The Declaration Is There. But Will There Be Accountability for Violations?

Following the signing of Draft Law No. 13271-1, officials will have more leeway to live beyond their means. What changes does this law introduce to the system of financial control? And why might officials come out ahead — even with millions in assets of questionable origin?

To begin with, let us recall: corruption is a hidden phenomenon. It is not always possible to catch a bribe-taker “red-handed” with a suitcase of cash. Bribes may take the form of apartments, land plots, and other assets.

That is why, after the Revolution of Dignity, Ukraine finally moved from ineffective paper declarations to public electronic asset declarations, requiring officials, who are paid with taxpayers’ money, to disclose their wealth. The state established a special agency (NACP) to verify these declarations and to identify discrepancies between an official’s income and lifestyle. In parallel, the Criminal Code was amended with a provision on “illegal enrichment,” punishable by imprisonment in cases of major discrepancies.

Over time, the system expanded further, introducing a simplified civil confiscation mechanism for smaller unlawful assets. Moreover, following the controversial Constitutional Court decision, sanctions for false asset declarations were reinstated, including possible imprisonment.

Draft Law No. 13271-1, adopted by Parliament, was presented as a step toward strengthening liability for corruption-related offenses. The results of its implementation will be seen later, as investigations under the new provisions are still ongoing. Yet even now, the question arises: does this law bring Ukraine closer to genuine accountability, or does it merely simulate progress?

What does the new law change?

Not every discrepancy automatically triggers severe criminal liability. For this purpose, the law establishes thresholds — minimum amounts from which liability arises. These thresholds are intended to rationalize the use of the legal framework and the capacity of anti-corruption institutions, ensuring that nobody is imprisoned over a discrepancy of 100 hryvnias.

Parliament defines these thresholds in the Criminal Code, and Draft Law No. 13271-1 modifies them. However, it disregards several key recommendations from international partners within the EU integration process. The 2024 EU Enlargement Package explicitly calls for broadening penalties for unexplained wealth and considerably reducing the applicable thresholds to ensure a real deterrent effect.

In practice, however, Ukraine is raising the criminal liability thresholds for false declarations — from UAH 1.5 million and 6 million to UAH 2.27 million and 7.5 million. Formally, these amounts have only slightly changed, since when adjusted for inflation they remain nearly the same as in 2020, when they were first introduced, with corresponding increases in fines. The threshold for civil confiscation rises from UAH 1.5 million to UAH 2.27 million, which is also nearly unchanged in inflationary terms since 2019. The threshold for illegal enrichment is lowered by almost UAH 1 million but still remains high — UAH 9.04 million.

By comparison, Moldova, ranked higher than Ukraine in the latest Corruption Perceptions Index (43 points vs. Ukraine’s 35), with a government-projected average monthly wage of UAH 38,000 in 2025 and also an EU candidate state, imposes 7–12 years of imprisonment for illegal enrichment amounting to just UAH 2.2 million. Moreover, Moldova has a “light” version of liability — 3–7 years of imprisonment for UAH 1.5 million, which is more than six times lower than the Ukrainian threshold. In Ukraine, UAH 1.5 million merely triggers civil confiscation of unjustified assets, even though the circle of subjects has been expanded, with the possibility of returning to office after serving the penalty.

Another example: Lithuania, an EU member state. There, the illegal enrichment threshold is about UAH 2.9 million — already sufficient to open a criminal case and impose up to four years in prison. Compared to this, Ukraine’s thresholds appear noticeably more lenient toward corruption.

Petro Petrenko and a few million

Let me illustrate with an example. Suppose Petro Petrovych Petrenko heads a state-owned enterprise in a large Ukrainian city and is required to submit a declaration. His official salary is modest, yet he owns a downtown apartment and a new car, sends his children to study abroad, and holds several million in savings. This is where the problem arises.

For corruption control to be effective, not only is a public e-register of declarations necessary, but so are realistic criteria. In fact, the new law, ostensibly designed to catch corrupt officials, provides them with even more room to maneuver by adjusting the thresholds. Civil confiscation or liability for illegal enrichment arises only when the assets amount to tens or hundreds of thousands of dollars. Otherwise, one can “get away” with a minor administrative fine of UAH 17,000 for false declarations — a sanction most frequently applied by Ukrainian courts in corruption cases, as confirmed by Opendatabot analytics.

As a result, even if Petro Petrovych’s lifestyle is entirely disproportionate to his income, the state appears reluctant to act. An extra million or two of unexplained assets? The state simply shrugs, refrains from confiscation, and certainly does not imprison him for illegal enrichment — because he has not reached the threshold. This reveals a preference for compromise rather than genuine financial control.

Half-measures will not suffice

Draft Law No. 13271-1 undoubtedly contains positive elements. Yet in essence, it is more of a cosmetic adjustment than a substantive reform. It preserves a major flaw: the sanction system’s insufficient sensitivity to the scale of the problem.

The EU expects from Ukraine not simulations of reform but concrete changes capable of reducing corruption levels. Encouragingly, Ukraine’s recently adopted Rule of Law Road Map provides for a review of sanctions for corruption-related offenses in Q2 2027. It also envisions revising liability thresholds for illegal enrichment and false declarations to improve financial control, including better coordination between criminal and civil proceedings.

But the key question remains: will this review actually reduce the thresholds?

Ukraine has an opportunity not merely to patch superficial flaws but to reform the accountability system in line with existing European approaches. This would mean lowering the thresholds for criminal liability for false declarations and illegal enrichment from UAH 7.5 million and 9 million to UAH 2.4 million (800 subsistence minimums for able-bodied persons), which would place Ukraine at an intermediate level between Lithuania and Moldova. It would also mean reducing the threshold for civil confiscation and criminal false declarations from UAH 2.27 million to UAH 1.2 million (400 subsistence minimums), which corresponds to Moldova’s standards.

If Ukraine truly seeks EU accession, it must focus not on narrowing the scope of sanctions but on strengthening liability.

Otherwise, the only thing Ukraine confidently “declares” is its willingness to remain stuck with the very problems it faces today. Meanwhile, Petro Petrovych will continue enjoying life in the big city — and he will not be the only one.