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

On May 15, the Cabinet of Ministers submitted its version of the Anti-Corruption Strategy for 2026–2030 to the Verkhovna Rada — two days after Anastasiia Radina, Chair of the Anti-Corruption Policy Committee, submitted hers. 

Both draft laws build on the NACP text prepared after consultation with stakeholders and sent to the government on April 2, but the versions are not identical. We compared the two on the subsections covering anti-corruption policy, corruption prevention, the anti-corruption segment of criminal justice, and recovery, and identified several substantive differences. Here is what they mean.

Key findings

The comparison shows that the government’s draft law, most notably:

• removes, as a separate problem, the absence of a competitive procedure for appointing the Prosecutor General (Problem 2.2.2 in the Committee Chair’s version);
• omits the provision on reforming the selection of the SBI Director (Problem 2.2.7 in the Committee Chair’s Strategy);
• does not include, among the SAPO Head’s potential powers, the right to independently enter information on MPs into the Unified Register of Pretrial Investigations and the right to direct individual international legal assistance measures without involving the Prosecutor General’s Office;
• scales back the detail on setting NACP staff salaries in the dedicated law (Problem 1.10.1.1 in the Committee Chair’s Strategy).

Some of the removed parts concern reforms within the Kachka-Kos plan — a list of 10 priority steps agreed between Ukraine and the EU in December 2025. According to monitoring by TI Ukraine and seven other think tanks, progress on this plan as of April 2026 stands at just 9 out of 100.

Why the Strategy must be adopted without delay

The Anti-Corruption Strategy is the highest-level policy document setting state anti-corruption priorities for five years. On its basis, the government must, within six months of the law taking effect, approve the State Anti-Corruption Program (SAP) — an operational plan with specific measures, deadlines, and responsible parties.

This is Ukraine’s third Strategy. The first covered 2014–2017 and focused on building anti-corruption institutions. After it expired, Ukraine spent five years without a strategic document; the next was adopted only in June 2022, effectively under EU pressure ahead of candidate status. That strategy was largely declarative and did not reflect the realities of the full-scale invasion. The new 2026–2030 Strategy is far more detailed, covers more areas, and for the first time includes a separate section on recovery. It must also reflect Ukraine’s international commitments across all relevant areas.

Adopting the Strategy is itself an international commitment — required by the Ukraine Facility plan, the Rule of Law Roadmap, and the Kachka-Kos plan. The Ukraine Facility deadline for adopting the relevant law is the end of June 2026.

TI Ukraine took part in preparing the Strategy: our DOZORRO experts worked directly on the public procurement subsection and joined discussions on the others, providing written comments. We previously published a detailed analysis of the NACP Strategy text following public consultations.

That said, some of our comments on criminal justice in that analysis were also incorporated by the Agency into the version sent to the government for approval in early April and registered as a draft law by Anastasiia Radina. Notably, this version also provides for repealing the Lozovyi amendments.

What changed in the government’s version

Neither competing draft law is perfect, and several provisions in both could be refined. Still, the bill registered by the Committee Chair is currently the most ambitious version. The government, by contrast, dropped a number of important reforms, weakening the Strategy. Let us examine the government’s cuts in detail.

Competitive appointment of the Prosecutor General. The most significant difference is in the Prosecution Service subsection (2.2). The Committee Chair’s version lists eight problems; the government’s, seven. The government removed Problem 2.2.2, which provided for:

• appointing the Prosecutor General through a selection commission that recommends candidates to the President; 
• defining in law the grounds for a vote of no confidence in, and dismissal of, the Prosecutor General.

The Kachka-Kos plan envisages a comprehensive overhaul of the Prosecutor General’s selection and dismissal procedure to align it with best European practice, with input from the Venice Commission. This reform scored 0 out of 10 in the expert coalition’s monitoring, as no steps have been taken since December 2025. In the government’s draft law, the problem is not merely deferred to the SAP but removed entirely.

Reform of the SBI Director selection. In the Committee Chair’s version, Problem 2.2.7 covers the selection of the heads of the National Police and the State Bureau of Investigation — with a specific outcome on improving the SBI Director selection procedure in line with European Commission recommendations. 

In the government’s version, Problem 2.2.6 covers only the selection of the National Police leadership; a competition for the SBI head is absent. Yet SBI reform is also part of the Kachka-Kos plan and scored 1 out of 10 in the expert coalition’s monitoring.

Narrowing the SAPO Head’s powers. In the Committee Chair’s Strategy, point 1.10.3.1 granted the SAPO Head four categories of powers:

1. a) entering information on MPs into the URPTI and approving motions heard by an investigating judge; b) independently sending extradition requests and forming joint investigation teams; c) extending pre-trial investigation deadlines; d) carrying out any investigative and procedural actions in NABU proceedings without involving the Prosecutor General.

The government’s version keeps only (b) and (c). The removed points — (a) and (d) — are precisely those that most reduce SAPO’s dependence on the Prosecutor General and limit political influence over investigations. Requiring SAPO to clear procedural actions with the Prosecutor General is a structural vulnerability that allows investigations to be blocked or slowed through administrative tools.

Detail on NACP salaries. In the Committee Chair’s version, point 1.10.1.1 contains specific wording: to define in law the size and structure of salaries for all categories of NACP staff to ensure transparency and minimize the variable component. The government’s version retains only the general “proper legal regulation of financial provision,” without detail on pay structure. This change is not critical, since the requirement to set NACP staff salaries in the dedicated law is better placed in the SAP. 

What remained unchanged

Most of the Strategy’s text is identical in both versions. Both retain: autonomous wiretapping for the NABU, abolition of the automatic closure of criminal cases upon expiry of the statute of limitations, selection to the HQCJ and HCJ with international experts holding a decisive vote, and whistleblower protection under EU Directive 2019/1937.

Yet one of the weakest sections in both Strategies is the subsection on asset declaration, which omits most of Ukraine’s international commitments in this area — in particular, on the ineffectiveness of automated checks and the need to revisit the risk-based approach. The current financial control system cannot effectively prevent top-level corruption specifically, and this must be fixed.

Conclusions and recommendations

The comparative analysis shows that the government used the month-long delay not to improve the document but to weaken three provisions directly tied to the Kachka-Kos plan priorities.

These and other shortcomings must be corrected when the relevant law is adopted.

• The version developed by the NACP and registered by the Anti-Corruption Committee Chair is more ambitious and more fully reflects Ukraine’s international commitments. In any case, between the first and second readings the committee will be able to consider amendments from all entities with the right of legislative initiative, including the government.
• Removing points (a) and (d) from point 1.10.3.1 on the SAPO Head’s powers directly affects the operational independence of the anti-corruption prosecution. These provisions must appear in the final text of the Strategy.
• Regardless of which version parliament adopts as the basis, several provisions should be strengthened between readings — above all, the effectiveness of countering money laundering and the approaches to assessing e-declaration. Here, the NACP should focus on the quality of full checks, not merely the number of automated ones.

Further delay in voting on the Strategy is not an option. The previous cycle showed that late adoption of the Strategy and the SAP renders part of their content obsolete before implementation even begins. It is essential to preserve the document’s ambition and to strengthen it further.