This document is a joint publication of Transparency International Ukraine (TI Ukraine) and the Basel Institute on Governance. It analyses the measures taken to strengthen Ukraine’s anti-corruption ecosystem during the period from March to the end of June 2025.

This paper supplements the previous report covering progress up until February 2025, and is published ahead of the fourth Ukraine Recovery Conference, which takes place in Rome on 10 and 11 July 2025.

Summary

1. New Roadmap: The Government of Ukraine has approved over five hundred future actions in the field of the rule of law as part of the European integration process. Overall, the Roadmap is comprehensive and includes a number of proposals from civil society.
2. Ongoing development and implementation of anti-corruption policy: The drafting of a new Anti-Corruption Strategy and State Anti-Corruption Program is underway. We call for the inclusion of important reforms not yet reflected in policy documents, such as granting the Specialized Anti-corruption Prosecution (SAPO) the authority to lead investigation mandates on current MPs, and competitive selection procedures for the Prosecutor General as well as for the heads of the State Bureau of Investigation (SBI) and the National Police.
3. ARMA reform: We welcome the adoption of a law launching the reform of the Asset Recovery and Management Agency. It is now essential to proceed with the next steps without delays to fully implement the reform, i.e. amend the Criminal Procedure Code of Ukraine and adopt relevant bylaws.
4. The mandate of the High Qualification Commission of Judges (HQCJ) selection commission, which includes international experts, has expired. We expect MPs to support the reinstatement of this selection procedure. Otherwise, it may lead to the return of political influence over judicial governance and pose challenges for other institutions whose reform required significant efforts.
5. HACC staff expanded: The High Anti-Corruption Court (HACC) has seen two new judges join, but 23 judicial vacancies remain open across the first and appellate instances. The HQCJ will begin accepting applications for the competition in July. It is important to ensure that the competition is conducted transparently and interviews with candidates take place within the Public Council of International Experts’ mandate.
6. First independent NABU audit conducted: International experts carried out the first independent audit of the National Anti-Corruption Bureau, providing a series of recommendations for both the NABU and lawmakers to improve the legal framework governing its operations. The audit, for example, also supported the long-standing position of civil society that the so-called “Lozovyi’s amendments” should be abolished and access of the Bureau to independent and timely forensic examination should be ensured.
7. Expiration of statutes of limitations: Several high-profile corruption cases adjudicated in the High Anti-Corruption Court are at risk of dismissal due to the expiration of statutes of limitations in 2026–2027. It is necessary to address this systematic problem and suspend the statute of limitations after a first-instance court verdict or during international cooperation.
8. Register of Corrupt Officials reform: In the case of Sytnyk v. Ukraine, the European Court of Human Rights found the indefinite inclusion of an individual in the Register of Corrupt Officials disproportionate with the right to respect for private life. The Parliament adopted a draft law introducing limits for retaining records in the Register depending on the type of legal liability of a corrupt official. We support this legislative change, but the limit on the disciplinary liability should be further introduced.
9. Recovery and reconstruction: A reform of public investment management is being implemented, covering, among other things, the financing and prioritisation of recovery projects. However, most of these projects lack secure funding in 2025. Public-private partnerships – whose preparation and implementation procedures were streamlined by the Draft Law adopted in June 2025 – are expected to cover part of this gap. The Restoration Agency’s role in the procurement of restoration projects is being strengthened after the transfer of some procurement functions from its regional units to a newly-established centralised procurement organisation (CPO). However, policy-level issues that facilitate overpricing in construction procurement, including a lack of a unified approach to determining material costs and price verification, must still be addressed for these changes to be transformative.