ARMA on the Road to Reform: Progress on Asset Management and Unresolved Issues

Early February marked six months after the ARMA reform law entered into force. For the authorities, this was an ambitious agenda: meet clear deadlines for accepting assets, launch a new competition model, and identify the assets that had already been transferred to the Agency. What has been delivered—and where has the process stalled?

On February 24, 2026, Members of Parliament on the Anti-Corruption Committee heard a kind of progress report on the reform’s implementation. Acting Head of ARMA Yaroslava Maksymenko and Valerii Saienko, Director of the Asset Management Department, presented updates on the regulatory framework and the results of the inventory process. Here is what came out of that discussion.

Reform status and implementation of the law

To meet the requirements of the ARMA reform law, a package of subordinate regulations has already been drafted, and a substantial portion has entered into force. The implementation status of the key documents is as follows:

• The government has approved procedures for selecting asset managers for “simple” and “complex” assets, for monitoring the effectiveness of management, and for calculating estimated value.
• The resolution on asset insurance has successfully passed the government committee stage and is being prepared for consideration at a Cabinet of Ministers meeting.
• The procedure for approving template agreements and asset management programs is at the final stage of review within the Cabinet of Ministers Secretariat.

In addition, the meeting noted that the commission for selecting managers for complex assets is being finalized, and central executive authorities have already submitted nominations.

Inventory results and asset classification

This was among the most extensive tasks to be completed in the six months after the updated ARMA law was adopted. According to the Agency, as of December 31, 2025, the Unified Register of Seized Assets contained 102,569 entries. To determine the real volume of liquid assets, ARMA filtered out items without independent economic value, including 28,000 household items from Mezhyhiria and 20,000 items from Medvezha Dibrova.

This claim sparked a serious debate at the committee meeting: participants spent considerable time trying to establish how many assets are actually under ARMA’s management. We find the very reasons for this debate deeply unfortunate, because the same ARMA reform law launched the inventory of remaining assets and introduced the concept of an “asset pool” precisely so that economically meaningful groupings of assets could be identified and transferred for management effectively. 

Committee Chair Anastasiia Radina pointed out that ARMA was unable to produce a single official document confirming the inventory results, relying instead on “working materials” and internal memos. Yaroslava Maksymenko explained that methodological confusion and outdated accounting persist, along with a “clogged” seized assets register filled with small items and limited resources. In fact, a full, in-depth inventory of all 102,000 objects—given current staffing—would take roughly four months.

Ultimately, ARMA proposed fixing as a baseline 44,815 assets transferred since 2017 under 1,435 court rulings received by the Agency as of December 31, 2025.

Overall, the breakdown by asset category is as follows:

• Vehicles and equipment: 22,384 assets (including 19,307 units of railway rolling stock)
• Real estate and land plots: 6,842
• Various types of goods: 6,613
• Movable property and inventory items: 6,162
• Financial assets and corporate rights: 2,814 (including 533 business entities)

As for the economic liquidity of these results, there is still no final assessment. However, an overall review of identified assets showed the following distribution:

• 22,730 assets were deemed potentially manageable or suitable for sale;
• 6,982 items were destroyed, damaged, or located in occupied territories, abroad, or listed as wanted;
• 3,542 assets require procedural follow-up or a change in the method of management through the courts.

In summary, an accounting discrepancy was identified for 11,561 objects. As the Agency explained, this reflects a mismatch between assets transferred in practice and the assets listed in court rulings. In addition, work to define liquid units of assets has not yet been completed. Once identification is finished, the Agency plans to conduct a physical inventory and place assets on its balance sheet. When asked how many assets have been transferred to managers, and how many have been put out to competition, ARMA did not provide an answer.

Overall, Radina sharply criticized the absence of a single administrative act that would formally record the inventory results and establish the final number of assets. ARMA must therefore provide official information with verified figures, clearly distinguishing assets that can be managed, those requiring additional documentation, and the “gray zone” (unidentified property).

Social initiatives: housing for IDPs

Although the committee meeting did not ultimately yield a results-focused discussion of ARMA’s performance, MPs raised several questions they considered important. One concerned developing a mechanism for using seized residential real estate to meet the needs of internally displaced persons. ARMA proposed applying Article 21-1 and transferring such assets to state-sector entities, since commercial competitions for these properties did not attract private investors due to the social burden involved.

Maksymenko, however, pointed to technical obstacles. For example, many apartments are currently occupied by minor children, whose eviction is prohibited by law. In addition, commercial hotels have good-faith tenants whose equipment keeps building infrastructure functioning, and there is no mechanism to relocate people if a court unexpectedly lifts an arrest. The parties agreed to revisit the issue at the next meeting. We previously flagged similar risks related to transferring seized assets for IDP needs in our legal analysis of the relevant draft law.

High-profile asset cases: KAMparytet, Pin-Up, and CHP plants

The discussion of high-profile asset management cases was no less telling.

The first example concerned the KAMparytet management company whose interests, in spring last year, were allegedly advanced by then-ARMA head Olena Duma. Radina cited facts suggesting that the manager sublet shopping centers at prices three times higher than the income it declared to ARMA, leading to direct budget losses. The Agency confirmed the revealed violations and reported that it had begun procedures to terminate the contracts with this manager for inefficiency. 

One MP also expressed outrage at the return of UAH 122 million to Pin-Up owner Ihor Zotkin, described as having a questionable reputation. Yaroslava Maksymenko responded that she was executing a court decision: the plea agreement approved by the prosecutor did not provide for confiscation of these funds, which automatically required returning both the funds and the income generated from their management once the arrest was lifted.

A separate point is worth making here: the amendments allowing confiscation as a punishment when concluding an agreement that provides for release from serving a sentence applied only to corruption offenses. In this case, questions should have been directed not at ARMA’s leadership, but at Prosecutor General’s Office prosecutor Maksym Kapustin, who is listed on the court’s website as the prosecutor who submitted the agreement, and at Pecherskyi District Court judge Oleh Soloviov, who issued the judgment based on that agreement after finding it to be in the public interest. 

As for the management of the Novyi Rozdil and Novoiavorivsk CHP plants, seized in the case involving former MP Dubnevych, MPs emphasized the risk of disrupting the heating season because the current contracts expire in November 2026. They stressed that Naftogaz needs guarantees of continued management now to plan budgets for technical upgrades and modernization. ARMA’s leadership assured the committee that all contracts are being processed, but that extending them through the Cabinet of Ministers takes time.

Financial indicators and budget revenues

One committee member presented an analysis of budget revenues from asset management in the second half of 2025, showing a steep decline:

• July 2025: UAH 102 million
• August 2025: UAH 57 million
• September 2025: UAH 45 million
• November 2025: UAH 29 million

ARMA representatives explained that July’s UAH 102 million was an anomalous one-time spike driven by dividend payments from Ukrnafta and Naftogaz. Subsequent figures, they said, reflect problems with previously concluded contracts for managing seized assets and the genuinely low effectiveness of current management for other assets.

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Taken together, these developments show that ARMA’s reform requires significant resources and systematic, parallel management of several processes—something that still has not happened at the highest level.

Unfortunately, we still have not heard a clear picture from ARMA’s new leadership of how many assets are actually manageable. Confusion over the numbers remains, driven by different accounting approaches. That said, Maksymenko’s and Saienko’s answers were more focused on constructive work rather than populist statements—as was often the case before—which gives some hope that the processes described above will pick up pace.