On May 26, 2026, the Verkhovna Rada passed Draft Law No. 15056 as a basis, which enables Ukraine to accede to the OECD Convention.
The bill addresses certain inconsistencies in existing legislation and is a condition for the entry into force of the law on Ukraine’s accession to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
Joining the Convention is an important step toward EU integration that will allow Ukraine to become a full OECD member and strengthen international cooperation in corruption investigations. The changes will enable more effective responses to cases of bribery involving both foreign and domestic officials.
However, the draft law’s proposed introduction of “autonomous” criminal liability for legal entities will not, in our view, be fully effective without additional changes. To improve the bill ahead of the second reading, we recommend:
- extending the grounds for liability to cover criminal offenses under Article 364 (abuse of power or official position) and Article 191 (misappropriation, embezzlement, or seizure of property through abuse of official position) of the Criminal Code. This is necessary because legal entities are involved in schemes that enable abuse of office and misappropriation;
- applying “autonomous” corporate criminal liability also to cases where such offenses are committed against domestic officials. Currently, this mechanism applies only when the misconduct involves officials of foreign states.
We have previously highlighted these shortcomings in the proposed mechanism.
The draft law should accordingly be refined ahead of the second reading to ensure that the national “autonomous” corporate criminal liability framework not only complies with the OECD Convention’s requirements but is also effective in combating corruption involving domestic officials.
This publication has been produced with financial support from Norway. The contents of this publication are the sole responsibility of Transparency International Ukraine and can in no way be taken to reflect the views of the Government of Norway.
The draft law should accordingly be refined ahead of the second reading to ensure that the national “autonomous” corporate criminal liability framework not only complies with the OECD Convention's requirements but is also effective in combating corruption involving domestic officials.
