Anti-Corruption That Works: The Results of NABU, SAPO, and HACC

The performance of the NABU and the SAPO at the pre-trial investigation stage, as well as the HACC’s performance in court proceedings, is improving. But what exactly lies behind the figures in these institutions’ reports? 

In July, even before the protests in defense of NABU’s and SAPO’s independence, we once again heard a whole wave of manipulative claims about whether NABU and SAPO had any real results at all. As had happened many times before, many of those advocating for dismantling the independence of the anti-corruption bodies relied on unverified information or on data mixed with half-truths.

We have seen this approach—highlighting shortcomings while turning a blind eye to the anti-corruption bodies’ actual performance indicators—almost since their launch after the Revolution of Dignity. But time has passed, and the results are there. 

All of this underscores the relevance of ongoing discussions about how to properly assess the effectiveness of pretrial investigations. It also points to the need to implement one of the measures laid down in the Rule of Law Road Map: creating a unified system for collecting and publishing anti-corruption statistics by the end of 2026. This system is expected to cover data on investigations, court cases, asset seizure and confiscation, and corruption prevention measures.

Until such a system is in place, the NABU and the HACC publish semiannual activity reports. Just a few weeks ago, the heads of NABU and SAPO held a briefing to present their performance report, while earlier the HACC published its statistical reports on its activities in 2025.

In this article, we want to take a closer look at what lies behind the reported figures and what trends can be seen over the past two turbulent years for anti-corruption efforts. 

How quickly NABU investigates cases and SAPO sends indictments to court

The data presented in February point to a certain decline in the number of people notified of suspicion in corruption cases in 2025, but overall, they indicate intensified work targeting top officials. 

While in 2024 notices of suspicion were served on 231 people in total, in 2025 that number was 218. 

So how did these figures change across categories of officials?

• The number of the highest-ranking officials notified of suspicion (ministers, heads of central executive authorities, and their deputies) doubled, from 6 people in 2024 to 12 in 2025.

For example, in 2024 former Minister of Agrarian Policy Mykola Solskyi was notified of suspicion in a land seizure case in Sumy region; former Deputy Head of the Office of the President Andrii Smyrnov was notified of suspicion for laundering illicitly obtained funds and accepting an offer of a bribe; and former Deputy Energy Minister Oleksandr Kheilo was notified of suspicion for offering a bribe. In 2025, those notified of suspicion included Antimonopoly Committee Head Pavlo Kyrylenko in a new episode of failure to declare assets and illicit enrichment; former Deputy Prime Minister and Minister of National Unity of Ukraine Oleksii Chernyshov for alleged abuse of office and accepting an undue benefit; and former Deputy Minister of Agrarian Policy and Food Volodymyr Topchii for alleged abuse of office.

• Representatives of the judiciary: 10 people received notices of suspicion in 2025, compared with 5 in 2024.

Among the NABU-SAPO proceedings in 2024, notable cases included the bribery case involving economic court judges in Lviv region and the case involving judges of the Bilhorod-Dnistrovskyi court in Odesa region, who allegedly accepted bribes for rulings that became grounds for draft deferments. In 2025, suspects in NABU bribery cases included a judge of a city district court in Dnipropetrovsk region, a judge of one of Odesa’s district courts, and a judge of the Volovets district court.

• Members of Parliament and local councils, as well as other local senior officials: the figure remained at roughly the same level—21 people in 2025 versus 22 in 2024. 

In this category, those notified of suspicion in 2024 included MP Mykola Zadorozhnii, who, according to the prosecution, together with accomplices solicited a bribe from the head of a village council in Sumy region and organized its transfer. Notices of suspicion were also served on Iryna Kormyshkina in a case involving illicit enrichment and false declarations, and on Mukachevo Mayor Andrii Baloha for allegedly ensuring the adoption of a decision to sell a municipally owned land plot at an understated price. In 2025, NABU and SAPO notified MP Viktor Bondar of suspicion for organizing a scheme to supply products to Ukrzaliznytsia at inflated prices. In another case, as many as four sitting MPs—Yevhen Pyvovarov, Ihor Nehulevskyi, Olha Savchenko, and Yurii Kisiel—were named as suspects for, according to the investigation, systematically receiving undue benefits in exchange for voting in Parliament.

• The number of suspected officials of state agencies and state-owned companies decreased: there were 23 such individuals in 2025, compared with 37 in 2024.

This can be explained, among other things, by the implementation of a policy of prioritizing investigations into high-level corruption.

The process of sending cases to court has also changed. The number of people in respect of whom indictments were prepared increased. In 2024, indictments were drawn up against 243 people (131 in the first half of the year and 112 in the second half), while in 2025 that number rose to 280 (154 in the first half and 126 in the second half).

In 2025, the largest number of SAPO indictments concerned:

• heads of other state agencies and state-owned companies—56 people. Among them were four defendants in the case about the embezzlement of funds from Ukrzaliznytsia; officials and their accomplices in the case concerning abuse at the Odesa Portside Plant; and officials charged in connection with laundering funds belonging to state-owned enterprises that were part of the Ukroboronprom concern.
• Members of Parliament and local councils, as well as other local senior officials—23 people. In 2025, cases sent to court included those against two former members of the Odesa Regional Council, who together with other accomplices seized 32 vessels, converted them into 12 barges, and unlawfully appropriated them. Also sent to court with an indictment was the case against MP Zadorozhnii, who, with the assistance of National Police officials, demanded a bribe in exchange for not obstructing infrastructure repair works in Sumy region. A former member of the Kharkiv Regional Council also became a defendant after allegedly organizing a criminal group whose actions in electricity sales during wartime caused losses of more than UAH 58 million to Ukrenergo.
• Law enforcement officials—26 people. Defendants in NABU and SAPO cases in this category included an ex-detective of the central office of the Bureau of Economic Security and a senior investigator of the Main Department of the National Police in Kyiv region for demanding an undue benefit of $150,000; the head of a sector within the SSU Department for the Protection of National Statehood and two other individuals exposed for demanding an undue benefit of $300,000; and a former head of a department of the Cherkasy Regional Prosecutor’s Office and a civilian who were exposed while receiving $41,000.

This trend shows that NABU and SAPO are not only opening more proceedings but are also more effectively bringing pretrial investigations to completion. This dispels the myth that NABU merely announces suspicions while the number of indictments remains low. Of course, once a person has been notified of suspicion, completing the pretrial investigation takes time, especially where mutual legal assistance measures are involved or suspects are being sought. 

Even so, for analytical purposes it would be appropriate for the statistics to include the average duration of pretrial investigations of criminal offenses, with a breakdown of the number of criminal proceedings in which the investigation has been suspended and an indication of the reasons for that, as well as the duration of the defense’s review of the case materials under Article 290 of the Criminal Procedure Code of Ukraine. At present, these aggregate indicators, which significantly affect the understanding of the timeline of top-level corruption cases, are unfortunately unavailable.

In addition, NABU’s statistics do not publish information on terminated criminal proceedings, including a breakdown showing whether these are cases with identified suspects or cases without suspects. That would make it possible to take a broader view of the pretrial investigation body’s work, including whether criminal proceedings remain pending there for long periods without notices of suspicion being issued.

It is also worth noting that Parliament still has not passed the changes that would strengthen NABU’s work and that international auditors have stressed are necessary. These include, in particular, abolishing the automatic closure of cases once investigation time limits expire, as well as resolving jurisdiction-related issues. This would allow the NABU and the SAPO to demonstrate an even higher level of effectiveness in investigating cases. In addition, unresolved issues remain with access to wiretapping without SSU involvement, as well as other matters affecting the efficient handling of state secrets and access to independent forensic examination.

The HACC’s effectiveness in court proceedings

The HACC’s annual report shows that its performance in court proceedings improved markedly across key indicators in 2024–2025: from the volume of cases reviewed to the speed of decision-making and the value of confiscated assets.

The HACC significantly increased the pace at which it completed criminal cases. In 2025, the court reviewed 114 cases (concerning 180 individuals), compared with 88 cases involving 137 individuals in 2024.

The number of judgments also rose, from 77 in 2024 (including 38 plea-based judgments) to 109 in 2025 (including 72 plea-based judgments). Overall, 154 individuals were convicted last year, substantially more than in 2024, when the figure was 112. We also see a decline in the number of acquittals, from 10 in 2024 to 8 in 2025. This, too, shows that most of the cases SAPO sends to court are built on a solid evidentiary foundation.

For example, in 2024 the HACC Appeals Chamber sentenced ex-MP Ruslan Solvar to three years in prison for unlawfully receiving compensation for housing rent. The HACC sentenced former SSU investigator Serhii Hlivinskyi to nine years in prison for soliciting and accepting a bribe, and MP Andrii Odarchenko also received his sentence—eight years in prison for attempting to bribe the former head of the State Agency for Recovery with bitcoin. 

Then, in 2025, the HACC sentenced ex-MP Dmytro Kriuchkov in absentia to 15 years in prison for embezzling more than UAH 1.5 billion from the companies Cherkasyoblenergo and Zaporizhzhiaoblenergo; former head of the State Judicial Administration Salnikov to three years for abuse of influence; and, finally, former head of the State Fiscal Service Roman Nasirov received his sentence—six years of imprisonment for abuse of office.

We also see a rise in the number of plea-based judgments. For example, in 2025, based on plea agreements, the HACC sentenced former head of the Western Economic Court of Appeal Borys Plotnytskyi to eight years of imprisonment, barred him from holding senior civil service positions for three years, and imposed a fine of UAH 85,000. Former Prosecutor General’s Office prosecutor Volodymyr Derhunov was sentenced to one year of actual imprisonment; in addition, he was banned from holding office for three years, and his residential house, together with a KIA Sportage, was confiscated. A plea agreement was also concluded with businessman Tyshchenko, a defendant in the case involving the embezzlement of the “Kurchenko oil products.” At the same time, for example, the texts of the judgments in the Plotnytskyi and Tyshchenko cases are sealed, and public communication on these cases does not make it possible to determine what exactly the state received in exchange for mitigating their punishment.

So although the increase in the number of cases reviewed is positive in itself, the growing number of plea-based judgments—especially when access to them is limited—may undermine trust in both the HACC and SAPO. In this regard, it would be advisable to use classification only for specific parts of a judgment and to improve SAPO’s communication regarding its policies on plea agreements in high-level corruption cases.

Despite the increase in the number of cases, the HACC managed to improve the efficiency of its use of time in court proceedings. While in 2024 one criminal case took an average of 618 days from receipt to final judgment, in 2025 that average fell to 405 days. This may have been aided, among other things, by the introduction of single-judge proceedings, as well as by the increased number of plea-based judgments, since such cases take significantly less time to review.

Even so, the number of unresolved proceedings is growing. While there were 287 such proceedings in 2024, involving 749 individuals, in 2025 there were already 327, involving 862 individuals. This shows the need for both legislative and organizational measures aimed at improving the efficiency of criminal case review. 

For example, in the course of monitoring HACC cases, we recorded instances of abuse and delay, including in the case involving the criminal organization at the District Administrative Court of Kyiv, in former State Fiscal Service head Roman Nasirov’s case within Onyshchenko’s “gas scheme,” and in the case of the so-called “king of smuggling,” Vadym Alperin. All of this could be addressed through amendments to the Criminal Procedure Code of Ukraine aimed at countering abuse of procedural rights.

Cassation review of HACC and HACC Appeals Chamber decisions by the Supreme Court also shows positive trends. In 2025, the cassation court reviewed a larger number of appeals filed by parties—164 in total, including 41 reviewed on the merits. By comparison, in 2024 there were 150 such appeals, and only 28 were reviewed on the merits. Overall, the number of HACC decisions left unchanged upon review also increased: in 2025, there were 27 such decisions, or 65.9% of those reviewed on the merits, whereas in 2024 there were 16, or 57%.

It is also encouraging that the court’s effectiveness in asset recovery improved in 2025. Last year, the total value of assets subject to special confiscation exceeded UAH 673 million across 13 proceedings. By comparison, in 2024 this figure stood at UAH 158.8 million in 11 proceedings. Meanwhile, the value of confiscated assets in money laundering cases increased almost tenfold—from UAH 50.6 million in 2024 across 4 judgments to UAH 470.3 million in 2025 across 7 judgments.

Even so, the HACC’s and NABU’s reports contain no information on the enforcement of asset confiscation decisions, which means it is impossible to track how much of this money has actually reached the state budget. Still, if provided by other state bodies, this information could be highly illustrative from the standpoint of public communication quality.

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The effectiveness of NABU, SAPO, and the HACC is no longer just about the figures in their reports. These are already indicators that stakeholders in Ukraine and abroad look to. 

Indeed, the visible uptick in these institutions’ work was the main reason Ukraine’s score in the 2025 Corruption Perceptions Index improved by 1 point. In that study, the Bertelsmann Foundation gave Ukraine 5 points, primarily taking into account the extent to which officials who abuse their office are held accountable or punished. And the figures above speak directly to that. The Corruption Perceptions Index is an international study that takes into account a whole range of factors affecting the state of anti-corruption efforts.

So the increase in the number of notices of suspicion issued to top officials, indictments, and judgments is a positive trend not only for the work of NABU, SAPO, and the HACC, but for the entire field overall. At the same time, real trust in the anti-corruption system requires more than just bigger numbers. It also requires transparency: publishing more aggregated information, opening up plea-based judgments to the extent possible, and reporting on the actual enforcement of confiscation decisions. 

We have no doubt that NABU, SAPO, and the HACC are indeed working, but systemic work also means addressing the shortcomings that still exist. That is what will determine whether quantitative growth in the indicators turns into a qualitative result.