A Strategy That Bypasses the Government: Will Changing the Rules for Ukraine’s Main Anti-Corruption Document Have Consequences?

A draft law on the Principles of Ukraine’s Anti-Corruption Policy for 2026–2030 has been registered in the Verkhovna Rada — but this time without prior government endorsement, as had been the case in previous anti-corruption policy cycles.

Here we explain why this happened and how it ties in with Ukraine’s international commitments.

On April 2, the National Agency on Corruption Prevention (NACP) submitted a refined draft of the Anti-Corruption Strategy for 2026–2030 to the Cabinet of Ministers. The Agency had worked on the document for two years, with input from experts and members of the public, and its adoption is one of Ukraine’s international commitments.

Since the Cabinet had still not processed the document by mid-May, on May 13 the Chair of the Verkhovna Rada’s anti-corruption committee registered the strategy as a draft law in the version the NACP had submitted to the Cabinet — without waiting for final government clearance (or any government amendments).

Notably, moving ahead of the Cabinet helped preserve the document’s ambition: the government had been preparing to drop (or water down) some of its key elements.

So what exactly did the Cabinet plan to change, but never got around to? Why did a new procedure have to be used? What is the new strategy about overall?  And what should be done with it next?

This article will sort all that out.

What happened and what the Cabinet should do

In early April 2026, the NACP completed inter-agency clearance of the draft Anti-Corruption Strategy and submitted it for the Cabinet’s consideration. The Agency had developed the Strategy with the help of expert working groups that conducted sectoral studies, which then formed the basis of the document. The NACP has published all the relevant materials on its website — the draft of the final document and a table showing which public comments had been incorporated and which had not.

Although the Law on Corruption Prevention does not require the Cabinet to process the anti-corruption strategy and register it in parliament as a government draft law, this has been the established practice in Ukraine, and it was the expectation of everyone involved — government officials, international partners, and experts alike. And indeed, anti-corruption strategic documents have always been adopted through government legislative initiative in the past.

Moreover, the law provides that the next step after the anti-corruption strategy is adopted is the approval of a State Anti-Corruption Program to implement it. These next steps will have to be carried out by the government — so it would be logical for it to be involved in shaping the first document as well.

However, because the strategy sat with the Cabinet for over a month without being adopted, and there emerged a real threat that deadlines would be missed (along with potential financial losses for Ukraine — more on that below), Anastasiia Radina, Chair of the Verkhovna Rada Committee on Anti-Corruption Policy, decided on May 13, 2026 to break with tradition and register the draft law on the Principles of State Anti-Corruption Policy for 2026–2030 herself.

This is not “Radina’s own draft,” though. Its content has been agreed upon — it simply lacks the government’s “sign-off.”

The version of the draft law that has been registered matches the version the NACP sent to the Cabinet in April, after coordination with the relevant stakeholders.

The urgency on the part of the anti-corruption committee’s chair is entirely justified. Adoption of the anti-corruption strategy is one of Ukraine’s international commitments. It is required, in particular, by the Ukraine Facility plan (an EU initiative in which each reform Ukraine carries out or each decision it adopts unlocks specific financial assistance), the Rule of Law Roadmap, and the so-called “Kachka-Kos 10-point plan,” which gathers together the most important reforms in the areas of rule of law and anti-corruption.

Under the Ukraine Facility plan, the deadline for adopting the strategy and the anti-corruption program to implement it is the end of June 2026 — and given parliamentary procedure, there is already very little time left.

But the registration of the draft law by Anastasiia Radina does not mean the government can now forget about this document — quite the opposite. If the Cabinet of Ministers has views of its own on the document, it should still review the NACP’s version of the anti-corruption strategy as quickly as possible and convey its position to parliament. The Committee on Anti-Corruption Policy will then be able to take the government’s comments on board and, where it agrees with them, introduce “government” changes to the draft law that has already been registered.

The Verkhovna Rada’s Rules of Procedure do allow subjects of legislative initiative — including the government — to submit amendments and proposals to draft laws during preparation for the second reading (Articles 89 and 116 of the Law on the Rules of Procedure of the Verkhovna Rada of Ukraine).

If the government ignores this opportunity, it will deprive itself of any say in the content of the strategy — and end up in a situation where it has to develop the SAP on the basis of a document finalized without it.

What the new strategy is about

The current strategy will be Ukraine’s third.

The first covered 2014–2017 and was primarily aimed at setting up new anti-corruption institutions. After it expired, Ukraine went five years without an anti-corruption strategy. A new one was adopted with considerable delay only in June 2022 — and even then not really by choice, but to fulfill EU requirements: Kyiv needed this step in order to obtain candidate-country status. But that strategy, which covered 2022–2025, had largely declarative goals. And — most importantly — it did not take into account the problems associated with Russia’s full-scale invasion at all, since it had been drafted before 2022.

The new document is fundamentally different.

The Strategy for 2026–2030 is considerably more detailed and covers a broader range of areas than its predecessor, in line with the challenges of the moment. In particular, for the first time, a document of this kind includes a dedicated section on recovery.

Structurally, the document the NACP sent to the Cabinet in early April consists of three sections. The first covers the general system of corruption prevention and counteraction. The second covers corruption prevention in priority sectors. The third, added after public consultations, governs the procedural aspects of implementing, monitoring, and evaluating the Strategy and the SAP.

The NACP approached the preparation of the new strategy more inclusively than it had during the previous cycle. External expert groups conducting thematic studies were brought in to work on individual subsections, public consultations were held on each subsection, and the recordings, presentations, and tables showing how comments had been incorporated were made public. This is good practice and improves the document’s transparency and quality.

Transparency International Ukraine was also involved in developing the strategy at several levels. Our DOZORRO experts worked directly on the public procurement section, and we also took part in public consultations on other subsections and submitted written comments on them to the NACP.

The strategy covers most of the key problems in the relevant areas and shows substantial progress in how thoroughly the strategic outcomes have been worked out, compared with the previous cycle.

In particular, several important additions emerged between the first public draft and the text sent to the government. One of the key changes concerns an indicator that now provides for revising pre-trial investigation timeframes and abolishing the automatic closure of criminal proceedings when those timeframes expire. TI Ukraine has long flagged this issue as one of the most acute practical problems.

Other gains include a “strategic pause” between anti-corruption policy cycles, a mechanism to incentivize those who implement the SAP, and the NACP’s right to issue prescriptions to government bodies. The whistleblower protection subsection is better prepared and provides for bringing legislation in line with EU Directive 2019/1937, standardizing the definition of “whistleblower,” and modernizing the Unified Whistleblower Portal.

In the anti-corruption segment of criminal justice (interaction among NABU, SAPO, and HACC), the document matches the European Commission’s technical recommendations — in particular on autonomous wiretapping authority for the NABU, expanded powers for the SAPO Head, and Prosecutor General appointment procedures.

However, the document does have its shortcomings.

We hope to see some of them corrected during parliamentary consideration.

In particular, the effectiveness of the mechanism for verifying e-declarations and for combating money laundering still needs to be addressed — areas whose continued relevance is confirmed by the European Commission’s recommendations as well.

That said, it is already known that some important aspects of the strategy — such as the competitive selection of the Prosecutor General — were ones the government had planned to remove from the document. But because of the Cabinet’s delay, the most ambitious version of the document is the one that has gone to parliament.

Going forward, the important thing is not to weaken the strategy in parliament, but to strengthen it further still.

What’s next?

It is now critical that the government quickly process the draft Anti-Corruption Strategy submitted by the NACP, and that parliament quickly review the comments of the government and the public and — once the document has been refined — vote as soon as possible on the new Law on the Principles of Anti-Corruption Policy for 2026–2030. Above all, this is an international commitment, and failure to meet it directly affects the European integration process.

Parliament’s overall pace of voting on draft laws has slowed considerably as of late, but Ukraine cannot afford to find itself once again in a situation where the state goes for several years without an up-to-date anti-corruption policy cycle.

All the more so given that we have already been in this situation before — and back in 2022, the strategy still had to be adopted in order to meet EU criteria. And by including this document in the “Kachka-Kos plan,” the European Commission has once again reminded us that, for the European Union, this document matters.

What is more, the previous cycle’s experience showed that the belated adoption of the anti-corruption strategy and SAP rendered part of their content outdated, which directly affected the effectiveness of anti-corruption policy. This time around, then, the government and parliament should do everything they can to avoid delaying the adoption of these strategic documents any further than has already happened.