Progress in Ukraine’s Anti-Corruption Efforts. June 2025 update

This document is a publication of Transparency International Ukraine (TI Ukraine). It analyses measures taken to strengthen Ukraine’s anti-corruption ecosystem during the period from September 2025 to June 2026.

This paper supplements the previous report and is published ahead of the Ukraine Recovery Conference in Gdansk and in the context of a critical juncture in Ukraine’s EU accession process: the member states have agreed to open Cluster 1 — Fundamentals, which sets out, among other elements, clear expectations for rule of law and anti-corruption reforms which must be completed for EU Accession. 

The reporting period was marked by a combination of institutional progress and growing systemic risks. Anti-corruption enforcement institutions, such as the National Anti-Corruption Bureau’s (NABU), the Special Anti-Corruption Prosecutor’s Office (SAPO), and the High Anti-Corruption Court (HACC), continued to expand on their impressive track record by progressing in high-level cases, including in the highly sensitive energy and defence sectors. The reform of the Asset Recovery and Management Agency (ARMA) commenced with a competitive selection of its new leadership. 

At the same time, targeted pressure on NABU detectives intensified, the National Agency on Corruption Prevention’s (NACP) mandatory external audit remains blocked, and Parliament has yet to address critical legislative gaps identified by the European Commission and featured in the IMF requirements, as well as in the top priorities outlined in the Kachka-Kos joint statement of December 2025. 

The adoption of the new Law on Public Procurement marks a significant step toward EU alignment in that sector, though substantial implementation work lies ahead.

TI Ukraine continues to work closely with Ukrainian institutions and international partners to support the anti-corruption reform agenda and will provide further analysis as the situation develops.

Status of Key EU Recommendations Implementation  

Ukraine has implemented several of the EU’s key recommendations and aligned its public procurement sector with European standards:

• The ARMA reform entered the implementation phase following Law No. 4503-IX.
• The NABU and the SAPO continued expanding their track record; both the SAPO and the HACC adopted institutional development strategies.

• The HACC substantially increased the pace of case completion, reducing average case-processing time from 618 to 405 days.
• The new Law on Public Procurement (draft law No. 11520) has been adopted.
• The State Audit Service received broader powers to oversee the use of international partners’ funds.
• The Roadmap for Strengthening Public Procurement Oversight for 2025–2027 has been approved.

However, a number of other substantial recommendations remain outstanding:

• Expanding the NABU’s jurisdiction to all high-risk public positions.
• Strengthening safeguards against circumvention of the NABU’s exclusive jurisdiction by the SBI, SSU, National Police, and ESBU.
• Empowering the SAPO to investigate MPs without prior approval of the Prosecutor General.
• Amending the CPC to remove automatic closure of criminal proceedings upon expiry of pre-trial investigation deadlines, and extending the statute of limitations for corruption offences in line with European standards — both specified in the Kachka-Kos plan.
• Improving the declaration verification system, including introduction of a risk-based approach focused on high-ranking officials as required by the February 2026 IMF Memorandum and European Commission.
• Adopting a new Anti-Corruption Strategy and the State Anti-Corruption Programme.
• Carrying out the selection procedure for Accounting Chamber members.
• Bringing into line the legislation on public-private partnerships and concessions with the EU acquis. 
• Continuing the defense procurement legislation update.
• Ensuring the comprehensive reform of the State Audit Service.  

Overall, the progress is mixed: meaningful advances, including the ARMA reform, continued growth in the NABU, SAPO, and HACC track record, and the adoption of the new Law on Public Procurement, are contrasted with growing risks to the independence of anti-corruption institutions, a widening gap between declared commitments and legislative action, persistent deficiencies in the criminal-law and asset-recovery framework, and stalled reform of the Accounting Chamber.