Experts from TI Ukraine’s DOZORRO project are helping refine Draft Law No. 11520, which aims to harmonize Ukraine’s public procurement legislation with European directives.
Overall, we have secured more than 40 important amendments to the document, including:
- Cabinet of Ministers approval of a set of methodologies that, among other things, will help contracting authorities correctly determine estimated value and apply non-price evaluation criteria;
- the ability to appeal to the AMCU regarding qualification decisions and procurements in Prozorro Market, so businesses can defend their rights;
- mandatory publication of work acceptance certificates for procurements over UAH 10 million to enable genuine oversight of high-value procurement;
- machine-readable tender documentation and publication of cost estimates in the software formats in which they were created, making procurement more transparent and accessible;
- safeguards against abuse of the negotiated procedure following failed open tenders: supplier requirements must match those used in the open tender;
- preserving the ability for the Cabinet of Ministers to set public procurement rules for the duration of martial law.
The first active stage of work on the draft law took place in late 2024. At that time, civil society experts were also brought into the working group under the Verkhovna Rada Committee on Economic Development. Specialists from TI Ukraine and KSE highlighted priority amendments and advocated for them in that version of the draft. The document was being prepared for submission to the European Commission by the end of the year, so the Commission could provide edits and recommendations on alignment with EU directives.
The Ministry of Economy received feedback from European counterparts and attempted to revise the draft law on its own based on that feedback. The Ministry chose to focus on consultations with the European Commission and did not address the issues flagged by civil society experts and other stakeholders.
Only in December 2025 was an updated version submitted to the Verkhovna Rada Committee on Economic Development. Only then did work begin to refine the draft law with a broad circle of experts—a process that is still ongoing.
“We are grateful to Oleksii Movchan for organizing the working group and bringing in a range of stakeholders. Not only NGOs, but also representatives of the State Audit Service, the AMCU, and state-owned enterprises. Developing high-quality legislative changes on this scale is impossible without engaging all interested parties,” emphasized Ivan Lakhtionov, Deputy Executive Director of TI Ukraine for Innovative Projects.
The draft law is expected to be finalized and submitted to the plenary hall by the end of this month. Adopting a new Law on Public Procurement is a World Bank requirement for Ukraine to receive the next tranche of macro-financial assistance. In addition, full harmonization of Ukraine’s public procurement legislation with EU directives is also a requirement under the Ukraine Facility, with a deadline in the third quarter of 2027, and is an overall EU-integration benchmark.
“Preparing a high-quality draft law of this scale in such a short period of time is practically impossible. That is why, as a working group, we are trying to bring it to an acceptable condition—among other things, so it can be implemented in practice. But we understand that changes will still be needed in the future,” Ivan Lakhtionov concludes.
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.
Developing high-quality legislative changes on this scale is impossible without engaging all interested parties
Ivan Lakhtionov