OECD Review of the Corporate Governance of State‑Owned Enterprises in Ukraine 2026

State-owned enterprises (SOEs) account for a substantial share of Ukraine’s economic activity and public assets, with a strong presence in network industries and other strategically important sectors. As of recent estimates, Ukraine’s SOE sector comprises more than 3 000 enterprises dominant in sectors such as energy, transport, infrastructure and finance. Strengthening SOE governance is therefore not only a matter of enterprise performance, but also of safeguarding public value and supporting Ukraine’s long-term economic transformation. This is particularly true in the context of Russia’s full-scale invasion of Ukraine.

Ukraine has significantly strengthened its SOE governance framework since 2021, bringing the legal architecture materially closer to the OECD Guidelines on Corporate Governance of State-Owned Enterprises despite wartime constraints.

Since 2021, Ukraine has undertaken substantial legislative and policy reforms to improve the SOE ecosystem. Most notably, the adoption of law No. 3587-IX/ 2024 (“SOE Law”) and the approval of a State Ownership Policy have significantly strengthened the formal governance framework. These reforms clarify the state’s role as an owner, reinforce the authority and fiduciary duties of supervisory boards, introduce clearer ownership principles, and expand disclosure and reporting requirements. Together, they bring Ukraine’s legal framework materially closer to the standards set out in the OECD Guidelines on Corporate Governance of State-Owned Enterprises (“SOE Guidelines”), despite the extraordinary operational pressures created by the war.

Implementation across the SOE portfolio remains uneven, and governance outcomes differ significantly between large SOEs and the broader portfolio.

While the legal framework has improved strongly, progress on enforcement mechanisms, institutional co‑ordination and professional ownership practices has not been as fast. Wartime exemptions, interim management arrangements, capacity constraints and fragmented ownership responsibilities have slowed the practical application of reforms. As a result, reform implementation has been more consistent in large, strategically important SOEs than across the wider portfolio, where governance practices remain more heterogeneous.

Fragmented ownership arrangements continue to weaken the state’s ability to exercise active, professional and conflict-of-interest-free ownership.

Ownership responsibilities remain dispersed across multiple line ministries and public bodies, many of which continue to combine ownership and regulatory or policy functions. This structural duality creates conflicts of interest and weakens consistent oversight at the portfolio level. Although the State Ownership Policy introduces important principles, further progress in strengthening co-ordination and institutional capacity, and moving towards a more centralised or effectively co-ordinated ownership function, would enhance the state’s ability to exercise active, informed and professional ownership.

Strengthening competitive neutrality and phasing out wartime exemptions will be essential to safeguard market confidence and fiscal sustainability.

Under martial law, SOEs have benefited from exceptional measures, including moratoria on insolvency, preferential financing arrangements and limitations on state aid enforcement. While many of these measures have been necessary to preserve economic stability, their prolonged use risks distorting markets, discouraging private investment and weakening fiscal discipline. A clear roadmap for phasing out wartime exemptions and restoring competitive neutrality and equal market conditions between SOEs and private firms, once conditions allow, will be essential for Ukraine’s recovery and accession-related commitments.

Public service obligations remain insufficiently formalised and inconsistently compensated.

While public service obligations (PSOs) play a critical role in ensuring affordability and social stability - particularly in the energy and transport sectors - their costs are not systematically separated, budgeted or disclosed. This weakens transparency, obscures fiscal risks and complicates performance assessment.

Disclosure, transparency and accountability have improved in the legal and regulatory framework, but remain inconsistent in practice.

Financial reporting obligations are extensive, yet publication remains uneven, particularly for enterprises classified as critical infrastructure or defence-related entities. Progress has been made towards building an electronic reporting system, but aggregate portfolio transparency remains limited. The absence of regular, public and comprehensive aggregate reporting on the SOE portfolio continues to constrain comprehensive oversight of fiscal risks, public service obligations and overall SOE performance.

Board governance has seen notable advances, including the establishment of independent supervisory boards in several major SOEs and the introduction of clearer nomination and evaluation procedures.

However, persistent delays in appointments, incomplete boards, interim leadership arrangements and ad-hoc modifications under martial law continue to undermine board effectiveness. Recent developments in certain SOEs underscore the importance of safeguarding board independence, ensuring due process in evaluations and dismissals, and reinforcing the role of boards in overseeing risk management, integrity and internal control systems.

Translating legislative progress into consistent, portfolio-wide practice is now the central reform challenge.

Against this backdrop, a set of priority reforms could support effective implementation. These include sharpening ownership rationales and institutionalising the triage process for determining the future of SOEs within the state ownership portfolio; strengthening ownership co-ordination and professional capacity; progressively restoring competitive neutrality and equal market conditions as circumstances permit; improving portfolio-wide transparency and aggregate reporting; reinforcing board independence, merit-based nomination processes and evaluation frameworks; and integrating sustainability, integrity and responsible business conduct more systematically into SOE governance.

The report proposes a reform roadmap with short- and medium-term priorities to support enforcement, institutional consolidation and sustained reform momentum. While Ukraine’s reform trajectory has been remarkable, durable progress will depend on translating legal reforms into consistent practice across the entire SOE portfolio. Continued alignment with the SOE Guidelines can play an important role in strengthening investor confidence, thereby supporting reconstruction efforts.