Chapter 2 provides an overview of Ukraine’s state-owned enterprise corporate governance landscape. It situates SOE governance within the broader economic and political context, including the impact of the war. The chapter outlines the size, structure and economic significance of the SOE sector, and reviews the legal and regulatory framework governing SOEs. It also examines how corporate governance arrangements have been adapted under martial law and the implications for oversight, accountability and reform implementation.
OECD Review of the Corporate Governance of State‑Owned Enterprises in Ukraine 2026
Abstract
Ukraine is one of the largest countries in continental Europe. Since transitioning from a centrally planned to a market economy in the 1990s, the country has faced significant political, economic, and security challenges. After a modest recovery from the 2008 global financial crisis, the 2014 Euromaidan revolution and Russia’s annexation of Crimea further destabilised the economy. Structural reforms and closer ties with the EU, including the Association Agreement and Deep and Comprehensive Free Trade Area (DCFTA), supported economic stabilisation and growth. However, the COVID-19 crisis led to a decline in GDP, currency devaluation, and increased government borrowing. Russia's full-scale invasion of Ukraine in 2022 has inflicted massive human and economic damage. Despite a challenging outlook, Ukraine's economy has shown signs of resilience, supported by extensive external assistance and adaptive fiscal and monetary policies (OECD, 2025[1]).
As of mid-2025, the population is estimated at approximately 37.9 million, reflecting a decline since 2022 due to war-related displacement, migration flows and demographic pressures. Real GDP growth is projected at around 2.7% in 2025, with a further slowdown to about 2.4% in 2026 according to official government forecasts, while OECD estimates suggest continued moderate expansion towards 2027 (OECD, 2025[1]). Public debt levels are expected to exceed 100% of GDP in 2025, reflecting large war-related deficits and continuing reliance on foreign financing.
The National Bank of Ukraine, in its April 2025 Inflation Report, forecasts real GDP growth to reach approximately 3.7–3.9% annually in 2026–2027, building on an estimated 3.4% growth in 2024 and projected 2.1% in 2025. The Rapid Damage and Needs Assessment (RDNA5)1 estimates that Ukraine’s recovery and reconstruction needs over the next decade total around USD 587.7 billion.
Ukraine is one of the largest countries in continental Europe. Strategically positioned, Ukraine borders Russia, Central Europe, and the Black Sea, and prior to the war, served as a critical transit route for oil and gas between Russia and the European Union (EU). The country remains one of the world's leading exporters of grain and sunflower oil and possesses significant natural resource deposits, such as mercury, titanium, iron ore, and coal.2 However, reliance on primary sectors renders Ukraine vulnerable to global price fluctuations and external shocks. The full-scale military invasion has exacerbated these vulnerabilities, leading to infrastructure damage, population displacement, and economic disruptions. Despite these challenges, Ukraine continues to pursue economic reforms and seeks closer integration with European markets to enhance stability and growth prospects.
Note: n.d. stands for no data.
Source: OECD (2025[1]), OECD Economic Outlook, https://doi.org/10.1787/9f653ca1-en; World Bank (2024[2]), World Development Indicators (database), https://data.worldbank.org/country/ukraine.
2.1.1. Government
Ukraine operates as a unitary parliamentary-presidential republic, with its 1996 Constitution establishing a balance of power between the President, Parliament, and the Cabinet of Ministers. Since 2014, the Prime Minister – appointed by the parliament on the President’s proposal – has headed the government and led the Cabinet of Ministers, Ukraine’s highest executive body. The Verkhovna Rada,3 composed of 450 members elected by popular vote, remains the country’s supreme legislative authority. President Volodymyr Zelensky, elected in 2019, saw his Servant of the People party secure a parliamentary majority in snap elections that year. Since then, the government has undergone restructuring, with ministerial reshuffles and administrative reforms.
Decentralisation efforts, initiated in 2014, continue to transfer powers to local governments across 24 oblasts and two cities with special status,4 strengthening regional governance through hromadas5 that manage local services, infrastructure, and budgets.
In July 2025, the government was reshuffled, marking a potential recalibration of economic and governance priorities. Parliament appointed the former First Deputy Prime Minister and Minister of Economy as the new Prime Minister. The reshuffle also consolidated several ministries, merging portfolios to create a Ministry of Economy, Environment and Agriculture, and a Ministry of Social Policy, Family and Unity. These structural changes potentially signal an intention to streamline policy coordination, particularly in economic reform and reconstruction. Despite these changes, it is expected that the Ministry of Economy, Environment and Agriculture will remain the main policymaker responsible for overseeing privatisation and corporate governance reforms, and that the newly appointed government will maintain continuity in advancing the large-scale privatisation agenda, improving SOE performance, and aligning governance practices with international standards.
2.1.2. Legal and judicial system
Ukraine’s legal system follows the civil law tradition (Romano-Germanic legal family) and is based on a hierarchical structure of normative acts, with the Constitution as the highest legal authority. While significant legal reforms have been implemented to support the market economy, gaps remain, and enforcement challenges persist. The judicial system operates on principles of territorial and subject matter jurisdiction, with separate courts for civil, criminal, administrative, and commercial cases. The Supreme Court serves as the highest judicial authority, reviewing cassation appeals, while the Constitutional Court interprets the Constitution and ensures compliance of laws.
Public prosecution and anti-corruption bodies
Ukraine’s specialised anti-corruption institutions – the National Anti-Corruption Bureau (NABU), the Specialised Anti-Corruption Prosecutor’s Office (SAPO), and the High Anti-Corruption Court (HACC) – have continued to function with notable resilience, even under the challenging conditions of wartime governance. These bodies have made significant progress in investigating and prosecuting high-level corruption, including cases involving ministers, judges, and executives of state-owned enterprises. In 2023, NABU launched more than 300 investigations and referred over 60 cases to court, with uncovered financial damage exceeding UAH 4.7 billion (USD 107 million). These outcomes reflect the institutional maturity of Ukraine’s anti-corruption infrastructure, which has evolved considerably since its establishment in the post-2014 reform period (OECD, 2025[3]).
However, despite these positive developments, enforcement challenges persist. Cases involving foreign bribery and money laundering remain frequent, and Ukraine continues to face structural barriers to effective enforcement, including fragmented data systems and the lack of centralised statistics on investigations, confiscations, and asset recovery. Additional barriers include SAPO’s inability to resolve jurisdictional disputes or independently initiate cases against Members of Parliament, the exclusion of some high-level officials from NABU’s jurisdiction, and NABU’s lack of independent wiretapping authority and certain specialised forensic capabilities. The legal framework also presents obstacles to effective enforcement. Restrictive limits on pre-trial investigations and statute of limitations pose constraints, and the frequent use of plea bargaining can also undermine the effectiveness of accountability mechanisms (OECD, 2025[4]).
The broader institutional and policy framework for integrity and corruption prevention also remains in flux. Ukraine’s Anti-Corruption Strategy for 2021-2025, developed through a participatory process and based on risk assessments, was adopted after significant delays, and its implementation was subsequently slowed. While the strategy remains comprehensive, its current formulation does not fully reflect emerging corruption risks stemming from wartime spending, post-war reconstruction, and increased flows of international assistance. In response, Ukraine’s National Agency on Corruption Prevention (NACP) has made notable progress in building digital monitoring tools and maintaining public registers. However, the agency continues to face institutional constraints, including insufficient resourcing, limited enforcement authority, and legal ambiguities regarding its powers in areas such as political party financing and whistleblower protection (OECD, 2025[3]).
Following mass demonstrations and international pressure, the Ukrainian Parliament repealed earlier legislative amendments adopted in July 2025 that had curtailed certain investigative powers and institutional safeguards of NABU and SAPO. While the reversal alleviated immediate concerns, the episode underscored the fragility of institutional checks and balances and negatively affected perceptions of the executive’s commitment to safeguarding independent oversight (OECD, 2025[4]). In the corporate sector, anti-corruption compliance remains a formal legal requirement for SOEs and major public procurement contractors. Under the Law on Prevention of Corruption, all central and local state-owned enterprises with more than 50 employees and annual revenues exceeding UAH 70 million (USD 1.7 million), or those engaged in procurement above UAH 20 million (USD 486 000), must adopt internal anti-corruption programmes. However, implementation across the SOE sector remains inconsistent. Many compliance systems are limited to formal policies and codes of conduct, with insufficient attention to internal controls, whistleblower channels, and risk-based auditing.
A recent OECD review highlights that for participants in high-value procurement, compliance requirements are often a formality. Procuring authorities currently do not verify the quality or existence of compliance programmes, nor can they rely on oversight by another authority, creating opportunities for abuse. Introducing some degree of quality control – whether through a checklist of essential compliance elements or reference to audits by a competent public body – would help ensure that anti-corruption programmes are meaningful and enforceable. Clearer regulatory expectations, sector-specific guidance, and better-resourced monitoring mechanisms will be important to raise standards and align practices with international expectations (OECD, 2025[3]).
2.1.3. Economic development
To address fiscal pressures exacerbated by the prolonged conflict, Ukraine implemented its first wartime tax increases in November 2024. These measures included raising the war tax on personal income from 1.5% to 5%, extending this tax to individual entrepreneurs and small businesses, increasing rental payments, and taxing commercial banks' profits at 50%. These initiatives aim to generate approximately UAH 140 billion (USD 3.4 billion) in additional revenue to support defence efforts (Reuters, 2024[5]).
International support continues to play a pivotal role in Ukraine’s economic stability. Between 2024 and 2027, the EU has pledged to allocate EUR 50 billion under the Ukraine Facility to support Ukraine’s state budget, catalyse investment, and provide technical assistance for programme implementation. The Facility outlines key reform priorities, including the “implementation of corporate governance in accordance with OECD principles and establishment of supervisory boards at state-owned companies” (Ukraine Facility, 2024[6]). In parallel, the EU continues to provide Macro-Financial Assistance (MFA+), disbursing relevant tranches throughout the reporting period. These MFA+ loans are aimed at covering Ukraine’s urgent budgetary needs while supporting structural reforms, including the strengthening of public finance management and corporate governance of SOEs.
Additionally, the International Monetary Fund (IMF) continues to play a central role in supporting Ukraine’s macroeconomic and financial stability. Approved in March 2023, the 48-month Extended Fund Facility (EFF), set at about USD 15.5 billion, enabled total disbursements of approximately USD 10.6 billion through its Eighth Review, concluded on 30 June 2025. The review unlocked an additional USD 0.5 billion in budget support. Key programme benchmarks included reforms in governance, revenue mobilisation, anti-corruption and alignment with the SOE Guidelines.
Other international financial institutions have similarly stepped-up their support. In particular, the European Bank for Reconstruction and Development (EBRD) committed to invest EUR 1.5 billion (USD 1.6 billion) in Ukraine in 2025, particularly in the energy and reconstruction sectors. Cumulative EBRD financing deployed in wartime Ukraine had reached EUR 8.5 billion (USD 9.9 billion) by end-September 2025. The World Bank has also approved major support packages intended to strengthen economic stability, public service delivery, and financial resilience, aligned with wider recovery plans.
2.1.4. Fiscal developments and market sentiment indicators
Business sentiment and employment expectations in Ukraine have improved since the initial shock of the full-scale invasion, with industrial production expectations turning positive by mid-2023. However, business confidence remains fragile, impacted by uncertainties over international aid, rising logistics costs, high energy prices, labour shortages, and weakening demand. Staffing constraints, driven by military recruitment and emigration, further challenge economic recovery, underscoring the economy’s dependence on the war’s progression and continued global support. On the fiscal side, war-related spending has significantly increased government borrowing, pushing Ukraine’s debt-to-GDP ratio from 49% in 2021 to nearly 90% in 2024. The August 2024 restructuring of USD 20.5 billion in external debt provided temporary relief, allowing the government to reallocate resources.
Ukraine’s fiscal position has deteriorated sharply since the full-scale invasion, with widening budget deficits financed by a combination of official support, concessional borrowing and domestic debt issuance. General government gross debt is projected to reach around 110% of GDP in 2025, up from below 50% before the war (IMF, 2025[7]). This rapid debt accumulation heightens fiscal vulnerabilities and places additional pressure on public finances.
2.1.5. Banking sector
Ukraine’s banking sector is relatively small compared to peer countries, yet assets in the sector have continued to increase despite the war, rising in nominal terms from UAH 2.05 trillion in December 2021 to UAH 3.26 trillion in November 2024 (from USD 49.2 billion to 78.3 billion). This is partly driven by increasing holdings of liquid instruments, as well as government debt securities. Comparison against peer countries shows that there is room for expansion of banks’ lending to the private sector, which in 2022 totalled 17.7% of GDP in Ukraine (OECD, 2025[8]).
Note: The table excludes insolvent banks.
Source: National Bank of Ukraine (2025[9]), Banking sector statistics, https://bank.gov.ua/en/news/all/oglyad-bankivskogo-sektoru-serpen-2025-roku
In terms of ownership, the banking sector is dominated by seven state-owned banks (SOBs), which account for 53% of all assets in the sector and hold over 60% of retail deposits. One state-owned bank (PrivatBank) plays an especially prominent role, holding 35.7% of retail deposits (OECD, 2025[8]).
The National Bank of Ukraine classifies five of these banks as systemically important banks (SIBs), subject to additional regulatory oversight. Among the state-owned non-SIBs, two banks have been recently nationalised: Motor Bank and PIN Bank. State-owned banks have a higher non-performing loan (NPL) ratio, recorded at 40.1% (excluding PrivatBank) as of June 2024 (latest available data), with PrivatBank standing out at 59.2%. In comparison, private domestic and foreign-owned banks have much lower NPL ratios, both around 13.6%. A large proportion of NPLs, dating from the pre-war period, are “legacy” loans issued by PrivatBank before nationalisation. The NBU advises that these are highly unlikely to be recovered and are fully provisioned by the bank (OECD, 2025[8]). The NBU has been proactive in implementing reforms to bolster financial stability, improve the resilience of the financial sector, and address NPL resolution.
Some state presence in the banking sector brings benefits, particularly in wartime, when SOBs play a critical role in financing the defence sector and implementing government programmes. Their greater capacity and willingness to meet stringent security and confidentiality requirements enables lending to defence companies in line with Ukraine’s policy to increase defence financing. Evidence also shows that SOBs can help stabilise credit during domestic shocks. However, these advantages must be balanced against potential drawbacks, including reduced fiscal discipline and the crowding out of private sector credit, which can be particularly problematic for businesses facing already tight financing conditions during war. Moreover, SOB’s institutional capacity to open the foreign accounts needed to service debt securities gives them a competitive advantage over private banks, raising concerns about compliance with EU state aid rules (OECD, 2025[8]).
Privatisation of some SOBs could enhance efficiency in the banking sector, attract foreign capital, expand banking activity, and generate state revenue while supporting alignment with EU State Aid requirements. In 2024, legislation was adopted to strengthen the management of state assets in the banking sector and establish a procedure for the sale of SOB shares. The authorities are currently preparing Sense Bank and Ukrgasbank for privatisation (OECD, 2025[8]; IMF, 2025[10]). In line with IMF commitments, all systemic banks with majority state ownership are placed under the responsibility of the Ministry of Finance, while non-systemic state-owned banks will not be recapitalised using fiscal resources, but instead transferred to the Deposit Guarantee Fund for resolution if prudential requirements are breached (IMF, 2025[10]).
Note: Values as of 1 November 2024.
Source: Ministry of Finance of Ukraine (2025[11]), State-owned banks data, https://www.mof.gov.ua; National Bank of Ukraine (2025[9]), Banking sector statistics, https://bank.gov.ua.
Source: OECD (2025), Mapping Ukraine’s Financial Markets and Corporate Governance Framework for a Sustainable Recovery, OECD Publishing, https://doi.org/10.1787/866c5c44-en.
2.1.6. Capital markets
Ukraine’s capital markets remain underdeveloped. Stock market capitalisation – a key indicator of market depth – is projected to reach approximately USD 1.21 billion in 2025, reflecting only modest annual growth. Currently, Ukraine has three operating stock exchanges: the Ukrainian Exchange (UX), the Perspectiva Stock Exchange (PrJSC), and the First Stock Trade System (PFTS). With respect to the PFTS, the National Securities and Stock Market Commission reported that a settlement agreement had been issued concerning insufficient capital and the exchange had until the end of February 2025 to restore the required capital levels or face potential licence revocation. Despite these challenges, in 2023 the PFTS recorded a 260% increase in trading volume, reaching UAH 320.8 billion (USD 7.7 billion) and accounting for 63% of Ukraine’s total securities trading (Interfax, 2024[12]; OECD, 2025[8]).
2.2.1. Number and type of SOEs
As of January 2025, the central government managed a portfolio of more than 3 071 SOEs, which consists largely of statutory corporations (State Unitary Enterprises) (~82%), majority-held joint-stock companies (JSC) and limited liability companies (LLC) (~10%), and a small number of SOEs organised with other types of legal forms. The ownership of these SOEs is fragmented across 79 ministries, central executive bodies and state agencies. While over half of these SOEs are inactive or in the process of being liquidated, SOEs still retain a high share of assets in many sectors of the economy. In 2019-2021, SOEs accounted for roughly 14% of national business fixed assets annually on average, and in many sectors held even larger shares of fixed‐asset capital. These figures suggest that SOE’s large asset base may limit private sector capital accumulation and investment, particularly in sectors with high SOE concentration (OECD, 2025[1]).
The 3 071 SOEs include 155 SOEs located in the Autonomous Republic of Crimea and Sevastopol. Only 813 SOEs (about 26% of the total) are operational and submit financial statements for regular monitoring by the Ministry of Economy. In August 2025, the total number of full-time employees in SOEs, excluding SOBs, was 474 621.6 These numbers do not include over 14 000 municipally-owned enterprises (MOEs).
2.2.2. Operational performance
Financial performance data indicates that in 2022,7 the SOE portfolio generated losses of UAH 154 billion (USD 3.7 billion), whereas it achieved a profit of UAH 22.5 billion (USD 540 million) in 2023 and 24.3 billion (USD 606 million) in 2024 (Cabinet of Ministers of Ukraine, 2024[13]). The aggregate return on equity (ROE) of SOEs in 2024 was 2.3% (compared with an inflation rate of 12%), while the current liquidity ratio stood at 1.21, the debt-to-equity ratio at 1.06, and the asset turnover ratio at 0.45.
While some SOEs are profitable, their pre-war financial performance is significantly below that of companies operating in the private sector. Lower returns on equity and assets, smaller profit margins, and lower revenue generation per employee point to operational inefficiencies. SOEs also tend to be more highly indebted than their counterparts in the private sector. The causes of these inefficiencies vary but historically include a combination of excessive government and political interference in SOE operations, poor management, burdensome public service obligations, and corruption (OECD, 2021[14]; OECD, 2025[1]).
2.2.3. Sectoral distribution of SOEs
Table 2.4. presents an overview of the total number of centrally-owned SOEs. The highest share of SOEs (by number) are in manufacturing and the primary sectors.8 The 813 operational SOEs collectively contribute to an equity value of over UAH 1.05 trillion (USD 24.93 billion).
Note: The total number of 2 916 centrally-owned SOEs excludes 155 enterprises located in Crimea, which are listed separately. Including these enterprises, the total would amount to 3 071. The primary sector includes agriculture, forestry, and fisheries, as well as mining and quarrying. Manufacturing includes the manufacturing industry and construction. ‘Other activities’ refers to administrative and support services, accommodation and food services, professional and technical activities, public administration, education, healthcare, arts, sports, and other service activities. The ‘finance’ category covers SOEs operating in the financial sector, but not the state-owned banks (the state-owned banks collectively employ around 42 000 people, while the “finance” SOEs shown here have only about 400 employees).
Source: Questionnaire responses from the Ukrainian Government received in February 2025.
2.2.4. Privatisation
Following its independence in 1991, Ukraine aimed to transition to a market economy by privatising state-owned assets. The 1992 privatisation law allowed employees to purchase shares in state enterprises under preferential terms, later expanded through a voucher programme. The State Property Fund of Ukraine (SPFU) was established to oversee privatisation and manage state assets, absorbing some functions of the briefly established Ministry of Privatisation. However, the process was poorly managed, leading to over 60 000 SOEs being sold at artificially low prices, often benefiting former executives. By 2000, privatisation revenues amounted to just 3% of GDP, compared to an average of around 9% of GDP across several Central and Eastern European transition economies during the same period, depending on the scope and pace of national privatisation programmes. Disputes between line ministries and the SPFU over asset management, coupled with opaque sales, eroded public trust in privatisation (OECD, 2021[14]).
By 2013, privatisation proceeds had dwindled to less than 0.2% of GDP (IMF, 2014[15]). In response, the government authorised the SPFU in 2014 to identify 160 entities for privatisation. However, outdated frameworks and challenges, such as difficulties in selling the Odessa Portside Plant and Centrenergo, hindered progress.9
In 2018, Ukraine enacted the Law on Privatisation of State and Municipal Property to streamline the sale of large and small assets. This law introduced measures for transparency and investor guarantees, and facilitated small-scale privatisations (valued under UAH 250 million, USD 6 million) via the Prozorro.Sale electronic platform. The international community viewed this as a pivotal move to rejuvenate Ukraine's privatisation efforts. To further accelerate the process, the government initiated a "triage" system, categorising SOEs for retention, privatisation, or liquidation. Despite these efforts, large-scale privatisations faced delays, notably due to the COVID-19 pandemic, changes in government and the SPFU, and as of 2022 the full-scale invasion which halted privatisation activity.
In 2023, the Verkhovna Rada adopted legislation to resume privatisations, leading to the SPFU's "Large Privatisation-2024" initiative. This programme targeted significant assets, including the Ukraine Hotel in Kyiv and the United Mining and Chemical Company (UMCC) (Table 2.3). In 2024, the SPFU successfully privatised 377 state-owned assets through auctions, generating UAH 11.1 billion (USD 266.6 million) in revenue, surpassing the annual target by 2.5 times (UKRinform, 2025[16]). Efforts to address the policy framework to privatise SOBs have also progressed. In September 2024, the Verkhovna Rada passed a law facilitating the sale of state stakes in banks, allowing for partial sales rather than requiring full divestment. This legislation applies to institutions like PrivatBank and Ukrgasbank, aiming to reduce the state's footprint in the banking sector.
Despite efforts to streamline and accelerate privatisation, the process still faces challenges. The USAID/ UKaid SOERA programme10 assisted the SPFU in determining the optimal course of action for SOEs, whether through privatisation, management reform, or liquidation. However, USAID/ UKaid noted key obstacles, including delays in transferring assets from other managing bodies, interference by enterprise directors in preparatory processes, and artificially inflated valuations that push SOEs into large-scale privatisation, thereby stalling transactions. Additionally, legal and financial barriers, such as asset seizures and criminal proceedings, further complicate the process (USAID/UKaid, 2023[17]). Even after privatisation, issues persist, as ineffective regulation of receivables, payables, and inventories often prevents SOEs from being fully liquidated. The legal framework remains complex, with privatisation contracts typically covering tangible assets but not liabilities, creating uncertainty for buyers. The need to renegotiate land use agreements and transfer licenses adds further complications. A new Law on State Enterprise Termination11, No. 3037-IX/ 2023, allows buyers to decide whether to merge or liquidate acquired SOEs, but implementation remains inconsistent (CIS legislation, 2023[18]).
The SPFU has emphasised the need for full control over all SOEs slated for privatisation/liquidation to ensure efficient privatisation. It argues that retaining 706 enterprises under various ministries and state agencies contradicts legal provisions that all state-owned assets are subject to privatisation unless explicitly restricted, such as those vital for national security. According to SPFU, between January 2022 and October 2025, the Fund accepted 1 282 SOEs into its management, including: 184 enterprises in 2022, 1 038 in 2023, 32 in 2024, and 28 in 2025. As of October 2025, 46 SOEs remain to be transferred.
To support the privatisation of SOEs during the war – particularly to support the state budget – the recently adopted State Ownership Policy outlines a concrete privatisation strategy. Alongside this strategy, the State Ownership Policy establishes triage categories and designates the Ministry of Economy as responsible for its implication, subject to approval by the Cabinet of Ministers. In line with the CMU Resolution No. 13/ 2024, the initial triage process was completed by December 2024 (see Table 2.5). The triage was conducted according to the following three categories:
SOEs that remain state-owned: This category includes SOEs that continue in state ownership without changing their organisational form, as well as those that are subject to reorganisation or corporatisation.
SOEs subject to further privatisation: This category includes SOEs that are temporarily exempt from privatisation until the end of martial law, due to the need to ensure the security and defence of the state.
SOEs subject to immediate liquidation and privatisation.
Note: Extract from CMU protocol #135 dated 27 December 2024. The triage did not cover 804 SOEs located in temporarily occupied territories, which accounts for a different total than in Table 2.1. Strategically important SOEs are determined pursuant to CMU Resolution No. 83/ 2015, “on Approval of the List of State-Owned Assets of Strategic Importance for the Economy and State Security.” Natural monopolies are determined in accordance with the Consolidated List of Natural Monopoly Entities maintained by the Antimonopoly Committee of Ukraine.
Source: Questionnaire responses from the Ukrainian Government received in February 2025.
While some SOEs designated to remain in state ownership clearly align with the categories set out in the State Ownership Policy (e.g. natural monopolies or entities prohibited from privatisation by law), the rationale for retaining others – such as hotels, canteens, and recreation facilities – has not been elaborated. The triage protocol decision does not include individual rationales for specific SOEs, and while the State Ownership Policy identifies broad categories justifying state ownership, individual SOEs have not been classified under these headings.
Table 2.6 summarises the main outcomes of large and small-scale privatisation implemented from 2021 to 2024. As of 30 June 2025, the small-scale privatisation list contained 1 296 assets. In addition, 21 assets remain subject to large-scale privatisation. Between 1 May and 30 June 2025, proceeds from privatisation of state property transferred to the State Budget of Ukraine amounted to UAH 291 million (USD 7 million) (State Property Fund, 2025[19]).
Source: State Property Fund of Ukraine (2025[19]), Privatisation reports, https://www.spfu.gov.ua/ua/documents/docs-list/spf-reports.html.
Note: In 2024, total proceeds from privatisation amounted to UAH 9.94 billion (USD 240.9 million). This was equivalent to just 0.46% of total general fund revenues of the State Budget, which reached UAH 2 177 billion (USD 52 million) in the same year.
Source: State Property Fund of Ukraine (2025[19]), Privatisation reports, https://www.spfu.gov.ua/ua/documents/docs-list/spf-reports.html.
This section takes stock of how Ukraine’s legal framework for SOEs has evolved since the 2021 OECD Review of the Corporate Governance of State-Owned Enterprises in Ukraine (OECD, 2021[14]).12 Rather than providing a purely descriptive inventory, it highlights the direction, pace and coherence of recent reforms, and assesses how legislative changes reshape the state’s role as an owner. The chapter focuses on developments in both primary and secondary legislation, while also signalling key initiatives that are under preparation or expected to have systemic implications for the SOE sector.
Ukraine’s SOE framework remains anchored in a complex legal architecture, reflecting the coexistence of commercial, public-law and sector-specific regimes. The principal pieces of primary legislation governing SOEs include:
Civil Code of Ukraine (No. 435-IV/ 2003)
Law on Management of Objects of State Property (No. 185-V/ 2006)
Law on Reforming Enterprises of the Defence-Industrial Complex of State Ownership (No. 1630-IX/ 2021)
Law on Banks and Banking (No. 2121-III/ 2000)
Law on Joint-Stock Companies (No. 514-VI/ 2008)
Law on Limited and Additional Liability Companies (No. 2275-VIII/ 2018)
Law on Holding Companies in Ukraine (No. 3528-IV/ 2006)
Law on Privatisation of State and Municipal Property (No. 2269-VIII/ 2018)
Law on the State Property Fund of Ukraine (No. 4107-VI/ 2011)
Tax Code of Ukraine (No. 2755-VI/ 2010)
Code of Ukraine on Bankruptcy Procedures (No. 2597-VIII/ 2018)
Law on Accounting and Financial Reporting in Ukraine (No. 996-XIV/ 1999)
Law on Audit of Financial Statements and Auditing Activities (No. 2258-VIII/ 2017)
Complementing this primary framework is an extensive body of secondary legislation, including Cabinet of Ministers’ resolutions, ministerial orders, and decisions issued by central executive authorities. These instruments play a decisive role in shaping how ownership rights are exercised in practice, often determining board appointment procedures, performance monitoring arrangements, dividend policies and reporting obligations.
2.3.1. New and amended legislation bearing on corporate governance of state-owned enterprises
Ukraine’s corporate governance framework for SOEs is dispersed across multiple laws, each addressing different dimensions of ownership, control and accountability. The key legislative pillars include:
Law on Management of Objects of State Property13 (No. 185-V/ 2006)
Law on Joint-Stock Companies (No. 2465-IX/ 2023)
Law on Banks and Banking (No. 2121-III/ 2000)
Law on Management of Objects of State Property in the Defence-Industrial Complex (No. 3531-V/ 2011)
Law on the Improvement of SOE Corporate Governance (No. 3587-IX/ 2024)
Since the 2021 Review, several of these laws have been substantively revised, marking a shift from fragmented governance arrangements towards a more structured and rule-based model. Amendments to the Law on Management of Objects of State Property, the adoption of a new Law on Joint-Stock Companies, and targeted changes to the banking framework have together reshaped board responsibilities, clarified fiduciary duties and strengthened oversight mechanisms. The following sections review these developments, beginning with the revised Law on Joint-Stock Companies. The amended SOE Law is analysed separately below, given its cross-cutting importance.
Law on Joint-Stock Companies
The JSC Law, which entered into force on 1 January 2023 (Verkhovna Rada of Ukraine, 2023[20]) represents a major modernisation of Ukraine’s corporate framework. While applicable economy-wide, the law has particular significance for SOEs organised as joint-stock companies, as it introduces governance tools more closely aligned with international practice. Key improvements include:
Allowing electronic shareholder participation: The law enables general shareholder meetings to be conducted through electronic voting, expanding participation and reducing procedural barriers.
Providing for a one-tier board option: Joint-stock companies (excluding banks) may now adopt a one-tier board structure, comprising executive and non-executive directors within a single board of directors. This model consolidates oversight and management functions and offers SOEs greater flexibility in tailoring governance arrangements to their operational needs.
Strengthened liability and fiduciary duties of officials.14 The law operationalises fiduciary obligations by requiring officials to act in the best interests of the company, exercise due care, avoid conflicts of interest and take independent decisions. It introduces clearer rules on compensation for damages, restrictions on holding positions, and early termination without severance in cases of misconduct.
Formalisation of the corporate secretary function: The law clarifies the legal status and responsibilities of corporate secretaries, positioning the role as a key institutional safeguard for shareholder rights, board effectiveness and information flows. For listed companies, enterprises of public interest, and private companies with more than 1 000 shareholders, the appointment of a corporate secretary is mandatory.
Alignment of independence requirements for SOE supervisory boards.15 The revised law resolves earlier inconsistencies between company law and state ownership legislation by establishing that, in joint-stock companies with state ownership of 50% or more, the majority of supervisory board members must be independent.
In addition, the law amends the framework for limited liability companies by allowing exclusive supervisory board powers to be outlined in company charters. This change removes a key structural obstacle to SOE corporatisation outside the joint-stock form and expands the range of governance-compatible legal structures available to SOEs and state-owned banks.
Law on Banks and Banking
The legal framework governing state-owned banks has remained broadly stable since the 2021 SOE Review (OECD, 2021[14]). Nevertheless, targeted amendments adopted in 2023 under the Law on Improving Corporate Governance in Banks further refined governance standards in line with prudential and integrity objectives (Verkhovna Rada of Ukraine, 2023[21]). These amendments introduced:
Enhanced collective suitability requirements for supervisory and management boards of state-owned banks.
Mandatory prior approval by the NBU for candidates to supervisory boards of SOBs.
Clearer procedures for competitive selection of CEOs and management board members, led by board-level nomination and remuneration committees and announced at least three months prior to mandate expiry.
Mandatory annual supervisory board performance evaluations, including assessment of strategic implementation.
Updated independence criteria, prohibiting individuals from simultaneously serving as independent members on more than one SOB supervisory board.
Together, these changes reinforce the professionalisation of governance in the banking segment of the SOE portfolio, which remains among the most institutionally advanced in Ukraine.
2.3.2. Law on the Improvement of SOE Corporate Governance – New “SOE law”
As noted, a defining milestone since 2021 has been the adoption of Law No. 3587-IX/ 2024 (Verkhovna Rada of Ukraine, 2024[22]). The law constitutes the centrepiece of Ukraine’s SOE reform agenda and reflects a deliberate effort to align the national framework with the SOE Guidelines. Rather than introducing isolated amendments, it establishes a coherent governance architecture spanning ownership, boards, performance oversight and accountability.
To ensure legal consistency, complementary amendments were introduced into the Civil Code, the Law on JSC, and the Law on the Cabinet of Ministers of Ukraine, reinforcing the horizontal application of corporate governance principles across the SOE sector. The new SOE Law introduces several key improvements for SOEs, including:
Strengthening supervisory board authority: Supervisory boards are granted exclusive powers to appoint and dismiss CEOs and to approve strategic and financial plans, including in SOEs overseen by the Cabinet of Ministers. Exceptions remain only for enterprises governed by special legislation.
Safeguarding board independence: An exhaustive list of legal grounds for early dismissal of supervisory board members is established, limiting discretionary interpretation and reducing exposure to politically motivated removals. Recent dismissal decisions affecting entire supervisory boards without publicly articulated justification have nonetheless raised questions regarding the consistency of implementation; these issues are examined further in the assessment against the SOE Guidelines.
Institutionalising board performance evaluations: Supervisory boards must be evaluated at least once every three years, with procedures defined by Cabinet resolution. Evaluations may be based on independent consultant assessments or structured self-assessments, with results subject to approval by the ownership entity. In November 2025, CMU Resolution No. 1441 introduced a temporary mechanism allowing shareholders to evaluate supervisory boards for the duration of martial law. While intended to ensure continuity of oversight, its application has generated concerns regarding safeguards for board independence; this is analysed in greater detail in the relevant section of the assessment against the SOE Guidelines.
Reforming dividend regulation: The law abolishes the minimum dividend payout ratio from primary legislation, allowing greater flexibility and differentiation across SOEs. It also enables consolidated dividend payments for corporate groups and instalment-based transfers. Temporary wartime exemptions apply to seized or confiscated assets.
Introducing a formal state ownership policy framework: The Cabinet of Ministers is required to adopt an overarching State Ownership Policy, complemented by letters of expectations, thereby linking ownership objectives, strategic planning and performance monitoring within a unified hierarchy.
Secondary legislation under the new SOE Law
Following the adoption of the new SOE Law, the government moved swiftly to operationalise its provisions through secondary legislation. Within months, a package of Cabinet resolutions established the procedural backbone necessary for implementation, directly addressing long-standing OECD recommendations from the 2021 Review (OECD, 2021[14]).
Most notably, the adoption of Ukraine’s first State Ownership Policy marks a conceptual turning point. For the first time, the state articulated a clear rationale for ownership and introduced systematic criteria for reviewing whether continued state ownership remains justified. Developed through a six-month consultative process, the State Ownership Policy sets expectations regarding goal-setting, performance indicators and ownership conduct, thereby promoting consistency across a large and decentralised SOE portfolio (Verkhovna Rada of Ukraine, 2024[23]).
Complementing this, a new State Dividend Policy seeks to balance fiscal interests with SOE sustainability. While the policy introduces transparency and predictability compared to earlier discretionary practices, it reinstates a 75% minimum payout ratio and retains special wartime provisions. Although flexibility mechanisms exist, some stakeholders view the minimum rate as constraining reinvestment capacity.
Board accountability mechanisms have also been strengthened. A resolution adopted in early 2025 introduced a unified methodology for supervisory board evaluations, requiring annual self-assessments and external reviews at least every three years. This represents a shift from largely formalistic assessments towards a documented and performance-oriented process.
In parallel, new reporting obligations require supervisory boards to regularly document progress against strategic plans and ownership expectations. The standardised reporting format enhances transparency by requiring explanations for deviations and timelines for corrective action.
Finally, the government introduced a mechanism for approving key financial indicators in strategic SOE documents, particularly for economically significant enterprises. While this additional Ministry of Finance oversight does not necessarily limit operational autonomy, stakeholders have raised concerns that the use of integral financial indicators may be overly rigid and insufficiently adaptable to enterprises with non-standard business models. At the same time, the mechanism aims to strengthen fiscal oversight and ensure closer alignment between SOE financial planning and broader macro-fiscal objectives, reflecting a wartime compromise aimed at safeguarding fiscal discipline and macroeconomic stability.
Taken together, these measures signal a structural evolution in Ukraine’s approach to SOE governance, from reactive and case-specific intervention towards a more predictable, rules-based and performance-driven ownership framework. While most secondary legislation has now been adopted, several bylaws remain under development, notably in relation to nomination procedures for major SOEs.
2.3.3. Other legislative initiatives
A further transformative reform was initiated with the adoption of Law No. 4196-IX on 9 January 2025, which fundamentally reshapes the legal foundations of state entrepreneurship. The law repeals the Commercial Code of Ukraine – long a source of legal dualism – with effect from 28 August 2025, thereby accelerating the transition of SOEs towards standard corporate forms.
The reform introduces a time-bound corporatisation process, requiring ownership entities to decide on liquidation, transformation into joint-stock or limited liability companies, or conversion into non-commercial entities. State enterprises must complete corporatisation within three years, after which management rights may be transferred to the State Property Fund if deadlines are not met.
Beyond organisational form, the law also modernises asset ownership regimes, replaces outdated concepts of economic and operational management, strengthens transparency of unused public property, and reinstates post-war financial reporting obligations. Collectively, these changes address one of the most persistent structural weaknesses in Ukraine’s SOE framework and lay the groundwork for greater legal clarity, accountability and market compatibility. Key anticipated changes under the new law are summarised in Table 2.8.
Note: The legal regime allows SOEs and MOEs to use state or municipal property transferred to them and retain profits.
Source: Verkhovna Rada of Ukraine (2024[24]), Law No. 6013 (consolidated version), https://zakon.rada.gov.ua.
Since the declaration of martial law16 in February 2022 following Russia’s full-scale invasion, Ukraine has been required to operate its state-owned enterprise sector under exceptional conditions. In response, the government introduced a series of temporary governance adjustments aimed at preserving continuity of essential services, safeguarding national security, and supporting wartime resilience. While some standard corporate governance safeguards were suspended or adapted, these measures largely reflect an effort to balance emergency decision-making with the longer-term objectives of SOE reform. This section reviews how martial law has reshaped SOE governance arrangements in practice.
2.4.1. Special obligations imposed on state-owned enterprises
Under Presidential Decree No. 64/ 2022, the Cabinet of Ministers adopted a comprehensive plan to operationalise martial law across the public sector. Within this framework, a number of SOEs were assigned critical responsibilities linked to national defence, territorial resilience and the uninterrupted provision of essential services. These responsibilities span sectors such as rail transport, energy generation and distribution, logistics, and postal services, positioning SOEs as central operational actors during wartime.
Several SOEs were formally entrusted with additional tasks reflecting their strategic importance, operational scale and nationwide presence. These special obligations go well beyond normal commercial activities and include evacuation support, humanitarian logistics, price stabilisation mechanisms, and direct support to military and civilian authorities. While these arrangements are formally temporary, their duration and intensity raise important questions regarding the eventual transition back to peacetime governance, particularly where enterprises have adjusted their structures, finances or risk profiles to meet expanded wartime mandates.
In some cases, public service obligations predate the full-scale invasion and stem from the systemic role of certain SOEs in energy, transport or social service delivery. The coexistence of long-standing mandates with newly imposed wartime obligations further blurs the boundary between commercial and non-commercial objectives. As Ukraine plans for recovery and reconstruction, clarifying this distinction will be critical to restoring accountability, performance monitoring and financial transparency across the SOE portfolio.
Source: OECD Secretariat compilation.
2.4.2. CEO appointment
To ensure operational continuity during wartime, temporary exceptions were introduced to standard CEO appointment procedures for SOEs and municipally-owned enterprises. Competitive selection requirements were suspended, and foreign nationals were temporarily barred from appointment as chief executives. Individuals appointed under these emergency procedures may remain in office for no more than twelve months following the lifting of martial law, at which point a competitive process must be initiated. In addition, candidates were exempted from Ukrainian language certification requirements. While these measures facilitated rapid staffing decisions during crisis conditions, they also reduce safeguards related to merit-based selection and managerial accountability.
2.4.3. Supervisory boards
Additional grounds for early dismissal
In April 2022, amendments adopted under Law No. 2182 introduced additional powers for ownership entities to mitigate perceived national security risks within SOEs and state-owned banks. In particular, ownership entities may designate a specific physical location where company officials – including supervisory board members – are required to perform their duties if deemed necessary for security reasons.
Once such a location is determined, board members must report there “immediately”. However, the legislation does not define this timeframe, nor does it establish objective criteria for determining the existence of national security risks. Failure to comply may constitute grounds for early dismissal. These provisions apply exclusively during martial law.
Although this mechanism has rarely been used in practice, it introduces a latent governance risk. The possibility of requiring physical presence in Ukraine – including for non-resident independent board members – may be difficult to fulfil given travel restrictions and security constraints. In the absence of procedural safeguards, this provision could, in principle, be used to justify premature termination of supervisory board mandates, thereby weakening board stability and independence.
Specific carveouts under the new SOE law
The adoption of the new SOE law marked a significant step towards strengthening supervisory board authority and independence in line with the SOE Guidelines. However, several of its core provisions are subject to temporary limitations during martial law and for up to twelve months following its termination, with an overall cap of three years from entry into force.
In particular, while the law grants supervisory boards exclusive authority over strategic, financial and investment plans, a sunset clause applies to large and systemically important SOEs – including natural monopolies and enterprises with net profits exceeding UAH 50 million. For these entities, the Ministry of Finance retains approval authority over key financial indicators embedded in strategic documents. Under the relevant procedure, such approval must be issued by 30 April each year, after which decisions are escalated to the Cabinet of Ministers.
Moreover, during martial law and the subsequent transitional period, ownership entities may temporarily exercise powers normally reserved for supervisory boards where no board exists or where its composition is not quorate. While intended as a contingency mechanism, this arrangement may inadvertently reduce incentives to appoint or reconstitute boards, particularly when combined with expanded dismissal powers during wartime. In practice, this creates a risk of prolonged substitution of board functions by ownership entities.
Abolishing the supervisory board’s competitive selection procedure
Cabinet of Ministers Resolution No. 643 of May 2022 suspended competitive selection procedures for supervisory board members across most SOEs for the duration of martial law. Exceptions were maintained for a limited group of strategically significant enterprises, including Ukrenergo, Naftogaz, Ukrposhta, Ukrzaliznytsia, Energoatom, GTSOU, the Ukrainian Danube Shipping Company, the Sea Ports Authority, Boryspil International Airport, Forests of Ukraine, and majority state-owned banks.
Subsequently, Resolution No. 1596 reinstated competitive selection for a subset of energy SOEs; however, it introduced an additional nomination regime that further differentiated board appointment practices across the SOE portfolio. The resolution also reassigned Centrenergo from the Nomination Committee framework to this special regime, where procedural safeguards appear comparatively more limited.
At the outset of the invasion, these measures were widely viewed as necessary to ensure uninterrupted governance. Since then, competitive nomination processes have been completed for several major SOEs, including Ukrenergo, Naftogaz, Ukrposhta, Energoatom, GTSOU and Forests of Ukraine.
Nonetheless, implementation remains uneven across the SOE portfolio and largely dependent on the discretion of ownership entities. While some entities have voluntarily applied competitive procedures – as in the case of Medical Procurement of Ukraine – others have relied on direct appointments, for example in the case of the state-owned enterprise Ukrainian Defence Industry (Ukroboronprom). This divergence illustrates how temporary exemptions have evolved into differentiated governance practices during wartime (Ministry of Defence of Ukraine, 2024[25]).
Disclosure rules
Revisions to the Law “on Capital Markets and Organised Commodity Markets” significantly strengthened disclosure obligations for joint-stock companies, including SOEs operating as JSCs. The framework requires annual and interim reporting equivalent to that of listed companies and enterprises of public interest, encompassing financial statements, management reports, corporate governance disclosures, sustainability reporting, remuneration information, ownership structures and dividend policies.
In parallel, SOEs are required to publish a broad set of internal governance documents, covering internal control systems, conflict-of-interest frameworks, stakeholder engagement, diversity policies, remuneration arrangements, anti-corruption measures and information disclosure practices. However, the practical effect of these enhanced requirements has been substantially limited by wartime disclosure exemptions. In particular, legislation governing financial sector functioning during martial law permitted companies to defer publication of financial statements. Draft law No. 6013 subsequently introduced an obligation to publish all deferred financial reports within six months of its entry into force.
To operationalise these requirements, the National Securities and Stock Market Commission mandated that issuers disclose outstanding annual and interim information for 2021–2023 within 90 days following the end of martial law, while ongoing disclosure obligations were reinstated from 1 January 2024 (National Commission on Securities and Stock Market, 2024[26]).
In June 2024, additional exemptions were introduced for enterprises of public interest operating in sensitive sectors – including energy, defence, transport, pipeline operations and extractive industries – allowing them to submit disclosures to the regulator without public publication. As these sectors encompass most large SOEs, the overall availability of public corporate information was significantly reduced during this period.
These exemptions were repealed with the adoption of Law No. 4196 in January 2025, and the NSSMC formally revoked its earlier decision in May 2025. Companies are now required to submit all outstanding disclosures by 30 September 2025. This step is expected to restore the integrity of the disclosure framework, although the temporary information gaps have constrained transparency and data availability for this Review.
Bankruptcy procedure
Under transitional provisions of the Bankruptcy Procedure Code, a moratorium applies during martial law and for two years thereafter on initiating or continuing bankruptcy proceedings for certain SOEs. The moratorium applies where enterprises operate critical infrastructure, have been subject to compulsory expropriation, and remain majority state-owned. These measures aim to protect strategically important entities while preserving the possibility of liquidation in clearly defined cases.
Confiscation, nationalisation, and asset seizure
The war has also given rise to new forms of state ownership resulting from asset seizures and nationalisation measures. Property seized for state needs is governed by legislation requiring either restitution or fair compensation. In such cases, corporate rights are typically transferred to the Ministry of Defence, which may subsequently delegate ownership functions to other authorised bodies. Notably, in November 2022, the Security and Defence Council ordered the transfer of corporate rights of Ukrnafta, Ukrtatnafta, Motor Sich, AvtoKrAZ and Zaporizhzhiaoblenergoto the state.
A parallel mechanism operates under the Law “on Sanctions”, whereby the High Anti-Corruption Court may order confiscation of assets belonging to individuals deemed to threaten national security. These assets are transferred to the State Property Fund of Ukraine for management or sale, with proceeds channelled to the Fund for the Elimination of the Consequences of Armed Aggression. While these instruments serve urgent national objectives, they also expand the SOE perimeter and introduce additional governance, ownership and accountability challenges for the post-war period.
References
[13] Cabinet of Ministers of Ukraine (2024), від 29 листопада 2024 р. № 1369, https://www.kmu.gov.ua/npas/deiaki-pytannia-polityky-derzhavnoi-vlasnosti-1369-291124.
[18] CIS legislation (2023), LAW OF UKRAINE - About features of the termination of the state companies for the decision of Fund of state-owned property of Ukraine, https://cis-legislation.com/document.fwx?rgn=150608.
[7] IMF (2025), A Critical Juncture amid Policy Shifts, https://www.imf.org/en/publications/weo/issues/2025/04/22/world-economic-outlook-april-2025.
[10] IMF (2025), Ukraine: Eighth Review Under the Extended Arrangement Under the Extended Fund Facility, Requests for Modification of Performance Criteria, Rephasing of Access, and Financing Assurances Review-Press Release; Staff Report; and Statement by the Alternate Exe, https://meetings.imf.org/en/IMF/Home/Publications/CR/Issues/2025/06/30/Ukraine-Eighth-Review-Under-the-Extended-Arrangement-Under-the-Extended-Fund-Facility-568152.
[15] IMF (2014), 2013 ARTICLE IV CONSULTATION AND FIRST POST-PROGRAM MONITORING—STAFF REPORT; PRESS RELEASE; AND STATEMENT BY THE EXECUTIVE DIRECTOR FOR UKRAINE, https://www.imf.org/external/pubs/ft/scr/2014/cr14145.pdf?.
[12] Interfax (2024), Ukraine may create new stock exchange involving state-owned banks, govt bonds - IMF, https://interfax.com/newsroom/top-stories/103931/.
[27] MacroTrends (2025), Ukraine GDP 1987-2025, https://www.macrotrends.net/global-metrics/countries/ukr/ukraine/gdp-gross-domestic-product.
[25] Ministry of Defence of Ukraine (2024), The Government has set up the supervisory boards for the acquisition agencies of the Ministry of Defence, https://mod.gov.ua/en/news/the-government-has-set-up-the-supervisory-boards-for-the-acquisition-agencies-of-the-ministry-of-defence.
[11] Ministry of Finance of Ukraine (2025), State-owned Banks, https://mof.gov.ua/en/banki-derzhavnogo-sektoru.
[9] National Bank of Ukraine (2025), Banking Sector Review, August 2025, https://bank.gov.ua/en/news/all/oglyad-bankivskogo-sektoru-serpen-2025-roku.
[26] National Commission on Securities and Stock Market (2024), On amendments to the decision of the National Securities and Stock Market Commission of January 24, 2024 No. 98, https://www.nssmc.gov.ua/document/?id=20786705.
[8] OECD (2025), Mapping Ukraine’s Financial Markets and Corporate Governance Framework for a Sustainable Recovery, OECD Publishing, Paris, https://doi.org/10.1787/866c5c44-en.
[1] OECD (ed.) (2025), OECD Economic Outlook, OECD, https://doi.org/10.1787/9f653ca1-en.
[3] OECD (ed.) (2025), OECD Integrity and Anti-Corruption Review of Ukraine, OECD, https://www.oecd.org/en/publications/oecd-integrity-and-anti-corruption-review-of-ukraine_7dbe965b-en.html.
[4] OECD (ed.) (2025), Ukraine Fifth Round of Anti-corruption monitoring follow up report, OECD, https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/09/ukraine-fifth-round-of-anti-corruption-monitoring-follow-up-report_218cbaa8/097f0a38-en.pdf.
[14] OECD (2021), OECD Review of the Corporate Governance of State-Owned Enterprises: Ukraine, Corporate Governance, OECD, https://doi.org/10.1787/9dcc5ed0-en.
[5] Reuters (2024), Ukraine’s economy grew 5.3% in 2023, statistics service says, https://www.reuters.com/markets/europe/ukraines-economy-grew-53-2023-statistics-service-says-2024-03-28.
[19] State Property Fund (2025), , https://www.spfu.gov.ua/userfiles/pdf/analityka-6-mis-2025-_18776.pdf.
[6] Ukraine Facility (2024), Ukraine Facility, https://www.ukrainefacility.me.gov.ua/en/.
[16] UKRinform (2025), Almost 380 state-owned objects privatized in Ukraine in 2024, https://www.ukrinform.net/rubric-economy/3947708-almost-380-stateowned-objects-privatized-in-ukraine-in-2024.html.
[17] USAID/UKaid (2023), STATE-OWNED ENTERPRISE REFORM ACTIVITY IN UKRAINE - Minutes of the Thematic Subgroup Privatization of SOEs Meeting of Reform Coordination Mechanism.
[23] Verkhovna Rada of Ukraine (2024), Some issues of State Property Policy, https://zakon.rada.gov.ua/laws/show/1369-2024-%D0%BF#Text.
[22] Verkhovna Rada of Ukraine (2024), Про внесення змін до деяких законодавчих актів України щодо вдосконалення корпоративного управління, https://zakon.rada.gov.ua/laws/show/3587-20#Text.
[24] Verkhovna Rada of Ukraine (2024), Проект Закону про особливості регулювання підприємницької діяльності окремих видів юридичних осіб та їх об’єднань у перехідний період, https://w1.c1.rada.gov.ua/pls/zweb2/webproc4_1?pf3511=72707.
[20] Verkhovna Rada of Ukraine (2023), About joint-stock companies, https://zakon.rada.gov.ua/laws/show/2465-20.
[21] Verkhovna Rada of Ukraine (2023), On amendments to certain legislative acts of Ukraine regarding the improvement of issues of organizing corporate governance in banks and other issues, https://zakon.rada.gov.ua/laws/show/1587-20#n131.
[2] World Bank (2024), World Bank Open Data, https://data.worldbank.org/country/ukraine.
← 1. Prepared jointly by the Ukrainian government, World Bank, United Nations (UN) and European Union.
← 2. A vast amount of these natural resource deposits are located in the east of the country in areas currently occupied by Russia, or close enough to the frontline to make extraction impractical.
← 3. Ukraine’s Parliament
← 4. Kyiv and Sevastopol
← 5. Amalgamated territorial communities
← 6. Down from 511 408 full-time employees in 2023.
← 7. Due to martial law, updated data was not shared by the Ukrainian authorities.
← 8. The primary sector includes agriculture, forestry, and fisheries, as well as mining and quarrying.
← 9. For a more detailed historical perspective on privatisation refer to (OECD, 2021[14]).
← 10. SOERA was initially established as a seven-year (2021-2028) USAID/UKaid activity to help the Government of Ukraine enhance public sector governance and property management. In November 2023, the group organised a Thematic Subgroup on ‘Privatisation of SOEs Meeting ofReform Coordination Mechanism’ which largely fed into the information of this section.
← 11. Full title of the law: About features of the termination of the state companies for the decision of the Fund of state-owned property of Ukraine.
← 12. The 2021 SOE Review of Ukraine outlined additional regulations that shape SOE legal and operational frameworks, alongside laws and strategies related to corporate governance. Unless they were subject to reform since 2021, they have not been reconsidered in this section.
← 13. The Law on Management of Objects of State Property remains the core legal act regulating corporate governance practices in SOEs, regardless of their legal form. In 2024, the law was significantly amended due to the adoption of the Law on the Improvement of SOE Corporate Governance. The new SOE Law introduced amendments to several laws governing the SOE framework, including the Law on Management of Objects of State Property, without replacing any of them.
← 14. According to the 2022 JSC Law, officials of joint-stock companies include: the chair and members of the supervisory board or board of directors, the CEO and members of the collegial executive body, the head of the internal audit function (internal auditor), the head of the budget department, the corporate secretary, and members of any other body of the joint-stock company if such a body is envisaged by the company’s charter.
← 15. For non-SOE JSCs, the law stipulates that at least one-third of the board of directors of a company publicly trading shares must consist of independent board members. The law also specifies a list of persons who cannot be considered as an independent director.
← 16. Martial law in Ukraine is a special legal regime introduced in response to external threats, such as armed aggression, that grants expanded powers to the military and government authorities while imposing temporary restrictions on certain rights and freedoms. It is regulated by the Law on the Legal Regime of Martial law and is declared by a presidential decree.
← 17. Prohibiting being on the streets and in other public places during certain periods without specially issued permits and identification.
← 18. In accordance with CMU Resolution No. 305/ 2022 on the Specifics of the Operation of the Joint-Stock Company ‘Ukrposhta’ under martial law.
← 19. Resolution No. 222/ 2022 on the approval of the Regulation on imposing public service obligations on natural gas market entities to ensure public interests in the functioning of the natural gas market.