Why ARMA’s New Rules for Selecting Asset Managers Are Delayed

The updated rules for selecting managers of seized assets were not launched on January 30. The ARMA is still working on implementing the new procedures.

The changes introduced by the ARMA reform law regarding the rules for selecting asset managers through the electronic procurement system will not start operating from January 30, 2026. This became clear from ARMA’s response to a request from Transparency International Ukraine.

The law adopted in June 2025 regulated the procedures for selecting managers for simple and complex assets and provided that the new rules should enter into force six months after the adoption of these amendments. Those six months expired in late January 2026, but the electronic procurement system still does not have the functionality required to select asset managers.

As a result, until these changes are implemented in the Prozorro system, the selection of asset managers will not take place. In response to our request, the ARMA reported that, according to its projected estimates, testing of the working module format is divided into two key stages:

• Second half of February 2026 — testing functionality for selecting complex asset managers,
• March 2026 — testing functionality for selecting managers for simple assets.

It is important that the ARMA, Prozorro State Enterprise, and the Cabinet of Ministers ensure proper technical implementation of the new provisions of the ARMA law and systematically track any problems that may arise during rollout. Given that this is a new model, its implementation should be handled with particular care and improved based on the testing results.

Before the adoption of the ARMA Law, managers were selected under public procurement procedures regulated by the ARMA itself. These procedures were complex and not fully suited to the task, since when selecting a manager the state does not spend money, it earns it. In addition, the processes were excessively lengthy: in some cases, ARMA took more than 1.5 years to prepare even to announce a competition.

That is why the reform sets deadlines for announcing competitive procedures and introduces a division of assets into simple and complex categories, with selection rules tailored to each category.

For simple assets, the selection of a manager must be conducted through the electronic procurement system in two stages:

• preliminary qualification of participants;
• selection of the manager for a simple asset(s) through an auction among pre-qualified participants.
• For complex assets, the procedure includes more steps:
• announcement of the selection procedure for participants;
• submission of documents for participation in the selection of a complex asset manager through the electronic procurement system;
• disclosure of participants’ offers and their assessment for compliance with qualification requirements;
• determination of the manager of a complex asset through an auction among participants who meet the qualification requirements.

Although the updated ARMA law sets out the key elements of the manager selection process, timely adoption of the secondary regulatory framework is also critical. On August 20, 2025, the Agency established an Interagency Working Group to prepare legal regulations necessary to implement Law No. 4503-IX. However, preparation of the required regulations was delayed, and the ARMA obtained approval from the State Regulatory Service for the rules on selecting managers for complex and simple assets only on January 21 and January 16, 2026, respectively.

Therefore, until the Cabinet of Ministers adopts the relevant package of secondary regulations and the ARMA, together with Prozorro State Enterprise, launches the necessary modules in the electronic procurement system, the selection of managers for seized assets will, in practice, not take place. This is because the rules under which the Agency selected managers from July 30, 2025 to January 29, 2026 have ceased to be effective, while the technical framework for selecting managers under the new rules has not yet been created.

It is also worth noting that in Q3 2025 the ARMA concluded 19 asset management agreements, and in Q4 it concluded another 12 agreements. This follows from the quarterly reports on asset management performance indicators published by the Agency pursuant to the updated law. This already exceeds the number of asset management agreements the ARMA concluded in 2023 and 2024.