At first glance, 2025 was a relatively measured year in procurement: while the rules and the electronic system did change, the changes were less sweeping than, say, the introduction of Resolution No. 1178 in 2022 or the temporary abolition of three-round auctions in 2023. Yet there was also a great deal of work laying the groundwork for the sector’s future. The Ministry of Economy worked on the draft of the new Law on Public Procurement, a process TI Ukraine took part in. We also prepared proposals for the public procurement chapter of the Anti-Corruption Strategy for 2026–2030.
This report describes what happened in the sector in 2025: legislative changes and the main statistics, including oversight and appeals. Its structure resembles the one the European Commission uses in its annual Enlargement Report on Ukraine and reflects the broad dimensions along which the EU assesses the state of our public procurement. At the end, we set out our recommendations for improving the sector.
This is the third time we have prepared such a report. The previous editions are available here: 2023 and 2024.
Executive Summary
In 2025, progress on public procurement reform remained slow and uneven. The Government focused on drafting the new Law on Public Procurement and approved a Roadmap for Strengthening Oversight in the sector. Procurement preserved its transparency and competition level. However, legislation on public-private partnerships and concessions still has not been brought into line with the EU acquis, and work on defense procurement has yet to begin. To improve public procurement, Ukraine must above all accelerate the sector’s European integration, refine the State Audit Service’s risk-based and preventive monitoring, and minimize government regulation of procurement under martial law.
Legislative changes and strategic planning
The year’s main priority was drafting the new Law on Public Procurement (Draft Law No. 11520) — for the second year running, one of the European Commission’s key recommendations. In late 2025, the Ministry of Economy submitted its updated version for second reading to the Verkhovna Rada Committee on Economic Development. In addition, the Verkhovna Rada passed a new Law on Public-Private Partnership over the summer, but the adopted changes have shortcomings and the framework needs further work to align with EU rules.
The Government did not update the Public Procurement Reform Strategy for 2024–2026, nor did it prepare a 2026 implementation plan for it. A chapter on public procurement was, however, included in the draft Anti-Corruption Strategy for 2026–2030.
The current framework remained volatile: the rules on procurement under martial law were amended 14 times — twice as often as the previous year. The changes concerned the grounds for direct awards, procurement under Ukraine Facility, localization, and changes to the unit price in a contract.
Transparency and competition
The share of competitive procurement rose to nearly 78% of the value of all contracts — despite the expanded list of grounds for above-threshold direct awards.
However, overall competition barely changed from the previous year. The average number of bidders per lot held at 1.9, and only 39.15% of competitive procurements drew two or more bids.
Prozorro Market’s role grew further still. In 2025, nearly every second competitive procurement (45.3%) was run through the electronic catalog, and the share of contracting authorities using this tool rose from 25% to 49%. Yet procurement through Prozorro Market still cannot be challenged before the AMCU, and it falls outside the State Audit Service’s monitoring.
Oversight and accountability
Procurement monitoring remains the most responsive oversight mechanism in the sector. In 2025, the State Audit Service covered nearly 11,000 procurements with an estimated value of UAH 229.5 billion. However, procurements through Prozorro Market and defense framework agreements (12.4% of the estimated value of all procurement on Prozorro) currently fall outside monitoring.
Despite some progress, monitoring still lacks preventiveness and a focus on risks and material violations. Meanwhile, in 2025 the State Audit Service gained broader powers to hold violators accountable and to oversee the funds of international partners, and the Government approved a Roadmap for Strengthening Public Procurement Oversight for 2025–2027.
Protecting business rights and interests
In 2025, businesses filed 9,750 procurement complaints with the Antimonopoly Committee — 7.3% fewer than in 2024. Complaints were most frequently filed against construction and fuel procurement. Despite the appeals system working steadily, the AMCU’s workload remains high. Complaints are reviewed by only 6 of the 10 authorized commissioners provided for by law. Given the expected rise in workload — the introduction of appeals for Prozorro Market and PPPs, and the return of the negotiated procedure — the body’s institutional capacity needs strengthening.
Key developments in 2026
The most significant event in the sector was the adoption of the new Law on Public Procurement (Draft Law No. 11520) on 27 May 2026. The law brings Ukrainian legislation closer to EU standards: it introduces new procurement procedures, narrows the list of exemptions, updates the rules on contract modifications and the application of non-price award criteria. The law is also expected to bring long-awaited regulatory stability to the sector.
Procurement regulation during martial law also underwent several important changes: the government established rules for determining estimated value and evaluating bids on a VAT-exclusive basis, introduced disclosure of ultimate beneficial owners of contract performers, and launched two pilot projects with a separate procurement procedure for reconstruction. TI Ukraine has flagged the risks of the latter and called for the pilots to be discontinued, as the new procurement mechanism lacks adequate anti-corruption safeguards, restricts participants’ ability to protect their rights, and conflicts with other provisions of the law.
To improve the sector, TI Ukraine recommends, first and foremost:
- Accelerate the sector’s European integration (responsible bodies: Ministry of Economy, Verkhovna Rada). Ukraine must complete the harmonization of legislation on public and defense procurement, PPPs, and concessions with EU rules. It must also approve the Anti-Corruption Strategy for 2026–2030 and develop a sector development strategy for 2027–2030. These are at once a condition of European integration and, more broadly, steps toward improving public procurement.
- Refine the State Audit Service’s monitoring (responsible bodies: Ministry of Economy, State Audit Service). Monitoring must become more preventive and risk-based. It is also necessary to define a clear list of ways to remedy a violation, to track more accurately whether contracting authorities actually remedy them, and to make accountability more certain.
- Minimize the procurement specifics applied under martial law (responsible body: Ministry of Economy). Government regulation should narrowly cover only those cases genuinely warranted by martial law.
This report is funded by the European Union. Its content is the sole responsibility of Transparency International Ukraine and does not necessarily reflect the views of the European Union.
