Analysis of the Draft Anti-Corruption Strategy for 2026–2030

The new draft Anti-Corruption Strategy, as regards the sections covering anti-corruption policy, corruption prevention, the anti-corruption segment of criminal justice, and recovery, broadly addresses most of the relevant issues in these areas. The section on public procurement cannot be independently assessed, as our experts contributed to drafting it. The NACP did engage external expert groups to carry out research on the respective topics — a positive practice.

The NACP also maintained its positive practice of holding discussions on all sections of Chapters I and II of the Anti-Corruption Strategy. In addition, the Agency published the materials used to prepare the draft sections, along with presentations, recordings of public discussions, and a table indicating which public comments were accepted or rejected, with explanations.

On the substance of the document, the following improvements are also worth noting.

1. The NACP incorporated a number of TI Ukraine’s proposals: the introduction of a “strategic pause” between anti-corruption policy cycles, a mechanism to incentivize implementers of the State Anti-Corruption Program, and the right of the NACP to issue binding instructions to government bodies.
2. For the first time, recovery is designated as a standalone priority section of the Strategy. This section correctly diagnoses the problems in the recovery area, though the proposed mechanisms require further elaboration at the level of the SAP.
3. The draft demonstrates a high degree of alignment with the European Commission’s technical recommendations, particularly with respect to anti-corruption criminal justice.
4. The whistleblower section proposes amendments aimed at aligning national legislation with EU Directive 2019/1937 — changes long called for by civil society representatives and international partners alike. 

That said, certain elements of the Strategy could be improved.

1. Duplication of existing norms. Certain sections (for example, the section on state anti-corruption policy) repeat provisions of existing legislation without adding regulatory value. 
2. Insufficient specificity of certain strategic results. This applies, for example, to the protection of anti-corruption bodies’ independence from harmful legislative initiatives.
3. Failure to incorporate critical comments in the draft Strategy. The current version of the document leaves unaddressed concerns regarding the ineffectiveness of the e-declaration verification mechanism, the absence of automated assignment of monitoring cases at the NACP, and the need to abolish the automatic closure of cases upon the expiry of pre-trial investigation deadlines. 
4. Incomplete coverage of problems identified but unresolved under the previous Strategy. The document contains no provisions on the effectiveness of anti-money laundering efforts, despite evident problems in this area. 

Some of these shortcomings may undermine the effectiveness of both the Anti-Corruption Strategy and the SAP to be adopted on its basis.

The draft Anti-Corruption Strategy has now been submitted to the relevant authorities for approval, after which the final version of the document will be published. 

Introduction

In January 2026, the NACP published the draft Anti-Corruption Strategy for 2026–2030 (hereinafter — the AS, or the Strategy), which the Agency submitted for approval to stakeholder bodies. The new strategic document contains three chapters, rather than the four found in the current Strategy. 

In this iteration, Chapter I covers the general system of corruption prevention and counteraction, while Chapter II addresses corruption prevention in priority sectors. Also, a new final chapter has been introduced, dealing with the regulation of key procedural aspects of implementation, reporting, monitoring, coordination, and effectiveness assessment of the Anti-Corruption Strategy and the State Anti-Corruption Program (SAP) for 2026–2030. This chapter was added after the round of public discussions had concluded and was presented only in the finalized draft, meaning that civil society organizations had no opportunity to comment on it. 

It is also worth noting that, in drafting the new Anti-Corruption Strategy, the NACP engaged external expert groups — an approach that is positive in terms of inclusivity and the overall quality of individual sections. This was likely a contributing factor to the insufficient uniformity across sections, particularly in terms of the level of detail provided. 

TI Ukraine was involved both in drafting certain sections and in discussions of drafts already published by the NACP. In particular, our experts worked directly on the public procurement section, and the analysis below reflects this.

With respect to sections 1.1, 1.3, 1.4, 1.5, 1.6, 1.7, 1.9, and 1.10 of Chapter I, and sections 2.1.1, 2.1.2, 2.3.2, and 2.5 of Chapter II of the Strategy, TI Ukraine’s experts participated in public discussions of these parts and submitted written comments to the NACP.

It is also important to note that NACP published the relevant supporting materials for all sections, as well as tables indicating whether comments were accepted or rejected. This is a good practice that the Agency applied when preparing the previous Strategy as well. 

We now turn to the sections reviewed by TI Ukraine. 

State Anti-Corruption Policy

Section 1.1, on state anti-corruption policy, addresses the regulation of the preparation and implementation of the AS and SAP for future periods. Compared to the anti-corruption policy section of the current Strategy, the new draft covers a narrower set of problems and strategic results, drawing directly on the experience of preparing and implementing the current anti-corruption policy cycle.

The section’s focus on the development and implementation of the anti-corruption policy cycle is entirely justified. The previous Anti-Corruption Strategy was the first document of its kind and contained, in its anti-corruption policy chapter, broadly framed problems and declaratory expected results — such as a reduction in the general level of public tolerance for corruption in Ukraine. The corresponding section of the new draft AS is free of such superfluous provisions.

That said, the draft has its weaknesses. Section 1.1 frequently proposes that the NACP and other responsible bodies carry out a range of activities that these institutions already perform on a regular basis. Despite this, our comment — that the Strategy should not duplicate activities already required by law — was not accepted. The Agency explained that the Strategy must be aligned with existing legislation to ensure proper implementation by the relevant bodies, and that the document should contain all possible measures for addressing the problems it identifies. This rationale is difficult to accept, since the AS is itself adopted at the level of a law, and its provisions are equally binding as those of sector-specific legislation. There is therefore no need for duplication. 

On the positive side, the NACP accepted our proposal to introduce a “strategic pause” between the end of the 2026–2030 Strategy and SAP and the preparation of the next anti-corruption policy cycle. The Agency also agreed on the need to introduce incentive mechanisms for SAP implementers and to grant the NACP the right to issue binding instructions — both of which should significantly improve the implementation discipline of government bodies.

However, our comment proposing that an acceptable rate of SAP implementation be set at 90% of completed measures — with the remaining 10% either having justifiably lost relevance or being unimplemented for financial reasons — was not reflected in the final draft. This threshold corresponds to OECD requirements. The question of implementation rates is not addressed at all in the current draft AS.

Some of our comments aimed at improving the coordination of AS and SAP implementation were accepted, which is also a positive development. For example, the final draft provides for the possibility of including representatives of the business community, academic community, non-governmental organizations, international technical assistance projects, and international organizations in the Coordination Working Group on Anti-Corruption Policy.

Corruption risk analysis and conflicts of interest

Sections 1.3 through 1.5 of the Strategy — covering anti-corruption programs, authorized units and officers, corruption risk analysis, and conflict of interest monitoring — broadly address most of the relevant issues in these areas. Sections 1.3 and 1.4 attracted fewer critical comments from us than the conflict of interest section, which is also one of the most detailed in Chapter I of the AS. 

The NACP accepted our proposal to review approaches to the remuneration of authorized officers in light of the complexity of their functions, as well as the proposal to explicitly designate the failure to incorporate the results of a previous anti-corruption program as grounds for the NACP to reject a new program.

However, although the section addresses the strengthening of the institutional independence of authorized officers, TI Ukraine’s comments regarding sanctions for the absence of authorized units or officers, as well as for the absence of anti-corruption programs, were not reflected in the Strategy’s expected results. The Agency explained that heads of organizations should themselves be motivated to maintain effective internal anti-corruption policies, and that sanctions would therefore not be effective. 

In our opinion, the existence of sanctions for failing to adopt an anti-corruption program or for not having an authorized anti-corruption officer would nonetheless serve as an additional incentive to comply with legal requirements, since sanctions are designed precisely to motivate those who would not act on their own initiative.

The NACP also did not provide for a more systematic involvement of civil society expert organizations in corruption risk assessments and the preparation of anti-corruption programs.

With respect to the quality of NACP’s and the Ministry of Justice’s anti-corruption assessments, the comment-response table indicates that the Agency intends to implement some of TI Ukraine’s comments at the SAP development stage. However, NACP’s intention to reconsider its discretion in selecting draft regulatory acts for expert review was not clearly reflected. The Agency may yet revise its position during the SAP development stage and incorporate this measure into that document.

On the conflict of interest section, the NACP still has not addressed the most critical comment — namely, that the Agency does not yet apply automated assignment of monitoring cases among its authorized officers, despite this approach having been criticized in the external independent assessment report of NACP’s performance for 2020–2021. The Agency explained that introducing automated assignment for proactive monitoring would artificially limit NACP’s ability to respond independently and swiftly to information appearing in the public domain and would significantly reduce the effectiveness of the proactive oversight mechanism. 

We cannot agree that the effectiveness of monitoring is contingent on the absence of automated assignment. Full declaration reviews can also be triggered by notifications from individuals and legal entities or information from media — and this does not prevent automated assignment from being applied in far more complex verification procedures. 

Moreover, the logic of prioritizing oversight effectiveness over oversight transparency is simply untenable in the context of NACP’s anti-corruption work.

Likewise, despite TI Ukraine’s comment, the NACP retained provision 1.5.3.2, which introduces exceptions to the general prohibition on officials receiving gifts in cases of “difficult life circumstances” (medical treatment, damaged housing). In our view, this creates identifiable risks of abuse. Issues of financial support for officials should instead be resolved through improvements to the social protection system for such persons or through the creation of charitable public fundraising mechanisms.

The NACP also declined to accept TI Ukraine’s position that the introduction of the concept of “perceived conflict of interest” into legislation would be premature, given that problems persist with the interpretation of existing terms. Specifically, despite the definitions of real and potential conflicts of interest established by law, courts have still been unable to develop consistent case law in matters involving violations in this area.

The remaining provisions of the conflict-of-interest section — regarding restrictions related to gifts, corporate ownership, and the combination or concurrent holding of official positions — were, in our opinion, developed to a high standard. The section successfully addresses the issue of disproportionate requirements concerning the mandatory transfer of corporate rights, the need to revisit the prohibition on receiving gifts, and the insufficient regulatory clarity surrounding the rules on combining and concurrently holding positions.

Financial control

Section 1.6 on financial control captures the problem of incomplete coverage of declaration subjects (staff of patronage services, members of local council executive committees, etc.), the excessive burden of completing declarations, ineffective oversight of timely declaration submission, and the insufficient effectiveness of the financial control mechanism as a whole. All of these issues are important for strengthening this mechanism and are consistent with the European Commission’s requirements.

Despite this, Section 1.6 attracted our sharpest criticism. While the NACP does acknowledge the insufficient effectiveness of financial disclosure, it attributes this primarily to inadequate automation and interoperability of registries, as well as legislative shortcomings — whereas civil society and international experts have consistently argued that it is the Agency itself that has built a financial disclosure system that fails to deliver results.

For example, the EU’s latest Enlargement Report on Ukraine calls for a stronger e-declaration system to genuinely and effectively prevent and detect unexplained assets. The Commission stated that the system has practical and legal shortcomings, primarily relating to the automated verification process.

What the NACP needs is not more automation of verifications, but a focus on enhancing the capacity of its authorized officers to conduct full verifications — only a human investigator can carry out a quality investigation of circumstances that appear suspicious. TI Ukraine has on numerous occasions provided the NACP with detailed recommendations for overhauling the financial disclosure system. 

Despite significant resources invested in developing and operating the electronic asset declaration registries, the financial control tools are mostly used to hold officials accountable for fairly minor instances of concealment or inaccurate declarations. Rarely does an e-declaration review escalate into a serious top-level corruption investigation.

Among our proposals, we suggested that the section include a problem statement to the effect that the existing financial disclosure mechanisms at the NACP are ineffective due to the Agency’s limited resources, their suboptimal use, the existence of duplicative functions, and other underperforming elements of the system. Addressing this problem would require a series of legislative amendments, updates to internal regulations, and changes to NACP’s implementation practices. 

The NACP did not agree with our proposals and even signaled an intention to enshrine in law the automation of verifications as a substitute for manual full-review procedures.

Among the comments that were accepted: the abolition of the obligation to submit certain interim disclosures already covered by the annual declaration, and the extension of oversight to officials of state-owned enterprises (with a shareholding above 50%) and members of executive committees.

With this approach — ignoring genuinely important problems in the corruption prevention system in the new AS — we will continue to fail to see any real effect from the Agency’s work for a long time to come, and will instead witness, once again, corruption scandals that could not be prevented. 

Whistleblower protection

The whistleblower protection section attracted almost no critical comments from us. The NACP developed it to a high standard, with an appropriate level of detail for a document of the Anti-Corruption Strategy’s standing. 

This section covers both the need to bring legislation and practice on whistleblower protection into conformity with European standards, and the need to improve the operation of the Unified Whistleblower Reporting Portal and the responsible bodies, as well as to foster a culture of whistleblowing.

To achieve these objectives, the Strategy proposes a set of interrelated measures: bringing national legislation into line with EU Directive 2019/1937 and harmonizing the definition of “whistleblower”; establishing an institutional framework with a designated coordinating body and a network of responsible units within public and private organizations; promoting a culture of whistleblowing and raising employees’ awareness of their rights; modernizing the Unified Whistleblower Reporting Portal through integration with state systems and the introduction of a mobile application; and other critically important steps to improve how the whistleblower institution functions.

The only substantive proposal from TI Ukraine was to clarify the relationship between the statuses of “whistleblower” and “confidential informant” so as to avoid legal confusion. However, given its specific nature, this point is likely to be addressed at the SAP stage.

Comments from another expert organization were also well-taken concerning the absence of adequate tracking of complaints about violations of whistleblowers’ rights and the low number of cases in which rights are actually restored. The number of whistleblowers effectively protected is the real measure of the Agency’s performance in this area, so it is important to keep the focus here. The NACP did not fully incorporate these comments but did take them into account. We hope these observations will be reflected, if not in the final text of the AS, then in the SAP. 

Anti-corruption segment of criminal justice

Sections 1.9 (“Counteracting corruption and corruption-related offenses”) and 1.10 (“Independence, institutional resilience and effectiveness of anti-corruption institutions”) of the draft Anti-Corruption Strategy cover the system of legal liability for corruption and the capacity of anti-corruption bodies to enforce it. Section 1.9 systematically covers the types of liability — from disciplinary measures through civil law instruments to criminal liability. Section 1.10 is structured around four anti-corruption institutions: NACP, NABU, SAPO, and HACC.

Overall, the draft AS in this part demonstrates a high degree of alignment with the European Commission’s technical recommendations: it includes autonomous wiretapping powers for NABU, expanded authority for the SAPO Director, measures to counter the abuse of procedural rights in HACC, and strengthened internal oversight within NABU. The recommendation on the statistical data system (1.9.4.3) was fully incorporated, while the “fugitives” issue (1.9.4.4) was addressed partially.

That said, the draft Strategy provides for granting NACP the right to independently file civil confiscation claims (Result 1.9.2.2). During public discussions, we recommended against this, citing the Agency’s already heavy workload and the advisability of limiting the measure to granting NACP procedural powers to collect evidence following amendments to Article 290 of the Civil Procedure Code of Ukraine. Instead, the NACP would be better served by gaining the ability to independently represent its own protocols in court, rather than relying on prosecutors — a measure already envisaged in the State Anti-Corruption Program for 2023–2025 but not yet implemented.

The draft’s wording also fails to cover the scenario of filing a civil confiscation claim following an acquittal, addressing only cases where proceedings have been closed. This creates a legal gap, since an acquittal and the closure of proceedings are distinct procedural institutions. In the absence of a clear provision allowing for civil confiscation following an acquittal, the state risks losing this tool in cases where individuals are acquitted due to evidentiary shortcomings and the higher standard of proof in criminal proceedings compared to civil ones. The problem of SAPO prosecutors lacking the right to obtain restricted-access information for the purpose of building an evidence base in unjustified assets cases also goes unaddressed.

TI Ukraine proposed conditioning the referral of cases based on NACP protocols to the HACC on a prior strengthening of the court’s capacity, citing the court’s heavy caseload and shortage of judges. The draft retains provision 1.9.3.3 on the adjudication of cases by HACC without any such caveat, although Section 1.10.4 provides for measures to improve the court’s efficiency. The logical connection between these provisions is not apparent, and the temporal sequencing of their implementation is not defined.

We emphasized the need to specify the provisions on special confiscation and statutes of limitations in the Criminal Code of Ukraine (modifying the point at which the limitation period begins and expanding the grounds for suspension). The draft operates with general language about bringing legislation into conformity with EU and OECD standards, which could theoretically encompass these issues.

The most problematic gap is the absence of any provision on abolishing the automatic closure of cases upon the expiry of pre-trial investigation deadlines. This is one of the most acute problems in practice and is already included on the list of priority reforms on Ukraine’s EU accession path and in the Rule of Law Roadmap — yet the anti-corruption strategy, as the highest-level anti-corruption policy document, makes no mention of it.

Compared to the previous Anti-Corruption Strategy, the draft contains no provisions on the effectiveness of anti-money laundering efforts. This is a cause for concern given the circumstances of the Midas case, which point to insufficient financial monitoring effectiveness, and the European Commission’s warning that the freezing and confiscation of criminal assets remain very limited in scope.

However, in the section on the judicial system and the status of judges, our proposal was accepted: selection to the High Qualifications Commission of Judges and the High Council of Justice should continue to be based on an improved selection process with the participation of independent experts nominated by international partners and holding a decisive vote. And in the section on the prosecution service, public order, and countering criminal offenses, a positive development is the proposal to establish robust procedures for the appointment and dismissal of the Prosecutor General to mitigate risks of informal or political influence, as well as to reinstate competitive selection for positions of prosecutors in the Prosecutor General’s Office and regional prosecution offices, in line with European Commission recommendations.

At the same time, it is critically important that ambitious strategic outcomes do not remain merely declaratory. The experience of the previous Strategy shows that even progressive provisions can be nullified by a lack of political will. The Strategy could also have established mechanisms to protect the independence of anti-corruption bodies from harmful legislative initiatives, as occurred in the summer of 2025 with the law that sought to curtail the independence of the NABU and the SAPO.

Recovery

Recovery has for the first time been designated as a standalone chapter of the draft AS, as one of the priority areas of state policy. Given its cross-cutting nature, some of the related problems are also reflected in the chapters on construction and public procurement. The dedicated recovery chapter focuses on strategic planning, regulatory framework, and the selection of recovery projects.

The absence of a comprehensive state recovery strategy is the first problem the Strategy aims to address. Despite the existence of individual planning documents at the local and regional levels, no holistic state-level strategy for eliminating the consequences of the armed aggression and for post-war recovery has been approved, notwithstanding the regulatory prerequisites for one and prior attempts to develop such a document.

The existence of a document that would conceptually define the nature, objectives, and priorities of recovery — and provide for mechanisms of coordination, monitoring, and accountability — is a critically necessary precondition for effective planning, adequate financing, and the implementation of recovery projects. At the same time, approving a comprehensive and actionable recovery strategy will be no simple task, for several reasons.

Recovery is a complex area that intersects with many areas of state policy. Certain aspects of recovery have already been addressed in a range of sector-specific policies and strategic documents. Under these conditions, formulating a coherent recovery strategy requires careful alignment of its key provisions with a broad range of stakeholders and proper coordination among different priorities.

Moreover, there is no shared understanding of the very concept of “recovery” — its scope, priorities, and components. For some, it means returning to the pre-war state; for others, modernization and “building back better”; for others still, a mixed model dependent on sector and territory. The Strategy risks being either too general or failing to secure the support of key stakeholders.

Second, the data on which the strategy would need to be based (the scale of destruction, losses, needs, and their prioritization) is constantly changing. Furthermore, management decisions in the recovery sphere are not always grounded in complete, reliable, and systematized data. Under these conditions, it is difficult to enshrine in a strategic document objectives and priorities that will not have lost their relevance by the time of implementation. The draft AS rightly identifies this as a distinct critical challenge requiring resolution.

Third, in wartime conditions, the logic of recovery is largely subordinated to the priority of rapid response in specific areas or sectors, which complicates the alignment of such decisions with long-term planning.

Among the other problems identified in the draft Strategy’s recovery section, it is worth noting the government’s active use of pilot projects as an alternative to applying the provisions of permanent legislation. This mechanism effectively allows for departures from general permitting procedures, funding rules, and oversight mechanisms.

Since the start of the full-scale war, the use of pilot projects has taken on a systemic character — driven, on the one hand, by the need for swift decision-making, and giving rise, on the other hand, to risks of legislative fragmentation, reduced procedural predictability, weakened transparency and accountability, and inefficient use of public funds.

TI Ukraine previously researched the pilot project on the comprehensive recovery of settlements affected by Russian aggression. The findings showed that, due to gaps in the conditions governing the experiment, the reconstruction of one of the planned settlements was effectively dropped from the program. Moreover, over two years of implementation, only approximately 8% of the planned number of facilities had been restored.

The draft Anti-Corruption Strategy proposes to regulate the mechanism for launching government pilot projects, by providing for a clear definition of their legal nature, a mandatory justification for departures from standard procedures, the publication of information on their implementation and results, and the exercise of state financial oversight with respect to such projects. The proposed approach would create the preconditions for a more transparent and clearly defined use of pilot projects and for reducing corruption risks in the recovery sphere. 

At the same time, the requirement to justify departures from standard procedures risks becoming a formality in the absence of clear criteria for the permissibility of such departures. Furthermore, failure to achieve the declared objective of a pilot project, or the absence of a substantiated report on its results, should be treated as grounds for its termination. These aspects should be taken into account in the preparation of the State Anti-Corruption Program.

The final two problems in the recovery — the absence of a single approved mechanism for prioritizing recovery projects, and the absence of a Unified Public Investment Project Management Information System — are closely interrelated.

The public investment management reform envisages the creation of a Unified Public Investment Project Management Information System (the Unified Information System), which is meant to be used for the prioritization and selection of public investment projects and programs — including those in the recovery sector — and to contain information on their implementation. However, the Unified Information System is not yet operational, and the formation of the Unified Project Portfolio for 2026 was carried out using the DREAM system, which only partially captures information on project implementation, readiness status, level of financing, and so forth.

Prioritization at the state level is currently applied to individual investment projects and investment programs, which may combine several such projects. However, legislation does not provide for a clear mechanism for prioritizing the projects included within investment programs. This gap creates risks of non-transparent selection, the inclusion of questionable projects in investment programs, and their subsequent entry into the Unified Project Portfolio.

The implementation of the measures set out in the draft Strategy will be of key importance for preventing non-transparent allocation of funds, duplication of financing, and their inefficient use. This includes ensuring the prioritization of all investment programs and projects — including those forming part of investment programs — as well as the introduction and proper functioning of the Unified Public Investment Project Management Information System, of which the DREAM system is an integral component. 

Public procurement

Last year, experts from the DOZORRO TI Ukraine project participated in drafting the Anti-Corruption Strategy’s public procurement section, conducting the necessary research and continuing to develop proposals for the corresponding expected results and measures. 

Based on the outcomes of a public expert survey, five problems were identified as the most significant in this area, the first of which is the abuse of the ability to modify essential terms of a procurement contract. Such practices occur both at the contract execution stage — when parties diverge from the draft contract published in the tender — and at the implementation stage. 

To minimize such abuses, we proposed the following: 

• defining a minimum list of procurement contract terms that are essential and may not be arbitrarily modified, taking into account how specific terms affect competition and the interests of the contracting parties,
• improving the legal regulation of the conditions for modifying procurement contracts, clarifying the rules governing price amendments, and expanding the volume of information published on contract modifications,
• developing the Prozorro system to a level that allows a procurement contract to be concluded automatically on the basis of its machine-readable draft form and introducing a full-text search function across contracts and supplementary agreements to facilitate oversight of their legality. 

The second problem the future Anti-Corruption Strategy will seek to address in the procurement sector is discriminatory and excessive requirements in procurement. This refers not only to overt discrimination in the classical sense, but also to excessive requirements that make procurement unattractive to participate in yet cannot be challenged — for example, excessively long payment terms and minimum timeframes for the submission of tender proposals. 

To improve the situation, we proposed introducing an appeal mechanism before the Antimonopoly Committee for purchases conducted through electronic catalogs; researching the factors that prevent businesses from challenging discriminatory conditions; defining requirements for permissible payment terms under procurement contracts; and extending the timeframes for the submission of tender proposals. It would also be appropriate to digitize procurement conditions and raise the professional level of contracting entities.

The third problem is the abuse of direct procurement, particularly under martial law. To address it, the list of grounds for conducting non-competitive above-threshold procurements needs to be revised and reduced, and the conditions and methods for conducting them optimized — including by reinstating the negotiated procedure where possible. In addition, it is important to regulate how the value of a procurement subject is determined when conducted directly, without a tender. 

The final two problems relate to proper oversight and accountability for intentional procurement violations. The procurement monitoring mechanism requires further development and improvement — in particular, a preventive and risk-based approach to monitoring is needed, primarily through pre-contract monitoring. It is equally important to ensure the effective implementation of the obligations identified in monitoring conclusions. A standardized list of remedial measures depending on the severity of violations, as well as an expedited court review procedure for monitoring conclusions, should help here. 

With respect to accountability for violations, the focus of proposals is primarily on ensuring that such accountability is inevitable. This requires updating the composition of administrative offenses and eliminating the factors that lead courts to frequently classify identified violations as minor or to dispute their existence altogether. 

The problems outlined may in some cases manifest not only as corrupt practices but also in situations where there is no corrupt intent. Nonetheless, each of them facilitates such practices or reduces the preventive effect on corruption in the work of contracting authorities.

Most of the expected strategic results will require legislative amendments, technical changes in the Prozorro system, and additional research. The adoption of Draft Law No. 11520 should facilitate the implementation of some of the steps outlined. 

The author team has traveled a long road of research and development of the Anti-Corruption Strategy draft, which began in January 2025 and continues to this day. We hope that, following the necessary approvals and revisions, the key ideas and intentions embedded in our proposals will be preserved. 

Conclusions

The draft new Anti-Corruption Strategy for 2026–2030 is fairly uneven in terms of both coverage of the necessary issues and NACP’s responsiveness to TI Ukraine’s comments. Certain sections of the Strategy are well prepared, reflecting both the positions of civil society and international partners, including the EU. However, on other matters our assessments were more critical and were not taken on board.

Among the key issues, we highlight the following.

1. Duplication of existing norms. Certain sections (for example, the section on state anti-corruption policy) repeat provisions of existing legislation without adding regulatory value. 
2. Insufficient specificity of certain strategic results. This applies, for example, to the protection of anti-corruption bodies’ independence from harmful legislative initiatives.
3. Failure to incorporate critical comments in the draft Strategy. The current version of the document leaves unaddressed the concerns regarding the ineffectiveness of the e-declaration verification mechanism, the absence of automated assignment of monitoring cases at the NACP, and the need to abolish the automatic closure of cases upon the expiry of pre-trial investigation deadlines. 
4. Incomplete coverage of problems identified but unresolved under the previous Strategy. The document contains no provisions on the effectiveness of anti-money laundering efforts, despite evident problems in this area. 

A recurring issue is the uneven level of detail across sections of the Strategy — a problem likely attributable to the involvement of different author groups without sufficiently rigorous editorial processing of the final document. This uneven structure creates the risk of uneven implementation of the Strategy in practice. 

We hope that some of these problems will still be addressed through the approval process with the relevant authorities — though the prospects for this currently appear uncertain.