Analysis of the Rule of Law Roadmap: Anti-Corruption Aspects

On 15 May 2025, the Government Office for the Coordination of European and Euro-Atlantic Integration announced on its Facebook page that on 14 May, during its meeting, the Cabinet of Ministers of Ukraine reviewed and approved the final Road Map in the area of “Rule of Law,” prepared by the Ministry of Justice of Ukraine in cooperation with other relevant state authorities. Among other things, the Road Map addresses matters covered by Negotiating Chapter 23 – Judiciary and Fundamental Rights, and Chapter 24 – Justice, Freedom and Security, and is intended to be implemented through the end of 2027. The Rule of Law Road Map constitutes a prerequisite for opening negotiations under Cluster 1: The Fundamentals of the Accession Process (Fundamentals).

Below is the analysis of this Road Map by Transparency International Ukraine.

Anti-Corruption Reform

Strategic and Institutional Foundations of Anti-Corruption Policy

A positive development in the final version of the Road Map is the incorporation of several recommendations previously provided by Transparency International Ukraine. In particular, it envisages the introduction of accountability mechanisms for responsible authorities in cases of unjustified failure to implement anti-corruption policy measures; it also removes an indicative target of 40% implementation of the future Anti-Corruption Strategy and State Anti-Corruption Programme (SAP), which was inconsistent with the essence of strategic planning; and it further elaborates the approach to anti-corruption analysis in areas vulnerable to corruption — providing for its continuous application and defining a list of priority sectors.

However, some of the proposals remain unaddressed or have only been partially implemented. Namely:

• The mechanisms for assessing a “high level of implementation” of the Anti-Corruption Strategy have not been specified. It would be appropriate here to define this as the timely and full implementation of at least 90% of the measures (excluding those whose relevance has been justifiably lost or up to 10% of measures that did not receive funding).
• The mechanisms for incentivizing or applying disciplinary measures to the heads of bodies responsible for implementing the SAP have not been detailed. This could include the introduction of specific goals and key performance indicators, performance-based bonuses, binding precepts from the NACP, disciplinary measures in cases of systemic deficiencies, and so on.

Corruption Prevention

Following the consultations held, the content of the relevant section of the Road Map was significantly revised. It now offers more comprehensive coverage of conflict of interest regulation and electronic asset declaration. However, several implementation deadlines remain unrealistic, as illustrated by the key examples outlined below.

A notable improvement compared to the initial version of the document is the increased focus on the need for the NACP to adopt bylaws regulating the agency’s inspection powers, reflecting the recommendations of TI Ukraine. This should help limit the excessive discretion currently retained by the NACP, especially in the areas of lifestyle monitoring and conflict of interest, where there is still no system for automatic case distribution and no established procedure for verifying compliance with anti-corruption restrictions. Moreover, the Road Map shifts the focus from formal declaration checks to a comprehensive evaluation of the financial control system’s business processes, aligning with the European Commission’s conclusions in the Enlargement Package for Ukraine. Another positive development is the reference to improving lobbying legislation to increase the effectiveness of related regulation.

At the same time, a number of provisions remain in need of further refinement:

a) Legislative framework in line with international standards

The measure concerning the review of draft laws for compliance with the EU acquis and international standards (GRECO, OECD, UNCAC) does not include a reference to the need for adequate funding to carry out such reviews. Instead, it merely specifies the requirement for “effective analysis.” Furthermore, the measure on implementing international recommendations would benefit from the inclusion of an obligation to ensure their timely execution.

b) Independence, capability, and accountability of the National Agency on Corruption Prevention

In the context of ensuring the NACP’s access to adequate resources, it would be appropriate to provide for the introduction of transparent and objective recruitment processes, including through amendments to the agency’s internal procedures.

The development of the NACP’s institutional development strategy should also require broad consultations with relevant stakeholders. Also, the term “capacity” would be more appropriate than “capability” in the title of this section, to ensure terminological consistency throughout the Road Map, particularly since “capability” has a different legal meaning in relation to legal entities under Article 92 of the Civil Code of Ukraine.

The measure concerning the enhancement of internal control within the NACP does not specify the need for clear and objective performance indicators, nor does it mention the necessity of staff training based on a proper needs assessment.

c) Conflict of interest and related regulation

The measures related to legislative amendments introducing the concept of “apparent” conflict of interest, as recommended earlier by the European Commission, do not clarify the category of persons to whom such regulation would apply. Ideally, it should cover top public officials in high-risk positions, without being excessively extended to other groups. At the same time, a risk-based approach should be introduced in the monitoring of conflicts of interest — a component currently missing from the respective measure in the Road Map.

d) Asset declarations by public officials

This Road Map should also include provisions not for reviewing, but for lowering the thresholds for administrative and criminal liability for illicit enrichment and false asset declarations, as well as for extending the statute of limitations for such declarations. 

Interagency cooperation during financial control measures could be strengthened by involving the State Tax Service and the State Financial Monitoring Service as co-implementers. Furthermore, the expansion of access to foreign data for enhanced verification of declarations should be specified, including through the conclusion of relevant international agreements and revision of national legislation on the NACP’s powers.

Measures to improve internal NACP procedures for declaration verification do not provide for transparency, alignment with current legislation, or public consultation on the proposed amendments.

The measure aimed at ensuring up-to-date data on the identification of individuals and objects collected in official registries and databases lacks requirements regarding data quality and omits the need to introduce procedures for the rapid correction of errors in such information systems.

e) Lobbying

The implementation timelines for measures in this section, especially those related to launching the Transparency Register, are inconsistent with the Law of Ukraine “On Lobbying.” Moreover, all future regulatory amendments in the area of lobbying should include broad consultation with stakeholders, which is currently missing. An analysis of the identified gaps in the lobbying system, intended to inform further legislative changes, should be made public — a requirement that is currently missing from the Road Map.

f) Whistleblower protection

The law on whistleblower protection, based on the “broad definition” of a whistleblower, should align not only with Directive (EU) 2019/1937 but also with best international practices, since the Directive establishes only minimum standards. The law’s development must be accompanied by extensive stakeholder engagement and should begin no later than the fourth quarter of 2025 (in line with the SAP), rather than in the second quarter of 2027.

Protection guarantees should be extended to individuals mistakenly identified as whistleblowers, as well as to those who disclose restricted information, including state secrets. However, the final version of the Road Map removed previously included language that provided for such protection guarantees. 

The measure concerning the improvement of the Unified Portal of Whistleblower Reports should avoid the phrase “facilitating the submission of reports,” since the appropriate term in this context is “disclosures.”

Liability for Corruption Offenses

a) Independence, efficiency, capacity, and accountability of the National Anti-Corruption Bureau, the Specialised Anti-Corruption Prosecutor’s Office, and the High Anti-Corruption Court

A positive aspect of the approved Road Map is the significantly improved specificity of measures aimed at strengthening the NABU, SAPO, and HACC. The document clearly outlines the necessary steps to enhance the institutional capacity of these anti-corruption bodies. Notably, the Road Map provides for the filling of judicial vacancies at the HACC with the involvement of the Public Council of International Experts — an important element in maintaining public trust in the selection process.

Another positive feature is the inclusion of measures aimed at ensuring appropriate premises for the HACC, as well as adequate financial and human resources, and competitive remuneration for staff of the anti-corruption institutions, all of which are critical to safeguarding their independence.

At the same time, several recommendations to further enhance the institutional capacity of these bodies remain unaddressed. For example, while the Road Map provides the SAPO Head with the authority to independently initiate extradition requests and form joint investigation teams, it fails to incorporate the proposal to grant the SAPO Head the power to initiate proceedings and approve investigative actions concerning Members of Parliament — a measure that could strengthen the effectiveness of anti-corruption efforts.

A positive addition is the inclusion of measures for full integration of the electronic criminal case management system (e-Case) with the Unified Judicial Information and Communication System (UJICS) and for enabling procedural communication among parties through this system.

In general, although the Road Map includes a substantial number of measures aimed at institutional strengthening, certain critical elements for improving the operational efficiency of anti-corruption bodies and streamlining procedures for investigating and adjudicating corruption cases require further detail.

b) Grounds and procedural aspects of liability for corruption and corruption-related offenses

The section of the Road Map addressing the grounds and procedural aspects of liability for corruption offenses shows significant improvements. Among the positive developments is the inclusion of measures aimed at improving statutes of limitations and procedural oversight in corruption cases. In particular, the Road Map foresees the extension of limitation periods and the revision of grounds for their suspension and termination — an important step in ensuring the inevitability of punishment for corruption crimes.

A major advancement is the inclusion of provisions eliminating the automatic closure of high-level corruption cases upon expiration of pre-trial investigation deadlines — consistent with the proposal to remove the requirement for mandatory termination of criminal proceedings due to expired deadlines for pre-trial investigation.

Another positive development is the plan to improve legislation on the liability of legal entities for corruption offenses, which includes expanding autonomous liability and defining effective, proportionate, and dissuasive criminal-law sanctions, both financial and non-financial.

Nonetheless, several gaps remain in the Road Map. Specifically, there are no concrete measures to enhance criminal liability for obstruction of corruption investigations. Moreover, insufficient attention is given to systemic analysis of the performance of anti-corruption bodies, including monitoring the length of investigations, reasons for delays, grounds for case closures, and instances where evidence is ruled inadmissible.

The Road Map also lacks specific legislative amendments aimed at eliminating procedural bottlenecks and enhancing the efficiency of criminal proceedings in cases involving top officials. Proposals to allow judicial proceedings to continue after a judge is replaced without the consent of the parties, to establish liability for procedural abuses, and to adopt a balanced approach to suspending proceedings due to a person’s mobilization were not taken into account.

A significant shortcoming is the deferral of key reforms until 2027, which may hinder the pace of systemic development. For example, legislative amendments aimed at ensuring proportional and effective criminal sanctions are scheduled for adoption only in the second quarter of 2027, which appears unnecessarily remote.

Overall, despite substantial progress in the formulation and specification of measures, there is a need to accelerate implementation timelines, close outstanding gaps, clarify certain provisions, and supplement the Road Map with actions to ensure systematic analysis of law enforcement effectiveness in the anti-corruption area.

c) Track record

The updated “Track Record” section in the approved Road Map demonstrates significant progress in formulating measures aimed at improving the performance of anti-corruption institutions. A positive clarification is the inclusion of the State Financial Monitoring Service of Ukraine among the implementing parties for the measure on effective inter-agency cooperation, reflecting TI Ukraine’s recommendations.

An important step is the inclusion of a measure to establish a coordinated system for the collection, analysis, and publication of statistical data on pre-trial investigations, indictments, and adjudication of corruption offenses and high-profile corruption cases. However, this only partially addresses the recommendation to enhance analytical work by anti-corruption bodies. 

At the same time, the implementation deadline for this measure (the fourth quarter of 2026) appears excessively distant, given its importance for assessing the overall effectiveness of the anti-corruption system. Introducing such a monitoring system at an earlier stage would help identify and remedy systemic weaknesses more swiftly.

The Road Map does not reflect proposed measures to develop and implement a system for monitoring investigation duration, causes of procedural delays, reasons for case closures, or the prevalence of inadmissible evidence. The absence of such a system may hinder the identification of structural problems and the development of methodological guidance for improving investigative practices.

The Road Map also overlooks the proposal to track the effectiveness of asset confiscation (the ratio between the value of identified assets and assets actually confiscated), a key indicator of anti-corruption performance. While this issue is indirectly referenced under a general measure on data collection and analysis, the current wording may not yield the expected results. For example, the NACP, the SJA, and the Prosecutor General’s Office are listed as implementers, yet past TI Ukraine research has revealed inconsistencies in data maintained by the PGO and NABU, while the HACC produces its own statistical reports, as the SJA is not responsible for its reporting.

In conclusion, despite notable improvements to the “Track Record” section, further specificity is required in some measures, and timelines should be shortened to ensure the timely assessment of the effectiveness of Ukraine’s anti-corruption system.

Audits of the Activities of Specialized Anti-Corruption Bodies

The section of the approved Road Map concerning audits of the activities of specialized anti-corruption bodies has undergone positive changes and demonstrates a balanced approach to ensuring their independence, capacity, and accountability. This section includes key measures aimed at ensuring effective external oversight of anti-corruption institutions.

A significant improvement is the inclusion of a measure to adopt and implement legislation for optimizing the procedures for external independent evaluations of the performance of anti-corruption bodies. This measure is aimed at addressing identified shortcomings and incorporating best practices, which could significantly enhance the quality and effectiveness of audits. However, in the course of implementation, it will be important to ensure that the legislator does not undermine the progress already achieved in regulating the external audit system.

Particularly noteworthy is the requirement to promptly adopt and implement action plans for the execution of recommendations resulting from external independent evaluations of anti-corruption bodies. Importantly, such plans must be developed through public and expert consultations to ensure that they reflect actual needs and public expectations. 

At the same time, the revised Road Map does not reflect recommendations to amend the NABU Law to allow for less frequent external audits, rather than conducting them annually. Given the duration and resource intensity of audit procedures, such changes could help optimize the process and reduce the administrative burden on anti-corruption bodies.

Overall, this section of the Road Map establishes an adequate framework for conducting independent audits of anti-corruption bodies and for ensuring the implementation of audit recommendations. 

Judicial Cooperation in Criminal Matters

The section “Judicial Cooperation in Criminal Matters” of the approved Road Map outlines a comprehensive set of measures aimed at harmonizing Ukrainian legislation with EU law in the field of mutual legal assistance. The Road Map sets out the sequence for implementing key EU framework decisions related to the European Arrest Warrant, resolution of jurisdictional conflicts, and mutual legal assistance mechanisms.

A positive aspect is the inclusion of a measure to align legislation on mutual legal assistance and extradition with FATF standards, scheduled for the fourth quarter of 2025. This partially reflects the recommendation to improve the legal framework on international cooperation.

However, the analysis reveals that the section fails to incorporate a key recommendation to develop and adopt draft legislation establishing procedures for the recognition and enforcement of Ukrainian court decisions on asset confiscation abroad. It also lacks a focus on setting clear deadlines for the execution of mutual legal assistance requests and on regulating procedures for concluding and implementing asset allocation agreements. These aspects are essential for the effective recovery of assets obtained through corruption-related offenses.

In addition, the recommendation to establish an electronic system for monitoring the execution of mutual legal assistance requests and decisions on asset confiscation remains unaddressed. While the Road Map provides for the introduction of a digital automated system within the Ministry of Justice to manage and track international legal cooperation cases, the current wording is general in nature and does not emphasize the monitoring of deadlines, tracking grounds for refusal, or analyzing the effectiveness of international cooperation.

A significant portion of the measures under this section are scheduled for implementation only in the fourth quarter of 2026 or 2027. Such extended timelines may hinder Ukraine’s integration into the EU legal space and delay the timely application of effective international cooperation tools in combating corruption. 

Combating Organized Crime

The section “Combating Organized Crime” in the approved Road Map reflects significant improvements compared to the previous draft. It proposes a systemic approach to reform in this area, including institutional support, clarification of the division of powers among law enforcement bodies, and strengthening their capacity to counter organized crime. 

A positive development is the inclusion of a measure establishing disciplinary liability for conducting investigations in violation of jurisdictional rules. The Road Map also acknowledges the need to develop an interagency guideline on cooperation among pre-trial investigation bodies in resolving jurisdictional issues, although TI Ukraine’s proposal was partially modified and presented as a “clear procedure for transferring criminal proceedings from one investigative body to another.”

Despite these improvements, several outstanding issues remain unresolved. Notably, recommendations to amend the appointment procedure for the head of the SBI and to introduce a competitive selection process for the Prosecutor General were not incorporated. Regarding the leadership of the National Police of Ukraine, while the introduction of competitive selection is foreseen, the establishment of selection commissions with international experts holding a decisive vote is not envisaged.

The measure on improving the application of criminal-law remedies to legal entities is also insufficiently formulated. The Road Map limits this measure to the contexts of drug trafficking and human trafficking, whereas a comprehensive improvement of the system was recommended. Furthermore, it employs terminology typically used for individuals, such as “conviction” and “punishment,” rather than legal entities.

The Road Map also fails to place sufficient emphasis on establishing an electronic system to monitor the application of criminal-law remedies, which would support the evaluation of their effectiveness. Although improvements in statistical reporting on investigations, prosecutions, and judgments in serious crime cases are foreseen, this is not a substitute for a dedicated monitoring system.

A significant number of measures are scheduled for the fourth quarter of 2026 or 2027, which may slow the pace of reform and hamper the near-term effectiveness of organized crime prevention efforts.

Overall, while the Road Map demonstrates notable progress in the approach to combat organized crime, further specificity is required in areas such as transparent selection of law enforcement leadership, evaluation of the effectiveness of criminal-law instruments, and shortening the timelines for implementing key measures. 

b) Financial investigations

The “Financial Investigations” section of the approved Road Map reflects a weighted approach to improving mechanisms for detecting, investigating, and prosecuting criminal offenses related to illicit income. A key positive aspect is the inclusion of a measure to establish a Unified Register of Accounts of Individuals and Legal Entities, aimed at aligning national legislation with EU Directives 2015/849 and 2019/1153.

An important step is the planned development and adoption of a Financial Investigation Strategy targeting crimes related to illicit income, which is expected to form the foundation for a systematic approach in this area. However, the Road Map does not provide details on the content of this Strategy, such as a comprehensive analysis of the current state and effectiveness of financial investigations, the identification of key money laundering schemes, or the determination of priority areas based on risk assessments.

The section includes measures to strengthen the institutional capacity of law enforcement and prosecution bodies for conducting financial investigations, including the development of methodological guidelines and the creation of specialized investigative teams. It also foresees the recording of financial investigations in the Unified Register of Pre-Trial Investigations, contributing to better monitoring and analysis of their effectiveness.

Nonetheless, the Road Map lacks clarity regarding methodologies for conducting financial investigations into non-predicated money laundering, including approaches for proving the illicit origin of assets without the need to establish a specific predicate offense, coordination mechanisms between financial intelligence units and pre-trial investigation bodies, and the introduction of specialized investigators and prosecutors.

c) Criminalization and investigation of money laundering

The section “Criminalization and Investigation of Money Laundering” in the approved Road Map places considerable focus on harmonizing national legislation with EU regulations. It includes the development and adoption of a law to align Ukrainian legislation with Directive (EU) 2018/1673, as well as ongoing monitoring of the EU acquis in this area and the implementation of amendments in line with Directives 2015/849, 2018/843, and 2024/1640.

A positive change is the inclusion of measures to improve coordination and information exchange between the State Financial Monitoring Service and law enforcement agencies, in particular, the implementation of a pilot project with the National Anti-Corruption Bureau to exchange information via electronic communication channels.

Another important element is the inclusion of measures to ensure effective pre-trial investigations and timely judicial proceedings in money laundering cases, aimed at ensuring reliable tracking of final verdicts. The Road Map also includes provisions for developing and adopting a regulatory framework for virtual assets in line with FATF standards and the EU acquis.

However, certain important aspects remain underdeveloped. In particular, the Road Map does not specify practical mechanisms for detecting and investigating complex money laundering schemes, especially those involving modern financial technologies and cryptocurrencies. Nor does it provide details on measures to strengthen international cooperation in countering cross-border money laundering.

It is also important to ensure that the responsible authorities do not artificially generate a “Track Record” in money laundering cases by entering into plea agreements or applying suspended sentences solely to improve statistical indicators, without effectively targeting high-risk areas.

It is worth noting that many of the planned measures are scheduled for implementation in 2026–2027, which may delay their practical impact. 

Overall, while the sections demonstrate considerable progress in the approach to financial investigations and anti-money laundering efforts, they require greater specificity regarding methodological aspects and shorter implementation timelines for key measures.

d) Confiscation, freezing of assets, and financial sanctions

The section “Confiscation, Freezing of Assets, and Financial Sanctions” in the approved Road Map reflects a comprehensive approach to improving the asset management system for seized and confiscated property. The Road Map outlines important steps to strengthen the institutional capacity of the Asset Recovery and Management Agency (ARMA).

A positive aspect is the intention to reform ARMA through the adoption of a dedicated law that would establish a clear and transparent procedure for selecting the agency’s head, introduce an independent external evaluation system, and ensure transparent procedures for management and sale of seized assets. This aligns with international standards and should improve the agency’s effectiveness. However, Parliament has yet to adopt this law.

An important measure is the development and adoption of a law to align national legislation with Directive (EU) 2024/1260 of the European Parliament and of the Council of 24 April 2024 on asset recovery and confiscation. This reflects a commitment to bringing Ukraine’s asset management system in line with the EU’s latest standards.

Additional measures aim to improve the functioning of the “Unified State Register of Assets Seized in Criminal Proceedings” to enhance transparency and efficiency in asset management, as well as to ensure standardization, maintenance, and publication of statistical reports on asset freezing and confiscation.

Nonetheless, several important recommendations remain unaddressed. These include proposals to prohibit blocking asset management based on decisions by non-criminal courts; eliminate the requirement for the manager of corporate rights to coordinate actions with the owner; and introduce a mechanism for joint planning of asset management between ARMA and law enforcement bodies.

The Road Map also does not address the introduction of “extended” confiscation with a differentiated approach to proving the criminal origin of assets, the possibility of seizing assets to secure such confiscation, or the establishment of clear timelines and transparent procedures for enforcing confiscation decisions. These issues may be partially addressed through the implementation of Regulation (EU) 2018/1805 and Directive 2024/1260.

Some measures, including the development and adoption of legislation to align with Directive 2024/1260, are scheduled only for the second quarter of 2027, which may delay progress in asset confiscation reform.

In general, while the section shows substantial progress in the approach to confiscation, it would benefit from additional detail regarding asset management mechanisms, broader grounds for confiscation, and faster implementation of key reforms.

Anti-Corruption Mainstreaming in Public Procurement 

One of the strategic outcomes in the fight against corruption envisages the application of anti-corruption measures in the area of public procurement to effectively address corrupt practices and risks. The Road Map outlines two procurement-related measures under this section.

First, it proposes to reduce the use of non-competitive procurement procedures (permanently) and to strengthen integrity requirements in public procurement, including exclusion criteria for participants. The Ministry of Economy is designated as the responsible authority, with a deadline set for the end of the third quarter of 2027.

The word “procedure” is likely redundant here, as the term “non-competitive procurement procedure” refers specifically to the negotiated procedure, which is currently not used during wartime. The Road Map developers probably meant reducing non-competitive procurement in a broader sense — namely, legislative exemptions that allow procuring entities to sign direct contracts without any procedures. This interpretation aligns with the EU’s assessment of Ukraine’s procurement legislation against the requirements of the EU directives.

Second, it foresees an increase in transparency and public engagement in reconstruction planning, project selection and prioritization, and procurement. This measure is to be implemented by the Agency by the end of 2025.

The section also emphasizes the importance of preventing corruption in defense procurement. However, it does not contain any specific measures directly addressing this area.

It is worth noting that measures under this section should be relevant and feasible across all sectors of public life undergoing reform in connection with EU alignment. In our view, the first measure is somewhat limited in scope and, on its own, insufficient to “effectively address corruption risks.” Moreover, the Road Map does not clarify whether it refers to a quantitative reduction in the volume of such procurement transactions or to a narrowing of the list of grounds for their application.

In our opinion, it would be more appropriate not only to revise the grounds for such direct contracts, but also to introduce clear pricing rules for non-competitive procurement procedures.

While the first measure was supplemented with provisions to strengthen integrity requirements, we believe this enhancement risks being implemented through formalistic approaches in practice and may prove insufficient as a safeguard against abuse.

The second measure on reconstruction transparency lacks specificity and verifiable indicators for assessing implementation. Furthermore, it raises questions as to its relevance across all sectors simultaneously.

Public procurement reform should include a revision of procurement monitoring approaches by state financial control bodies. Such monitoring should primarily occur before the contract is concluded, with mandatory monitoring categories clearly defined and procedures for addressing the specified violations.

Overall, public procurement warrants a dedicated section in the future Anti-Corruption Strategy and State Anti-Corruption Programme, with clear goals and measurable indicators covering both civilian and defense procurement.

We believe that such measures would have a broader and more effective impact on the sector than those currently included in the Road Map, and their implementation could be assessed both qualitatively and quantitatively. Nevertheless, the proposals outlined above were not taken into account in the Road Map.

Conclusions

The approved Road Map for Ukraine’s European integration in the areas of criminal justice and corruption prevention demonstrates significant progress and reflects a degree of cooperation between state institutions and civil society. Several proposals from Transparency International Ukraine were taken into account, which positively influenced the quality of the document. In particular, recommendations were reflected regarding the conduct of the HACC competition with the participation of the PCIE, the improvement of statutes of limitations and procedural oversight mechanisms in corruption cases, as well as the introduction of liability for prosecutors for violations of investigative jurisdiction.

At the same time, the omission of several key recommendations leaves room for further improvement of the Road Map. These include proposals to empower the head of SAPO to initiate proceedings and authorize investigative actions concerning MPs, to introduce a competitive selection process for the Prosecutor General, and to establish selection commissions with the participation of international experts for appointing law enforcement leadership. Proposals regarding the development of a monitoring system for the duration of investigations and court proceedings in corruption cases, improvement of asset management mechanisms, and the prohibition of blocking asset management through rulings by non-criminal courts were also not fully addressed. Measures in the area of public procurement also remain largely unchanged and could benefit from further refinement.

A particularly concerning aspect is that a number of critical initiatives are scheduled only for 2027, which may slow down the process of European integration and the reform of the criminal justice system.