Appoint the three missing experts to the accounting chamber selection commission

Six of the eleven positions on the Accounting Chamber are currently vacant. A competition for new members formally launched a year and a half ago but has since stalled entirely: the Verkhovna Rada has not approved the composition of the Advisory Group of Experts (AGE) that is to conduct the process. The group is to comprise six members — three from the Ukrainian side and three from international partners. While the international nominees were selected relatively quickly, parliament has yet to settle on its own representatives. 

This is not Ukraine’s first such commitment. In February 2026, completing the competitive appointment procedure for Accounting Chamber members appeared as a requirement in the memorandum with the IMF — and Ukraine has already missed the declared intention to form the advisory group by the end of April this year. 

The formation of the AGE will now also be a condition of EU macro-financial assistance.

Develop and present a new Public Procurement Strategy for 2027–2030 to the European Commission

The current public procurement reform strategy covers 2024–2026. In practice, however, it has been largely nominal: the Government did not adopt an action plan for its implementation in 2026, and even the steps planned for earlier periods were only partially completed — in part because many of them logically follow the update of the primary legislation, a process that stretched over two years. 

But on May 27, parliament finally adopted the new Public Procurement Law. Over the coming years, Ukraine will need both to implement it in practice — adopting around 40 pieces of secondary legislation and making the necessary technical upgrades to Prozorro — and to complete legislative harmonization. A robust sector development strategy will be essential to planning this work properly and navigating the challenges ahead.

Prepare a concept note on a defense procurement law

This marks what may be the first time the European Commission has set specific timelines for harmonizing defense procurement legislation with European standards. The Ukraine Facility previously covered only the reform of public procurement, public-private partnerships, and concessions — with a deadline in the third quarter of 2027.

Based on the wording of the condition, the concept note is to be developed this year. A separate challenge here — and throughout the broader harmonization of defense procurement legislation — will be establishing which body is responsible: the Ministry of Economy, which sets procurement policy; the Ministry of Defense, which does so for the defense sector; or parliament.

Prepare structural changes at the state audit service

The European Commission is calling on Ukraine to develop proposals for a clear organizational and managerial separation between inspection and audit functions within the State Audit Service.

These two activities differ in purpose, procedure, and methodology. Audit is oriented toward helping the entity under review systematically improve its operations — trust and cooperation are essential here, enabling auditors to provide the most useful recommendations possible and ensuring those recommendations are properly implemented. Inspection, by contrast, involves a detailed examination of financial and operational activities for legal violations, with the possibility of liability for those found at fault. This is not a partner trying to help — it is a controller looking for errors. 

Currently, auditors and inspectors work within the same thematic departments — for example, the local budget oversight department or the construction sector oversight department. When an audit uncovers indications of violations, inspectors from the same unit may initiate an inspection of the same entity, even though this practice is inappropriate. It undermines confidence in audits, makes them less effective, and blunts their focus.

The need to separate these two forms of oversight has already been recognized in the Public Financial Management Reform Strategy for 2026–2030, which envisages the separation of audit and inspection functions within the State Audit Service by the end of 2027. Under the further development of the state internal financial control system, the State Audit Service’s audit function is expected to increasingly serve as an independent external assessment of management systems — complementing the internal audit conducted directly within government bodies.

On one level, the macro-financial assistance conditions relating to procurement and financial control may seem relatively modest — particularly compared with what is being asked on the tax side. That impression, however, could be misleading. Ukraine has been unable to appoint the Advisory Group of Experts to finally launch the Accounting Chamber competition for over a year. Initiating the reform of defense procurement legislation is also a substantial undertaking. 

The fact that the European Commission has included these reforms among the conditionality is a signal that they genuinely matter. But for them to become true priorities, they will require awareness of that need — and political will — at multiple levels within the country.

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.

From the princely court to “paper pushing”: a history of the principle

The history of this principle in Ukraine reaches back to the Kyivan Rus era and its foundational legal text, “Ruska Pravda.” Justice then was strictly direct and immediate: the defendant was brought before the prince, with proof consisting of physical actions — “pursuing the trail” or “zvid.” No stacks of paper — the judge personally observed the process, and only the one who had begun it could issue the verdict. 

But as bureaucracy grew in the 15th–17th centuries, immediacy gave way to documents. Under the Sobornoe Ulozhenie — the universal code of criminal and civil law of the Tsardom of Muscovy — “paper pushing” took over. Investigators wrote down the parties’ words and drew up brief summaries, while judges often issued rulings without ever seeing the participants. Immediacy made its comeback only with the judicial reform of 1864. That was when legal scholarship finally accepted that, to find the truth, the judge has to be physically present rather than merely read transcripts. 

In the Ukrainian lands that were part of Austria-Hungary — Galicia, Bukovyna, and Transcarpathia — the principle of immediacy took root thanks to the Austrian Code of Criminal Procedure of 1873.

That code set immediacy and orality against the old “inquisitorial” process built on written submissions, where the judge simply read the papers gathered by the investigator without listening to anyone live. The Austrian code, instead, required the court to perceive all evidence directly (Hauptverhandlung): the judge personally heard defendants, witnesses, and experts, and the verdict had to rest exclusively on what took place in the courtroom. Reading out interrogation transcripts was permitted only as an exception: if the witness had died, vanished, fallen seriously ill, or if both parties consented.

The code also required that the bench remain unchanged — the same judges had to hear the case from start to finish. If any judge could not attend, the trial was suspended, or a substitute judge was brought in, who had to be present in the courtroom from the very first minute. Appeal as to guilt was limited: the higher instance could not review what only the first judge had seen without rehearing the case. This tradition laid the groundwork for what we now call a high standard of proof.

A paper transcript is not yet evidence

The substance of the immediacy principle is set out in Ukraine’s Criminal Procedure Code and can be summarized as follows.

• Live and in person: the court examines evidence directly and obtains testimony from participants in criminal proceedings orally (Article 23).
• Out of court means non-evidence: the court cannot recognize as evidence any information contained in testimony, items, or documents that it has not directly examined (Article 23).
• The prosecution must secure the witnesses’ attendance: so that the defense can question them before an independent and impartial court (Article 23(3)).

Immediacy in examining testimony is a general principle of criminal proceedings and applies by default. The exceptions are quite limited: testimony from individuals who do not appear in court is admitted only in select cases set out in the CPC — for example, where the questioning was conducted by an investigating judge during the pre-trial stage (Articles 23, 225 of the CPC of Ukraine). Beyond that, video recordings of interrogations may be used, as provided by Article 615(11) of the CPC.

Video recording as a “bridge” of immediacy

Martial law has forced the justice system to adapt to new and often extreme conditions. Familiar approaches have had to be revisited, since the physical presence of all participants in a trial can sometimes be impossible for objective reasons. 

The fundamental rule remains that set out in Article 95(4) of the CPC: a court may not base its rulings on testimony given to an investigator or prosecutor, or refer to such testimony. That means a paper transcript of an interrogation by an investigator or detective is not evidence until the witness, victim, or defendant repeats it in person before the court.

However, Article 615(11) of the CPC allows the use of testimony from witnesses or victims obtained during a martial-law investigation as evidence — provided it is mandatorily recorded on video. The video recording becomes that very “bridge” of immediacy: by viewing the footage, the judge sees a living person, their emotions and behavior, which is far more reliable than dry text on paper. Where the suspect is being questioned, the proceeding must include continuous video recording and the participation of defense counsel.

The court’s technical evolution

In this context, one cannot overlook another important principle of criminal justice — the full recording of court proceedings by technical means. Recording of court hearings has come a long way: from the ordinary paper court journal to the full digital video and audio recording that is the standard today. Previously, the only source of information on what had taken place in the courtroom for those who had not personally attended was a court hearing record handwritten by the secretary or typed on a typewriter. 

The first step in this transformation was the move to mandatory audio recording with systems such as “Kamerton” or “Oberih.” But sound did not convey the full picture: gestures, facial expressions, or whether someone was prompting the witness off to the side. Today we have arrived at full audio and video recording of hearings — that is, complete digitalization of justice. Modern courtrooms are equipped with cameras that capture everything happening in the room, while the remote videoconference (VC) system allows participation in a hearing from home or office. The issue became especially acute during the pandemic, and later during the full-scale war. Video recording has secured the “remote immediacy” of the judicial process.

One of HACC’s challenges: why cases start “from scratch”

In practice, the immediacy of the trial sometimes becomes a challenge, which we described in detail in our HACC monitoring report. The core problem is the conflict between quality and speed. Top corruption cases are extremely voluminous and are heard for years. The principle of immediacy requires an unchanging composition of the bench: if one judge changes (for instance, due to maternity leave, dismissal, or appointment to another body), the panel in its new composition must restart the case from the very beginning to personally examine all evidence (Article 319 of the CPC).

The law provides two exceptions to this rule.

The first applies when the parties to the proceeding do not object to the new judge continuing the trial, and the new judge has reviewed the case file and agrees with the rulings already issued. The court may then rule that there is no need to start the trial over.

Cases where the defense voluntarily agrees not to start the trial over are a real rarity in anti-corruption proceedings. One example is the case concerning the construction of the Shyrokyi Lan training ground. The defense did not object to continuing the trial after a judge replacement. That stance let the parties avoid wasting time on duplicate procedures.

But in a number of high-profile cases — such as the Kraian plant case or the Derzhinformiust embezzlement case — HACC decided not to restart the trial despite objections from individual participants. The judges argued that full audio and video recording of earlier hearings allows a new judge to familiarize themselves with every nuance of the case in detail without spending years on repeat witness questioning.

This approach is not shared by all judges, as their dissenting opinions show. They stress that the defense’s right to demand a fresh trial must take priority. Their position rests on the view that no video can replace personal contact between the judge and the defendant, and that an unchanging composition of the court is more valuable than the speed of the trial. The divergence in practice is a problem in itself: in some cases HACC continues the hearing, in others it starts from scratch — dragging the process out for years. Some judges, meanwhile, stress that a literal reading of immediacy must not turn into an absurdity that blocks justice.

For example, in June 2023, during the trial of the bribery case against Olena Polishchuk, a former official at the Ministry of Agrarian Policy, one of the panel judges was replaced due to a long business trip. The trial court, guided by the logic of procedural economy and the principle of reasonable time limits, ruled: do not restart the trial, do not re-examine the evidence. The case was already at the stage of questioning the defendant. The judges noted that the new judge had reviewed the case file and agreed with earlier rulings. In February 2024, HACC sentenced the former official to 8 years’ imprisonment with additional penalties.

In their appeal, however, defense counsel did not even ask for a new trial — they sought acquittal for lack of evidence. Yet the HACC Appeals Chamber, instead of ruling on the appeal on the merits, focused precisely on the procedural moment of the judge’s replacement. Two of the three appellate judges took the position that continuing the trial after a judge change against the defense’s wish to start over was a substantial violation of the law. In their view, a verdict issued by a judge who had only partially participated in the case undermines the principles of immediacy and unchanging composition of the court. As a result, the verdict was overturned and the case sent back for retrial.

Notably, one judge disagreed with the colleagues and, in a dissenting opinion, stressed that the principle of immediacy is not absolute. In their view, the principle has built-in flexibility: both the law and the case law of the Supreme Court already permit a number of exceptions, in particular:

• the use of testimony from earlier trials (Criminal Cassation Court of the Supreme Court ruling of June 1, 2022, in case No. 206/6584/19);

• the use of the results of victim questioning in the absence of the defendant (Criminal Cassation Court of the Supreme Court ruling of January 18, 2022, in case No. 404/2468/17);

• courts grounding their conclusions on testimony given to the trial court (Criminal Cassation Court of the Supreme Court ruling of October 17, 2023, in case No. 638/18452/17);

• examining at the hearing only the parts of the documentary evidence that the parties draw attention to, rather than the full body (Criminal Cassation Court ruling of December 6, 2021, in case No. 756/4855/17).

The key takeaway is that the unchanging composition of the court matters, but it cannot be read in isolation from the circumstances of the specific case, and the principle of immediacy must not become an obstacle to effective justice.

The second exception is the concept of the substitute judge (Article 320 of the CPC). In long proceedings, a substitute judge is to be assigned, who sits in the courtroom and can immediately step in for an absent or dismissed primary judge without halting the trial.

In real life, however, with judges already in short supply and corruption cases almost always drawn out, the prospects for this mechanism are highly questionable. In the current chronic personnel shortage, keeping an experienced judge on the “bench of substitutes” for years on end is a luxury. As a result, when one of the panel members drops out, the trial often has to be restarted from square one.

International experience: a balance between immediacy and effectiveness

A look at international practice shows that approaches to applying the principle of immediacy when the bench changes range from strict mandatory rules to flexible procedures built on the use of technical means. 

In German criminal procedure, the judge has no discretion as to whether to restart the trial when the bench has changed and no substitute judge is in place. Under §226 of Germany’s Code of Criminal Procedure, the main hearing is held in the continuous presence of the judges. But, of course, various human factors may make a judge’s participation in every session impossible. For that reason, section 192 of another statute provides that, in lengthy proceedings, the presiding judge may bring in substitute judges who attend the hearing and step in for any judge unable to be present. From this it follows that the trial cannot continue if one of the judges has been replaced and no substitute was brought in. An unlawful composition of the court is an absolute ground for overturning the verdict on appeal.

The situation in Lithuania is similar: every case must be heard by an unchanging bench, and replacing a judge automatically triggers a restart from scratch, unless a substitute judge was involved in the proceedings (Articles 222, 223).

Other countries, meanwhile, have opted for a more flexible path geared toward reasonable time limits. Poland’s Code of Criminal Procedure (Articles 404 and 404b) allows the trial to continue after a panel member is replaced if this does not endanger the proper handling of the case. The new judge is given time to review the case file and the evidence, after which they can formally state whether they need the evidence to be re-examined. 

The most telling example for the Ukrainian context is Italy’s experience. Despite the historically strict requirement that judges remain unchanged, set out in Article 525 of Italy’s CPP, practice changed radically after the precedent-setting ruling of the Supreme Court of Cassation in the Bajrami case (2019), which was later reflected in Article 495 of the Code. An interested party now has the right to a renewed questioning of witnesses only where the earlier testimony was not fixed by audio or video recording, or where the judge sees an objective need for it.

This trend toward technological “compensation” for immediacy is also reflected in the case law of the European Court of Human Rights. The Court has repeatedly stressed that the accused’s ability to confront a witness in the presence of the judge who ultimately decides the case is an important guarantee for assessing the truthfulness of the testimony. 

But the ECHR does not consider the principle of immediacy an absolute ban on any change of the bench. In Cutean v. Romania and P.K. v. Finland, the Court noted that administrative or procedural factors may impede a judge’s participation, and “compensatory measures” must be applied in such cases. These include providing the new judge with transcripts or technical recordings of the hearings. 

For example, in Graviano v. Italy and Škaro v. Croatia, the ECHR found no violation, since the change of judge was accompanied by access to materials from earlier hearings, and the truthfulness of the witnesses’ testimony was not in dispute. However, the Court does find a violation where the entire panel changes, or where the new judge issues a verdict without seeing key witnesses whose testimony was decisive. 

The matter of immediacy and the right to renewed questioning of witnesses is also relevant for Ukraine. Specifically, in Famulyak v. Ukraine, the ECHR stressed that replacing a judge on the panel after a witness has been heard should normally lead to a renewed questioning of that witness. However, if the witness has already been questioned by the defense at an earlier stage and this is properly recorded, the principle of immediacy may be limited.

In another case — Chernika v. Ukraine — the Court stressed that an important element of a fair trial is the defendant’s ability to “confront” a witness in the presence of the judge who ultimately decides the case. The judge must personally satisfy himself or herself of the truthfulness of the testimony, see the person’s reactions and emotions. Yet again, the ECHR points out that the principle of immediacy is not absolute and may be limited where: full transcripts of earlier interrogations are available; the witness’s truthfulness is not in question.

This allows the conclusion that both international practice and ECHR case law show a gradual shift from physical presence to substantive immediacy, where high-quality audio and video recording acts as a proper means of ensuring that the case is heard by a fair court when its composition changes.

Substance or formalism: why this issue calls for legislative change

The disparity in HACC practice on the procedural consequences of replacing a judge creates legal uncertainty and may invite abuse by participants in the proceeding. Parliament must clearly establish: where there is full audio and video recording, the participants’ consent to continuing the trial should not be decisive. The new judge already has every digital tool needed to acquaint themselves with the nuances of the trial, without zeroing out years of work by their colleagues. 

At the same time, on a reasoned motion from a participant, the court may re-examine certain pieces of evidence or re-question key witnesses where this is necessary to safeguard the right to a fair trial.

This step would balance immediacy against the principle of reasonable time limits. Today’s technology is already sophisticated enough to deliver a fair trial without years of going around in circles through the same procedures.

How we calculated

For this study, we took all procurements for 2025 — regardless of the procedure used — but counted only contracts with the status of “active” or “completed.” The sample also includes procurements announced last year for which contracts were signed in early 2026. 

The core of the sample consists of procurements under classification 79340000-9, Advertising and marketing services. We also checked other common categories that PR work may fall under. To avoid missing relevant procurements that contracting authorities may have classified differently, we ran keyword searches — “coverage,” “placement,” and “promotion.”

Separately, we analyzed media mentions tied to these advertising contracts. To do this, we wrote Python scripts using the Claude AI assistant. The scripts collected 2025 materials from online media where the city councils under study had procured coverage of their activities. From these, the scripts filtered out items that contained mentions of the city councils (in various grammatical forms) and their mayors. We also verified the samples manually. We then compared the number of mentions against the KPIs set out in the corresponding 2025 advertising and information service contracts. 

Which city councils order the most advertising 

In 2025, city councils and their subordinate entities contracted nearly UAH 149 million for advertising. That is slightly less than in 2024, when the figure reached UAH 157 million. The top of the ranking has shifted somewhat this time. The largest sums on advertising services were directed in Kryvyi Rih, Kharkiv, Kyiv, and Kamianske. Dnipro, which had spent more on advertising than any other city in the country for years, sharply reduced its spending and dropped down the list. 

Most often, city councils procured:

• social media advertising,
• outdoor advertising (billboards),
• radio and television,
• the design and implementation of comprehensive advertising campaigns.

Below — more detail on how cities spend these funds, who receives the orders, and what content is produced as a result. 

Kryvyi Rih: recurring contractors and the Vilkuls in most publications

In 2025, Kryvyi Rih ranked among the leaders in advertising spending, with UAH 37 million in contracts. More than half of this sum, however, comes from contracts signed in early 2026 — though the procurements themselves were announced in 2025, which affected the overall annual figure. If we count only contracts actually signed during 2025, the city directed UAH 17.3 million to advertising.

The largest sum was contracted by Municipal Enterprise Kryvyi Rih City Development Institute. In February 2025, the enterprise signed a UAH 12 million contract with Media-System TV and Radio Company LLC for coverage of security, infrastructure, social programs, and the work of the authorities. The content aired on the radio stations Radio Piatnytsia, Megapolis, Radio Kryvbas, Perets FM, and Stilnoe, and on the TV channels Pershyi Miskyi and OTV. Media-System TV and Radio Company LLC is reportedly linked to the inner circle of Oleksandr Vilkul — head of the Kryvyi Rih Security Council and a former member of the Verkhovna Rada and the Dnipropetrovsk Regional Council. His father, Yurii Vilkul, has been acting mayor of Kryvyi Rih since 2021. 

In early 2026, the same municipal enterprise signed another, effectively identical, contract worth UAH 13.7 million. This time the contractor was Nova TV and Radio Company LLC (the OTV channel). Its owners, Stanislav Basov and Oksana Nechai, also own Public Television OTV LLC. The same company provided similar services in 2024. 

Separately, Municipal Enterprise Kryvyi Rih City Development Institute procures coverage in newspapers and online media. Last year, UAH 5.2 million was contracted for this purpose, with another UAH 6 million added in early 2026. The order went to Kryvbas Online Information Agency LLC, which had worked with the city before. The company is linked to Yaroslav Hyvel, an MP representing Vilkul’s Ukrainian Perspective party. The funds go toward placing materials on the websites Kryvbas Online, Puls, 1 Pershyi Miskyi.KR, and Informator, as well as in the newspapers Puls, Moia Hazeta Domashnia, Vechir, and Vik. Visnyk Kryvbasu. The list of outlets barely changes from year to year. 

Spending, however, is only part of the story. Content analysis showed that press releases from the Kryvyi Rih City Development Institute are fairly easy to trace in local media — these materials are openly signed with the name of the municipal enterprise, and sometimes appear in dedicated sections. At the same time, more than 90% of such publications, depending on the outlet, consistently mention either Yurii or Oleksandr Vilkul. This shows that a significant share of the city’s official content is built around personalized coverage of local leaders. On top of that, in roughly half of all cases the press release headlines are direct quotes from one of the Vilkuls. For example: “O. Vilkul: We are gradually equipping kindergartens, schools, and gymnasiums with modern energy-efficient technologies — for the comfort of children and educators and to reduce energy costs.”

DOZORRO reached out to the Kryvyi Rih City Council to ask it to explain the high advertising expenses, their objectives, and how their effectiveness is assessed. The city council responded that the main budget spending units determine how funds are used within the approved budget on their own, and that all expenditures are made in accordance with the law.

Kharkiv: more about the city council’s activities

Second place goes to the Kharkiv City Council, with UAH 19.3 million. That is roughly the same as in 2024 (UAH 21 million). In Kharkiv, PR spending is consistent not only in scale but also in approach: city hall continues to work with the same contractors and bets on television, radio, and local online media.

Kharkiv City Council contracted nearly UAH 7 million to place news items and programs on television. The contract with Interkom-invest LLC was signed in late 2025 for services to be delivered in 2026. The city used the same practice the year before.

Another UAH 5.5 million-plus was directed toward placing materials about the city council, the mayor, and the executive committee on radio. One contract was signed in late 2025 for services to be delivered this year. As in 2024, the services are provided by individual entrepreneur Denys Okuniev.

A separate UAH 4.5 million went to coverage of the authorities’ work, infrastructure projects, security measures, and social programs in local outlets: Slobidskyi Krai, Dumka, Status Quo, and Obiektyv. The last of these belongs to city council official Oleksandr Davtian and his children. 

Spending alone, however, does not always show what such communication actually looks like. Content analysis showed that in Kharkiv it is less personalized around the mayor than in Kryvyi Rih. In Slobidskyi krai and Dumka, the city council was mentioned more often than Ihor Terekhov. Some outlets focus more heavily on the mayor himself. This is most evident on the Obiektyv website, where Terekhov was mentioned in nearly 15% of all 2025 news items — roughly twice as often as the city council. That said, a substantial portion of these mentions are quotes from official statements about the shelling of the city. The mayor’s name appears in news headlines far less often than in Kryvyi Rih.

Kyiv: social campaigns

Third place goes to Kyiv. Structures within the Kyiv City Council contracted UAH 18.4 million for information and communication campaigns — slightly less than in 2024 (UAH 20 million).

The capital’s main focus is on social projects: distribution of printed materials, promotion on social media, radio, and outdoor advertising. The largest sum was contracted by Municipal Enterprise Communication Center — UAH 7.4 million for more than 20 campaigns. These include:

• Information on Ukraine’s partnership with the EU — UAH 376,000
• Recruitment for the Rubizh National Guard brigade — UAH 389,000
• Vaccination campaigns — UAH 386,000
• Promotion of service in the Territorial Defense Forces of the Armed Forces of Ukraine — UAH 379,000
• The “KMAN — A Space of Opportunities, Development, and Victory” campaign — UAH 350,000 
• The “Report Corruption!” campaign — UAH 315,000
• The “Space for Business in the Capital — Fast, Modern, Lawful!” campaign — UAH 338,000
• The “Metro for Everyone: Convenience, Safety, Operations” campaign — UAH 235,000

Materials and descriptions of these campaigns are available on the Communication Center’s website. To determine where exactly this advertising was placed, we filed a public information request. In response, the Communication Center provided a list of locations and distribution channels — from billboards, citylights, and metro to radio stations and social media.

Another approximately UAH 6 million was spent by the Department of Public Communications of the Kyiv City State Administration. The funds went, among other things, to the following campaigns:

• Information about social benefits via the Defenders’ Portal — UAH 477,000
• Information on protocols of action for families of those who went missing or were captured during the war — UAH 463,000
• Public consultations and explanations regarding the renaming of place names — UAH 390,000
• Information about the MSEC reform and the assessment of people’s functioning — UAH 334,000
• The “Become Part of the Team. Choose Your Sport” campaign — UAH 335,000 

According to the department, these campaigns were placed on billboards, citylights, in the metro, at transit stops, and in other busy locations. Audio versions were broadcast on radio, while video appeared on outdoor screens, in metro cars and on platforms, at Administrative Service Centers, and on social media. More detailed materials and descriptions of these campaigns are available on the department’s website. 

Other Kyiv contracting authorities also spent money on advertising. For example, the Kyiv Zoo allocated UAH 1.8 million to advertising in the metro, while Municipal Enterprise Kyivinform spent UAH 700,000 promoting Vechirnii Kyiv news through Ukr.net.

Kamianske: social advertising and what the mayor did

Kamianske took fourth place with UAH 12.8 million. That is slightly less than in 2024 (UAH 15 million). The largest sum, UAH 3 million, was contracted by the city council’s advertising department. More than half of this sum — UAH 1.7 million — went to individual entrepreneur Dmytro Riabov for producing public service advertising and video stories. He had also worked with the department in 2024. The remaining UAH 1.3 million was directed toward coverage of the executive bodies’ work on the websites Naspravdi.net, Kamenskoe.net, Ukrtime.net, DneprNEWS, and DneprLife.

Separately, the Kamianske City Council itself spent UAH 2.9 million. These funds were allocated as follows:

• UAH 698,000 to S-Kolehiia LLC for online coverage of the city council’s work;
• UAH 600,000 to Sterkh TV and Radio Company for airing segments on television;
• UAH 599,000 to Municipal Enterprise Municipal Information Service for producing and broadcasting materials;
• UAH 596,000 to Skifiia TV and Radio Company for radio broadcasts;
• UAH 277,000 to Pylnyi pohliad! Information Agency LLC for publications on its website;
• UAH 97,600 to 05692 LLC for coverage of the city council’s work on its website.

In Kamianske, nearly all of the analyzed outlets mention Mayor Andrii Bilousov significantly more often than the city council. This is most visible in the municipal outlet MIS, where the mayor’s name appears in nearly a third of all materials for the year. The overall trend shows that the city’s information communication is largely concentrated around the mayor. News headlines frequently use formulations along the lines of “the Mayor of Kamianske did such and such.” The share of such publications varies by outlet, but they appear everywhere. It should be noted, however, that a substantial portion of news items mentioning Bilousov still contain only his quotes, while the content itself describes social services, the work of city departments, and the city council itself

Dnipro: a sharp drop in spending

Next on the list is Dnipro, where PR spending has shrunk considerably. Last year, the city contracted UAH 8.7 million — roughly seven times less than in 2024, when Dnipro led the country with UAH 43 million.

This sharp decline came against the backdrop of a criminal investigation into past PR spending. In October 2024, the SBU and the National Police reported uncovering a scheme involving the embezzlement of at least UAH 34 million on advertising procurements in 2021–2023. In August 2025, the Office of the Prosecutor General announced charges against Andrii Kovalenko, the former director of Municipal Enterprise Organizational and Analytical Service. According to investigators, the money was transferred to individual entrepreneurs under his control, many of whom had no connection to advertising. The funds were then converted into cash. In total, UAH 95 million was allocated for these services in 2022–2023, of which, according to expert analysis, UAH 42 million may have been embezzled.

Even so, the city’s overall approach to communications has not disappeared — only the scale and the structures involved have changed. Following the scandals, the city council liquidated Municipal Enterprise Organizational and Analytical Service, through which most PR spending had previously flowed. In its place, a new Municipal Enterprise, Open Dnipro, was created, which from the outset contracted UAH 886,000 for outdoor advertising. This includes billboards featuring Mayor Borys Filatov, which may bear the hallmarks of political advertising.

Photo: Municipal Enterprise Open Dnipro

Separately, the Department for Public Self-Organization spent UAH 1.1 million on producing and installing address signs.

The largest contracting authority in 2025 was Municipal Enterprise Dnipro City Television Studio (DniproTV). The enterprise signed a UAH 4 million contract with Zolota Seredyna LLC for the placement of 166 publications on the Obozrevatel website. An additional UAH 2 million was directed toward developing a strategy and promoting the municipal TV channel on social media.

Who buys advertising on Prozorro besides city councils

In total, nearly UAH 600 million was contracted for advertising through Prozorro in 2025. That is more than in 2024, when the figure exceeded UAH 520 million. The market’s growth, however, was driven mainly by the commercial sector. The largest advertisers again included PrivatBank, Oschadbank, Naftogaz Ukraine, the Ministry of Internal Affairs, and Ukrposhta. They finance advertising not from the state budget but from their own commercial activities. At the same time, the large contracting authorities also include those spending budget funds — notably, city councils and education sector entities.

Contracts by region

The regional picture broadly resembles that of the previous year. Over half of all advertising contracts are concentrated in Kyiv Region — UAH 346.2 million. However, a significant share of this sum comes from state banks, Ukrposhta, and major commercial companies registered in the capital. Excluding these, the volume of contracts in the region amounts to roughly UAH 73.9 million. Second place goes to Dnipropetrovsk Region, with UAH 75.5 million. The largest share here comes from Kryvyi Rih — UAH 37 million. Kharkiv Region also made the top three, at UAH 34.8 million.

Separately, six procurements worth UAH 2.2 million were not tied to any specific region and were therefore excluded from the regional analysis. These were recruitment campaign services ordered by military units and the Central TV and Radio Studio of the Ministry of Defense of Ukraine as part of the “Defending What Is Ours” information campaign.

Conclusions 

Overall, the analysis shows that despite changes in spending volumes, the communications approach of most city councils has barely changed. Year after year, it is the same contractors, the same outlets, and the same formats — television, radio, online resources, and social media. Dnipro, after the criminal investigation, has become more of an exception: the city has significantly cut its advertising spending, but the communication model itself has not gone anywhere — it has merely shrunk in scale and partially shifted to new structures.

The issue is not only the size of the spending but also the content of such communication. Some information campaigns genuinely serve an important public function: they inform about security, the operation of critical infrastructure, social services, and support for military personnel and veterans. Such communication can be especially necessary during wartime.

In parallel, however, a significant share of the content looks like systematic promotion of local authorities’ work and image-building for officials. This is most evident in Kryvyi Rih and Kamianske, where the media content is largely personalized around the local leaders. Kharkiv looks more restrained, although some outlets there also place noticeable emphasis on the mayor.

As a result, the line between socially important information and political PR funded by the public budget remains blurred in many cases. 

This material was made possible with the support of the MATRA program of the Embassy of the Kingdom of the Netherlands in Ukraine. 

Summary: 

To enter into a framework agreement, participants in both pilots will undergo a qualification selection. To then choose the contractor for a specific procurement contract from among the parties to the agreement, they will be able to use one of two tools: open tenders or a request for proposals. 

Our analysis of the new procedures has identified the following risks and conflicts:

1. No right to appeal to the AMCU in qualification selections and requests for proposals, meaning that an entire procurement may proceed with no possibility of AMCU appeal at all. 
2. Limited coverage of these procurements by State Audit Service monitoring.
3. Too broad a range of contracting authorities participating in the pilot. 
4. Conflict with the Law, with Procurement Specifics No. 1178, with Directive 2014/24/EU, and with other Cabinet of Ministers resolutions — and the Cabinet of Ministers exceeding its powers.
5. Other risks of abuse, including overly short deadlines for submitting proposals, the option to set an unlimited financial-capacity criterion, no requirement to disclose payment terms, and ambiguous rules on the contents of contract conclusion and amendment reports in the Prozorro system.

We call for Resolutions No. 520 and No. 521 to be canceled. If the efficiency of the CPO under the Agency for Restoration needs to be improved, framework agreements for it can be provided for in Procurement Specifics No. 1178 — but only with the right to appeal to the AMCU, with State Audit Service monitoring, and provided the other risks are addressed.

Who will buy what, and how?

Under Resolution No. 520, the contracting authorities will be local self-government bodies, regional state (military) administrations and their divisions, and local-level military administrations. They will procure construction works, technical inspections and engineering surveys, demolition, the development and expert review of design documentation, author and technical supervision, consulting engineer services, and turnkey projects combining design with construction and other works or services as needed. These procurements are intended to restore settlements and facilities damaged by the war. 

Resolution No. 521 will be applied by the CPO under the Agency for Restoration. On top of the works and services listed above, it will procure routine repair services, material resources, the modernization of a range of facilities, works at state border crossing points, road maintenance, and various road works. 

To enter into a framework agreement, participants in both pilots will undergo a qualification selection. This will, in effect, be the first stage of the framework agreement. Businesses will be able to take part in it throughout the term of the agreement by submitting an application and documents in line with the qualification documentation. The scope of requirements at this stage may vary — from purely qualification-based requirements to technical specifications for the subject of procurement. The contracting authority or CPO will include candidates that meet the selection requirements in the framework agreement. At the second stage, to choose the contractor for a specific procurement contract from among the parties to the agreement, one of two tools may be used: open tenders or a request for proposals. 

Conceptually, these approaches would look promising — and the framework agreements would resemble European dynamic procurement systems — were it not for some critically substantial risks. 

Risk No. 1: Qualification selections and requests for proposals cannot be appealed to the AMCU

The qualification selection — the only way to enter the new framework agreement — is not a procurement procedure within the meaning of the Law of Ukraine on Public Procurement (the Law). Its terms, and the decisions, actions, and inaction of the contracting authority or CPO during the qualification selection, therefore cannot be appealed to the AMCU. The same applies at the second stage of the framework agreement, when a request for proposals is announced. As a result, the only part of this whole structure that can be appealed to the AMCU is an open tender at the second stage of the framework agreement — and only if the contracting authority or CPO actually chooses to use one. If, after the qualification selection, the contracting authority or CPO opts for a request for proposals instead, the entire procurement from start to finish will be without recourse to AMCU appeal. In that case, participants will have no way to challenge either the procurement terms (in particular, the terms of the qualification selection and the decisions taken within it, technical requirements, the draft contract, or the contract-price negotiation procedure attached to the request) or groundless rejections — other than through the courts.

In the resolution for local governments and regional state administrations, the Government has stated outright that qualification selections and requests for proposals are appealed through the courts.

In the resolution on the CPO under the Agency for Restoration, by contrast, the Government added that these are “appealed to the review body under the procedure determined by the Cabinet of Ministers of Ukraine.” Yet no such appeal procedure for qualification selections and requests for proposals exists. Even Procurement Specifics No. 1178 sets out an appeal procedure for open tenders only. And the “pilot” resolutions contain no deferred entry into force tied to the adoption of a new AMCU appeal procedure for these special framework agreements. This is to say nothing of the basic untenability of an arrangement in which the Cabinet of Ministers grants itself the power to determine the appeal procedure for specific above-threshold procurement methods. Moreover, the powers of the AMCU as the review body are defined by the Law of Ukraine on the Antimonopoly Committee of Ukraine, which also refers to the Law on Public Procurement. Its powers are therefore set only at the statutory level, and the Cabinet of Ministers has no authority to expand them. 

The resulting situation around appeals against framework agreements under Resolutions No. 520 and No. 521 conflicts with European Directive 89/665/EEC. The directive requires ensuring: 

• that the contracting authority cannot conclude the contract before the review body has issued its decision — yet a procurement cannot be suspended where the appeal is brought before a court; 
• enough time for effective review of contract-award decisions — yet a procurement contract under a request for proposals may be concluded as early as the day the winner is determined, leaving no window for appeal;
• effective enforcement of decisions taken by review bodies — yet enforcing a court decision within the Prozorro system is problematic, since a completed procurement cannot be returned to an earlier stage, the winner re-selected, and so on. 

The lack of an effective appeals mechanism in construction procurement will create extremely high corruption risks. It will make it possible to admit only companies close to the contracting authority to the framework agreement.

Risk No. 2: Unpredictable outcomes and limited State Audit Service monitoring 

As with AMCU appeals, the Law extends the option of monitoring specifically to procurement procedures. Paragraph 23 of Procurement Specifics No. 1178 also brings into scope simplified procurements and those for which a report on a procurement contract concluded without using the electronic procurement system is published in that system.

Unfortunately, neither the qualification selection for the framework agreement under Resolutions No. 520 and No. 521 nor the request for proposals falls into any of these categories.

At present, the State Audit Service can monitor framework agreements concluded under the Law precisely because, under the Law, they are concluded on the basis of open tenders. Open tenders, as a procurement procedure, therefore fall within the scope of monitoring regardless of whether they are used to conclude an ordinary procurement contract or a framework agreement. 

The framework agreements provided for in Resolutions No. 520 and No. 521, by contrast, will be concluded in a way that differs from what the Law prescribes — through a qualification selection, not open tenders. This raises a number of questions: will auditors monitor qualification selections at all? If so, on what legal basis? Our assumption is that if such monitoring activities do appear, their findings will be challenged. That will make the performance of framework agreements and procurement contracts less predictable for all parties.

Risk No. 3: Too broad a range of contracting authorities in the pilot

The pilots will remove a significant portion of procurements from the mandatory application of the procedures set out in the Law and in Procurement Specifics No. 1178. A project framed as a pilot in fact covers far too broad a range of contracting authorities and their procurements.

 According to the public BI Prozorro analytics module, in 2025 alone roughly 2,000 local self-government bodies announced over 61,400 construction procurements and signed contracts worth more than UAH 46 billion. 

At the same time, NACP research finds construction and land relations to be the area with the highest prevalence of corruption — according to the experience of both the public and businesses. Public procurement also appears on the list of areas most affected by corruption.

Stripping anti-corruption safeguards en masse from construction-sector public procurement, and framing this as a pilot, therefore creates a double risk of abuse. 

An experiment of this kind makes sense only in a limited form — for a single contracting authority, SE Infrastructure Projects. This newly established centralized procurement organization for construction genuinely needs new tools, which will otherwise take at least another year to arrive — until the new Law comes into force. The standard framework agreement under the current Law does not allow for procuring works or prequalifying potential contractors on an ongoing basis. So this CPO is precisely where such new instruments can be piloted. 

Risk No. 4: Conflict with the Law, Procurement Specifics No. 1178, and Directive 2014/24/EU — and the Cabinet of Ministers exceeding its powers

The divergence of the pilot rules from the Law and from Procurement Specifics No. 1178 is itself a risk worthy of attention. The framework agreements will differ from those provided for by the Law and the Procurement Specifics in the following ways:

1. Under Resolutions No. 520 and No. 521, a framework agreement is concluded on the basis of a qualification selection. Article 15 of the Law, however, provides that framework agreements are concluded on the basis of open tenders. Even paragraph 7 of Procurement Specifics No. 1178 explicitly states that CPOs organize and conduct procurements under framework agreements on behalf of contracting authorities in accordance with the terms set by the Law — not in some pilot manner devised by the Cabinet of Ministers. What is more, for the CPO under the Agency for Restoration in particular, Procurement Specifics No. 1178 sets out the available procurement methods, framework agreements among them — and only under the Law:

“Pursuant to a decision of the Cabinet of Ministers of Ukraine, a centralized procurement organization that is established during the legal regime of martial law in Ukraine and that falls within the management domain of the Agency for Restoration may conduct procurements of services and/or works on behalf of contracting authorities by way of open tenders under these Specifics and procurements under framework agreements in accordance with the terms set by the Law.”

Resolution No. 521 thus creates a conflict, contradicting not just the Law but other resolutions as well. 

1. The Law does not envisage the use of framework agreements for the procurement of works. And while this option is mentioned in Procurement Specifics No. 1178 for the CPO under the Agency for Restoration, no such exception is available to other contracting authorities. Procurement Specifics No. 1178 permits them to use framework agreements for public procurement of goods and services only. And again — only under the terms set by the Law.
2. The Constitution of Ukraine requires the Cabinet of Ministers to act only on the basis, within the limits of the powers, and in the manner prescribed by the Constitution and the laws of Ukraine. The Law does not give the Cabinet of Ministers any authority to create new procurement procedures or methods for particular categories of contracting authorities and subjects of procurement. And while the Law does grant the Cabinet of Ministers the power to designate CPOs and set the specifics of their operations, it also makes clear that CPOs “organize and conduct tenders and procurements under framework agreements on behalf of contracting authorities in accordance with this Law” — not in a manner determined by the Cabinet of Ministers.

These conflicts breach other provisions as well — for example, Article 3(10) of the Law, which prohibits procuring goods, works, and services before or without conducting the procurement or simplified procurement procedures set by the Law.

The conflict with the Law in turn produces non-compliance with Directive 2014/24/EU, which permits concluding framework agreements only where the procedures set out in Directive 2014/24/EU are applied. Even if the pilot framework agreements are treated as the equivalent of dynamic procurement systems, in the EU these must follow the rules of the restricted procedure. The process described in the resolutions, however, departs from that procedure in terms of the right to appeal to the review body, the deadlines for submitting tender proposals (and proposals), and other elements. 

Adoption of these resolutions therefore takes domestic regulation further away from EU requirements and risks undermining Ukraine’s European integration progress, drawing a negative response from the European Commission and international partners — especially now, when bringing Ukrainian procurement legislation in line with the EU acquis is a central focus of the Ukrainian state’s attention and efforts.

Risk No. 5: Overly short submission deadlines, unlimited financial requirements, undisclosed payment terms, ambiguous reporting rules in the system, and more

Beyond significantly limiting the ability to challenge abuses during procurement, the pilots contain a number of features that could actively encourage such abuses: 

• Overly short minimum deadlines for submitting tender proposals (as little as 7 days in tenders announced by the CPO) and proposals in response to a request (as little as 3 days for all participants in these pilots). TI Ukraine had advocated for — and successfully secured — an increase in the minimum deadline for submitting tender proposals in works procurement to at least 14 days. 
• CPOs and contracting authorities setting up framework agreements will be able to set the financial-capacity criterion on the basis of an “approximately calculated” — and therefore potentially inflated — estimated value. For example, they could require candidates to show UAH 1 billion in income for the previous year while in fact announcing procurements worth only UAH 50 million. This approach risks limiting business access to procurement.

• Neither the qualification selection stage nor the request for proposals requires disclosing information on payment terms.
• While the winner of a request for proposals is given 4 days to submit their documents from the moment they are named, the procurement contract may be concluded as early as the day of that determination. This allows for a situation in which a contract is signed with a party whose absence of a criminal record, corruption offenses, and so on has not yet been confirmed. 
• For local governments and regional state administrations, the resolution effectively introduces alternative (and curtailed) content requirements for the notice of amendments to a procurement contract concluded under a request for proposals. The substance of and grounds for the amendments, along with the prices of material resources, drop out of the report. For the CPO, by contrast, the requirement to disclose price changes did make it into the resolution. Even so, disclosure of information on material resources in machine-readable formats when concluding a contract looks problematic in both resolutions. That is because, instead of referring to the requirements of the Law, Resolutions No. 520 and No. 521 contain their own requirements for reporting on the concluded contract and publishing it — and these contain no separate requirement to disclose prices of material resources in machine-readable format (!). Pilot participants will therefore do this only if they apply the Law’s requirements on disclosing procurement contracts directly. (That said, under the Law these are only contracts concluded as a result of procurement procedures and simplified procurements, whereas contracts under Resolutions No. 520 and No. 521 are not concluded as a result of either.) 

Conclusions and recommendations: how to fix the situation

In sum, the pilot resolutions will remove a substantial share of procurements from the procedures set by the Law, from AMCU appeals, and from State Audit Service monitoring. They conflict with the Law, with EU Directives, and even with other resolutions, and they set overly short submission deadlines and inadequate disclosure requirements. Their implementation will create risks of abuse that cannot be effectively or promptly stopped, and may also harm Ukraine’s European integration progress.

The very fact that the Cabinet of Ministers is introducing — for specific categories of procurement and contracting authorities — a procedure different from the one prescribed by the Law sets a dangerous precedent that destabilizes the legislative framework and cannot be left unaddressed by civil society. Procurement Specifics No. 1178 is expressly provided for in the Final Provisions of the Law. By contrast, allowing the Cabinet of Ministers to set “as a pilot” a procedure different from the statutory one — taking thousands of procurements out of full appeal and monitoring coverage — is not provided for in the Law on Public Procurement, in the sector-specific Law on the Cabinet of Ministers of Ukraine, or, ultimately, in the Constitution of Ukraine. This could become a dangerous precedent that destabilizes the legislative framework and gives rise to a whole series of court disputes.

To fix the situation:

1. We call for the cancellation of Cabinet of Ministers Resolutions No. 520 and No. 521 of April 24, 2026, which approved the procurement procedures under framework agreements in pilot projects for the CPO under the Agency for Restoration, local governments, and regional state administrations. Contracting authorities that want to use dynamic procurement systems should wait for the new Law of Ukraine on Public Procurement (Draft Law No. 11520) to come into force. In that law, such systems will come with appropriate safeguards. 
2. Since there is demand to improve the efficiency of the CPO under the Agency for Restoration, framework agreements for it can be provided for in Procurement Specifics No. 1178 — but only with the right to appeal to the AMCU, with State Audit Service monitoring, and provided the other risks are addressed. 

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.