9 out of 100: Experts Rate Progress on the “Kachka-Kos Plan” as Critically Low

An expert coalition has released the first findings of its “Membership Check” monitoring initiative, which tracks Ukraine’s progress on 10 priority EU integration reforms. The joint assessment by leading think tanks puts the overall score at just 9 out of 100.

This baseline evaluation covers the “Kachka-Kos plan” — a set of equivalent reforms defined in December 2025. Alongside Transparency International Ukraine, which focused on key anti-corruption areas, the study involved the MEZHA Anti-Corruption Center, European Pravda, the ANTS National Interests Advocacy Network, DEJURE Foundation, New Europe Center, Centre of Policy and Legal Reform, and the Anti-Corruption Action Centre.

TI Ukraine experts assessed the plan’s items most critical to effective anti-corruption work:

• Criminal justice (2/20). A draft amendment to the Criminal Procedure Code has reportedly been in preparation but remains unpublished, making it impossible to assess the quality of the proposed changes.
• NABU access to independent forensic examinations (0.5/10). The newly established Center has not yet given the NABU genuine access to independent expert examinations — adequate safeguards against undue influence are still absent.
• International experts in the HQCJ competition (1/10).  A draft law to restore international participation in the HQCJ selections has not been considered by parliament since June 2025, stalling the judiciary’s renewal.
• Adoption of the Anti-Corruption Strategy and SAP by end of June 2026 (0.5/5). Approval of the 2026–2030 Strategy is being delayed by objections from certain agencies, risking the dilution of key reforms. TI Ukraine has previously analyzed individual chapters and flagged potential shortcomings.
• Internal control and whistleblower protection (0.5/10). The State Audit Service has begun incorporating internal control checks into its inspections, but the Whistleblower Portal requires significant technical improvements to offer meaningful protection.

Progress on the remaining plan items is equally minimal:

• Prosecutor General selection (0/10): no progress on revising procedures.
• Prosecutorial leadership appointments (0.5/10): transparent competitive selection has not resumed. 
• SBI reform (1/10): relevant draft laws have not been put up for public discussion.
• New CCU justices and HCJ members (1/5): procedures are delayed, vacancies unfilled.
• Benchmark 8. Judicial integrity (2/10): Legislation does not reflect EU recommendations on asset declaration reviews for Supreme Court judges.

“The overall score of 9 largely reflects the declarative nature of many steps taken and insufficient public access to key draft legislation. We believe that to advance EU integration more effectively, it is essential to increase transparency in document preparation and step up the Verkhovna Rada’s legislative activity,” said TI Ukraine Executive Director Andrii Borovyk.