Key Anti-Corruption Challenges Identified in the 2026 Shadow Report

On October 19, Transparency International Ukraine, together with a coalition of partner civil society organizations, presented the third Shadow Report on Chapter 23 (Judiciary and Fundamental Rights) and Chapter 24 (Justice, Freedom and Security) of the European Commission’s 2025 Report on Ukraine.

The reporting period (September 2025 to August 2026) brought mostly piecemeal progress that depended on the efforts of individual institutions. TI Ukraine experts made 141 recommendations to improve the situation.

“This year, we see two parallel stories. The first is about anti-corruption bodies that are working more and more effectively: more verdicts, more confiscated funds, and new judges at the HACC. The second is about systemic legislative changes without which these successes remain fragile. For the most part, these changes are still waiting their turn, and more than half of all the recommendations from our previous Shadow Report remain relevant,” noted Kateryna Ryzhenko, Deputy Executive Director of Transparency International Ukraine for Legal Affairs. 

In preparing the report, we identified four groups of problems that are slowing Ukraine’s progress toward the EU.

1. Institutional capacity of anti-corruption bodies. Materials from NABU and SAPO investigations pointed to attempts by top officials to influence the formation of selection commissions. This confirms that the participation of international experts with a decisive vote remains a critical safeguard. The audit of the SAPO has still not begun, and the independent evaluation of the NACP has been blocked for more than four years. The NABU’s investigative jurisdiction has not been extended to the leadership of the Office of the President, the State Bureau of Investigation, or the Economic Security Bureau.
2. Criminal justice. The “Lozovyi amendments” have still not been repealed, and legislation improving the rules on statute of limitation has yet to be adopted. The draft law on abuse of procedural rights has not been adopted either. Two-thirds of HACC verdicts were delivered on the basis of plea agreements, and the terms of these agreements and the approach to concluding them should be better explained to the public.
3. Financial control (NACP). Problems persist with the NACP’s financial oversight, moreover the NACP still does not publish its rules for logical and arithmetic control.
4. Proceeds of crime. The management of seized and confiscated assets still requires improvements in record-keeping and practical procedures. 

In the Shadow Report, TI Ukraine also places particular emphasis on the pressure on the NABU and the SAPO, which did not ease throughout the year. This includes searches and detentions of detectives, surveillance devices discovered targeting heads of units, and the activities of a temporary investigative commission of the Verkhovna Rada, which civil society organizations have described as a tool for pressuring the anti-corruption bodies.

How we prepared the report

In addition to TI Ukraine, experts from the Agency for Legislative Initiatives, the ZMINA Human Rights Centre, Tomorrow’s Lawyer, Europe Without Barriers, the Ukrainian Bar Association, the Civil Network OPORA, and the Centre for Democracy and Rule of Law worked on the report, and European Pravda provided informational support. 

In preparing our section on combating corruption and organized crime, Transparency International Ukraine experts:

• conducted 17 interviews with various experts, representatives of international partners, civil society experts, and public officials;
• sent 12 requests to state bodies to clarify statistical information;
• analyzed 73 measures of the Rule of Law Roadmap in the area of fighting corruption and countering money laundering;
• examined legislation and its application in practice;
• analyzed international standards, including EU regulatory documents;
• reviewed official and statistical data and, based on these, identified trends in the activities of the state bodies covered by the report.

Chapter 23 on Justice and Fundamental Rights and Chapter 24 on Justice, Freedom, and Security, examined in the Shadow Report, are part of Cluster 1, Fundamentals. This cluster is key to the entire negotiation process: it was the first to open and will be the last to close, at the final stage of negotiations, once all EU member states give their consent.

This material is funded by Norway. Its content is the sole responsibility of Transparency International Ukraine and does not necessarily reflect the views of the Norwegian Government.