and sectoral monitoring groups, allowing sectoral groups to submit proposals to the CWG based on implementation progress. In preparing for the next strategy, these groups could contribute to the evaluation of the 2021-2025 Strategy and systematically reflect on the lessons learned. By consolidating inputs from the sectoral monitoring groups and from the NACP, the CWG could play a central role in ensuring inter-institutional ownership and commitment in the new strategy cycle besides the NACP.
The NACP could use the CWG’s inaugural meeting in 2025 to launch a structured timetable of regular activities extending through the design and implementation of the 2026-2030 Strategy. For sustainability, the composition of the CWG could be revised. Currently, the LPC stipulates the participation of all implementors of the SACP and Members of Parliament, resulting in an excessively large group of (over 100 participants). A more effective approach could limit participation to key decision-makers from priority sectors, with the potential inclusion of international partners and civil society representatives.
Greece provides an example of an inter-institutional approach to the design of the country’s Anti‑Corruption Action Plan 2022-2025 that ensures whole-of-government ownership and high-level commitment to the anti‑corruption policy across the government (Box 1.5).
Greece’s National Anti‑Corruption Action Plan (NACAP) 2022-2025 was developed through an extensive consultation process. For the coordination of the consultation process, a Central Coordinating Committee (CCC) was established to ensure ownership and high levels of commitment. The Greek Cabinet has a supervisory and strategic role in the CCC because it approves the final draft of the Action Plan and any major upcoming revision. Further members of the CCC are representatives of the Presidency of the Government, the General Secretariat for Coordination, and the Ministries of Interior, Finance, Justice, and Digital Governance. The representatives of the Court of Auditors also participate as observers.
The role of the specialised anti‑corruption body – the National Transparency Authority (NTA) – is to moderate the process of consultation and monitoring of NACAP's implementation. NTA also plays the role of a major implementation actor in NACAP 2022 – 2025. The General Directorate of Integrity and Accountability has a variety of competencies distributed in various departments relevant to prevention initiatives.
Source: European Commission (2023[42]), Handbook of Good Practices in the Fight against Corruption, http://dx.doi.org/10.2837/575157.
1.3.2. The NACP developed several prioritisation mechanisms to address the implementation gap of the strategy, which should be tested and refined during the implementation of the ongoing strategy and applied to the next strategy
Implementation gaps, in which countries’ regulatory frameworks are not fulfilled in practice, are among major challenges to the integrity frameworks in OECD countries (OECD, 2024[9]). Strategic objectives may be meaningful but not met if management structures, processes, information technology, data registries and staffing are inadequate or if time and budget are insufficient to put ambitions into practice. In establishing objectives, the strategy designers need to match expectations with the implementation capacity, the time needed, and the available resources of the public administration. It is crucial to avoid developing an unrealistic “wish list”. Prioritisation in strategy development can be done through establishing short-, medium- and long-term objectives and sequencing the implementation of activities (OECD, 2020[10]).
In Ukraine, the implementation gap is below the OECD average. As of March 2025, 318 measures (28%) of the total 1 146 measures were fully completed, and 101 measures (9%) partially completed. 277 measures (24%) are in progress, with a deadline of December 2025, and can only be considered completed after the latest monitoring report. 360 measures (31%) have not yet started. The NACP reports that “not started” indicates the planned measures and activities that implementing authorities should start in 2025 and is not a negative indicator on the rate of implementation. The 90 measures (8%) indicated as “not completed” should theoretically have been completed but have not been implemented (either partially or fully). According to the NACP, this indicator alone has a negative impact on the pace and content of the SACP implementation. In addition, 514 measures are foreseen for the last quarter alone of the final implementation year. The NACP reports that the final monitoring of the implementation of the current SACP will be conducted in 2026. Although this indicates that their assessment will be captured in the end-term evaluation of the current Strategy, it may be too late to be considered in the design of the new Strategy (Figure 1.8).
Source: National Agency on Corruption Prevention.
The NACP reports that one of the challenges for public authorities to adequately implement the Strategy is the relatively short period of time – three years instead of five – in which it has been in force, due to delays in its final adoption, as well as the fact that the Parliament did not extend its validity for a sufficient period and the Government lacked the authority to do so. The martial law context has exacerbated this challenge.
To ensure the adjustments of the SACP to the implementation challenges, on 18 October 2024, the Cabinet of Ministers of Ukraine made changes to the SACP, initiated by the NACP (Cabinet of Ministers of Ukraine, 2024[43]). The design of the adjustments was a lengthy process, with 85 public bodies participating in 30 expert meetings and public consultations (NACP, 2024[44]). The changes are aligned with the new conditions under martial law, strategic state documents and the redistribution of powers among public authorities, while also enabling the attraction of international technical assistance funds. On the one hand, this adjustment demonstrates that the legal instrument for agile policy design in the LPC (Art. 18) is operational. On the other hand, anticipating the implementation challenges of the current Strategy in the next one could avoid repeating shifting deadlines.
To improve evidence-based prioritisation, the NACP significantly improved the coherence of the data for the overall problem analysis and for prioritising corruption-prone sectors in at least three ways:
Systematised statistical data tracing information about the criminal and administrative procedures in corruption cases, whistleblowing-related data, information on specially authorised anti‑corruption entities, and information on cooperation with NGOs and international partners (NACP, 2023[45]).
Developed the index of corruption-prone areas, which supports strategic sectoral prioritisation (Box 1.6).
Created the dashboard overview of functions and powers of the authorities in the spheres of state policy. This allows the identification of responsible stakeholders but also the detection of duplications of functions undermining not only the implementation of the SACP but also the effectiveness of governance.
The aim of the index is to combine statistical and survey data for ranking of corruption-prone spheres to prioritise them in anti‑corruption policy. The baseline list of 35 spheres has been set based on the expert surveys conducted in 2021 and 2023. The single data points are interpreted and combined into an integral value.
Based on this methodology, in 2024, NACP identified 18 highly corruption-prone spheres. The top five are: law enforcement activities and investigations (except for street police); customs service (for business); oversight and control of business activities; land and constructions; and customs and border crossing for individuals.
Source: NACP (2024[46]), Method of Determining the Index of Corruption of the Spheres of Public Life, https://dap.nazk.gov.ua/uploads/osr-29/zahid-36/sources/808-1144807137-671f977ddb1b2.pdf.
The evidence- and risk-based approach to the prioritisation of areas provides a solid basis to re-assess the priorities of the current Strategy with a view to the next one. In addition to the rigorous problem-prioritisation, the NACP could advance the overall analytical process of the strategy design by developing an analytical framework to prioritise not only corruption risks but also response measures. The adjustments of the SACP outputs can take place on an annual basis, following the NACP’s regular monitoring reports. Importantly, the adjustments should follow the principles and legal requirements of transparency, as well as public and intra-governmental consultations.
1.3.3. The NACP could prepare and publish a national report on the effectiveness of the implementation of the state anti‑corruption policy, providing findings to the inter-institutional body to inform the design of the upcoming strategy and ensure continuity
A strategic approach to public integrity foresees not only benchmarks and indicators on the level of implementation but also a credible assessment of the overall performance and effectiveness of the public integrity system (OECD, 2017[1]). A strong evaluation, incorporating a structured review of the strategy, is essential to embed learning in the policy cycle and improve the effectiveness of the anti‑corruption framework. Evaluation reports for integrity strategies should be made publicly available, and it is often useful to include non-state actors either as evaluators or as part of a formal quality assurance process. Monitoring data should be used actively in the evaluation reports, and the ultimate goal is for the evaluation exercise to improve approaches and practices, for example, by informing the design of follow-up initiatives (OECD, 2020[10]).
Ukraine has an advanced monitoring system of the SACP implementation, covering both the monitoring of individual measures as well as specific benchmarks of the outcome indicators for the Expected Strategic Results. The implementation monitoring is open to the assessment of the public. While some evaluation was conducted on the 2014-17 Strategy, (NACP, 2017[37]; EUACI, 2019[38])4, it was perceived as limited, which could explain a perception of ineffective evaluation. This could be improved by incorporating more frequent and in-depth evaluations. Furthermore, the lack of such evaluation undermines the continuity of the public integrity strategy in the country. According to LPC Art. 20, the NACP is tasked to prepare and publish a report on the effectiveness of implementing the state anti‑corruption policy by 1 April 2025. By providing an assessment of the 2021-2025 Strategy, the results of an evaluation can inspire a more effective future strategy design.
The NACP states that one of the main challenges for effective monitoring is the consecutive policy cycles between current and future strategies. The new Strategy will already enter into force before a full and complete evaluation of the previous Strategy can be conducted, as the LPC requires the NACP to prepare a national report on implementation in April 2025, which is before the end of the 2021-25 NACS and SACP. The overlapping policy cycles therefore create challenges in ensuring the formation, coordination and monitoring of anti‑corruption policy as well as its consistency and continuity.
Good evaluations seek to understand whether a strategy was effective in fulfilling its objectives and achieving intended impacts. In addition, they determine its relevance within its context and for different groups in society, including marginalised people. They also seek to assess a strategy’s coherence, sustainability and efficiency. The OECD Development Assistance Committee (DAC) outlines six criteria NACP could consider structuring the 2021-2025 Strategy evaluation (Table 1.4).
Source: Adapted from OECD (2021[47]), Applying Evaluation Criteria Thoughtfully, http://dx.doi.org/10.1787/543e84ed-en.
Fostering public integrity is not only a responsibility of specialised anti‑corruption bodies or central government. Actors across the whole of government (legislative, executive and judicial) as well as across all levels of government (national and sub-national) have a responsibility for public integrity. Responsibilities are also found within each public sector organisation. All public officials at all levels of government are expected to carry out their duties in the public interest (OECD, 2020[10]).
To prevent fragmentation and overlap in the public integrity system, the OECD Recommendation on Public Integrity recommends that adherents “clarify institutional responsibilities across the public sector to strengthen the effectiveness of the public integrity system, in particular through:
establishing clear responsibilities at the relevant levels (organisational, sub-national or national) for designing, leading and implementing the elements of the integrity system for the public sector
ensuring that all public officials, units or bodies (including autonomous and/or independent ones) with central responsibility for the development, implementation, enforcement and/or monitoring of elements of the public integrity system within their jurisdiction have the appropriate mandate and capacity to fulfil their responsibilities
promoting mechanisms for horizontal and vertical cooperation between such public officials, units or bodies and where possible, with and between sub-national levels of government, through formal or informal means to support coherence and avoid overlap and gaps, and to share and build on lessons learned from good practices” (OECD, 2017[1]).
It should be noted that upcoming amendments to the Law on Local Self-Government (expected to be complete in 2026, according to Ukraine Plan) aim to delineate central and delegated powers among regional, district and local bodies, which could support establishing clear responsibilities concerning integrity-related functions. Notwithstanding future legislative changes, Ukraine has all the components in place to support the commitment of sectoral and local-level public organisations to public integrity. The LPC requires the leadership of public organisations to set the tone from the top and initiate actions for building public integrity. These include establishing authorised units for corruption prevention, assessing corruption risks, and adopting anti‑corruption programmes. The NACP provides methodological guidance and coordination support to these activities.
While the focus of the anti‑corruption in the last decade has been on building specialised anti‑corruption bodies, the mainstreaming of public integrity across sectors and into local self-governments took place sporadically and unevenly. As a result, some sectors remain highly prone to corruption, as the NACP index shows, despite significant progress in other areas. The same effect of extreme differences with regard to commitment to and implementation of public integrity measures is present on the local level across municipalities (Keudel, Grimes and Huss, 2023[48]; Keudel, 2025[49]). This section provides recommendations on mainstreaming public integrity principles and actions horizontally across sectors and vertically on the local government level.
1.4.1. The NACP could continue advancing the coordination of authorised persons for corruption prevention in public organisations and strengthen their role in the overall system of public integrity
While leadership plays the key role in initiating and supporting the culture of public integrity in their organisations (see more in Chapter 2), in Ukraine, authorised units or persons (also referred to as Anti‑Corruption Officers, herein “ACOs”) drive the analytical process behind the anti‑corruption programmes and implementation of the anti‑corruption measures on the organisational level. They fulfil key functions of corruption prevention in the system of public integrity. According to NACP’s estimations, between 10 000-12 000 ACOs were operating in Ukraine in 2024 (Box 1.7).
A broad range of public organisations are required to establish ACOs (Art. 13-1, LPC). They are accountable to the head of the respective organisation, who ensures the ACO’s independence. ACOs can be dismissed on the initiative of the head, but only with NACP’s consent.
The NACP approves the Model Regulation on the Authorised Units and establishes mandatory requirement for the minimum staffing of the authorised unit in public bodies. The main tasks of the ACOs include:
developing, organising and controlling the implementation of measures for the prevention of corruption and corruption-related offences
arranging assessment of corruption risks, proposing measures for their mitigation
providing methodological and advisory assistance on compliance with the anti‑corruption legislation
implementing measures to identify conflict of interest, facilitate its resolution, inform the head of the relevant authority and the NACP on detection of a conflict of interest, and measures taken to resolve it
verifying the fact of submission of asset and interest declarations by the subjects and notification of the NACP on cases of non-submission
control over the compliance with the anti‑corruption legislation
ensuring protection of whistle-blowers
informing the head of the relevant authority, the NACP or other specially authorised counter-corruption entities about the facts of violation of legislation on preventing and combating corruption.
Source: Verkhovna Rada of Ukraine (2015[12]), Law on Corruption Prevention 1700-VII, https://zakon.rada.gov.ua/laws/show/en/1700-18#top.
Although the NACP provides methodological support for the work of authorised persons, their overall work cannot yet be characterised as systemic or impactful. The NACP’s study on authorised persons highlights several challenges, including understaffing, involvement in unrelated tasks that may compromise their impartiality, insufficient skills for key responsibilities, and inadequate leadership support for fulfilling their duties effectively. These systemic issues undermine the broader goal of ensuring integrity in public organisations.
Furthermore, the systemic evaluation of their work and overall coordination remains limited. The NACP is mandated to evaluate the effectiveness of authorised persons’ activities under Article 11(11) of the LPC. This evaluation is conducted using the Methodology for Assessing the Effectiveness of the Work of Authorised Persons on the Prevention and Detection of Corruption, approved by NACP Order No. 164/23 of 1 August 2023. To enhance transparency, the NACP designed a public dashboard with assessments based on the annual reports provided by authorised persons (NACP, 2024[50]). As of January 2025, over 4 000 authorised persons were registered in the NACP’s registry, with 615 submitting reports in 2024.5 This is only a small fraction of the total number of ACOs in Ukraine.
Given the key functions of the ACOs, Ukraine could boost their role in the overall system of public integrity. To improve the overall system of ACOs, the NACP could advance the evaluation of the reports. Given the shortage of human resources, the NACP could reassess the feasibility of the number of public organisations that require authorised units.
In addition to the lack of human resources, integrity-related skill sets become increasingly specialised, technical and digital (from legal to investigative background, IT, public management, accounting, finance, sectoral knowledge, support functions, etc.). Several approaches can be used to make the most of ACO’s skills, including:
Talent pools can be established centrally and used to help individual organisations access skills that they may be unable to bring in on a permanent basis.
Rotation programmes can be established across various actors in the system, systematically trading employees for specific periods between, for example, local integrity offices. At the same time, a certain degree of labour stability and job security is important to build knowledge and expertise and reduce the learning curve regarding co-ordination among bodies.
Continuous and lifelong training and development can be prioritised.
Monitoring the quality and quantity of human resources for integrity systems across levels of government to identify bottlenecks and areas for improvement (OECD, 2020[10]).
1.4.2. The NACP could revise the methodological approach to developing anti‑corruption programmes by shifting from a narrow focus on corruption risk mitigation to a strategic integrity framework, and enhancing capacity-building on diverse public integrity instruments
Ukraine has three layers of strategic guidance for building integrity: (1) the NACS, (2) the SACP for public organisations and (3) municipal anti‑corruption programmes and integrity plans. The organisational programmes must be aligned with the NACS and contain the action points in the SACP foreseen for implementation by the relevant body. The specific, sectoral measures in the organisational anti‑corruption programme are designed based on organisational corruption risk assessment. The LPC provides for compulsory anti‑corruption programmes for high-risk public bodies, while the NACP advises other public bodies to develop one (Box 1.8). As of 2024, of the 162 public organisations required by the LPC to have an anti‑corruption programme, 140 organisations adopted such programmes, while 22 did not.
Public bodies identified as having a high corruption risk, including all ministries, Central Executive bodies, state bodies in judiciary and law enforcement, State Trust Funds, Verkhovna Rada, Office of the President, SCMU, Accounting Chamber, Regional State Administrations, Regional Councils and others, are required to implement anti‑corruption programmes (LPC Art. 19).
Anti‑corruption programmes in public organisations should include (LPC Art. 19 (2)):
Principles of the general departmental policy on preventing and combating corruption in the relevant area, measures for their implementation, as well as measures for the implementation of the National Anti‑Corruption Strategy and the State Anti‑Corruption Programme.
Assessment of corruption risks in the activities of a body, institution, organisation, the causes and the conditions that contribute to them.
Measures to eliminate the identified corruption risks, persons responsible for their implementation, deadlines and necessary resources.
Training and activities to disseminate information on anti‑corruption programmes.
Procedures for monitoring, evaluating and periodically reviewing programmes.
Others are aimed at preventing corruption and corruption-related offences.
Sources: Verkhovna Rada of Ukraine (2015[12]), Law on Prevention of Corruption https://zakon.rada.gov.ua/laws/show/en/1700-18#top.; NACP (n.d.[51]), Integrity Portal, https://antycorportal.nazk.gov.ua/.
While the organisational leadership sets the tone from the top and initiates the process of corruption risk assessments and development of the organisational anti‑corruption programme, the central role in developing the anti‑corruption programme is assigned to ACOs responsible for anti‑corruption. Their function is to facilitate a working group that assesses corruption risks and designs corresponding anti‑corruption measures. The NACP provided a methodology (NACP, 2021[52]) guiding this process and supports through capacity building (NACP, 2022[53]).
Although the compliance rate with the obligation to have an anti‑corruption programme is high, organisational strategic documents for public integrity are often perceived as formalities, as highlighted by authorised persons for corruption prevention during a focus group for this report. Moreover, the NACP survey of ACOs indicates that methodologically-speaking, corruption risk assessments are the most challenging exercise in their work (NACP, n.d.[54]). These two interconnected challenges can undermine the effectiveness of the overall strategic framework for public integrity if public organisations do not take their responsibilities seriously.
In practice, the design of anti‑corruption and integrity plans is mainly focused on the corruption risk assessments, guided by the detailed NACP methodology. However, a risk-based approach to integrity does not mean it should be risk-centred. While awareness of corruption risks in public organisations and their systematic assessment is a strong side of Ukraine’s public integrity system, an over-focus on corruption risks in strategic documents can undermine the effective functioning of public organisations. For example, additional layers of control and overregulation may mitigate corruption risks but reduce the discretion of public officials to react in a flexible way to crisis situations. Anti‑corruption and integrity plans should serve the purpose of the overall strategic development of the sector or municipality, while systematically considering specific corruption risks.
To shift the focus from a narrow and technical approach to anti‑corruption and integrity plans towards making those useful tools for the overall strategy of public organisations, three steps in the methodological guidance and capacity-building are helpful:
While the role and methodological guidance of the authorised persons remains important, to ensure internal risk management and control (see Chapter 5) and the strategic development of an integrity framework in public organisations the risk management process should ultimately be the responsibility of the leadership. This will lift the burden from authorised persons to perform the tasks associated with internal audit and control, in addition to other tasks. Instead, they should have strategic oversight of the organisational integrity framework and how to make it useful for the overall strategic goals of the public organisation or municipality.
Integrate sector-specific conflict of interest (COI) prevention and management into an assessment of corruption risks and anti‑corruption plans in public organisations. A systemic analysis of widespread ad-hoc COI situations can reveal sector-specific risks while also having a preventive effect if managed properly (see Chapter 2).
Close the knowledge and skills gap on public integrity instruments used in the organisational anti‑corruption and integrity plan. Currently, capacity-building is focused on training to work with corruption risks. Given the legal background of most authorised persons, responses to corruption risks are often focused on proposals to amend normative frameworks, reduce discretion through increased controls and similar measures. There is however a significant variation in approaches and instruments beyond legal changes that can enhance public integrity in organisations. Training programmes should address this diversity, systematically focusing on how to select appropriate integrity instruments, while taking into account the identified catalogue of corruption risks.
1.4.3. Ukraine could further strengthen the public integrity system in local self-governments (LSG), by improving coordination of integrity-related functions between LSGs and other levels of governance and establishing regional NACP chapters to support LSGs capacities for integrity
When assigning integrity responsibilities at the local level, there are several issues to consider. On the one hand, local governments face specific integrity risks: conflict-of-interest situations for example are more likely due to proximity to the community, with family and network ties a typical characteristic of the operational environment. On the other hand, local governments can face capacity limits in human, financial and technical resources, making it difficult to assign responsibility to an institution, unit or individual for all the functions (OECD, 2020[10]).
Ukraine’s decentralisation reform from 2015 to 2020 resulted in the creation of local self-governments, or hromadas. Over 12 000 administrative units were amalgamated into 1 470 functional hromadas, with increased political responsibilities (e.g. education, healthcare, social services) and more financial resources (60% of private income tax is allocated to hromadas).6 Reducing corruption and improving societal accountability by increasing proximity of decision-making to citizens was one of the goals of the reform. Research shows that the trust of amalgamated hromadas increased (Arends et al., 2023[55]). Some hromadas pioneered public integrity measures even before such obligations became compulsory (e.g. use of the ProZorro.Sale platform for transparent state auctions) (Keudel, Grimes and Huss, 2023[48]). Under war conditions, hromadas proved to be the backbone of societal resilience, as they continued providing public services, while demonstrating commitment to public integrity principles despite martial law (Keudel and Huss, 2024[56]). Some latest developments include the following:
Although the LPC does not oblige municipalities to have anti‑corruption programmes, the NACP encourages and supports such initiatives. The Association of Ukrainian Cities defines municipal integrity plans as “a strategic document that shows the path on the way towards transparent, accountable and effective work of local self-governance” (Association of Ukrainian Cities, n.d.[57]). It aims at preventing corruption, increasing citizens’ trust, contributing to economic development and ensuring effective use of public resources. The Association of Ukrainian Cities stresses that the municipal integrity plans “are not mere formality”, but the step to the overall community’s improvement. The Association of Ukrainian Cities provides a Handbook for municipal integrity plans (Association of Ukrainian Cities, 2024[58]) and the Ministry of Recovery provides a methodology for corruption risk assessments at the local level of governance. Both are supported by international technical assistance projects.
External audit functions of hromadas are currently carried by the Accounting Chamber of Ukraine (ACU) – the Supreme Audit Institution - and the State Audit Service (SAS) under the Government of Ukraine. The ACU’s scope of responsibility for the independent external audit of the local level is new to the ACU since the reforming 2024 law and is yet to be implemented (see Chapter 5).
Several legislative changes in 2023 and 2024 aimed at improving a culture of integrity, including conflict of interest regulations for local authorities, strengthening meritocracy and transparency in hiring procedures in civil service on the local level, improving ethical principles (see Chapter 2). To support the efforts of building a culture of integrity, several collective action initiatives proved to be successful, such as the Declaration of Integrity, signed by over 40 hromadas as of 2024, the coalition of Virtuous Hromadas, participation in the Transparent Cities Index.
The concept of the Digital Restoration EcoSystem for Accountable Management (DREAM)7 was developed with the support of the civil society coalition RISE Ukraine. The system’s functionality was developed by the Open Contracting Partnership with the support of international technical assistance and transferred to the Ministry of Communities and Territories Development of Ukraine. It is in use under the State Agency for Restoration and Infrastructure Development of Ukraine to support, among others, LSGs in transparent and accountable reconstruction processes. DREAM is used by more than 1 200 local governments, ministries, and all regional military administrations in the country.
Nevertheless, major corruption risks in hromadas are associated with the ongoing reconstruction and infrastructural maintenance processes. At the same time, there is an issue of capacity and expertise to ensure integrity in large reconstruction projects. For example, although many hromadas follow the rule of having authorised persons for corruption prevention, only 7% of such authorised persons work full-time (Keudel, 2025[49]). Rather few hromadas have required capacities and trained staff for internal audits. External audits face also challenges of sufficient staff to conduct necessary external audits and ensure compliance with the recommendations. The use of DREAM is relatively new and thus lacks the necessary legislative basis for the compulsory and aligned use by hromadas.
An effective approach to public integrity in LSGs requires local governments to weigh their capacity constraints against integrity risks and assign responsibilities accordingly. As a minimum, dedicated processes for managing conflict of interest and basic internal control functions should be established. As additional functions may be too resource-intensive to operate in every municipality, it may be prudent to assign some integrity functions at the regional or national level. For example, an already existing whistleblowing mechanism at the regional level could also cover local governments. Making use of formal and informal networks, both at the horizontal and vertical levels, can also help identify where responsibilities should be allocated. The core consideration is to ensure that regardless of the level of government, responsibilities for the integrity functions are clearly assigned (OECD, 2020[10]).
The NACP could expand its support of the LSGs. Local actors in Lviv stated in the preparation of this report that the NACP’s methodological guidance, coordination and advice activities are helpful for the LSGs to build own public integrity systems. Thus, the NACP should consider creating territorial chapters. The LPC provides for a possibility to establish up to six NACP chapters in different regions of Ukraine, but none have been created so far. The NACP’s regional chapters could serve the purpose of capacity building and provide support to authorised persons regarding conflict-of-interest prevention and management, corruption risk assessments, design of municipal integrity plans, and public awareness raising. In addition, such regional chapters could serve as the purpose of demonstrating the NACP’s resilience during the ongoing war.
The legal and institutional integrity framework in Ukraine
Ukraine could further strengthen its robust regulatory framework by fostering value-based culture extending beyond compliance.
Ukraine has a well-developed institutional system that covers all integrity functions. However, specialised anti‑corruption bodies require more resources, regular law-enforcement system needs improved accountability, and external oversight bodies should be more strongly integrated into the overall system.
Public integrity strategy
Ukraine could reinforce an inter-institutional working approach in the anti‑corruption policy cycle to ensure the commitment and engagement of key stakeholders for an effective and continuous public integrity strategy.
The NACP developed several prioritisation mechanisms to address the implementation gap of the Strategy, which should be tested and refined during the implementation of the ongoing Strategy and applied to the next Strategy.
The NACP could prepare and publish a national report on the effectiveness of the implementation of the state anti‑corruption policy, providing findings to the inter-institutional body to inform the design of the upcoming Strategy and ensure continuity.
Mainstreaming public integrity across sectors and local self-governments
The NACP could continue advancing the coordination of authorised persons for corruption prevention in public organisations and strengthen their role in the overall system of public integrity.
The NACP could revise the methodological approach to developing anti‑corruption programmes by shifting from a narrow focus on corruption risk mitigation to a strategic integrity framework and enhancing capacity-building on diverse public integrity instruments.
Ukraine could further strengthen public integrity system in local self-governments (LSG), by improving coordination of integrity-related functions between LSGs and other levels of governance and establishing regional NACP chapters to support LSGs capacities for integrity.
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← 2. The amount of the subject of the criminal offense provided for by Articles 354 (in relation to employees of legal entities under public law), 368, 369, 369-2 (active and passive bribery) of the Criminal Code of Ukraine is five hundred times or more higher than the amount of the subsistence minimum (ca. EUR 34 000 in 2024), as well as the subject of the criminal offense or the amount of damage caused in criminal offenses provided for by Articles 191, 206-2, 209, 210, 211, 364, 410 of the Criminal Code of Ukraine, two thousand or more times higher than the amount of the subsistence minimum (ca. EUR 135 000 in 2024).
← 3. LPC Art. 21 regulates citizen engagement in anti-corruption, providing for 20 days for public consultation regarding anti-corruption draft laws and decisions. Regulations of the Cabinet of Ministers of Ukraine are the main guidelines for the development and approval of draft legal acts at the inter-institutional level. The Regulation establishes a mechanism for inter-institutional consultation in Article 37, under Article 38 the consultation period must be at least 10 days.
← 4. The National report on the implementation of the principles of anti-corruption policy in 2017 discusses the state of anti-corruption policy, however it does not provide systemic evaluation of the impact of the Strategy 2014-2017. The analytical report on strategy implementation from 2019 has been prepared with support of EUACI and with involvement of external experts. It is helpful to reflect about lessons learned from the expired Strategy, however, the assessment has not followed pre-defined benchmarks for evaluation.
← 6. Since Russia’s full-scale invasion, the government has determined an additional 4% of PIT for the local level (meaning it is now maintained at 64%).