15 out of 100: Limited Progress on the Kachka-Kos Plan

An expert coalition has presented the findings of the second Membership Check monitoring of Ukraine’s progress on 10 priority EU integration reforms. According to the think tanks’ joint assessment, the country’s overall progress has risen only marginally, to 15 out of a possible 100 points.

As the first negotiating cluster, Fundamentals, opens, Ukraine is still showing extremely slow progress in implementing the reforms set out in the EU integration Kachka-Kos plan. According to the Membership Check expert monitoring, overall implementation of the tasks reviewed has grown by just 6 points since the first round and now stands at only 15 out of a possible 100.

This is the second such assessment of Ukraine’s progress in meeting these commitments to its European partners; the first was published in April 2026, when Ukraine scored 9 out of 100.

At this stage of the monitoring, Transparency International Ukraine experts again took part in assessing the points of the plan that are critical to effective anti-corruption work in Ukraine. In particular, the organization’s analysts assessed in detail the implementation of key goals in judicial and anti-corruption reform, criminal justice, and competitive selection for positions in law enforcement bodies. 

“Ukraine’s progress on the Kachka-Kos plan is rather modest so far — we are seeing only isolated changes, while the overall pace of reform lags behind the expectations of the public and our partners. The opening of the Fundamentals cluster could energize this process, since implementing the plan is a basic EU integration requirement. Whether these changes happen in time now depends on the political will within the country,” says Kateryna Ryzhenko, Deputy Executive Director of Transparency International Ukraine for Legal Affairs.

Goal 1. Criminal justice (2.5/20 — up 0.5)

• Government track: The draft law developed by the Ministry of Justice to deliver on elements of this point of the plan was sent back for revision following a meeting of the government committee. It is currently being refined together with the NABU and the NACP, but the document has still not been published for public consultation or registered in parliament.
• MP initiatives: Two draft laws have been registered in the Verkhovna Rada — No. 15333 (on improving the efficiency of proceedings after the expiry of pre-trial investigation deadlines) and No. 15334 (on improving investigative jurisdiction and international cooperation).

Goal 2. Ensure that NABU has effective access to impartial, timely and high-quality forensic examinations (2/10 — up 1.5)

Providing the NABU with effective access to impartial and timely examinations is still stalled by the lack of a shared vision among the agencies.

• The Ministry of Justice has begun work on amendments to the Law on Forensic Examination to strengthen safeguards for forensic examination activities.
• The NABU has submitted its comments, but significant disagreements remain between the ministry and the Bureau over the concept for establishing such an expert institution.

Goal 7. International experts in the HQCJ selection (1.5/10 — up 0.5)

The issue of expanding international experts’ participation in the Selection Commission for members of the High Qualification Commission of Judges (HQCJ) remains frozen.

• Draft Law No. 13382, intended to restore international experts’ participation in selecting HQCJ members, has been stalled in the Verkhovna Rada since June 2025.
• According to the Cabinet of Ministers, another legislative initiative has now been drafted and is undergoing consultations with the European Commission. This document has not yet been officially registered or published.

Goal 9. Adopt the Anti-Corruption Strategy and the SAP by the end of June 2026 (1.5/5 — up 1)

The plan required the Anti-Corruption Strategy and the State Anti-Corruption Program (SAP) to be adopted by Q2 2026, but the deadlines have already been missed.

• Blocked in parliament: Three competing draft laws are awaiting consideration in the relevant parliamentary committee. The most ambitious, and the one consistent with EU integration requirements, is Draft Law No. 15230 from the head of the Anti-Corruption Committee.
• SAP delay: The State Anti-Corruption Program was developed in parallel, but the NACP will release its draft for public consultation only after parliament finally votes on the Strategy.

Goal 10. Strengthen internal control and whistleblower protection (1/10 — up 0.5)

There are already initial practical steps in building up internal control and efforts to adapt the Ukrainian system to European standards, although the core legislative framework is still awaiting final approval. 

• The State Audit Service has stepped up its checks, Internal Audit Standards in line with the European GIAS requirements have entered into force, and a whistleblower portal is operating, though it still needs technical improvements.
• Several strategic goals have been incorporated into Draft Laws No. 15230, No. 15230-1, and No. 15230-2, On the Principles of State Anti-Corruption Policy for 2026–2030, which are currently awaiting consideration in the relevant committee.

Other goals of the plan: the overall picture according to experts

In the other reform areas reviewed, the situation also remains unsatisfactory:

• Selection of the Prosecutor General (0.5/10 — up 0.5): there has been virtually no progress in revising the competitive selection procedures, with only one MP draft law registered.
• Selection for senior positions in the prosecution service (0.5/10 — no change): transparent competitive appointments have still not been restored, and new government initiatives risk dragging out the process through lengthy consultations.
• SBI reform (1/10 — no change): the relevant draft laws have not been presented for broad discussion, creating the risk that new leadership will be selected under the old procedures.
• New CCU judges and HCJ members (1/5 — no change): the competitive procedures are continuing with delays, and key vacancies under certain quotas remain unfilled.
• Judicial integrity and enforcement proceedings (3.5/10 — up 1.5): the legislation adopted does not take into account the EU’s recommendations on checks of the integrity declarations of Supreme Court judges, although there is some positive movement on digitalizing enforcement procedures.

This baseline evaluation covers the “Kachka-Kos plan” — a set of equivalent reforms defined in December 2025. Alongside Transparency International Ukraine, which focused on key anti-corruption areas, the study involved the MEZHA Anti-Corruption Center, European Pravda, the ANTS National Interests Advocacy Network, DEJURE Foundation, New Europe Center, Centre of Policy and Legal Reform, and the Anti-Corruption Action Centre.