The European Commission has published its Ukraine 2025 Report assessing Ukraine’s progress as a candidate country.

In the area of anti-corruption, the Commission noted limited progress. In particular, following the attempt to dismantle the independence of the National Anti-Corruption Bureau of Ukraine and the Specialized Anti-Corruption Prosecutor’s Office, as well as several other harmful legislative initiatives, the Commission raised concerns over Ukraine’s commitment to its anti-corruption agenda. At the same time, the Commission highlighted that the anti-corruption institutions themselves continued to deliver results: the number of high-level corruption cases, indictments, and convictions increased.

Positive trends were also noted in the reform of the Asset Recovery and Management Agency and the Accounting Chamber.

Public procurement was among the areas where limited progress was achieved. 

The report outlines a number of key priorities that we welcome, as they correspond to the vast majority of our recommendations and the findings of the Shadow Report. 

Below is a closer look at the Commission’s assessment of Ukraine’s progress in Transparency International Ukraine’s key areas of expertise and its recommendations for these sectors.

Prosecution of high-level corruption 

The European Commission stressed the importance of preserving the independence of the anti-corruption institutions, particularly in the context of the July Law No. 4555. According to the Commission’s assessment, this law dismantled essential safeguards for the independence of NABU and SAPO and subordinated their operational activities to the politically appointed Prosecutor General. These amendments could have significantly weakened Ukraine’s anti-corruption system. 

The Commission noted that undue pressure on anti-corruption institutions remains a matter of concern.

It also observed that the specialized anti-corruption bodies (NABU, SAPO, and HACC) continued to carry out their mandates and build their track record by intensifying investigations, prosecutions, and judgments in high-level corruption cases. However, the trend for investigations of corruption offenses by other law-enforcement bodies (the State Bureau of Investigation, the National Police, and the Economic Security Bureau) remained stagnant.

The Commission further pointed out that very few final convictions for illicit enrichment and false asset declarations have been issued in both high- and low-level cases, which calls for corrective measures at the legislative and institutional levels. It also noted that the number of arrests and final confiscations of assets in high-level corruption cases remains low and that further progress is needed, in particular through effective parallel financial investigations.

The Commission’s recommendations regarding NABU, SAPO, and HACC include the following: 

  • Preserve the independence of anti-corruption institutions, introducing robust safeguards against interference in the work of NABU and SAPO and against circumvention of their exclusive jurisdiction over high-level corruption cases. 
  • Expand NABU’s jurisdiction and remove obstacles to its investigations. Its jurisdiction should cover all public positions with a high level of corruption risk. At the same time, it is necessary to promptly resolve the problems related to NABU’s access to timely and impartial forensic examinations and to ensure its independent wiretapping capabilities in practice. Further, internal control mechanisms should be strengthened to prevent improper disclosure of investigative information.
  • NABU should focus more on cases with significant impact. 
  • Strengthen SAPO’s autonomy in investigating members of parliament without prior approval by the Prosecutor General.
  • Increase HACC’s capacity. In particular, by enlarging the number of judges with the mandatory participation of the PCIE and by developing a comprehensive strategy to enhance judicial efficiency. The Commission also recommended repealing the provision on the automatic closure of criminal cases due to the expiration of pre-trial investigation time limits.
  • Amend the Criminal Procedure Code to alleviate impediments and procedural delays to the efficient holding of criminal proceedings, particularly in high-level corruption cases.
  • Review and adjust statutes of limitation and the grounds for their interruption and suspension, in line with European standards.

The EU also noted that in June 2025, Parliament established the Temporary Investigative Commission to examine possible corruption in law-enforcement bodies, courts, and judicial institutions. The report emphasized that parliamentary oversight does not erode public trust in anticorruption institutions through unwarranted public statements nor overstep the limitations stemming from the separation of powers.

Effectiveness of the National Agency on Corruption Prevention

The Commission stated that overall, the National Agency on Corruption Prevention (NACP) maintains its central role in anti-corruption policy making and preventing corruption, but concerns have been raised regarding its impartiality and effectiveness in some of its operations. 

In particular, the Commission identified legal and practical deficiencies in the electronic asset declaration system and stressed the need to ensure some degree of external oversight of the logic and arithmetic control of declarations. Despite these concerns, the report positively assessed the NACP’s effectiveness in lifestyle monitoring of public officials, including effective follow-up actions and civil confiscation decisions by the HACC. However, TI Ukraine does not share this assessment.

The Commission described the impact of the 2021–2025 Anti-Corruption Strategy and the State Anti-Corruption Programme as limited, and found no significant effect from the Agency’s legislative review activities. 

In the area of anti-corruption and financial control, the Commission recommended that Ukraine:

  • Expand the personal scope of declarants and simplify and improve the procedures for the verification of asset declarations. 
  • Strengthen the capacities and focus of the National Agency on Corruption Prevention (NACP) to detect unexplained wealth.
  • Urgently implement the outstanding recommendations of the report issued in 2023 based on the results of an independent assessment of the effectiveness of the NACP.
  • Develop and adopt the 2026-2030 Anti-corruption Strategy and the State Anti-Corruption Programme without delay, in a transparent and inclusive manner.

Criminal asset recovery and management 

The Commission notes that Ukraine has some level of preparation in the field of justice, freedom and security, and made some progress during the reporting period. In particular, Ukraine moved forward with the reform of the Asset Recovery and Management Agency (ARMA).

It observed that the selection of ARMA’s head is still ongoing, but full implementation of the reform requires an independent performance evaluation of the Agency as well as the adoption of necessary legal framework. This likely refers to the adoption of qualitative bylaws for the updated ARMA law and amendments to the Criminal Procedure Code to ensure its effective enforcement.

The Commission further underlined that special confiscation and extended confiscation are largely underutilized, while consolidated statistics on confiscations are not produced. It therefore formulated several recommendations: 

  • Amend the Criminal Procedure Code to to enable pre-trial asset seizure for the purpose of extended confiscation and special confiscation.
  • The rules on non-conviction-based confiscation in criminal proceedings should be further aligned with the EU Directive on asset recovery and confiscation.

Public procurement 

The Commission concluded that Ukraine has some level of preparation in the area of public procurement and achieved limited progress. Progress has been made in implementing the Strategy for Reforming the Public Procurement System for 2024-2026 (the Strategy). The European Commission also positively assessed professionalisation of public procurers and further development of the electronic procurement system Prozorro. 

However, “the long-due public procurement law was not adopted.”

The Commission also noted the adoption of a new public-private partnership law, albeit with significant gaps vis-à-vis EU standards, as it fails to ensure equal treatment of domestic and foreign companies. 

Therefore, last year’s recommendations were implemented only partially and remain valid. 

In the area of public procurement, the Commission called on Ukraine to:

  • Make progress towards further aligning legislation on public procurement, concessions, public-private partnerships, and defense and security procurement, complying with the EU acquis. Ensure that EU operators can participate in Ukrainian procurement processes on fully non-discriminatory terms.
  • Strengthen control measures over procurement procedures. 
  • Enhance the e-procurement functionality, including development of new procurement tools and e-contracting in the Prozorro system, as well as operational interoperability with DREAM system and other applicable state IT systems.

Amend the Strategy to better define the strategic goals, tasks and performance indicators. 

Financial control

According to the Commission, Ukraine has some level of preparation in implementing financial control and made good progress by amending the Law on the Accounting Chamber.

Regarding internal public financial control, the Commission noted progress in developing the regulatory framework, although operational effectiveness remains low.

The Commission’s recommendations from last year were partially implemented and remain valid. In the coming year, Ukraine should in particular:

  • Increase the quality of public sector internal audit by applying the new Global Internal Audit Standards and strengthening the role and capacities of the Ministry of Finance’s Centralized Harmonization Unit.
  • Strengthen the political and financial independence, and administrative capacities, of the Accounting Chamber, including by forming and operationalizing its Board.

Adopt the amendments to relevant legislation on financial control to strengthen the state financial control system, including the role and capacity of the State Audit Service in protecting the financial interests of the EU and the monitoring of procurement procedures, prioritizing preventive risk-based audits and effectively acting upon detected violations.

Other important recommendations

  • Extend the participation of international experts in the selection of members of the High Qualification Commission of Judges. The Commission recommended urgently extending the temporary involvement of internationally-nominated independent experts in the selection of members of the HQCJ.
  • Fully restore the situation that existed prior to the adoption of Law No. 4555. The law adopted after the July protests to restore the independence of NABU and SAPO did not address other problematic provisions, including those allowing the recruitment of prosecutors to regional prosecutor’s offices and the Prosecutor General’s Office without competition, and granting the Prosecutor General access to any pre-trial investigation materials (except those of NABU and SAPO). The Commission stated that these provisions undermine meritocracy within prosecutorial service and raise risks of undue interference in criminal cases. They should be repealed, and in the meantime, their application should be put on hold.