1. Certain declaration verification procedures are unlawful, ineffective, and duplicative
Existence of procedures not provided for by law. Two procedures (completeness check and automated full verification of declarations) are not foreseen in the Law on the Corruption Prevention. They were introduced by the NACP on its own initiative. International experts have consistently supported a model of financial control without these procedures since the launch of asset declarations in 2016. Meanwhile, in its 2023 report, international external auditors strongly criticized the NACP’s model.
Duplication of procedures. Several procedures pursue identical goals (automated full verification, full verification, lifestyle monitoring, completeness check, and logical/arithmetic control — LAC) but are artificially differentiated by the Agency despite the law remaining unchanged for years. This is a make-work approach, without producing tangible results. The procedures are poorly coordinated, a problem also highlighted in the Rule of Law Roadmap. International standards do not envisage such procedural variety.
Lack of substance in automated full verification. Automated full verification compares data submitted by the declarant with state registers, many of which are incomplete or inaccurate. The NACP has recently allowed declarants to automatically extract data from registers into draft declarations, further undermining the logic of this procedure. As proof of its ineffectiveness, individuals implicated in future cases of illicit enrichment, false declarations, or civil forfeiture (e.g., a former Deputy Director of the State Bureau of Investigations, a former Deputy Minister of Environment, regional tax officials), as well as declarations with cryptocurrency, cash, and foreign assets, which cannot be verified automatically, have all passed this check.
Recommendations:
To Parliament:
- Define in the Law on Corruption Prevention the scope of the LAC, completeness, and accuracy checks to prevent duplication of objectives.
- Explicitly prohibit the NACP from introducing procedures not provided by law.
To the NACP:
- Simplify the financial control system, in consultation with international partners, by eliminating duplicative and unlawful procedures.
2. Full verification as the NACP’s core procedure is inefficient and disproportionate to corruption risks
Disproportionate focus under limited resources. The NACP has limited capacity and can conduct just over 1,000 full verifications annually. Resources are used inefficiently, with most checks targeting lower-level officials presenting minimal risks. Even successful verifications have a negligible deterrent effect. According to Opendatabot, in 2024, there were 358 criminal cases opened for false declarations and 258 in 2025. Only 20 (6%) reached court in 2024 and 17 (7%) in 2025. For illicit enrichment, 102 proceedings were opened last year, but only seven suspicion notices were served. This year, 52 proceedings resulted in just two suspicion notices and one indictment. False declarations also led to dozens of minor administrative fines (17,000 UAH ≈ 350 EUR).
Focus on minor discrepancies. Verifications largely concentrate on small inconsistencies with registers or documents, which have limited impact on corruption levels and weak prospects in court. Only 1 of 200 full verifications in the first half of 2024 avoided TI Ukraine’s criticism.
Variable quality of checks. The NACP has, in various cases: incorrectly valued assets; failed to use third parties, expert bodies, or national or foreign institutions; ignored tax evasion; poorly assessed cash and cryptocurrency holdings; and failed to disclose explanations from declarants or whistleblower reports for independent assessment. Even in the case of Tetiana Krupa, head of the Khmelnytskyi MSEC, the NACP had to repeat verification after a scandal, as the first one revealed no criminal wrongdoing.
Lack of proper oversight of NACP leadership declarations. No safeguards exist during verification of declarations filed by the Agency’s own leadership, creating additional risks.
Recommendations:
To Parliament:
- Set out in the Law on Corruption Prevention the content of full verification of declarations to avoid checking minor discrepancies.
- Extend the list of declarants to include leadership of separate units and branches of legal entities, and patronage staff.
To the NACP:
- Standardize and improve full verification practices to ensure effectiveness and impartiality.
- Focus on identifying unjustified assets and signs of illicit enrichment among high-level officials and in high-risk sectors, to achieve the best outcome given the resources spent.
- Introduce additional checks and balances for verifying declarations of NACP employees.
3. Lifestyle monitoring fails to meet European standards
Overlap with full verification and lack of risk-based approach. Lifestyle monitoring overlaps with full verification and mainly detects hidden assets without lawful income, mostly among lower-level officials. This reflects the absence of a risk-based approach.
No time limits. Current rules allow lifestyle monitoring to last indefinitely, potentially leading to excessive and disproportionate interference in private and family life, contrary to the law and Article 8 of the European Convention on Human Rights. Ukraine risks losing cases before the ECtHR. Some monitoring procedures already exceed one year. The absence of time limits allows the NACP to manipulate the four-year limitation period for civil forfeiture. The Agency has not changed its substantive approaches to lifestyle monitoring, despite criticism from international auditors and the public.
Lack of transparency in the distribution of lifestyle monitoring checks among NACP officials and the restricted nature of the results. Lifestyle monitoring cases are not auto-assigned, and the broad powers of authorized NACP staff (including issuing binding orders) raise risks of abuse. Recently, the NACP refused to disclose expert conclusions in the case of former SSU cybersecurity chief Illia Vitiuk, where no violations were found — prompting doubts about the Agency’s independence. Unlike full verification results, lifestyle monitoring outcomes are not made public.
Recommendations:
To Parliament:
- Differentiate in the Law on Corruption Prevention the procedures of full verification and lifestyle monitoring; establish appropriate parameters for lifestyle monitoring as a preliminary analytical activity of the NACP concerning a specific possible fact of an offense.
To the NACP:
- Implement the recommendations of TI Ukraine’s 2021 study on lifestyle monitoring regarding narrowing the mandate of NACP authorized officials, limiting lifestyle monitoring to clear timeframes of 4 months, introducing automatic distribution of lifestyle monitoring cases, etc.
- Publish the results of all lifestyle monitoring cases.
4. NACP illegally conceals regulations, content, and results of certain procedures, undermining accountability
The LAC is a type of financial control that identifies inconsistencies between declared information and registers and evaluates them according to certain rules and coefficients. The outcome of the LAC is a calculated risk rating indicator of the declaration, which affects the order of its selection for verification.
Non-transparent LAC rules. The last publicly available rules (2020) were heavily criticized by TI Ukraine and the Anti-Corruption Action Center. In 2024, the NACP further concealed the rules, which have not been public since 2021, not even to the Public Council at the NACP. International auditors found no legal grounds for secrecy. Current LAC rules, central to the NACP’s risk-based approach, lead to failure to detect signs of administrative or criminal violations in half of all declarations selected for full verification.
Secret procedures for special bodies. Verification rules for declarations of SSU staff, NABU employees, intelligence officers, and others remain classified, even withheld from international auditors, raising risks of conflicts of interest for the NACP Head.
Recommendations:
To Parliament:
- Require publication of LAC rules in the Law on Corruption Prevention.
To the NACP:
- Publish LAC rules and subject them to broad consultation.
- Provide the Public Council at the NACP with access to financial control procedures for special declarants.
5. Second external audit of the NACP is blocked
Flawed methodology and criteria. Given the NACP’s opacity and weak accountability, an external audit by international experts in 2024–2025 (the first two years of the current Head’s mandate) is a necessary step for strengthening corruption prevention and verification processes.
But before that, the Government must update the methodology and criteria for the audit, adopted in 2020, which proved overloaded and inadequate. Three Ministers of Justice failed to amend them. Instead, the Ministry unlawfully allowed the NACP, conflicted as the entity subject to the audit, to heavily influence their content. Current criteria exclude evaluation of the NACP’s lobbying mandate, while the inefficiency threshold for dismissing the Head is unrealistically high. The methodology and criteria also ignore the individual inefficiency and lack of integrity of the Head of the NACP.
Moreover, the NACP has not published the Implementation Plan for recommendations of the first audit, announced over two years ago.
Recommendations:
To Parliament:
- Establish in the Law on Corruption Prevention that the Audit Commission shall be the body adopting the methodology and criteria for the external audit of the NACP, as is provided for in the audit of the NABU–SAPO.
To the Government:
- Broadly consult on draft changes, simplifying audit methodology and criteria while minimizing the NACP’s role as the evaluated body.
- Form the Audit Commission based on proposals from international partners.
To the NACP:
- Disclose the status of implementation of recommendations from the first external audit and ensure their enforcement.
