Anti-Corruption Steps Ukraine Must Take in 2025

For almost three years, Ukraine has continued to fight back the enemy in a large-scale war. All these circumstances have not stopped us; they enhanced our efforts in the fight against corruption. 

Ukraine’s anti-corruption efforts in these years have not gone unnoticed. This, for instance, was mentioned by the European Commission in its latest 2024 EU enlargement report on Ukraine as a candidate country. But these steps, of course, are not enough. In the future, we will face many more challenges and the necessary complex changes. 

However, one way or another, the main task for us now is to ensure the resilience of the country, and therefore, to deal with reforms that can provide economic growth. Ukraine’s position in the future will depend on how skillfully we manage our resources and control costs.  

Therefore, Transparency International Ukraine is convinced that to strengthen our country, we must work primarily within three focus areas: the first two concern the streamlining of the Accounting Chamber (AC) and the improvement of the public procurement system; the third touches upon the anti-corruption system, namely, the operation of the Asset Recovery and Management Agency (ARMA).

Focus on costs control

Last year, together with partners, we explained the urgency of the need for Ukraine, even in conditions of war and uncertainty, to find internal opportunities for economic growth in a special report. The basis for such changes was laid by the Ukraine Facility Plan and the IMF program, and although Ukraine has already taken some steps to implement them, there are still many tasks to be fulfilled. In 2025, in our opinion, the country should focus on improving the operation of state financial control bodies and the effective and lawful distribution of funds, in particular through public procurement procedures. 

A full-fledged reform of the Accounting Chamber should become a priority nowadays because it is the key body for auditing the country’s finances. However, its control is still limited.  

State control of public finances should be a priority for the country in wartime because this is how the embezzlement of funds is prevented. Such a reform shall cover all key bodies at the same time to strengthen the system and increase the confidence of international partners. 

Actually, the reform of the Accounting Chamber has already started: on October 30, the Verkhovna Rada supported draft law No.10044-d, which considers most of the EU recommendations. But the adoption of the draft law is only the first step. It is important to put all the changes it envisages into practice.  

It is also essential to delineate the powers of the Accounting Chamber and the State Audit Service. The draft law did not cover this issue, but it needs to be resolved as soon as possible so that the bodies do not duplicate each other’s functions. 

Another issue is efficiency and control over the costs required for the functioning of the state. That is why it is necessary to improve public procurement. 

The welfare of Ukrainians depends on how the national budget is spent, but it is extremely difficult to ensure it in wartime. Since there is a catastrophic shortage of funds due to active defense, the sphere of public procurement shall ensure the efficient use of resources. 

In its 2024 report, the European Commission noted the modest progress of Ukraine in this area. The next step for it may be a new specialized law, and our experts will participate in its finalization. The purpose of legislative changes is to bring Ukrainian legislation closer to European standards, considering national realities. 

Another sub-sphere that should become our focus area is the control over public procurement. First of all, it is about increasing the effectiveness of monitoring—preventive procurement control measures conducted by the State Audit Service. However, approaches to these activities need to be reconsidered.  

Moreover, in wartime, reconstruction procurement will remain in focus. In particular, it is necessary to ensure their maximum transparency. TI Ukraine calls on procuring entities to publish documents for estimates in machine-readable formats to make it easier for businesses to participate in tenders. We also support the publication of service acceptance certificates because they allow the public and control bodies to see the real costs spent in reconstruction projects. 

At the same time, the Accounting Chamber and public procurement reforms are not limited by cost optimization and the effectiveness of cost control. For the quality recovery of the country and the fruitful filling of the budget, it is also important to balance the freedom of economic activity and reduce the impact of the shadow economy on the real sector. It is these tasks that necessitate the reform of the Bureau of Economic Security, which can both deter and stimulate the legal activities of enterprises. Increasing the efficiency and transparency of the State Tax and Customs Services responsible for filling the budget is key for the growth of domestic financial resources even under martial law.  

The Verkhovna Rada has already taken legislative steps towards part of these reforms, so now all we need is to implement them. Given that the implementation of changes is an equally significant step, it should be in the focus of additional control for the public and international partners.

What should be changed in the anti-corruption ecosystem? 

Many reforms can be carried out to achieve economic stability of the state, but without real rule of law and justice, we will not have tangible results. Justice institutions, law enforcement, anti-corruption ecosystem—these agencies can become a solid foundation that guarantees the protection of rights, freedom of economic activity, and liability for violations.  

The anti-corruption ecosystem has already been formed and is in active operation. However, there are still certain challenges that we need to work on. However, there is a problematic element—the ARMA. We consider the reform of this agency to be the third priority for the next year.  

The ARMA was established following the example of European offices for the recovery and management of assets. It was to become a compact, highly qualified body with great powers and a high level of independence. However, the current Agency does not meet these criteria at all. 

According to TI Ukraine experts, first of all, it is necessary to change the rules for selecting the head of the Agency. This is the only anti-corruption body in which the competition for the head does not comply with the existing best practices. It is also necessary to ensure adequate rules for the external independent audit of the ARMA because the Agency also lags behind other relatively new bodies in this regard.  

In addition, we need to ensure effective management of seized assets in criminal, including corruption cases. This, in particular, includes full planning before the transfer of an asset to the ARMA, clear regulation of manager selection, and the possibility to manage corporate rights.  

Other elements of the anti-corruption ecosystem are overall operational, although, surely, there is considerable room for development. In general, most news about suspicion notices concerning corruption often testify to the effective operation of the anti-corruption system, and not to the increase in bribery within the country. This is also indicated by the growth of the number of such investigations and the rise in the number of the HACC verdicts. As of December 18, 2024, the court has already issued 234 verdicts. So, the foundation has been laid, the system is operational; in the future, it only needs to be strengthened.

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Each of the steps we have mentioned requires additional resources, not even financial, but human resources.  

In this regard, it is worth mentioning that the parliament does adopt decisions on the necessary reforms, albeit not without surprises, but there are always issues at the level of implementation. At this stage, we often encounter a lack of resources, and above all human resources—people who could contribute to quality updates and changes in outdated and ineffective institutions. This applies not only to those who will head these bodies, but also to people who will surround them and implement changes. 

We have already done a lot, and there will be even more tasks and challenges ahead. They are much more difficult to implement and overcome during the war. However, Ukraine and Ukrainians have shown their ability to perform and achieve. 2025 may well become another step towards real improvement of the country.