What Does the 2026 European Commission’s Report Recommend?

The European Commission has published its 2026 EU Enlargement Report on Ukraine as a candidate country.

In its Enlargement Report, the European Commission notes that Ukraine has remained committed to the EU integration reform agenda. In particular, it states that the country continues to demonstrate that its institutional framework for the fight against corruption is effective and that its specialized anti-corruption institutions generally continue to operate independently and effectively.

At the same time, the slowdown in legislative decision-making during the reporting period is a matter of concern for European partners. Since the end of the summer, however, there has been increased focus on reforms and the actual implementation of policy conditionality under the Ukraine Facility and Ukraine Support Loan. In October 2026, Ukraine and the European Commission established a joint Task Force to help accelerate progress on the interim benchmarks and advance essential rule-of-law and anti-corruption reforms.

The Commission also noted that the ten priority reforms agreed with the Ukrainian authorities on 10 December 2025 (the “Kachka–Kos plan”) remain mostly outstanding.

For the fourth year, Transparency International Ukraine has analysed the Enlargement Report in the following areas:

• investigation and prosecution of high-level corruption (Chapter 23);
• corruption prevention and the effectiveness of the NACP (Chapter 23);
• management and confiscation of criminal assets (Chapter 24);
• public procurement (Chapter 5);
• financial control (Chapter 32);
• regional policy (Chapter 22).

Let’s take a closer look at the Commission’s assessment of Ukraine’s progress and recommendations in TI Ukraine’s areas of expertise.

Criminal Prosecution of High-Level Corruption (Chapter 23)

Ukraine is between having some and a moderate level of preparation in the fight against corruption. The Commission notes that some progress is primarily attributable to the results achieved by the NABU, the SAPO and the HACC, which continue building a track record of investigations, prosecutions, and final verdicts in high-level corruption cases. 

At the same time, the Commission describes limited progress on previously recommended legislative and institutional reforms as a “major concern.” It stresses that anti-corruption institutions continue to report pressure from state institutions, law enforcement, and security agencies, and that their situation remains fragile overall. 

Positive developments identified by the Commission. The European Commission assesses progress in the institutions’ track record as good. This reflects successful NABU and SAPO operations exposing high-level corruption, an increase in indictments and convictions, shorter proceedings at the HACC, an increase in judicial staffing and the adoption of strategic documents. The Commission also notes that the NABU has improved its case prioritization, with tangible results. European partners further highlight the contribution of an exceptionally active civil society in safeguarding institutional independence. 

Despite these achievements, no legislation substantially advancing the anti-corruption framework has been adopted. The Commission recalls that ratification of the OECD Anti-Bribery Convention remains incomplete because the necessary amendments to criminal legislation have not been adopted. It also calls for refraining from legislative initiatives that carry corruption risks (concerning politically exposed persons (PEPs), criminal proceedings in economic crime cases and free-of-charge privatisation of land). 

Proceedings at the HACC remain too lengthy, and its backlog needs to be reduced. In 2025, ten defendants in high-level corruption cases were released from criminal liability because the statutes of limitations had expired. Access to independent forensic expertise remains problematic, independent wiretapping capabilities are still lacking, Parliament has not changed the frequency of the NABU’s external assessment from annual to biennial, and SAPO’s external audit has yet to take place. The incumbent SAPO Head’s term expires in July 2027. In March 2026, following the resignation of the First Deputy Head in November 2025, the Prosecutor General appointed a commission to select SAPO’s leadership. The Commission explicitly identifies breaches of NABU’s exclusive jurisdiction by other law enforcement agencies as a problem undermining the Bureau’s mandate. 

The Commission explicitly points to continuous attempts to put pressure on the NABU and the SAPO, including criminal investigations and surveillance of NABU staff by other law enforcement and security agencies, as well as media campaigns targeting the institutions. Amid a NABU investigation, the Prosecutor General resigned in September and was dismissed by Parliament. Before that, he had left Ukraine and signed notices of suspicion against the NABU Director and a close associate of the SAPO Head; these notices were subsequently revoked by the Prosecutor General’s Office. 

For the next 12 months, the Commission recommends that Ukraine:

• further consolidate the track record in corruption cases, including the seizure and confiscation of criminal assets;
• strengthen NABU’s and SAPO’s autonomy in investigating cases involving Members of Parliament without prior approval by the Prosecutor General;
• expand NABU’s jurisdiction to cover high-risk positions, including the leadership of the Office of the President and heads of regional state administrations;
• adopt legislation ensuring anti-corruption bodies’ access to high-quality forensic expertise;
• introduce robust safeguards against interference with the NABU and the SAPO and circumvention of their exclusive jurisdiction;
• expand the scope of declarants and improve asset declaration verification to effectively detect and confiscate unexplained wealth;
• ensure the timely selection of a new Head and Deputy Head of SAPO;
• amend the Criminal Procedure Code to address procedural impediments, eliminate automatic case closures and revise statutes of limitations in line with European standards, and adopt amendments enabling single-judge adjudication of civil and administrative cases at the HACC. 

Almost all these concerns and recommendations fully coincide with those identified by TI Ukraine in its Shadow Report.

The Commission refers to a notice of suspicion against a Deputy Head of the Office of the President but does not link it to attempts to influence selection procedures for anti-corruption bodies (the correspondence disclosed by the SAPO on 5 August and Operation “Forrest Gump”). 

The Commission does not specify what “safeguards against interference” should entail. TI Ukraine proposes disciplinary liability for heads of investigative units that breach investigative jurisdiction, a clear procedure and deadlines for transferring cases to NABU, and liability for failure to comply with an order to transfer case materials.

Prevention and Effectiveness of NACP (Chapter 23)

The European Commission continues to note that the National Agency on Corruption Prevention (NACP), which adopted its institutional strategy in 2025, retains a central role in anti-corruption policymaking and prevention. At the same time, it continues to express concerns about the impartiality and effectiveness of certain NACP functions. The Commission also mentions unsubstantiated bribery allegations involving NACP officials following a NABU investigation. 

Positive developments identified by the Commission. The Commission welcomes the NACP’s increased oversight of compliance with lobbying rules, the establishment of a dedicated unit and the adoption of a separate monitoring and control procedure. In the Commission’s view, the latter should be reviewed in light of initial implementation experience. It also notes that the Transparency Register is fully operational and contains all necessary information accessible to the public. 

The Commission also notes that extensive digitalization of public services has helped reduce corruption risks in the relevant sectors. 

The report further acknowledges that Ukraine has achieved a high implementation rate for its current State Anti-Corruption Program and is in the process of adopting a new anti-corruption policy framework for 2026–2030. 

Concerns raised by the Commission. Most concerns repeat those from last year. The Commission again stresses the need for the NACP to implement the recommendations of the 2023 external audit report and to conduct the next assessment without delay, using robust methodology and criteria. 

The report again calls for strengthening the electronic asset declaration system. The Commission identifies practical and legal shortcomings in declaration verification, including the need for a comprehensive review of the risk-based methodology. It reiterates that asset declaration obligations should also cover staff working in the private offices of senior officials, including advisers and assistants, and top managers of all state-owned enterprises. The report also calls for legislative amendments to minimise risks related to declarations of cash held outside the banking system. 

The system of anti-corruption units and designated anti-corruption officers should be reformed to improve its effectiveness. In particular, the quality of corruption risk assessments and anti-corruption programs adopted by public authorities often remains low. The Commission states that the NACP should comprehensively review its corruption risk assessment methodology, including by applying a sector-specific approach, and that further efforts are needed to better integrate corruption risk management into public-sector institutions’ overall risk management systems. 

The legal framework for whistleblower protection still needs to be fully aligned with the EU acquis. The report also calls for reviewing legislation on conflicts of interest and related restrictions to address identified gaps, inconsistencies and disproportionate restrictions. 

The Commission also notes that the draft Anti-Corruption Strategy for 2026–2030 has not yet been adopted by Parliament and that a new State Anti-Corruption Program must also be developed and adopted. To prevent future implementation problems, capacities, expertise and resources should be strengthened, particularly at the NACP. In addition, to increase ownership of reforms, responsibilities should be clearly divided between line ministries and enforcement bodies, with regular involvement of political coordination bodies, including at the highest level. 

In addition to the recommendations outlined above, the Commission recommends, in line with the Ukraine Plan, that Ukraine:

• adopt an ambitious Anti-Corruption Strategy and State Anti-Corruption Program;
• ensure effective reduction of identified corruption risks in vulnerable sectors (energy, defence, procurement, construction and land management, justice and law enforcement) through national anti-corruption and relevant sectoral strategic frameworks. 

Almost all these concerns and recommendations fully coincide with those identified by TI Ukraine in its Shadow Report. 

At the same time, this year, the Commission does not explicitly mention the need for some degree of external oversight of logical and arithmetic checks of asset declarations. Nor does it positively assess the effectiveness and results of the NACP’s lifestyle monitoring of public officials, as it did previously. TI Ukraine did not share that positive assessment, since we consider the current lifestyle monitoring procedure insufficiently regulated. 

Compared with the previous report, the Commission also no longer raises the issue of insufficient NACP staffing or provides the number of confirmed whistleblowers alongside an assessment of the Unified Whistleblower Reporting Portal.

Management and Confiscation of Criminal Assets (Chapter 24)

According to the Commission, Ukraine is between having some and a moderate level of preparation under Chapter 24 in the fight against serious and organised crime. 

Regarding assets, the Commission finds that the use of financial investigations, asset freezing and confiscation has increased but remains limited overall. Its assessment of the legislative framework is clearly critical: Ukraine has made no progress in aligning legislation with the EU acquis on the fight against serious and organised crime, while the adoption of strategic documents, including the Financial Investigation Strategy and Asset Recovery Strategy, has been delayed. 

Positive developments identified by the Commission. First, the ARMA reform has advanced: an independent assessment of the Agency’s effectiveness was conducted, an inventory of assets under management was completed, and most secondary legislation needed to implement the reform was adopted. Second, improvements were noted in the fight against money laundering: in 2025, the numbers of criminal proceedings, indictments and convictions increased, while confiscation decisions nearly doubled, from 51 to 96. Third, the Commission notes that the NABU and the Economic Security Bureau (ESBU) established specialized financial investigation units. 

Concerns raised by the Commission. The first competition for the Head of the ARMA concluded without a result and has therefore been relaunched. Despite the adoption of secondary legislation, the Commission identifies shortcomings in the selection of asset managers and the lack of judicial oversight of this process. Amendments to the Criminal Procedure Code are still needed to regulate cooperation between the ARMA and prosecutors. The Asset Recovery Strategy and its action plan expired in 2025, and replacement documents have not been adopted. Practical guidance and templates for implementing the 2024 joint order on financial investigations are also lacking. 

The most significant concern is the absence of consolidated statistics on asset freezing and confiscation, which the Commission identifies as a major obstacle to assessing the effectiveness of these mechanisms. In the Commission’s view, available data indicate insufficient use of confiscation in criminal proceedings. In money-laundering cases, most convicted persons received suspended sentences (188 out of 271 in 2025); courts are overburdened and the backlog has grown. Legislation establishing registers of natural persons’ bank accounts and of beneficial owners of trusts remains blocked in Parliament. The MONEYVAL assessment has been postponed. 

The Commission’s recommendations in this area are to:

• finalize the selection of the Head of ARMA and begin implementing the recommendations of the Agency’s independent external assessment;
• establish a register of accounts and individual bank safes of natural persons and ensure access for competent authorities;
• adopt and start implementing the Financial Investigation Strategy and the 2026–2030 Asset Recovery Strategy and, under the anti-corruption chapter, consolidate the track record in seizure and confiscation of assets;
• adopt legislation ensuring the operational independence of the financial intelligence unit, with a transparent competitive selection of its head;
• align the provisions concerning politically exposed persons (PEPs) with the EU acquis. 

All these recommendations fully coincide with those TI Ukraine made in its Shadow Report. 

At the same time, the Commission devoted less attention this year to gaps in the legislative regulation of confiscation mechanisms. This issue is included in the Rule of Law Roadmap, but the Commission did not single it out in this section of the report.

Public Procurement (Chapter 5)

The Commission notes that Ukraine is between having some and a moderate level of preparation in public procurement. Legislation is partially aligned with the EU acquis, while the rules governing review procedures are largely aligned. 

According to the Commission, public procurement contracts worth EUR 19.74 billion were concluded in 2025, excluding defence and gas procurement. In practice, the State Audit Service identified violations in 63% of the procurements it monitored, while the Anti-Monopoly Committee of Ukraine upheld 66% of complaints. The Commission also refers to Operation “Midas” in the context of preventing corruption in public procurement, noting that the investigation uncovered alleged large-scale embezzlement and high-level political influence over defence contract awards. 

Positive developments identified by the Commission. The Commission notes some progress, primarily due to implementation of the Strategy for Reforming the Public Procurement System for 2024–2026 and adoption of the new Law on Public Procurement. The law further aligned the legislative framework with the EU acquis and marked a significant step towards meeting Ukraine’s public procurement obligations under the Deep and Comprehensive Free Trade Area (DCFTA). 

The Commission also notes that in 2025, 72.3% of public procurement contracts, excluding defence and gas procurement, were awarded through competitive procedures. The government also approved a Roadmap for Strengthening Public Procurement Control. The State Audit Service improved procedures for accessing the personal data of persons responsible for violations, while its findings were rarely challenged in court and challenges were seldom successful. Progress was also reported in updating training programmes for procurement professionals and economic operators.

Concerns raised by the Commission. Last year’s recommendations were only partially implemented. The Commission draws attention to continuing exceptions to competitive procedures, including direct contracting for the protection of critical infrastructure. 

The report specifically raises concerns about pilot framework agreements for certain construction works that allow purchases without tenders and provide limited opportunities for monitoring and review. In other words, the government’s experiments have not gone unnoticed. Single-bidder tenders accounted for 70.6% of tender value. The Commission also considers contracting authorities’ capacity and internal and external control mechanisms for preventing corruption and bid rigging to be weak. 

Other concerns include gaps in aligning public-private partnership (PPP) and concession legislation with the EU acquis and the unresolved distinction between ordinary public procurement and defence procurement. Regarding procurement monitoring, the Commission observes that only a small share of monitoring procedures were triggered by automatic risk indicators. 

The Commission recommends that Ukraine:

• align all public procurement legislation with the EU acquis, including legislation on utilities, concessions, PPPs, and defence procurement, while ensuring non-discriminatory treatment of EU companies in Ukrainian PPP projects;
• improve e-procurement functionality, including by introducing new EU-compliant procedures in Prozorro, improving e-contracting and reducing exemptions;
• implement and, where necessary, adjust the new Public Procurement Development Strategy for 2027–2030;
• strengthen integrity checks and exclusion grounds for tenderers, enhance monitoring, and build the capacity and integrity of procurement management within all contracting authorities. 

Conceptually, the Commission’s recommendations align with those of TI Ukraine’s Shadow Report on public procurement. However, some Commission observations require additional context and further research. When discussing exceptions, the Commission primarily refers to the exemption for critical infrastructure protection. In our view, the focus should instead be on unjustified exemptions that are not objectively necessary. 

The Commission also refers to certain problems with deadlines for submitting complaints. We have not observed such problems, so the issue warrants further examination. Its reference to problems with the automatic suspension of a procedure when a contracting authority’s decision is challenged also raises questions. 

Furthermore, the report should consider not only the procurement procedure itself but also the contract implementation stage. 

The Commission also positively assessed implementation of the Strategy for Reforming the Public Procurement System for 2024–2026. However, a significant share of measures under the Strategy had been postponed until the adoption of the updated public procurement law. Moreover, no action plan was approved for 2026.

Financial Control (Chapter 32)

The European Commission noted some progress in financial control. However, most positive developments in this chapter concern strategic and regulatory changes, while their implementation remains uneven. The Commission also notes that its recommendations from last year were only partially implemented and therefore remain relevant.

Key concerns include insufficient effectiveness of internal control, staffing constraints at the Accounting Chamber, and the need to further strengthen the fight against fraud involving EU funds.

Positive developments identified by the Commission. The Commission notes the approval of the strategic framework for developing public internal financial control for 2026–2030, the start of aligning national internal audit standards with the Global Internal Audit Standards, and the establishment of audit committees at key budget spending units.

The Commission also positively assesses the Accounting Chamber’s work, particularly its application of new audit methodologies based on ISSAI standards and stronger cooperation with parliamentary committees in overseeing public spending.

The Commission separately highlights the adoption of a national anti-fraud strategy to protect the EU’s financial interests in July 2026 and the developing role of the State Audit Service as the anti-fraud coordination service (AFCOS). Despite progress, further improvements are needed in the practical effectiveness of public internal financial control, the institutional capacity of the Accounting Chamber, and the State Audit Service’s powers to protect the EU’s financial interests.

Concerns raised by the Commission. Despite some progress, particularly in strengthening the regulatory framework, the assessment of practical results in financial control remains cautious.

The Commission’s main concerns relate to the institutional capacity and independence of financial control bodies. In particular, it reiterates the need to fill vacancies at the Accounting Chamber and strengthen its financial independence. Regarding the State Audit Service, the Commission identifies the need to expand its powers as the anti-fraud coordination service (AFCOS), which are currently limited to reporting irregularities under the Ukraine Facility.

Another unresolved issue is the incomplete alignment of national legislation with EU requirements for protecting the Union’s financial interests.

In public internal financial control, the Commission highlights uneven reform implementation, insufficient coordination and differences in institutional capacity. In particular, it calls for strengthening the Ministry of Finance’s Central Harmonization Unit and managers’ accountability for internal control and risk management.

The Commission recommends focusing on three priorities:

1. strengthening the Accounting Chamber — filling vacancies, enhancing institutional and financial independence, extending financial audit coverage of strategically important public expenditure and improving performance audits;
2. strengthening the fight against fraud — primarily by developing cooperation with OLAF and the European Public Prosecutor’s Office (EPPO), and aligning national legislation with EU law;
3. improving the effectiveness of public internal financial control — implementing the Global Internal Audit Standards, strengthening the Central Harmonization Unit, ensuring effective audit committees and expanding risk management practices.

Importantly, the process of filling vacancies at the Accounting Chamber has finally moved forward: the Verkhovna Rada has established the Advisory Group of Experts required to conduct the competition.

All the report’s recommendations fully coincide with TI Ukraine’s concerns.

At the same time, we believe that strengthening the Accounting Chamber’s financial independence requires a balanced approach that takes into account both international principles governing the independence of supreme audit institutions and budgetary constraints under martial law. The current approach appears balanced, and completely exempting the Accounting Chamber from general budget planning procedures may be premature. 

Furthermore, although the overall quality of Accounting Chamber audits shows a positive trend, including its audits of the HACC and the ARMA, insufficient depth of analysis in individual cases still undermines the completeness and soundness of the findings.

Regional Policy (Chapter 22) 

Ukraine is making progress in establishing rules and instruments of European governance, but their practical implementation at regional and local levels remains weak and uneven.

The principal positive developments concern updates to the regulatory framework and strategic planning for regional development.

However, the Commission pays particular attention to the insufficient coherence between strategic planning, financing and public investment management. Ukraine needs to prepare the institutional architecture for the future management of EU funds, strengthen administrative capacity at all levels and ensure meaningful participation of local authorities and civil society in policy development and monitoring.

The Commission also considers that the reorganization of the responsible ministry into two separate bodies has adversely affected reform continuity and implementation of previous commitments.

Positive developments identified by the Commission. The European Commission notes several positive developments in regional policy and strategic planning, including updates to the regulatory framework and the action plan for implementing the State Regional Development Strategy, and the start of preparations for the 2028–2034 strategy. The Interdepartmental Coordination Commission for Regional Development has also resumed its work.

Progress in public investment management reform is also assessed positively: a medium-term plan for priority public investments for 2027–2029 was approved, a single state project pipeline for 2027 was developed, and regional and local authorities advanced preparation of the relevant documents.

Some progress has also been achieved in financial control through legislative changes and improved internal control mechanisms. At the municipal level, anti-corruption tools were piloted, including procurement integrity procedures, integrity plans and internal audits. However, the Commission stresses that these initiatives still require systematic implementation and greater practical effectiveness.

Concerns raised by the Commission. The European Commission highlights several systemic problems holding back the development of Ukraine’s regional policy.

National, regional and local strategic documents remain insufficiently aligned, and their links to reconstruction needs, investment priorities and funding are weak. The State Fund for Regional Development is still not fully operational. Local authorities and civil society have limited involvement in shaping regional policy, and staff capacity remains insufficient.

Ukraine has yet to establish a fully functioning management, monitoring and audit system for future EU funds. Public internal financial control remains fragmented, the practical impact of local anti-corruption programmes is limited, and the functionality of DREAM as a transparency and corruption prevention tool requires further improvement.

The European Commission recommends that Ukraine:

• strengthen institutional coordination: adopt a government action plan to meet Chapter 22 benchmarks, clearly delineate the responsibilities of the relevant ministries and ensure the full operation of the Interdepartmental Coordination Commission;
• improve strategic planning: enhance reporting on implementation of the State Regional Development Strategy, prepare a new strategy for 2028–2034, and finalise regional and local strategies that reflect investment priorities;
• ensure transparent regional development financing: make the State Fund for Regional Development fully operational and digitalised and improve fund allocation and project selection mechanisms;
• increase administrative capacity: develop the skills of public authorities at all levels, particularly in investment project preparation, public procurement and EU fund management;
• strengthen stakeholder participation: systematically involve local and regional authorities, civil society and partners in the planning, implementation, monitoring and evaluation of regional programmes;
• improve financial control and integrity: strengthen internal audit, develop risk management, ensure transparent use of resources and improve DREAM as a tool for accountability and corruption prevention.

Thus, the European Commission notes some progress in improving the effectiveness and transparency of multilevel governance. Achievements include adoption of legislation to ensure legality and transparency in local self-government and the 2025 update of the Concept for its reform. At the same time, the report pays insufficient attention to the practical implementation of adopted legislation, namely access to information, digital capacity and local authorities’ accountability to residents. In particular, it lacks an assessment of how open council meetings, access to adopted decisions, public reporting by mayors and council members, municipal open data and electronic services actually work in practice.

The pilot European City Index reveals substantial problems in these areas: average compliance with open data requirements is only 23.1%, while the overall score of the 11 cities assessed is 44 out of 100. This confirms the need to assess EU integration progress not only through legislative changes and national systems, but also by examining how European standards of openness, accountability and accessible services are implemented in local communities.

Other Important Recommendations

1. International experts in selection procedures.

The Commission describes as a “challenge” the legislature’s longstanding resistance to the temporary involvement of independent experts nominated by international partners in various selection and vetting procedures. The report warns that ending their role prematurely, before national appointment bodies have been fully reformed, would put judicial reform at risk. 

The Commission therefore calls for urgent extension of the meaningful involvement of such experts in the selection of members of the High Qualification Commission of Judges (HQCJ), in line with the Ukraine Facility, and the High Council of Justice (HCJ). It also calls for their temporary involvement to improve the selection and integrity vetting of Supreme Court and other high-court judges. This aligns with our recommendations on draft laws Nos. 13382 and 16018 concerning the extension of international experts’ participation in HQCJ selection, our recommendation to involve the Public Council of International Experts (PCIE) in Supreme Court competitions and integrity declaration checks, and our conclusion that international experts’ decisive vote remains a critical safeguard against politicisation of selection procedures. 

These are among the Commission’s strongest concerns in the judiciary chapter.

2. Prosecutor General and prosecution service. The Commission calls for improving the procedures for selecting and dismissing the Prosecutor General and repealing provisions permitting the transfer and appointment of prosecutors without competition, as well as those granting the Prosecutor General access to pre-trial investigation materials.

The Commission also calls for legislation on the selection of management-level prosecutors, improved disciplinary accountability for prosecutors in line with GRECO recommendations, stronger capacity of the Qualification and Disciplinary Commission of Prosecutors, and the launch of electronic criminal case-management modules.