Новини - Transparency International Ukraine

Operation Midas: What NABU and SAPO Chiefs Said at the Briefing

TI Ukraine — Tue, 12 May 2026 12:55:52 +0000

Kryvonos and Klymenko on pressure against experts, the new Midas episode, and whether the president features in the case

On May 12, 2026, NABU Director Semion Kryvonos and SAPO Head Oleksandr Klymenko answered journalists’ key questions about Operation Midas — including the latest development: suspicion notices served on former Presidential Office Head Andrii Yermak and new notices for former Deputy Prime Minister Oleksii Chernyshov and several others.

Klymenko opened by noting that the case is highly complex and multi-layered, and that to prevent information leaks, it was divided into several tracks handled by separate detective units that had no knowledge of each other’s findings — a deliberate response to the leak allegations NABU had faced in previous years. Klymenko himself served as the lead prosecutor in Operation Midas.

He also reported attempts by various individuals to pressure expert witnesses in the case, and called for the creation of an independent expert institution protected from such interference.

“The pressure on experts is a difficult issue. We have been communicating the need to establish an independent expert institution for quite some time to prevent such attempts,” Klymenko said. “Because even when we find expert institutions capable of processing this volume of material and conducting examinations, we don’t always manage to complete them — experts genuinely encounter unknown individuals who convey messages along the lines of: ‘Don’t think this will end with just the loss of your certificate.’”

This problem is long-standing and has been acknowledged at the highest political level — specifically in the joint communiqué of Taras Kachka and Marta Kos. Furthermore, the Ministry of Justice has drafted a forensic expertise reform bill, which as of February 2026 had been submitted for approval.

Klymenko also cited difficulties arising from the State Financial Monitoring Service, which he said has been engaging in a work-to-rule slowdown — failing to respond to requests and providing documents of no investigative value. “They imitate activity but don’t actually engage with the investigation,” he added.

On Andrii Yermak, Klymenko stated that SAPO will seek pre-trial detention with a bail alternative of UAH 180 million.

More broadly, Kryvonos and Klymenko noted that the case extends beyond the energy sector to the defense sector, including investigations into drone and weapons procurement. NSDC Secretary Rustem Umerov has been questioned in this context but currently holds witness status.

Semion Kryvonos stated that the President of Ukraine has not featured and does not feature in this case.

On Andrii Yermak, Klymenko stated that SAPO will seek pre-trial detention with a bail alternative of UAH 180 million.

The post Operation Midas: What NABU and SAPO Chiefs Said at the Briefing first appeared on Transparency International Ukraine.

The Mindich Tapes: Did SAPO’s Former Deputy Head Have Unauthorized Access to the Case?

Павло Демчук — Fri, 08 May 2026 14:25:14 +0000

Ukrainska Pravda has published the third installment of the so-called “Mindich tapes.” Two of its segments concern Andrii Syniuk directly — at the time, Deputy Head of the Specialized Anti-Corruption Prosecutor’s Office. These details add new dimensions to the story of how this case has been investigated.

First, the suspects refer to Syniuk as a “good contact” inside the SAPO.

In a conversation between Myroniuk and Basov on September 25, 2025, Syniuk is described as a source ready to “help and tip them off.” The context suggests they are referring to “old friendly ties” with someone called “Oleh,” and they agree that this resource should be saved “for a rainy day” — kept for exceptional situations, not spent on routine matters. The conversation does not make clear which “Oleh” is meant, but journalist Mykhailo Tkach points to the portfolio of Oleh Tatarov, who oversees the law enforcement system within the Office of the President. Investigators should look into this further.

Second, Syniuk’s activity in the internal pre-trial investigation system on October 16, 2025 is on the record.

According to case files obtained by UP, Syniuk, who was not part of the group of prosecutors handling the relevant criminal proceedings, used his personal access credentials to look up participants in certain cases. The names he checked include Tsukerman, Halushchenko, Hrynchuk, and Jakob Hartmut, as well as Myroniuk and Basov themselves — the same two who, three weeks earlier, had discussed Syniuk as a useful contact at SAPO. According to the published data, the former SAPO Deputy Head ran this check a month before Operation Midas was publicly announced.

Third, the circumstances of the suspects’ departure on the eve of the searches come into focus from a different angle.

On October 26, ten days after Syniuk reviewed the data on case participants, Tsukerman’s assistant, on his boss’s instruction, arranged an urgent trip for him via Palanka to Vienna. The main suspect in the case, Timur Mindich, crossed the border at 2 a.m. — four hours before investigators arrived at his home with a search warrant. Both suspects have stated in their comments that the trips had been planned in advance.

Andrii Syniuk himself, in a November 2025 comment to UP, denied any involvement in leaking information, stating that he was unaware of these cases, did not take part in the relevant meetings, and never examined any materials. The information published by UP casts doubt on those statements.

The official position taken by SAPO Head Oleksandr Klymenko on November 25, 2025 warrants a separate note. He publicly confirmed that during Operation Midas there had been at least two stages of information leaks, with criminal proceedings opened in each instance, but that SAPO did not pursue active investigative steps so as not to compromise the main operation.

However, Klymenko stated that SAPO sees no link between the people filmed meeting with Syniuk and the Midas case, suggesting they may be connected to a different investigation. This position should be weighed against what UP’s published materials already contain. After all, the record of Syniuk reviewing the participants in the Midas proceedings is itself criminal case material — not journalistic observation of meetings, which is what Klymenko’s response relied on.

Pavlo Demchuk

What do these new details from the Mindich tapes mean?

Andrii Syniuk resigned from the SAPO at his own request back in November last year, right after NABU released the first “Mindich tapes.” As a result, the question of his disciplinary liability as a prosecutor is off the table — a person who has been dismissed cannot be held to disciplinary account within the prosecutorial system.

This resignation, however, in no way closes the question of a criminal-law assessment of Syniuk’s actions. The published materials raise a fundamental question: did Andrii Syniuk disclose pre-trial investigation data he could access by virtue of his position as Deputy Head of the SAPO?

The Criminal Code provides for liability for precisely such conduct. Article 387 specifically addresses cases in which a prosecutor discloses such data, regardless of whether they were directly involved in specific pre-trial investigation.

We understand why, for tactical reasons and to safeguard the main operation, the SAPO chose not to actively investigate the criminal proceedings opened over the leaks. But following the May 8 journalistic disclosures concerning Operation Midas, we — now as outside observers — see substantial grounds for a criminal-law assessment of Andrii Syniuk’s actions.

We therefore expect the NABU and the SAPO, in the course of the criminal proceedings, to establish whether Andrii Syniuk did in fact pass case information to the suspects — including data he obtained through the anti-corruption agencies’ internal systems. Given the public interest, we also expect those findings to be made public as soon as doing so no longer risks the investigation.

The published materials raise a fundamental question: did Andrii Syniuk disclose pre-trial investigation data he could access by virtue of his position as Deputy Head of the SAPO?

Pavlo Demchuk

The post The Mindich Tapes: Did SAPO’s Former Deputy Head Have Unauthorized Access to the Case? first appeared on Transparency International Ukraine.

What’s Wrong with Ukrainian Cities’ Budgets: A TI Ukraine Study

Євгенія Семчук — Tue, 05 May 2026 07:40:28 +0000

None of the large Ukrainian cities under review crossed the “performance threshold” in managing funds and resources. Municipalities maintain financial governability and publish core documents, but often shut residents out of decision-making. The highest score was 60 of 100 — and even the leaders failed to combine quality resource management with genuine engagement of community residents.

Transparency International Ukraine’s Transparent Cities program has released the findings of a study that comprehensively assesses how ready municipalities are for European standards in public finance. Analysts examined two key dimensions: how effectively cities manage budget funds and property — and how openly they explain this to residents and engage them in decisions. Municipalities were assessed against 40 criteria: half covered the direct handling of resources (based on data from Open Budget, Prozorro, and Prozorro.Sale), the other half covered information availability and user-friendliness on city council websites.

The pilot sample included the city councils of 10 regional capitals (Dnipro, Zaporizhzhia, Kropyvnytskyi, Lutsk, Lviv, Odesa, Poltava, Kharkiv, Khmelnytskyi, Chernihiv) and Kyiv.

On average, cities met the requirements on budget transparency and effectiveness at just 44.4%. The highest score — 60 points — went to Dnipro, but even Dnipro fell short of a comprehensive approach to managing finances. Lutsk followed with 57 points, then Kyiv and Khmelnytskyi with 52. The lowest scores went to Chernihiv (21), Poltava (24), and Kharkiv (25).

“Cities show individual strengths, but they cannot combine them into a system. Dnipro is an example of performance without sufficient openness — the city had accurate budget planning and worked actively with the Prozorro and Prozorro.Sale systems, but did not publish a number of important documents and did poorly on engaging residents in the budget process. Lutsk is the opposite: it set up information availability, but did worse on the effectiveness of managing finances and communal property. The State Audit Service captured this, by the way,” noted Olesia Koval, Transparent Cities Program Manager.

On budget openness, cities averaged 43.3%. Lutsk and Khmelnytskyi each scored 30 of 46 possible points, while the lowest scores went to Poltava (2 points) and Chernihiv and Kharkiv (5 points each).

8 of 11 cities already provide a baseline level of budget openness, and most of them publish key documents: the decision on the 2026 budget (8 cities), lists of spending administrators, and quarterly reports (7 cities). Only three municipalities published the budget regulations, and only Kyiv, Odesa, and Khmelnytskyi published the current consolidated version of the budget. The quality of access to information remains uneven: Poltava has no budget section at all, while in Kharkiv and Chernihiv it is overloaded with dozens of pages, making navigation difficult even for informed users.

On the effectiveness of fund management, despite the war, Ukrainian cities maintain a basic level of financial capacity and demonstrate fairly high accuracy in budget planning: the average deviation of actual revenues from plan was just 3.08%. This means that technically, local budget management is stable and close to European standards.

All cities under review supplied contracting authority hierarchies for the BI Prozorro analytical resource and used Prozorro.Sale for municipal property leasing auctions. 9 of 11 municipalities also held small-scale privatization procedures on Prozorro.Sale and created a dedicated thematic section on public procurement.

At the same time, the level of resident engagement in budget processes is a cause for concern. No city published, in a dedicated budget section, the list of public proposals to the draft 2026 budget. Minutes of public hearings on the draft budget and the results of consultations with business on procurement are missing in 10 of 11 cities under review. They also failed to deliver a budget surplus in 2025.

The budget sector needs to function as an integrated system, where effectiveness and transparency reinforce each other. This is not only about using the capabilities of state IT systems, but about shifting the approach: the public must not be an audience for reports, but a full participant in planning — with access to data and real influence over decisions. The point is not to avoid external scrutiny, but to use it, and to treat oversight not as a threat but as a tool for improvement.

The Transparent Cities program will prepare recommendations for each city council from the study, to serve as roadmaps for improving how they actually work with public finance.

For cities not included in the pilot study, program experts have prepared a form that will help them assess independently how effectively and transparently they manage their finances and highlight the weaknesses that need to be addressed.

This research is made possible with the support of the MATRA Programme of the Embassy of the Kingdom of the Netherlands in Ukraine, and with the financial support of Sweden within the framework of the program on institutional development of Transparency International Ukraine.

Content reflects the views of the author(s) and does not necessarily correspond with the position of the Embassy of the Kingdom of the Netherlands in Ukraine or the Government of Sweden.

Cities show individual strengths, but they cannot combine them into a system. Dnipro is an example of performance without sufficient openness — the city had accurate budget planning and worked actively with the Prozorro and Prozorro.Sale systems, but did not publish a number of important documents and did poorly on engaging residents in the budget process.

The post What’s Wrong with Ukrainian Cities’ Budgets: A TI Ukraine Study first appeared on Transparency International Ukraine.

Procedure for ARMA’s Acceptance of Seized Assets for Management: Legal Analysis

TI Ukraine — Mon, 04 May 2026 09:31:55 +0000

A joint order issued by ARMA and the Office of the Prosecutor General has approved the Procedure for ARMA’s Acceptance of Seized Assets for Management.

This procedure is one of the key elements of secondary regulation needed to launch ARMA’s updated asset management model. It substantially supplements the previous asset transfer mechanism that existed before the ARMA reform law took effect, and it should ensure procedural compatibility between the actions of prosecutors and the Agency.

Transparency International Ukraine has already analyzed a number of secondary acts adopted to implement the updated law, so we are also providing an assessment of this regulation.

This procedure is one of the key elements of secondary regulation needed to launch ARMA’s updated asset management model.

How it used to be

Before Law No. 4503-IX took effect, the procedure for accepting assets was governed solely by the ARMA law, and only in general terms. The old model suffered from a number of problems, such as:

the absence of a unified mechanism for prior asset identification — the ARMA effectively accepted “whatever was offered” for management, with no opportunity to fully assess whether it could manage the asset effectively;
vague deadlines for accepting assets, which generated conflicts between prosecutors and ARMA over the moment of actual transfer and the shift of responsibility for the asset’s preservation;
the absence of a procedure for examining (inspecting) the asset with the participation of the prosecutor or persons authorized by them, which created the risk of accepting assets in poor condition for management without proper documentation.

Before Law No. 4503-IX took effect, the procedure for accepting assets was governed solely by the ARMA law, and only in general terms.

How it is now

The new Procedure introduces a substantially different model, built on the following key elements.

1. Asset identification as a precondition for acceptance

While the Procedure itself does not regulate identification (which is the subject of a separate secondary act), it does take its results into account. Paragraph 7 of Section I provides that, if the investigating judge’s ruling contains no reference to the transfer of the asset to ARMA management, the Agency conducts the asset’s identification at the prosecutor’s request to determine whether it can be managed effectively.

2. Clear deadlines for processing requests

Deadline	Action
Day of receipt	ARMA notifies the operators of asset registers of the seizure
No later than the next business day	ARMA’s senior management instructs the relevant units to prepare the documentation required to accept the asset for management — depending on its type
No later than the 3rd business day	Where necessary, the Agency notifies the Cabinet of Ministers of circumstances that allow for “exceptional” management of the asset (Article 21-1 of the Law)
No later than the 5th business day	ARMA officials carry out actions aimed at the actual acceptance of the asset depending on its type (inspect the asset, take on the status of account administrator at a depository institution, send payment instruction to a bank, etc.)
No later than the 10th business day	The prosecutor signs the acceptance and transfer certificate (for movable and immovable property, securities, and non-cash funds)
Extension up to 30 business days	Granted where there are obstacles to accessing the asset or its components

These provisions align with the third paragraph of Article 19(1) of the Law, which sets a general 10-day deadline for accepting an asset, with the option of extending it to 30 business days.

3. A differentiated approach based on asset type

For the first time, the Procedure provides detailed regulation of how an asset is accepted for management:

movable and immovable property — with mandatory examination (inspection) at the asset’s actual location, with the participation of persons proposed by the prosecutor;
securities — through the appointment of a securities account administrator and engagement with a depository institution;
non-cash funds — through payment instructions, with the option of placing them on a deposit account;
cash funds — through the cash desk of a state bank branch;
bank metals — through an individual safe deposit box at a state bank.

4. Asset examination as a mandatory element

Subparagraph 1 of paragraph 4 of Section II introduces a mandatory procedure for inspecting the asset with the participation of “at least one of the persons proposed by the prosecutor in the request” (an investigator, detective, or specialist). This is a fundamental innovation intended to ensure proper documentation of the asset’s condition at the moment of transfer and to reduce the risk of subsequent disputes between the prosecutor and ARMA over the asset’s condition at the time of acceptance.

5. The option to call in the police

The Procedure expressly grants ARMA Interregional Territorial Department staff the right to call in police officers, under a joint order issued by ARMA and the Ministry of Internal Affairs, “where there are reasonable grounds to believe that there is a threat to the life and health of individuals and to public safety.” This is an important safety safeguard, given that assets are often in the actual possession of suspects or persons linked to them.

For the first time, the Procedure provides detailed regulation of how an asset is accepted for management.

What problems may arise?

Overall, the greatest challenges are likely to arise where there are discrepancies between the actual and the legal condition of the seized property. Paragraph 6 of Section I of the Procedure provides that the prosecutor may submit proposals to the draft acceptance and transfer act within four business days, which ARMA must then review within one day. However, the Procedure does not specify what is to be done if ARMA rejects the prosecutor’s proposals. This creates a risk of “endless approvals,” where the 10-day deadline is formally observed, but the actual transfer of the asset drags on through iterative revisions, which is inconsistent with the very nature of seizure.

In addition, the Procedure assumes that an opinion on the feasibility of managing the asset already exists at the time of the prosecutor’s request. Yet it does not address the situation where, during the asset’s examination at its actual location, the property is found to differ substantially from the data on which that opinion was based.

There is also uncertainty regarding the timing of the actual asset inspection. For example, no rule covers the case where a person proposed by the prosecutor cannot participate within the timeframe set by ARMA, leaving it unclear whether the inspection may proceed in their absence, and if so, on what conditions.

The ARMA accordingly needs to work all of this out in cooperation with the prosecution authorities, and these issues can be effectively resolved by drawing on the general principles of criminal proceedings and the relevant departmental standards. Where needed, the Procedure can be amended to formally regulate ways of overcoming these challenges.

Overall, the greatest challenges are likely to arise where there are discrepancies between the actual and the legal condition of the seized property.

Conclusion

The Procedure for ARMA’s Acceptance of Seized Assets for Management, approved by the joint order of the ARMA and the Prosecutor General’s Office, is a necessary step in implementing Law No. 4503-IX. It closes one of the key gaps in the secondary regulation of the new model for handling seized assets.

At the same time, practice may reveal individual problems that will require amendments to some of its provisions, so the ARMA should monitor this and respond promptly — including by initiating changes to the regulations.

The Procedure closes one of the key gaps in the secondary regulation of the new model for handling seized assets.

The post Procedure for ARMA’s Acceptance of Seized Assets for Management: Legal Analysis first appeared on Transparency International Ukraine.

The President Must Dismiss All Those Involved in the Mindich Case

TI Ukraine — Thu, 30 Apr 2026 12:13:22 +0000

The tapes released as part of Ukrainska Pravda’s investigation contain new evidence of Timur Mindich’s influence over the government and point to signs of corruption that undermine trust in the entire decision-making system, particularly in the defense sector.

Mykhailo Tkach’s report shows that, after the first notices of suspicion were served in this investigation, the authorities underestimated the damage done by the scheme’s participants. And they did not do enough to remove those under investigation from their posts.

Below are the key challenges that, in our view, change the overall context of the entire investigation and the related government processes.

Mykhailo Tkach’s report shows that the authorities underestimated the damage done by the scheme’s participants.

1. New evidence of improper influence over the government

The tapes document specific instances where Timur Mindich gave direct instructions to then-Defense Minister Rustem Umerov. In particular, he asks Umerov to “sign off on the acceptance” of body armor that the state had refused to accept, and lobbies for the appointment of certain people to positions. The tapes also reference potential “summoning” of NBU Governor Andrii Pyshnyi to resolve matters required by those under NABU investigation.

All this points to preferential treatment for certain businesses because they have powerful patrons. It has limited the potential growth and development of Ukraine’s defense sector and once again exposed an institutional gap in which state bodies remain vulnerable to interference by outside actors.

The tapes document specific instances where Timur Mindich gave direct instructions to then-Defense Minister Rustem Umerov.

2. The tapes indicate Mindich’s direct involvement in defense company Fire Point

The released materials show that former Defense Minister Umerov considers Timur Mindich to be the actual owner of Fire Point — and Mindich is evidently one of the firm’s beneficiaries.

As the Public Anti-Corruption Council under the Ministry of Defense has stated, if this fact is confirmed, Fire Point will completely lose the ability to supply its products to Ukraine’s Defense Forces, because Mindich is under sanctions. It can therefore be assumed that Fire Point disclosed knowingly false information about its beneficiaries, and so, in the PACC’s view, may face a fine and be classified as a risky supplier.

This creates additional difficulties for Ukraine’s defense capabilities during wartime.

The released materials show that former Defense Minister Umerov considers Timur Mindich to be the actual owner of Fire Point.

3. Questions raised again about the Dynasty cooperative and the President’s inner circle

The released recordings have given us still more detail about the cottage complex being built in Kozyn, previously reported on by investigative journalists. It is now known that mansions in this complex were being prepared for, among others, former Deputy Prime Minister Oleksii Chernyshov, “Vova,” “Andrii,” and Timur Mindich. These facts have once again revived discussion of the Dynasty cooperative and renewed questions about the origin of funds for its construction.

These challenges reveal a deep distortion of the governance system and demand an immediate change of approach to prevent abuses. Despite the President’s public support for the investigation into the “Mindich case” and the dismissal of the Head of the Office of the President, the new data point to the suspect’s likely influence over NSDC Secretary Rustem Umerov.

Transparency International Ukraine calls on the President to remove from office all those involved in the scheme and to ensure transparency of decisions. The Office of the President’s selective reactions to the investigation not only strike at the state’s reputation but also undermine Ukraine’s internal capacity in wartime.

Transparency International Ukraine calls on the President to remove from office all those involved in the scheme and to ensure transparency of decisions.

The post The President Must Dismiss All Those Involved in the Mindich Case first appeared on Transparency International Ukraine.

HACC Competition: The First Candidates Will Receive Their Final Scores

TI Ukraine — Fri, 24 Apr 2026 09:10:28 +0000

On April 24, one of the final stages of the HACC judicial selection competition begins — dossier review and the interview.

At this stage, candidates will finally receive concrete scores assessing their competence, integrity, and ethics. The HQCJ will then compile the final ranking of winners from the 22 who cleared the PCIE filter.

The first to receive their scores today will be:

Mykola Pika
Tetiana Troian
Olha Pevna
Lesia Skreklia
Oleh Khamkhodera

On March 17, the PCIE and HQCJ concluded the largest-ever round of interviews with HACC judgeship candidates, which only 22 of 73 passed. Those interviews did not involve scoring — their sole purpose was to screen out candidates with obvious ethical or integrity issues.

The HQCJ interviews can award candidates up to 400 of the total 800 points — the other 400 were available earlier through the tests and practical assignment. The top exam scores so far belong to two sitting HACC judges applying to the HACC Appeals Chamber: Olena Tanasevych (372.22 points) and Kateryna Sikora (360.92 points).

To earn the maximum score at the HQCJ interview, prospective HACC judges will need to demonstrate strong social and personal competencies, and their background must show a record of integrity and professional ethics.

Notably, the largest share of those 400 points — 300 (for integrity and professional ethics) — is awarded to candidates up front, with deductions for each violation identified. If the total falls below 225 points, or if a violation is serious enough, the candidate is removed from the competition.

Several candidates still raise serious concerns on our side. We hope the HQCJ will pay due attention and assess them accordingly.

The HQCJ interviews can award candidates up to 400 of the total 800 points — the other 400 were available earlier through the tests and practical assignment.

The post HACC Competition: The First Candidates Will Receive Their Final Scores first appeared on Transparency International Ukraine.

How the 22 Prospective HACC Judges Were Selected

Павло Демчук — Fri, 24 Apr 2026 08:31:38 +0000

The material was prepared in co-authorship with Andriy Tkachuk, legal advisor to Transparency International Ukraine.

The cap on HACC judges was raised back in September 2023, yet the competition for new judges is still ongoing. It has now been launched for the second time, and this round looks far more likely to actually fill the bench.

In mid-March, the Public Council of International Experts (PCIE), together with the High Qualification Commission of Judges of Ukraine (HQCJ), wrapped up the largest interview stage in the history of HACC judge selection. For a full month, anyone interested could watch the live stream as 69 candidates faced pointed questions from the PCIE and HQCJ, trying to prove their integrity and professionalism.

Twenty-two candidates cleared the interviews (32% of all those who participated). The PCIE and HQCJ selected 16 sitting judges, 5 scholars, and 1 attorney. One caveat: the HACC will not actually gain 22 new judges but 19, since three of those who advanced are sitting judges of the HACC first instance applying to the Appeals Chamber — meaning their first-instance seats will also open up.

Still, 19 new judges will grow the HACC bench by nearly one and a half times — from 40 to 59 — filling 93.65% of the current vacancies. That is enough for Ukraine to meet its commitments under the Ukraine Facility Plan. It is a result worth taking pride in, as the expanded bench will make it easier for the HACC to deliver timely justice.

So how were these 22 judges chosen? Let us take a closer look.

19 new judges will grow the HACC bench by nearly one and a half times — from 40 to 59 — filling 93.65% of the current vacancies. That is enough for Ukraine to meet its commitments under the Ukraine Facility Plan.

A study in contrasts: systemic improvement vs. opaque scoring

Last year, only 7 candidates reached the interview stage. This time, 73 made it through to the PCIE and HQCJ. And the reason is not luck — it is systemic improvement of the competition procedures, a process TI Ukraine also contributed to.

The overall elimination rate at each stage of the qualification exam dropped from 43.3% to 13% in the repeat competition.

The main driver was the new rules introduced under Draft Law No. 12331-2. It reopened the competition to those who had previously failed, missed, or refused the qualification exam — 82 of 205 applicants, or 40% of the total.

The impact of these changes is clearest in the numbers: without the updated rules, we would have had 6 finalists instead of 22, since 16 of those who successfully completed interviews with the PCIE this year had already taken part in prior judicial competitions.

At the same time, the HQCJ chose not to lower the minimum thresholds for the Ukrainian statehood test and the cognitive ability (IQ) test below 75%. In the previous HACC selection round, it was precisely the difficult IQ tests at that high threshold that produced the heaviest attrition — eliminating 79 of 123 participants.

Instead of adjusting the threshold, the HQCJ changed the IQ test provider and, judging by the results, reduced the difficulty of the tests. The Commission apparently took a similar approach with the Ukrainian statehood test — the elimination rate there was the lowest at just 2.5%.

The most dramatic contrast, however, is at the practical assignment stage: only 14.1% failed this time, versus 84% in the 2025 competition. And we have no answer as to why, because the HQCJ ignored calls from civil society to publish the candidates’ written judgments from the practical assignment, along with criterion-by-criterion scoring by members of the examination board.

None of this would matter if HQCJ members had not then squandered the interview opportunity to ask candidates — at least 8 times — about serious errors in their practical assignments. For example, Olena Roik was asked why her judgment convicted the defendant of a more serious offense than the one charged, and Ihor Omelian was asked why his sentence in a false declaration case ordered the convicted person to file an amended declaration. Equally puzzling were the questions about why Yevhen Didenko and Ivan Posokhov ordered special confiscation of laptops used to submit knowingly false declarations, or why Andrii Dudikov mistakenly applied a law that was not in force at the time the offense was committed.

Judging by the questioning, candidate Olha Pevna — one of the “22” — also made an error in her practical. HQCJ member Serhii Chumak pointed out that her judgment mistakenly imposed a fine above the statutory maximum, and that was not the only concern about Pevna.

We would be able to make sense of these questions if we had access to the completed practical assignments. This once again shows that opaque scoring of practicals only undermines trust in the competition process.

What came up in the PCIE and HQCJ interviews?

As mentioned, the interviews ran for over a month, and despite the punishing schedule and workload, the PCIE and HQCJ genuinely worked hard to keep the bar high. Civil society organizations supported that effort — Transparency International Ukraine, among others, submitted concerns about individual candidates to the Commission and the international experts.

None of this productive work would have been possible without new legal conditions. Draft Law No. 11426, in force since November 2024, gave the PCIE full access to the dossiers of both candidates and sitting judges applying for HACC positions, and extended the interview window from 30 to 45 days.

The longer window proved especially valuable: experts analyzed all available information and conducted interviews with 69 candidates in just 42 days.

As usual, the PCIE and HQCJ focused on assets, ethical conduct, and professionalism.

Questioning about assets, wealth, and lifestyle was sharp. Candidates often claimed they had managed to live on incomes below the subsistence minimum thanks to tight budgeting and food from their parents. Particular attention went to cases closed under Article 130 of the Code of Administrative Offenses (driving under the influence) — relevant because drawn-out handling of such cases often signals compromised adjudication.

An entirely new line of questioning concerned candidate-judges’ use of the Unified State Register of Court Decisions under full access. Full access, as a reminder, allows users to check whether assets are under arrest, whether a search or other investigative action is being planned, and to look up full names, addresses, and other highly sensitive information. As it turned out, questionable USRCD searches were common among the candidates, and any instance of baseless lookups on relatives and friends seriously damaged their credibility.

The Commission found cases where judges and their assistants had searched for information about themselves, relatives, or other people unrelated to their cases. Judge Tetiana Troian, for example, admitted she used USRCD to watch for a possible bank lawsuit over a debt. Vita Matolych searched for court decisions involving relatives by name or phone number. Candidate Dmytro Movchan looked up one of his relatives in the register more than 100 times.

Separate attention went to candidates’ visits to Russian territory or occupied parts of Ukraine after 2015 — which they described as tourism, personal, or business trips. Explanations like “I saw the occupation as temporary” or references to trips to Kursk Region in 2019 were met with skepticism.

The PCIE and HQCJ also monitored social media — including relatives’ TikTok accounts — to identify undeclared businesses, as happened with candidate Syvokin. He maintained that his wife had no business of any kind, but PCIE members produced what appeared to be her TikTok account, where she presented herself as a beauty professional.

As usual, the PCIE and HQCJ focused on assets, ethical conduct, and professionalism.

A trail of uncertainty

The challenges of the HACC competition do not end here. Three sitting HACC judges appear set to move up to the Appeals Chamber. This will not create a serious personnel gap in the first instance, but it will significantly affect cases in which these judges served as presiding judges or panel members — their withdrawal means those cases will have to be heard from the start. That includes cases against Hladkovskyi, the Kyrylenko spouses, Mykytas, and others.

On another front, the court will expand its headcount by nearly one and a half times, which creates an urgent need for suitable new premises. On March 25, the HACC even issued an open letter to the President of Ukraine on this.

The 4-judge shortfall at the HACC also means another HACC competition — the fourth — may lie ahead. Replicating the same selection procedure will be extremely difficult, since the PCIE’s mandate expires this May. For the PCIE to take part in the next round, Parliament will need the political will to extend its participation in HACC selection — so that every HACC judge is chosen under the same procedure.

The post How the 22 Prospective HACC Judges Were Selected first appeared on Transparency International Ukraine.

How Ukraine Is Building Veteran Hubs: Without Competition and with Inflated Material Prices

Наталія Іжицька — Thu, 23 Apr 2026 09:57:14 +0000

Ukraine already has around 1.5 million veterans, including thousands of people with war-related disabilities. That number grows every year, and so does the need for systemic support and adaptation of service members to civilian life. One of the state’s responses is the creation of veteran hubs — centers where veterans can access psychological, legal, and social assistance and undergo rehabilitation. They house gyms, recreation zones, and rooms for work with specialists. Any veteran can use these services, regardless of place of registration.

Alongside the new hubs, Ukraine is also mapping existing support sites. The Nashi Tut platform, for instance, runs an interactive map of recovery locations for veterans. It lists rehabilitation centers, sports clubs, veteran hubs, and other places where service members can get help or connect with a community.

The scale of funding in this area is already substantial: in 2025 alone, UAH 946 million was contracted for the construction, repair, and furnishing of veteran hubs. In this article, TI Ukraine’s DOZORRO project examines where veteran hub construction began in Ukraine last year, why works are running behind schedule, and which projects show inflated prices in the cost estimates.

Our analysis focused on procurements with the word “veteran” and its derivatives. Veteran hubs are funded not only from the state and local budgets but also by international donors. And although the system now has a dedicated modular procedure for donor-funded procurements, some construction and reconstruction projects for veteran hubs are still handled outside Prozorro, which means we cannot track them.

Contracted funding

In 2025, around 200 contracts worth about UAH 946 million were signed through Prozorro for the construction and furnishing of veteran hubs. The largest share — UAH 836 million — went to building veteran hubs from scratch. Another UAH 29 million covered the reconstruction of buildings, and UAH 42 million went to capital and current repairs. The remainder was spent on furniture, design documentation, and other related services.

By contract value, 94% of procurements were conducted through open tenders with special features, and only 6% through direct contracts. In practice, there was no competition — only one bidder submitted a bid in each tender.

State funding and unrealistic deadlines

Nearly half of all contracted funds came from the state budget. In summer 2025, the government allocated UAH 446 million in subventions for the development and construction of veteran hubs in seven regions of Ukraine. All these projects must follow a single architectural approach and shared operating principles. Veteran hubs are designed to be inclusive and accessible. The premises include shelters, ramps, facilities for people with disabilities, and assistive technologies. Projects could also be adjusted to local needs.

Funding was granted to Zhytomyr, Zakarpattia, Ivano-Frankivsk, and Kyiv regions, as well as the Kremenchuk, Lutsk, and Kryvyi Rih communities. Each received UAH 63.74 million, with the balance to be covered by local budgets. The subvention came with a number of conditions. Initially, the facilities were to be commissioned by December 1, 2025. As of that date, none had been completed. In most procurements, contracting authorities set unrealistic deadlines from the outset, apparently to formally meet the funding program’s requirements. In practice, these deadlines were impossible to meet, so the parties later signed additional agreements changing the due dates. In addition, on December 9 of last year, the terms of the subvention were also revised, extending the project deadlines to April 30, 2026.

Standardized veteran hub building design

How veteran hubs are being built: regional cases

DOZORRO analysts examined the seven most expensive tenders for veteran hub construction and identified potentially inflated prices for construction materials in six of them. The probable overpayment is UAH 37.3 million. The analysts sent their calculations to the contracting authorities and asked them to bring prices in line with the market.

Bucha

Ukraine’s most expensive veteran hub is being built in Bucha for UAH 140 million. In October last year, the Department of Regional Development of the Kyiv Regional State Administration signed the contract with the Construction Initiatives consortium. The contract price is dynamic. Works were initially to be completed by the end of 2026, but in March the deadline was already extended to the end of January 2027. The consortium was formed in summer 2025 and includes Systemgroup Plus, TK Lazurit, Drivebud, and BK M-Bud. The ultimate beneficiary is Denys Niunko.

The future veteran hub will consist of two blocks. The first will house a gym for physical recovery; the second and main block will house offices for psychological and social support, rooms for individual work, a coworking space, and conference rooms. The design also includes a cafe, a reception, a children’s area, changing rooms, showers, and restrooms.

A retaining wall, a foundation slab, and brick walls of the gym are already in place on the site, along with the foundation slab of the main building. Crews are currently digging the pit for the shelter, installing foundations for the entrance groups of the main building, and leveling the ground around the retaining wall. The department has already paid the consortium UAH 52 million for completed works.

Analysts did not identify significant potential overstatements in the estimate for this project. At the same time, some materials are listed in the documentation without detailed specifications. The analysts asked the procuring entity to clarify these data but received no response. Because of this, it is impossible to definitively assess potential overpayments for individual items. However, for the materials that could be identified, the analysts did not record significant deviations from market prices. The State Audit Service also found no violations during its monitoring of the procurement.

Construction of the veteran hub in Bucha. PHOTO by: Kyiv Regional Military Administration

Kremenchuk

In Kremenchuk, the veteran hub is being built at the corner of Flotska and Velyka Naberezhna Streets. The UAH 132.9 million contract was signed in November last year by the executive committee of the Kremenchuk City Council with the private company Ukrekospetsproekt. The company is owned by Stanislav Savichev.

The hub is being built next to a lake, tennis courts, a football field, and a swimming pool — facilities planned to be integrated into the veterans’ physical and medical rehabilitation system. Inside, there will be rooms for seminars, lectures, and group and individual work, as well as a reception, changing rooms, restrooms, and a kitchen area. Adaptive sports will receive particular attention, with outdoor sports grounds also planned.

The initial timeline for construction was optimistic, to say the least. Works were to be completed by November 20 — ten days after the contract was signed. The parties later signed an additional agreement and extended the project to March 2026, and then to April. At what stage the works now stand is unknown, as the procuring entity did not respond to our inquiry. In December, however, it transferred UAH 54 million to Ukrekospetsproekt for the procurement of construction materials.

By the analysts’ estimates, the project’s estimate points to a possible overpayment of UAH 5.2 million. The procuring entity offered no explanation in response to our letter. However, the contract price is fixed, so without an additional agreement, Kremenchuk City Council will not be able to adjust the cost of materials in the work acceptance certificates.

The largest possible overpayments are on concrete, linoleum, and membrane. Questions also arose around the price of RKP-350B roofing ruberoid. It is listed in the estimate at UAH 187.20 per sq.m (all prices here and below include VAT). On the market, the same material sells for five times less. Kromizol, for example, offers it at UAH 35.40 per sq.m, and Cube at UAH 41.10 per sq.m. The Kremenchuk price for ruberoid is also the highest among the regions where veteran hubs are being built. For comparison, in Uzhhorod the contractor plans to supply it at UAH 38.53 per sq. m, and in Zhytomyr at UAH 94.24 per sq.m.

The analysts also flagged excessive requirements in the tender documentation of the Kremenchuk City Council executive committee. It required numerous permits, declarations, and ISO 9001 certificates, some of which are not mandatory for this type of work. In practice, such conditions can hamper competition.

The State Audit Service also had questions about the procurement. It found that the Kremenchuk City Council executive committee should have rejected Ukrekospetsproekt’s bid but did not. The company’s documents had numerous issues — unconfirmed experience, missing mandatory documents, and violations of the goods localization requirements. The auditors ordered the procuring entity to terminate the contract. It disagreed and is challenging the decision in court.

Construction of the veteran hub in Kremenchuk. Photo by: Poltava Regional Military Administration

Kryvyi Rih

In Kryvyi Rih, the veteran hub is being built in Pokrovskyi district, near the 44th quarter. In September, the Capital Construction Department of the Kryvyi Rih City Council executive committee signed a contract with Sapsan-KR LLC, owned by Bohdan Lymanskyi. The works are valued at UAH 132.2 million. The same pattern of deadline extensions driven by state-program funding applies here.

The project provides for offices for a psychologist and a social worker, a conference room, a gym, a children’s area, and a cafe. The contractor has already completed about half of the works: it has built the foundation, brick walls, reinforced concrete beams, and gym columns. Installation of the modular shelter is in its final stages, and engineering networks are being laid. The procuring entity has already paid the contractor UAH 55 million.

DOZORRO analysts reviewed the estimate and identified a potential overpayment of UAH 5.3 million, mostly on paving slabs and tactile paving. The contracting authority responded that the project had passed expert review and received a positive opinion, and that there were no grounds for an additional agreement. But expert organizations do not check prices for individual construction materials; they only assess the overall justification of costs within the project. At the same time, the contract price is dynamic, so it may still be adjusted during execution.

In the tender documentation, the analysts also noticed a potentially discriminatory requirement — the provision of a site inspection report to be signed by the procuring entity itself. Without that signature, a bidder is automatically unable to participate in the tender. Such a requirement makes it easy to screen out unwanted bidders.

Construction of the veteran hub in Kryvyi Rih. Photo by: Kryvyi Rih City Council

Uzhhorod

Another city building a veteran hub is Uzhhorod. UAH 129.5 million was contracted for its construction in October. The contract price is fixed. The Service for Local Roads and Infrastructure Development in Zakarpattia Region selected Experience M Factory LLC as the contractor. The company is owned by Nataliia Sapiolkina. The veteran hub will be built on Heroiv 128-i Bryhady Street, with a multifunctional stadium next to it for sports and active rehabilitation. Works were initially to be completed by the end of 2026 but were later extended to the end of January 2027.

Our analysis of this procurement points to a probable overpayment of UAH 11.5 million. The largest possible overpayments are on concrete and rebar. Responding to our letter, the Service for Local Roads and Infrastructure Development in Zakarpattia Region stated that the design documentation had passed expert review and received a positive opinion, and that it saw no grounds for reducing prices. DOZORRO filed a letter with the prosecutor’s office regarding a criminal offense, as the contractor has already been paid UAH 45 million for completed works.

In the procuring entity’s tender documentation, the analysts found a potentially discriminatory requirement — a mandatory site inspection report. The same condition as in Kryvyi Rih creates additional barriers to tender participation.

The State Audit Service also reviewed the procurement. Auditors found that the Service for Local Roads and Infrastructure Development in Zakarpattia Region had, without valid grounds, declared Experience M Factory LLC the winner, although its bid did not meet the requirements. The company failed to submit some mandatory documents, used “equivalent” equipment without confirming its specifications, and did not submit documents on the origin of goods. The auditors ordered the procuring entity to terminate the contract, but it refused and is challenging the decision in court.

Experience M Factory LLC has already completed the foundation and the shelter and has moved on to wall construction. Construction of the veteran hub in Uzhhorod.

Photo by: Zakarpattia Regional Council

Ivano-Frankivsk

In Ivano-Frankivsk, the veteran hub is being built at 57 Bohdana Khmelnytskoho Street. In October, Budinvest, a municipal enterprise of the Ivano-Frankivsk Regional Council, signed a contract with Step-Solar LLC, which valued the works at UAH 111.27 million. The company is owned by Ivan Baranovych. The veteran hub was to be built by the end of 2026, but in February the deadline was already extended to the end of 2027.

Later, on November 17, the procuring entity signed another contract — for UAH 6.28 million. That procurement was explained by the need to supply an additional scope of works from the same contractor.

The future center will include sports zones for physical rehabilitation and recovery, consultation rooms for psychological, legal, and social assistance, and children’s areas. The walls and columns have already been built, the administrative building’s roof is in place, windows have been installed, and the shelter and the gym’s metal frames have been assembled. Ventilation, heating, and air conditioning installation is being completed, and wall finishing is underway. About 75% of the works have been completed overall. The municipal enterprise has already paid Step-Solar LLC UAH 76 million for these works.

Most of the high-value items are listed in the estimate in general terms — ceramic tiles, linoleum, doors, and so on. Without precise specifications, their actual cost cannot be verified. As a result, the analysts were able to identify only UAH 1 million in probable overpayment in the main contract and about UAH 600,000 more in the additional one. At the same time, the price in both contracts is fixed, so it cannot simply be corrected in the acceptance certificates. We have sent a second letter to the procuring entity and are awaiting a reply. The first time, it extended the review period for our inquiry but never provided a response.

The State Audit Service reviewed this procurement as well. No violations were found during the tender, but problems emerged in the signed contract. The amount of inflation costs did not match the estimate, and the work schedule was not adjusted after the price change. As a result, the auditors ordered the procuring entity to bring the documents into compliance — Budinvest published an updated schedule.

Construction of the veteran hub in Ivano-Frankivsk. Photo by: Ivano-Frankivsk Regional State Administration

Zhytomyr

Zhytomyr The veteran hub in Zhytomyr is being built at 101-a Chudnivska Street. The UAH 102.4 million contract was signed in September last year by the Department of Regional Development of the Zhytomyr Regional State Administration with Trading and Industrial Company Tsentr Komplekt LLC. The company is owned by Zhanna Opanasiuk.

The facility was initially to be handed over by the end of the year, but in December the deadline was extended — works are now to be completed by April 30, 2026.

The contractor has already installed external electricity, sewer, and water networks. The above-ground part is being completed, and installation of the shelter structures has begun. The contractor has so far been paid UAH 65 million for completed works.

The analysis of the construction tender points to a probable overpayment of UAH 6.4 million, in particular on concrete, rebar, and brick. In its reply to DOZORRO, the procuring entity stated that the design documentation had passed expert review and received a positive opinion. In addition, the contract price is dynamic.

The State Audit Service did not skip this procurement either. Its monitoring found that the winner had not provided a proper manufacturer’s quality certificate (ISO), as required by the tender documentation. The department failed to notice this non-compliance and did not give the bidder a chance to correct it. The auditors ordered the Department of Regional Development of the Zhytomyr Regional State Administration to hold the responsible officials to disciplinary or financial liability — the procuring entity withheld the authorized person’s bonus for one month.

Construction of the veteran hub in Zhytomyr. Photo by: Zhytomyr.info

Lutsk

In October, the Capital Construction Department of the Lutsk City Council contracted the construction of a veteran hub to Volynekobud LLC. The contract value was UAH 81.8 million. The hub is being built on Koniakina Street, not far from the city district court. The contractor undertook to complete the building by November 20. Given the unrealistic timeline, however, the contract was extended to the end of April 2026.

The center will include a sports complex with a gym and a fitness room, rooms for veterans to meet, spaces for psychologists and legal support, and a small cafe. The walls have already been built and the roof structure assembled, the floors have been insulated, and a screed has been poured. Engineering networks are now being laid, and interior and exterior finishing works are underway. The Capital Construction Department has already paid Volynekobud LLC UAH 68 million for completed works. Volynekobud LLC is owned by Mykhailo Shypelyk and Andrii Hrynchuk.

DOZORRO analysts’ review of the procurement points to a probable overpayment of UAH 7.3 million. At the same time, the contract price is dynamic. The largest overstatements relate to roofing panels, sand, and insulation. The procuring entity did not respond to our letter asking it to bring prices in line with the market.

The tender also contained potentially discriminatory requirements — only a bidder recognized as critical to the economy during a special period could win. Since this status is not established by law as a qualification criterion, such a condition restricts competition.

The State Audit Service reviewed the Lutsk City Council procurement — the contract had been signed with violations. The work schedule did not clearly set out stages or deadlines. As a result, the procuring entity was ordered to amend the contract, and it later published an updated schedule.

Brief conclusions

The analysis of veteran hub procurements points to systemic problems in the construction market. There was no competition in the seven largest tenders — a pattern typical of the industry in general, not only of this segment. In addition, the documentation contained potentially discriminatory requirements that narrowed the pool of potential contractors, as well as unrealistic work deadlines that were essentially impossible to meet.

A significant share of the estimates also shows signs of inflated prices for construction materials. DOZORRO analysts estimate that, in the reviewed procurements alone, probable overpayments could reach UAH 37.3 million. Such inflated prices are not isolated cases but another recurring problem in construction projects. They stem from the absence of unified approaches to determining construction costs already at the design stage, as well as insufficient state oversight and transparency.

At the same time, individual cases show that procurement at market prices is possible. With realistic estimates and transparent tender procedures, overstatements can be avoided and budget funds spent efficiently.

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

The post How Ukraine Is Building Veteran Hubs: Without Competition and with Inflated Material Prices first appeared on Transparency International Ukraine.

A Year of Impact and Strategic Change: TI Ukraine Presents 2025 Annual Report

TI Ukraine — Wed, 22 Apr 2026 09:44:07 +0000

2025 was a challenging year — yet despite all the obstacles, and thanks to the Defense Forces, we keep making Ukraine stronger. Here are the results of that work.

“This year confirmed TI Ukraine’s institutional maturity and capacity to deliver results under difficult conditions. We helped sustain the resilience of the anti-corruption system while driving concrete change — UAH 1.1 billion in budget savings and 14 criminal proceedings opened on our referrals. Equally important, we work proactively: shaping anti-corruption policy, strengthening institutions, and promoting Ukraine’s experience on the international stage,” said TI Ukraine Executive Director Andrii Borovyk.

The organization’s core priorities remain unchanged: strengthening state anti-corruption policy, public procurement, city council transparency, organizational resilience, and international advocacy.

Over the past year, our public procurement experts co-organized Prozorro Awards 2025 and launched Market Price — a price analysis app for goods on Prozorro Market. TI Ukraine’s experts also contributed to developing the Anti-Corruption Strategy for 2026–2030, the document that sets the direction of Ukraine’s anti-corruption policy.

We not only helped keep the anti-corruption system stable during a turbulent period but demonstrated concrete results: UAH 1.1 billion in budget savings and 14 criminal proceedings opened on our referrals

Andrii Borovyk

Our lawyers analyzed over 40 legislative and regulatory initiatives, monitored high-profile corruption cases, and helped prepare the Shadow Report for the European Commission — a critical contribution to Ukraine’s EU integration progress.

The Transparent Cities team presented the eighth Transparency Ranking of 100 Cities and developed recommendations for improving city council accountability under martial law. A new project was also launched: the European City Index.

International work focused on defending the independence of anti-corruption institutions and advancing meaningful reforms, pursued through advocacy meetings in Ukraine and abroad.

Organizational resilience was a distinct priority. TI Ukraine ran its second internship program, receiving over 150 applications and training 17 specialists, four of whom joined the organization’s team. The third wave of the nationwide sociological survey Ukrainians’ Awareness of Corruption, Reconstruction, and European Integration was also launched.

Support for Ukraine’s Defense Forces remains a constant commitment. For TI Ukraine’s anniversary, the organization ran a major fundraiser that brought in over UAH 300,000 for the military’s needs. Across the year, total assistance provided to the Armed Forces of Ukraine reached UAH 2,135,000.

Explore the report results below.

“The Board sees how the team’s systematic approach and professionalism make it possible not only to respond to anti-corruption challenges, but also to stay ahead of them. We are proud that TI Ukraine remains a model of accountability and independence, maintaining a high level of trust among both Ukrainian society and international partners. his is the foundation on which Ukraine’s European future is being built,” said Olena Kifenko, Chair of the Transparency International Ukraine Board.

TI Ukraine extends its gratitude to all partners who have supported — and continue to support — the organization. Thank you for making Ukraine stronger together with us.

The Board sees how the team’s systematic approach and professionalism make it possible not only to respond to anti-corruption challenges, but also to stay ahead of them. We are proud that TI Ukraine remains a model of accountability and independence, maintaining a high level of trust among both Ukrainian society and international partners. his is the foundation on which Ukraine’s European future is being built

Olena Kifenko

The post A Year of Impact and Strategic Change: TI Ukraine Presents 2025 Annual Report first appeared on Transparency International Ukraine.

NACP Identifies Corruption-Enabling Factors in Draft Law No. 12439

TI Ukraine — Tue, 21 Apr 2026 11:46:41 +0000

The National Agency on Corruption Prevention (NACP) has completed its anti-corruption review of Draft Law No. 12439 on the protection of business entities during criminal proceedings. The agency’s conclusions find that the draft contains corruption-enabling factors and requires revision.

TI Ukraine previously requested that NACP conduct this review, having identified in its own analysis a range of risks to the effectiveness of anti-corruption bodies. The NACP’s findings confirm our key concerns.

The NACP identified the following corruption-enabling factors.

Insufficient legal certainty and foreseeability of criminal law provisions

The draft contains evaluative concepts open to arbitrary interpretation by law enforcement. This applies in particular to proposed amendments to Article 214(1) of the Criminal Procedure Code, which would grant investigators, inquiry officers, and prosecutors discretionary authority to determine whether “sufficient grounds” exist to enter information into the Unified Register of Pre-trial Investigations. The NACP considers this arrangement conducive to selective registration of criminal offense reports and a source of corruption risk.

Risk of avoiding criminal liability through executive agency guidance

The proposed amendment to Article 41-1 of the Criminal Code provides that an act committed on the basis of guidance issued by central executive bodies does not constitute a criminal offense. However, the provision does not define which bodies are authorized to issue such guidance, its form or timeframe, or the criteria for assessing its lawfulness. The NACP notes that such guidance could be used as a shield against criminal liability — including guidance that is deliberately unlawful or contrary to existing legislation.

Opaque discretionary powers of the prosecutorial authority head

The proposed addition to Article 214(8) of the Criminal Procedure Code establishes a special procedure for entering information into the Unified Register of Pre-trial Investigations by the head of a prosecutorial body in cases involving criminal offenses in the sphere of economic activity and offenses under Article 191 of the Criminal Code. The NACP warns that this may lead to inconsistent application of the law and undermine the overall effectiveness of pre-trial investigations.

Unsystematic narrowing of grounds for urgent searches

Amendments to Article 233(3) of the Criminal Procedure Code propose a limited list of offenses for which an urgent search is permitted. The list includes Article 368 of the Criminal Code (“Acceptance of an offer, promise, or receipt of unlawful benefit by an official”) but excludes other offenses of comparable public danger, including Article 369 (“Offer, promise, or provision of unlawful benefit to an official”). The NACP characterizes this approach as unjustified.

The NACP’s findings confirm that the problems with Draft Law No. 12439 are systemic and cannot be resolved through “technical and legal refinement,” as the relevant Verkhovna Rada committee proposed ahead of the second reading. Before being put to a vote, the draft requires substantial revision in light of the NACP’s observations and recommendations.

TI Ukraine calls on the Verkhovna Rada not to proceed with the second reading of Draft Law No. 12439 until all identified corruption-enabling factors have been fully addressed.

The National Agency on Corruption Prevention (NACP) has completed its anti-corruption review of Draft Law No. 12439 on the protection of business entities during criminal proceedings. The agency’s conclusions find that the draft contains corruption-enabling factors and requires revision.

The post NACP Identifies Corruption-Enabling Factors in Draft Law No. 12439 first appeared on Transparency International Ukraine.

International Experts Do Not Support Dubovyk in the ARMA Head Competition

TI Ukraine — Thu, 16 Apr 2026 16:51:07 +0000

The selection commission for the Head of ARMA voted twice on Viktor Dubovyk’s candidacy — and on both occasions, four members voted in favor, while two voted against.

At the same time, under the law, a decision is considered adopted if it receives the support of at least four commission members, including at least two members nominated by international partners. This requirement proved decisive.

Why the international members voted against

Commission member Rita Simoes clearly articulated the position, stating in particular that integrity is not merely the absence of wrongdoing, but also the confidence that a person will withstand public scrutiny in the future. In her view, that confidence was lacking. The candidate’s explanations regarding the origin of his assets amounted largely to claims that were difficult to verify independently and that is insufficient for a position of this level.

Commission member Kateryna Ryzhenko noted, among other things, that the candidate provided many explanations, but where documentary evidence was lacking, the commission was left with little more than his word. In addition, his answers to questions directly related to ARMA’s work were too superficial.

What comes next

The commission finished its work for the day. Further updates on next steps will follow. Given that the decision to recommend Dubovyk for the position of ARMA Head was not adopted in accordance with the law, the logical next step would be for the commission to announce a new competition.

“The public and international partners expect the head of the Agency to have an impeccable reputation and a clear operational strategy — something we unfortunately did not see in full. Integrity and political neutrality remain essential to building trust in a body responsible for managing assets worth billions,” emphasized Andrii Borovyk, TI Ukraine Executive Director.

TI Ukraine considers the outcome of the competition a logical result of the concerns raised during the interview — both about the candidate’s integrity and his professional readiness to lead ARMA amid its ongoing reform. In our view, a new competition is an opportunity to find a candidate who clearly meets the required standards.

The full notes from the candidate’s interview are available on our website.

The post International Experts Do Not Support Dubovyk in the ARMA Head Competition first appeared on Transparency International Ukraine.

Interview with ARMA Head Candidate Viktor Dubovyk

TI Ukraine — Thu, 16 Apr 2026 13:50:40 +0000

The selection commission for the head of the Asset Recovery and Management Agency (ARMA) held a public interview with candidate Viktor Dubovyk. TI Ukraine monitored the interview and summarized it below.

Dubovyk scored 21 out of 50 points on the legal component and 9 out of 40 on the economics component of the practical assessment.

Career background

The commission flagged a discrepancy between the candidate’s official documents and media reports regarding his roles at law firms VivaLEX and Volkhv: his autobiography listed him as director and lawyer, while open sources described him as managing partner and partner. Dubovyk explained this as variation in internal job titles — his employment record shows “director,” while his actual role may have been described differently within the firms.

The commission also noted that his autobiography omitted parts of his political history: in 2012 he ran for the Verkhovna Rada on the Green Planet party ticket, in 2015 for the Mykolaiv Regional Council on the Batkivshchyna ticket, and in 2013–2014 he worked as an advisor in the office of First Deputy Prime Minister Arbuzov and as a parliamentary assistant. Dubovyk explained that he filled out the autobiography based solely on his employment record, which he said is standard practice for civil servants.

His candidacy for the Mykolaiv Regional Council drew additional scrutiny, as he is from Donetsk Region. He explained that his grandmother lived in a small town in Mykolaiv Region, giving him close familiarity with its issues.

Practical assignment: economics component

The commission asked follow-up questions on the economics portion. Asked to give a concrete example of state losses caused by ineffective asset management, the candidate gave a vague answer, describing the risk of incomplete transfer of property complexes to ARMA without naming specific assets. As a solution, he proposed involving ARMA at the pre-trial stage, during seizure proceedings, to assess whether an asset can be managed.

On legislative changes needed to prevent asset sales to persons connected to defendants or to residents of the aggressor state, the candidate proposed three approaches: establishing a mechanism to determine whether persons are related parties; enabling ARMA to suspend procurement procedures upon identifying such connections; and shielding ARMA decisions from judicial blocking, drawing on the model used to protect NBU decisions in bank market exit proceedings.

Property and integrity

This section took up a substantial part of the interview.

House in Donetsk. The candidate confirmed ownership of a house in the Khoroshov cottage development in Donetsk, built between 2009 and 2014 based on a standard developer project. No one had lived in it before construction was completed, and by the time it was finished, the full-scale invasion of Donetsk Region had begun.

Second house in Donetsk. Adjacent to his own house, the candidate and his wife purchased a smaller property with funds provided by her parents. After relocating to Kyiv, they sold it and used the proceeds for living expenses.

Property near Kyiv. A house in Vyshhorod District — which the candidate described as a “mansion” he liked for its setting, size, and neighbors — was purchased primarily with funds from his former wife’s parents, supplemented by his own savings and an inheritance from his mother. The property also includes an unfinished structure where construction has stalled due to a shortage of contractors. Unfinished structures are not subject to property tax; Dubovyk pays only land tax.

Apartment in Kyiv. The candidate purchased an apartment for $8,700 as a non-residential technical space with no separate entrance — access was through a boiler room and electrical panel. Over roughly three years, he carried out a technical conversion (adding a separate entrance, windows, and doors) and completed the legal reclassification needed to sell it. The apartment was sold in 2019 for $51,000. Dubovyk said he has not retained documentation of the conversion costs.

Total financial assistance. The commission chair calculated that the combined financial support received from his former wife’s parents for various property purchases exceeded $200,000. The candidate confirmed the figure, noting the actual amount was higher.

Division of property after divorce. Upon divorce, his ex-wife received a car, a plot of land, and an apartment. The candidate retained the house near Kyiv, where he lives with his son, and the unfinished structure. The committee noted an asymmetry: he kept assets on Ukrainian-controlled territory, while his former wife received property in occupied or frontline areas. Dubovyk considers the division proportionate, given that he is raising their child, and that she also received the car and the Kyiv apartment.

Powers of attorney from his father. The commission informed the candidate of two powers of attorney issued by his father — in March and August 2014 — of which Dubovyk said he was unaware until the interview. He explained that under Ukrainian law a power of attorney may be issued without the named person’s knowledge, and noted that he had discussed with the NACP head how this could be rectified. He also stated that he has had no contact with his father since 2012, following his mother’s death.

Valuation of his mother’s property. To document the origin of funds, the candidate submitted a 2023 appraisal of his mother’s real estate in Mariupol, which had been sold in 2005–2009. The commission chair questioned the methodology: physical access to the properties in 2023 was impossible. Dubovyk explained that the appraiser relied on State Property Rights Register data, records of a $50,000 mortgage agreement with Privatbank, and court decisions concerning the subsequent owner.

Leadership and vision for ARMA

As an example of strategic planning, Dubovyk cited his work developing the Justice System Development Strategy 2022–2030 in his current role at the Office of the President, which involved a broad range of stakeholders — the Supreme Court, the High Council of Justice, the High Qualification Commission of Judges, international partners, and civil society. The document is embedded in the Rule of Law Roadmap approved by the Cabinet of Ministers. He acknowledged that while leading the process he faced significant pressure from civil society organizations and media who alleged that certain decisions were unlawful.

On ensuring ARMA’s independence, he identified three priorities: developing a communications strategy with weekly public briefings, expanding the powers of the public council, including granting it the right to comment on ARMA’s draft regulations, and establishing a dedicated regulatory drafting unit within the agency.

Dubovyk also expressed interest in building a “direct communication mechanism” — in plain terms, using the ARMA head’s social media presence to publicly defend decisions and demonstrate the agency’s work. A similar approach was used by former ARMA head Olena Duma, though Dubovyk added that over the years the agency had been using this “powerful” tool in the wrong way.

As his key goal in the role, Dubovyk stated his aim to make ARMA “an institution where every decision can be explained, verified, and defended.”

The post Interview with ARMA Head Candidate Viktor Dubovyk first appeared on Transparency International Ukraine.

DOZORRO Saved UAH 186 Million for the Budget Since the Start of the Year

Наталія Іжицька — Fri, 10 Apr 2026 08:04:09 +0000

In the first quarter of 2026, the DOZORRO team prevented UAH 186 million from being spent ineffectively. This is the result of earlier referrals submitted to contracting authorities, oversight bodies, and law enforcement agencies on the basis of our monitoring findings.

The largest share of savings comes from direct communication with contracting authorities — when they respond to our letters by adjusting contract amounts, terminating contracts, or canceling procurements altogether, where no other remedy is available. A portion of the savings also stems from criminal proceedings opened by law enforcement when engagement with contracting authorities yields no results. For more detail on how we calculate our savings, see our methodology article.

Below are three of the most illustrative recent cases — each showing how unnecessary expenditure can be prevented.

In January 2026, the Education, Youth and Sports Department of Devladivka Village Council ordered fruits and vegetables from Ekofudtorg LLC at a contract value of UAH 201,000.

DOZORRO analysts reviewed the contract prices and identified a likely overpayment of UAH 59,000 — almost 30% of the total contract value.

The most glaring discrepancy involved white cabbage priced at UAH 60/kg — five times the market rate. According to Prozorro’s Market Price BI, the price in December stood at UAH 10/kg, rising to UAH 12.50/kg in January. State Statistics Service data confirms the same picture: the average nationwide price for white cabbage in December was UAH 10.07/kg. On this line item alone, the potential overpayment reached UAH 13,000.

Even more prominent was the case of bananas. The village council department planned to purchase them at UAH 200/kg — more than three times the going market rate. By comparison, bananas on Prozorro Market were priced at UAH 70–80/kg during the same period, while State Statistics Service figures for December put the average at UAH 61.61/kg. The potential overpayment on this item alone could have reached UAH 11,000.

In February, we wrote to the contracting authority requesting that prices be brought in line with market rates. That same month, the village council reported that it had conducted a review and contacted the supplier. In March, the parties signed a supplementary agreement reducing the contract amount without changing the delivery volumes. This prevented UAH 60,300 in ineffective spending.

Ekofudtorg LLC was registered in late 2024 in Kryvyi Rih. Its owner and director is Kostiantyn Moskalenko.

Criminal proceedings opened over rehabilitation equipment procurement

One of the most notable cases from March involves the procurement of rehabilitation equipment for the Yampil Territorial Hospital municipal non-commercial enterprise. In September 2025, the hospital signed a UAH 2.1 million contract with Oris Trade LLC, owned by Nataliia Bilokur.

In reviewing the cost estimate, DOZORRO analysts found significant price inflation risks. The total potential overpayment came to UAH 508,000 — approximately 24% of the contract value.

The single largest exposure was on the ZEPU-K2000B hand rehabilitation trainer, with a potential overpayment of UAH 435,000. Oris Trade LLC entered the unit price as UAH 820,050 VAT-inclusive, which included transportation and insurance, yet the same model is available on the market for at least half that amount. Oxydoc sells it for UAH 388,731; Rehamed for UAH 381,900; The Nine for UAH 380,000. Even accounting for additional costs, the gap with market prices is extraordinary.

Since the company had already received payment under the contract, influencing the situation through the contracting authority was not feasible. In March 2026, the DOZORRO team therefore referred the matter to the prosecutor’s office. Law enforcement responded by notifying us of an opened criminal proceeding. The UAH 508,000 figure has been counted as a prevention result in our March summary.

Contract terminated: UAH 4.1 million saved

Another case involves the reconstruction of a veterinary hospital building for use as a dormitory, contracted at UAH 37.6 million. In early 2025, Khotyn City Council’s City Development Agency municipal enterprise awarded the work to Mobile Mechanized Unit-47 LLC.

Analysis of this procurement identified a likely overpayment of UAH 4.1 million, or 11% of the contract value. In February of last year, the DOZORRO project contacted the contracting authority requesting a review of material resource prices. Since the contract price was fixed, this would have required a supplementary agreement. Instead, the City Development Agency responded that our calculations did not reflect market conditions. Notably, this is not the first time we have flagged potential overpayments in this institution’s procurements: back in March 2025, we reported a likely UAH 8.2 million overpayment across three reconstruction projects, including the dormitory conversion.

We returned to this case on multiple occasions — requesting acceptance certificates from the contracting authority and even approaching the prosecutor’s office — but received no response from law enforcement.

Ultimately, in early 2026, Khotyn City Council’s City Development Agency and Mobile Mechanized Unit-47 LLC terminated the contract. No new procurement has been announced to date. The termination prevented UAH 4.1 million in unnecessary expenditure.

Mobile Mechanized Unit-47 LLC was registered in Khotyn in 2020. The company’s owner is Mykhailo Biliaiev.

Other notable cases from our Q1 2026 monitoring results are available in our February and January reports.

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

The post DOZORRO Saved UAH 186 Million for the Budget Since the Start of the Year first appeared on Transparency International Ukraine.

Kyiv Residents Are Waiting for the Mayor’s Report

Євгенія Семчук — Thu, 09 Apr 2026 12:19:23 +0000

Andrii Borovyk, Executive Director of Transparency International Ukraine, has filed an e-petition to Kyiv City Council as a Kyiv resident, demanding that Mayor Vitalii Klychko hold a proper public accountability session before the city’s community. Borovyk called on fellow Kyivans to support the initiative, noting that a long-overdue honest conversation between the capital’s leadership and its residents is well past due.

The petition concerns compliance with a legal requirement that the mayor hold at least two open public meetings per year — where residents can ask questions, raise concerns, and submit proposals.

The last such meeting in Kyiv took place in December 2021. Since then, despite the city facing a growing number of challenges, the mayor has not met with residents.

The e-petition calls for:

holding an open mayoral report within the timeframe established by law
publishing the report in written form in advance so residents can review it
collecting and incorporating questions from Kyivans
ensuring the event is accessible, including through an online stream and inclusive participation conditions.

“We need to learn to have difficult, grown-up conversations. Since the start of the full-scale invasion, the number of challenges facing Kyiv has multiplied. Residents need contact with their authorities and answers to important, even contentious, questions. This is an obligation of those in power, not a choice,” said Andrii Borovyk, the petition’s initiator.

TI Ukraine’s Transparent Cities program consistently finds that in many Ukrainian cities, reporting requirements are either not met at all or fulfilled in a purely formal manner — with no real dialogue with the community. As the capital, Kyiv has the opportunity to set a standard of openness and accountability for other cities. But first, Kyiv’s community must show how to make full use of the tools available to hold power to account. We encourage you to sign the petition and share it with your networks.

The petition can be signed via the following link: https://petition.kyivcity.gov.ua/petition/?pid=14172

The post Kyiv Residents Are Waiting for the Mayor’s Report first appeared on Transparency International Ukraine.

Borzhava Land Buyer Sues ARMA Over Refusal to Sign Auction Records

TI Ukraine — Wed, 08 Apr 2026 09:46:16 +0000

The District Administrative Court of Kyiv has opened proceedings in a lawsuit filed by Andrii Vinhranovskyi against the Asset Recovery and Management Agency.

Vinhranovskyi is one of the buyers of land plots on the Borzhava mountain meadow — assets at the center of a high-profile scandal following the January 8, 2026 auctions, at which ARMA sold 460 hectares of land and ski lift stations for UAH 89.5 million, despite the assets’ initial valuation exceeding UAH 1 billion.

In his claim, Vinhranovskyi asks the court to declare unlawful ARMA’s failure to sign the auction records from the two January 8 electronic auctions, its failure to publish the results in the electronic system, and its effective blocking of the buyer’s security deposits totaling over UAH 34.2 million. He also seeks compensation of over UAH 1.68 million for loan interest, inflation losses, and 3% per annum.

ARMA, for its part, published an explanation stating that it declined to sign the records based on information received from the SBI and NABU. Following its review, the Agency concluded that persons whose assets are under arrest had participated in the auctions, and identified probable signs of collusion among participants and manipulation of results. ARMA notified law enforcement authorities and instructed the auction organizer to hold repeat auctions.

Vinhranovskyi and the other buyer, Ihor Vlasiuk, have been linked by media to Serhii Liovochkin and Vladyslav Kaskiv — it was in the Kaskiv case that these lands were seized and transferred to ARMA for sale. Under international standards, allowing individuals connected to criminal schemes to reacquire assets through auctions, even at market price, may undermine the deterrent purpose of confiscation.

It is also worth noting that, according to the parliament’s website, the government has yet to introduce the necessary legislative amendments to the procedure for selling seized assets that would prevent such situations from recurring.

The post Borzhava Land Buyer Sues ARMA Over Refusal to Sign Auction Records first appeared on Transparency International Ukraine.

9 out of 100: Experts Rate Progress on the “Kachka-Kos Plan” as Critically Low

TI Ukraine — Mon, 06 Apr 2026 08:49:54 +0000

An expert coalition has released the first findings of its “Membership Check” monitoring initiative, which tracks Ukraine’s progress on 10 priority EU integration reforms. The joint assessment by leading think tanks puts the overall score at just 9 out of 100.

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.

TI Ukraine experts assessed the plan’s items most critical to effective anti-corruption work:

Criminal justice (2/20). A draft amendment to the Criminal Procedure Code has reportedly been in preparation but remains unpublished, making it impossible to assess the quality of the proposed changes.
NABU access to independent forensic examinations (0.5/10). The newly established Center has not yet given the NABU genuine access to independent expert examinations — adequate safeguards against undue influence are still absent.
International experts in the HQCJ competition (1/10). A draft law to restore international participation in the HQCJ selections has not been considered by parliament since June 2025, stalling the judiciary’s renewal.
Adoption of the Anti-Corruption Strategy and SAP by end of June 2026 (0.5/5). Approval of the 2026–2030 Strategy is being delayed by objections from certain agencies, risking the dilution of key reforms. TI Ukraine has previously analyzed individual chapters and flagged potential shortcomings.
Internal control and whistleblower protection (0.5/10). The State Audit Service has begun incorporating internal control checks into its inspections, but the Whistleblower Portal requires significant technical improvements to offer meaningful protection.

Progress on the remaining plan items is equally minimal:

Prosecutor General selection (0/10): no progress on revising procedures.
Prosecutorial leadership appointments (0.5/10): transparent competitive selection has not resumed.
SBI reform (1/10): relevant draft laws have not been put up for public discussion.
New CCU justices and HCJ members (1/5): procedures are delayed, vacancies unfilled.
Benchmark 8. Judicial integrity (2/10): Legislation does not reflect EU recommendations on asset declaration reviews for Supreme Court judges.

“The overall score of 9 largely reflects the declarative nature of many steps taken and insufficient public access to key draft legislation. We believe that to advance EU integration more effectively, it is essential to increase transparency in document preparation and step up the Verkhovna Rada’s legislative activity,” said TI Ukraine Executive Director Andrii Borovyk.

We believe that to advance EU integration more effectively, it is essential to increase transparency in document preparation and step up the Verkhovna Rada’s legislative activity

Andrii Borovyk

The post 9 out of 100: Experts Rate Progress on the “Kachka-Kos Plan” as Critically Low first appeared on Transparency International Ukraine.