What components make up Ukraine’s CPI 2025 indicator?

The Corruption Perceptions Index is not only one of the largest thematic studies in its field but also a marker of how things stand inside a country. That is why Ukraine’s CPI score and its progress in fighting corruption are used as reference points by international partners and donors, as well as by potential investors.

In recent years, Ukraine has shown very restrained progress. After gaining +3 in 2023 and reaching a total of 36 points, the country has essentially remained at that level, alternately losing and then regaining 1 point from year to year.

As in the previous year, Ukraine’s results in the Corruption Perceptions Index 2025 were calculated on the basis of eight assessments covering the period from January 2023 through September 2025, inclusive.  Due to methodological limitations, many developments from fall 2025 (for example, the “Midas case”) and early 2026 (for example, NABU’s notice of suspicion to Batkivshchyna party leader Yuliia Tymoshenko) were not reflected in this year’s Index.

In one of the underlying sources, Ukraine’s score increased: the Bertelsmann Transformation Index added 5 points. By contrast, in the World Economic Forum’s Executive Opinion Survey, Ukraine lost 2 points. In the remaining six sources—the Freedom House Nations in Transit report, the Rule of Law Index compiled by the World Justice Project, the country risk ratings by The Economist Intelligence Unit, Varieties of Democracy, S&P Global Insights’ Risk and Business Environment Indicators, and the PRS Group’s International Country Risk Guide—Ukraine’s position did not change.

The 2026 Bertelsmann Transformation Index assessment, in which Ukraine gained 5 points, was conducted from January 2023 to January 2025 and incorporated the views of 280 experts worldwide. Among other factors, they assessed whether officials who abuse their positions are held accountable or punished. In other words, this outcome was driven by the active work of the NABU, the SAPO, and the HACC in investigating and adjudicating top-level corruption cases in 2023–2024. 

The World Economic Forum’s Executive Opinion Survey—conducted from March through August 2025, where Ukraine lost 2 points—includes, among other questions: “In your country, to what extent is it common for public funds to be diverted to companies, individuals, or groups due to corruption?”  To administer this survey, the World Economic Forum works closely with more than 160 partner institutions. Primarily reputable economics faculties at national universities, independent research institutes, or business organizations. These partners are selected based on their capacity to capture the views of leading business executives and their knowledge of the country’s business environment.

It is also important to note that, in some cases, Ukraine’s score did not change because certain source data were not updated from the previous Corruption Perceptions Index cycle. For example, S&P Global Insights’ Risk and Business Environment Indicators still cover October–December 2023. Likewise, Freedom House’s once-annual Nations in Transit report stopped being published after 2024.

Thus, it was the jump in the Bertelsmann Transformation Index that ultimately drove Ukraine’s overall +1 point in CPI 2025. In this context, a one-point increase may be perceived not as improvement, but as motion without progress that feels especially painful in a country at war. After all, despite having a concrete reform plan, Ukraine did not demonstrate real progress or readiness to implement it. The fulfilment of commitments already undertaken has once again been postponed, while genuinely positive developments in 2025 were relatively few.

During that period, many negative and positive events influenced public perceptions of corruption in our country. On the positive side: the Commission for the External Independent Audit published the results of the first independent assessment of NABU’s effectiveness; parliament voted for ARMA reform; and the Cabinet of Ministers approved Transformation Road Maps in the areas of the rule of law, public governance reform, and the functioning of democratic institutions. 

However, the audit of NACP remains blocked; a commission to select candidates for the Accounting Chamber has not been established; and international experts’ participation in the Selection Commission for appointing HQCJ members has ended. And the attempted dismantling of the anti-corruption system in July 2025 jeopardized Ukraine’s future progress in fighting corruption. These and other negative developments prevented Ukraine from achieving a larger increase.

What further anti-corruption measures should Ukraine implement to improve its CPI performance?

Ukraine’s CPI 2025 score shows that the progress achieved in fighting corruption has largely been made possible by the commitments Ukraine has undertaken with international partners, and by a united society that once again refused to let the country veer off its democratic path.

The following documents currently shape Ukraine’s trajectory: 

• Ukraine Facility Plan;
• EU Enlargement Report on Ukraine;
• the IMF program under the Extended Fund Facility (EFF);
• the Rule of Law Road Map;
• the Plan of 10 priority reforms in anti-corruption and the rule of law.

In line with these documents, Transparency International Ukraine emphasizes the need to implement 6 priority steps in 2026:

1. Safeguard the independence of anti-corruption institutions. 
2. Improve outcomes in corruption cases, especially in freezing and confiscating illicit assets.
3. Enhance the institutional capacity and focus of the National Agency on Corruption Prevention.
4. Update legislation to ensure swift, high-quality justice.
5. Expand the involvement of international experts in the selection commission for appointing HQCJ members.
6. Adopt an Anti-Corruption Strategy and a State Anti-Corruption Program. 

Global corruption perceptions trends in 2025

As CPI 2025 shows, the global corruption situation is worsening: even established democracies are seeing rising corruption amid weakening leadership. The study indicates that the number of countries scoring above 80 has fallen from 12 ten years ago to just five this year.

At the same time, CPI scores suggest that democracies, which are typically stronger at controlling corruption than autocracies or flawed democracies, are experiencing a worrying decline in performance. This trend includes countries such as the United States (64), Canada (75), and New Zealand (81), as well as parts of Europe, including the United Kingdom (70), France (66), and Sweden (80). Another troubling pattern is that many governments have intensified restrictions on freedom of expression, association, and assembly. Since 2012, 36 of the 50 countries with the most significant score declines have also seen civic space shrink. Based on CPI 2025, the global movement Transparency International concludes that the overwhelming majority of countries are failing to control corruption: more than two-thirds—122 out of 180—score below 50.

The study also shows that, over the past decade, anti-corruption efforts in many European countries have largely stalled. Since 2012, perceptions of corruption have significantly worsened in 13 countries in Western Europe and the EU, while only seven countries have posted notable improvements. 

In December 2025, the EU agreed on its first Anti-Corruption Directive to harmonize criminal legislation on corruption. However, provisions in a document that was supposed to establish a zero-tolerance framework were diluted by some member states, including Italy (53), which blocked the criminalization of abuse of office by public officials. As a result, the European Union ended up with a framework that lacks ambition, clarity, and enforceability.

Meanwhile, the United States continued its decline to the lowest CPI score in its history. Although 2025 developments are not yet fully reflected, actions targeting freedom of expression and undermining judicial independence are already a cause for concern. In the past year, the United States saw temporary suspension and weakening of enforcement of the Foreign Corrupt Practices Act of 1977, signaling the current administration’s tolerance of corrupt business practices. At the same time, cuts to U.S. support for civil society abroad weakened global anti-corruption efforts, while political leaders in other countries interpreted this funding rollback as a signal to further restrict the activities of NGOs, journalists, and other independent voices.

More broadly, high CPI scores do not guarantee that top-ranked countries are free from corruption, as several of the Index leaders facilitate corruption in other countries by enabling the laundering and cross-border transfer of corruption proceeds. For example, Switzerland (80) and Singapore (84).

Transparency International warns that the lack of bold leadership in the global fight against corruption is weakening international anti-corruption action and risks reducing pressure for reform worldwide.

In light of these trends, the Transparency International movement calls for:

• renewed political leadership in the fight against corruption, including full enforcement of laws, fulfillment of international commitments, and reforms that strengthen transparency, oversight, and accountability;  
• protection of civic space by ending attacks on journalists, NGOs, and whistleblowers, and stopping efforts to restrict the independent work of civil society; 
• closing secrecy loopholes that allow corrupt money to move across borders, including by ensuring transparency about who ultimately owns companies, trusts, and assets.

CPI study: how it works

Corruption Perceptions Index (CPI) is a ranking calculated by the global organization Transparency International since 1995. The organization does not conduct its own surveys. The Index is calculated based on 13 studies of reputable international institutions and think tanks.

The key indicator of the Index is the score, not the rank. The minimum score (0 points) means that corruption actually replaces the government, while the maximum (100 points) indicates that corruption is almost absent in society.  The index assesses corruption only in the public sector. 

The CPI incorporates the views of business representatives, investors, market analysts, and others. It reflects private-sector perspectives and how the private sector perceives corruption in the public sector.

It is important to keep in mind that CPI measures perception of corruption, not the actual level of corruption. A higher score for one country compared to another does not necessarily mean that the former has less actual corruption—it simply indicates that it is perceived as less corrupt.

The CPI methodology has been approved by the European Commission for its robust statistical approach.

CPI assesses perceptions of public sector corruption such as bribery, embezzlement of public funds, nepotism in public service, state capture, the government’s ability to implement integrity mechanisms, the effective prosecution of corrupt officials, excessive bureaucracy, and the adequacy of laws on financial disclosure, conflict of interest prevention, and access to information, as well as the protection of whistleblowers, journalists, and investigators.

Why do we need a CPI? 

• The CPI covers more countries than any single source.
• The CPI compensates for the error in different sources using the average of the results of at least three different sources.
• The CPI scale of 0 to 100 is more accurate than other sources, as some have a scale of 1 to 5 or 1 to 7, which results in many countries receiving the same results.
• The CPI balances different perspectives on corruption in the public sector and has a neutral approach to different political regimes.

Among its neighbors, Ukraine remains ahead of Russia—the terrorist state lost 4 points in 2024 and fell to 154th place with 22 points. Similarly, Belarus, Ukraine’s northern neighbor, also lost 4 points last year and now ranks 114th with 33 points.

Among its western neighbors, only Moldova improved its overall position, scoring 43 points and ranking 76th. For the second consecutive year, Romania maintained a score of 46 points, ranking 65th. All other countries worsened their positions: Poland (53 points, 53rd place) and Hungary (41 points, 82nd place) each lost 1 point, and Slovakia lost 5 points (49 points, 59th place). Thus, Ukraine and most of its neighbors—except Moldova and Romania—worsened their performance on the Corruption Perceptions Index in 2024.

What components make up Ukraine’s CPI-2024 indicator?

As in the previous year, Ukraine’s CPI-2024 results were calculated based on eight studies covering the period from February 2021 through September 2024 inclusive. Events that occurred in the fall of 2024 were most likely not included in the latest index.

In three of these studies, Ukraine’s performance improved: the Bertelsmann Transformation Index for 2024 increased our score by 2 points, while both the Freedom House report and the Global Justice Project’s Rule of Law Index improved our score by 1 point each. In the remaining five studies, Ukraine’s scores decreased. The Economist’s Country Risk Rating and the Varieties of Democracy Project reduced our results by 2 points, Global Insight’s Country Risk Rating and the World Economic Forum Executive Opinion Survey reduced our score by 3 points, and PRS Group’s International Risk Survey for 2024 resulted in a 6-point decrease. 

Taking the above data into account, one can argue that the overall change in Ukraine’s CPI indicator is primarily due to systemic trends rather than isolated point factors. 

At the same time, in 2024, the global movement Transparency International clarified the overall methodology for studying the Corruption Perceptions Index for all countries. As a result, some scores in specific studies have changed partially—not primarily due to shifts in the actual perception of corruption among the countries covered, but because of technical adjustments in converting the indicators to an updated 100-point scale.

The Bertelsmann Foundation Transformation Index for 2024—which recorded a 2-point increase for Ukraine—was conducted from February 2021 to January 2023 and included the opinions of 280 experts from around the world. In particular, they evaluated the extent to which officials who abuse power are prosecuted or punished. Since this study is conducted biannually, Ukraine’s improvement in its score is largely attributed to the general adjustment of the Transparency International methodology. 

At the same time, the 1-point increase in Ukraine’s Freedom House report was due less to methodological changes and more to an actual update in the assessment of Ukraine’s progress. This report examines public perceptions of corruption; the business interests of senior politicians; financial disclosure laws and conflicts of interest; as well as the effectiveness of anti-corruption initiatives, among other factors. 

According to the Freedom House report, improvements in Ukraine’s corruption perception were influenced by several factors: the resumption of public e-declarations, the initiation of a case against former Supreme Court chairman Vsevolod Kniazev, the exposure and legal evaluation of abuses in defense procurement, and the postponement of launching the Register of Oligarchs following recommendations from the Venice Commission. At the same time, the study identifies threats to the effective implementation of the SAP—stemming from sabotage by certain corrupt government agencies—as negative trends.

Instead, the Rule of Law Index from the Global Justice Project—which examines the extent to which government officials exploit their positions for personal gain—indicates minor positive trends. According to more than two dozen experts who contribute to this index for each country, Ukraine experienced a slight improvement in all measured indicators between February and June 2024.

What impacted Ukraine’s indicator in 2023?

The results of Ukraine, like last year, were calculated based on 8 studies covering the period from February 2021 to September 2023.  

Three of them (Bertelsmann Foundation Transformation Index 2024, World Economic Forum Executive Opinion Survey 2023, Varieties of Democracy Project 2023) showed a significant increase in Ukraine’s indicator. Another (Political Risk Services International Country Risk Guide 2023) showed a slight decrease in the score.  

In the other four studies, the indicators did not change: Freedom House’s Report on Nations in Transit (study period — 2022) — 35 points, Global Insights Country Risk Ratings 2022 — 35 points, World Justice Project Rule of Law Index according to an expert survey conducted in February-June 2023 — 33 points, The Economist Intelligence Unit Country Risk Ratings 2023 (as of September 2023) — 20 points.  

The study of Bertelsmann Foundation’s Transformation Index 2024, according to which Ukraine scored 12 points, was conducted from February 2021 to January 2023 and covered the opinions of 280 experts from around the world. They, in particular, assessed the extent to which officials who abuse power are persecuted or punished. Therefore, we can state that the corruption scandals that we witnessed until January 2023 inclusive were reflected in this study. According to this study, a country loses points if “officeholders who break the law and engage in corruption can do so without fear of legal consequences or adverse publicity.” 

The World Economic Forum Executive Opinion Survey 2023, according to which Ukraine scored 8 points, was conducted in April-August 2023. Business executives answered questions about the prevalence of budget funds falling into the hands of individual companies or individuals as a result of corruption. Therefore, we can conclude that conducting most public procurement transactions at the expense of the budget through tender procedures in the Prozorro system helped Ukraine score in this study, despite the continued war. 

Over 4,000 experts from different countries work on the Varieties of Democracy Project 2023, conducted throughout 2022; according to it, Ukraine scored 5 points. The CPI includes indicators of corruption in the public sector, in particular, in the executive, judicial, and legislative branches.  

Therefore, in our opinion, the process of adopting the State Anti-Corruption Program (SAP) based on the previously adopted Anti-Corruption Strategy had a positive impact on the result. After all, the implementation of more than 75% of the measures planned in the SAP falls on the executive branch. The SAP also contains sections on fair trial and ensuring the integrity of political parties and election campaigns (recording the need for standards of ethical conduct of MPs). 

The Political Risk Services International Country Risk Guide 2023, according to which Ukraine lost 2 points, covered the period from September 2022 to August 2023. The PRS Group, based in New York, assesses corruption within the political system. In this study, among the risks, analysts note the secret financing of parties. Accordingly, this indicator did not reflect the resumption of political parties reporting to be verified by the NACP, which came into force a month ago after an almost 4-year break.

Which anti-corruption steps Ukraine needs to take, according to its allies

On December 14, 2023, the European Council adopted a historic decision to start negotiations on Ukraine’s accession to the EU. What should Ukraine do for truly successful European integration? What do Europe and our Western partners expect from us?

The answers to these questions can be found in the following important documents:

1. 2023 EU Enlargement Report on Ukraine as a candidate country
2. List of priority reforms from the White House
3. The latest report on the implementation of the memorandum between Ukraine and the IMF

Among these documents, the basis for our European integration is the first one — the report of the European Commission (EC). It is upon the implementation of its main recommendations that the European Council in March 2024 will decide whether to adopt a negotiating framework for the actual meaningful start of Ukraine’s accession negotiations.  

That is, by the time the first section of the negotiations on fundamental rights opens, Ukraine should have fulfilled the previous seven requirements of the European Commission. The recommendations were provided together with the candidate status in summer 2022, and four more—in the November report of the EC. 

For example, in the report, the EC noted that to ensure the effectiveness and sustainability of efforts to combat corruption, Ukraine needs to continue effectively investigating, prosecuting, and adjudicating high-level corruption cases, including the seizure and confiscation of criminal assets. 

To cope with the increasing burden on the bodies of the anti-corruption ecosystem, the European Commission advises increasing the number of NABU employees, SAPO prosecutors, and judges of the High Anti-Corruption Court. Interestingly, all this resonates with the list of priority reforms from the United States, which also covers almost all anti-corruption problems in our country.

Of course, the structural benchmarks of the requirements of the memorandum with the IMF to some extent coincide with the above documents. Moreover, Ukraine and the IMF jointly note that they will not allow for a retreat from the progress achieved in anti-corruption reform because these efforts will also contribute to strengthening public trust and donor confidence. 

But, more importantly, all these documents reflect not only the demand of international partners to the Ukrainian authorities, but also the needs of Ukrainian society as well! According to the results of the second wave of our sociological survey at the end of 2023, 88% of Ukrainians are now concerned with corruption risks. The population sees corruption as the greatest danger in the process of Ukraine’s recovery, with two parameters at once: lack of control and, as a result, embezzlement of funds (79%) and the resumption of corruption schemes (75%).

Citizens might not understand the features of strengthening the anti-corruption ecosystem and determining the necessary recommendations, but they are fully aware of the impact of corruption on their lives and the importance of assistance from international partners. Now we can see that Ukrainians clearly realize that continuing anti-corruption reforms is not only in the interest of the West, but also in ours as well.

TI Ukraine recommendations for 2024

Transparency International Ukraine provides 3 comprehensive steps that will help improve the level of anti-corruption and contribute to Ukraine’s European integration processes in 2024. 

1. Increase the effectiveness of the fight against high-profile corruption

• Increase the capacity and conduct an objective competitive selection of NABU employees, SAPO prosecutors, and judges of the High Anti-Corruption Court.
• Launch forensic service reform to ensure timely and sustainable access to forensic expertise in high-level corruption investigations. 
• Eliminate contradictions in criminal legislation and ensure that criminal cases are considered within reasonable terms.

2. Effectively use the assets of corrupt officials and accomplices of russia for the needs of the state

• Amend management selection procedures and conduct an independent audit of the ARMA’s activities. Increase the efficiency of asset management and sale.
• Improve confiscation mechanisms and the legal framework for asset recovery, aligning them with international standards.
• Improve the processes of blocking (pro-)russian assets (as sanctions preceding confiscation) and introduce criminalization of sanctions circumvention.

3. Launch the reform of the Accounting Chamber and the State Audit Service of Ukraine

• Develop and approve a draft law on reforming the Accounting Chamber and update the procedure for selecting its management and members. Prior to the legislative reform, the selection and appointment to the Accounting Chamber should be suspended.
• Shift the focus of the monitoring of public procurement by the State Audit Service from post-control to prevention. Monitoring and identifying significant violations should precede the conclusion of a contract to prevent losses and other negative consequences. 

CPI study: how it works

The Corruption Perceptions Index (CPI) is a ranking calculated by the global organization Transparency International since 1995. The organization itself does not conduct its own surveys. The Index is calculated based on 13 studies by reputable international institutions and think tanks.

The key indicator of the Index is the score, not the rank. The minimum score (0 points) means that corruption effectively replaces the government, while the maximum (100 points) indicates that corruption is almost absent in society. The index assesses corruption only in the public sector. 

The CPI includes the perspective of business representatives, investors, market researchers, etc. It reflects the private sector’s point of view and its perception of corruption in the public sector. 

It is important to keep in mind that the CPI measures the perception of corruption, not the actual level of corruption. A higher score of one country compared to another does not mean that the former has less corruption than the latter; it means that the former is perceived as less corrupt. 

The CPI methodology received a seal of approval from the European Commission for its reliable statistical approach. 

The CPI covers the perception of corruption in the public sector by experts, including bribery, embezzlement of public funds, nepotism in the civil service, capture of the state, the government’s ability to implement integrity mechanisms, effective prosecution of corrupt officials, excessive bureaucracy, availability of adequate laws on financial disclosure, prevention of conflicts of interest and access to information, ensuring the protection of whistleblowers, journalists, and investigators.

Why is CPI necessary? 

• The CPI covers more countries than any single source.
• The CPI compensates for the error in different sources using the average of the results of at least three different sources.
• The CPI scale of 0 to 100 is more accurate than other sources, as some have a scale of 1 to 5 or 1 to 7, which results in many countries receiving the same results. 
• The CPI balances different perspectives on corruption in the public sector and has a neutral approach to different political regimes.

What Do the Results of the Ukrainian CPI Mean in the Context of the War?

33 points scored by Ukraine in 2022 is the highest indicator of our country since the launch of the updated CPI methodology. Thus, over the past 10 years, the indicator of Ukraine has increased by 8 points.

Despite the russian invasion, our country has shown that its progress in the fight against corruption is a sustainable process that continues even in the most difficult period of the state’s existence.

Among the undoubted positive results of the past year are the adoption of the State Anti-Corruption Strategy, the long-awaited appointment of the head of the Specialized Anti-Corruption Prosecutor’s Office (SAPO), which became a driving force for intensifying investigations into high-profile corruption. Moreover, the High Anti-Corruption Court showed its effectiveness — in 2022, the court considered 49 cases, 37 of which resulted in sentences.

However, the growth of Ukraine in recent years could have been much more noticeable, and the effect of the fight against corruption — more tangible.

Had the competition for the election of the SAPO head not been delayed, but had ended, as it should have, in 2021, when the name of the winner was already known, anti-corruption investigations would have intensified earlier. Had the parliament not delayed the adoption of the Anti-Corruption Strategy for 2 years, Ukraine would have received a clear action plan in the fight against corruption much earlier.

Had the anti-corruption bodies had full operational and institutional capacity (the actual possibility of wiretapping for the NABU, access to proper forensic expertise, expanding the powers of the SAPO, providing for audits of all anti-corruption bodies), the anti-corruption system, which survived during the full-scale war, would work more effectively.

What Influenced This Year’s Performance of Ukraine?

The growth of Ukraine by one point is a change within the margin of error, so, we should consider the results over several years. Our country shows positive dynamics, even despite the military aggression of russia.

This year, the results of Ukraine were calculated based on 8 studies (one less than last year). One of them (World Economic Forum Executive Opinion Survey 2021) showed a significant increase in Ukraine’s indicator. Another one (The PRS Group International Country Risk Guide 2022) showed a slight decrease in indicators, while in the other 6 studies, the indicators did not change.

The World Economic Forum Executive Opinion Survey 2021, according to which Ukraine has increased its score by 9 points, was conducted in April-October 2021 and covered the opinions of 12,550 business leaders in 124 countries. This study considers the opinion of entrepreneurs about the prevalence of bribes in the country. However, according to the terms of the survey, such trends were observed even before the full-scale invasion of russia into Ukraine. Moreover, the indicators could be influenced by positive changes in public procurement, effective privatization of public property, etc.

At the same time, The PRS Group International Country Risk Guide 2022, according to which Ukraine lost 2 points, was conducted from September 2021 to August 2022 and considers the assessment of corruption in the political system during the war as well. In particular, this study pays special attention to existing or potential corruption in the form of excessive selective protection, nepotism, booking jobs, trade turnover, secret financing of parties, and suspiciously close ties between politics and business.

Since Ukraine has suspended the obligation of political parties to submit financial and other reports for NACP verification, in our opinion, this could have led to a decrease in the scores under this study.

If we consider other studies that affected Ukraine’s performance in the CPI, then Freedom House Nations in Transit for 2021 positively mentions the restoration of proper criminal liability for false declarations in the summer of 2021. However, it is noted that in 2021, anti-corruption bodies experienced attempts to weaken their independence and institutional capacity, and the Specialized Anti-Corruption Prosecutor’s Office did not have a head due to a delayed competition. The unreformed sector of justice, prosecutor’s office, and law enforcement agencies is also mentioned as a threat to the stability of anti-corruption bodies. This also covers the lack of obligation of political parties to submit reports to the NACP. Therefore, according to this study, the score of Ukraine for the year has not changed.

Recommendations of Transparency International Ukraine for 2022: What Has Been Implemented?

According to the results of last year’s CPI, Transparency International Ukraine provided the authorities with 5 specific recommendations, the implementation of which could improve our performance in the study. None of these recommendations were fully implemented, four were partially implemented, and one was not implemented at all.

Partially implemented:

• Complete the competitions and select professional, independent, and honest leaders of the anti-corruption ecosystem: the Specialized Anti-Corruption Prosecutor’s Office, the Asset Recovery and Management Agency, and the National Anti-Corruption Bureau;
• Adopt the State Anti-Corruption Strategy and the program for its implementation;
• Ensure transparent accounting of public property and continue on the path to privatization;
• Minimize the risks of adopting draft laws that remove procurement from the scope of the Law of Ukraine “On Public Procurement”.

Not implemented:

• Conduct the reform of constitutional justice, considering the opinions provided by the Venice Commission.

Read a detailed analysis of the implementation of recommendations in the full text of the study.

Recommendations of TI Ukraine for 2023, Which Will Help Reduce the Level of Corruption

Transparency International Ukraine offers 4 comprehensive steps that will help improve the level of anti-corruption and contribute to the effective recovery of Ukraine in 2023.

Global trends in corruption perception in 2022

Corruption, conflict, and security are the focus of this year’s CPI. Last year’s findings showed that corruption can undermine political, social, and economic stability and ultimately threaten peace and security in general. At the same time, corruption also creates fertile ground for organized criminal activity, even terrorism, as criminals are aided in their illegal activities by the complicity of corrupt officials.

The Corruption Perceptions Index 2022 shows that most countries have not made significant progress in the fight against corruption in more than 10 years. However, the scale of the problem is enormous: the global average remains unchanged at 43 points out of 100 for the eleventh year in a row, and more than two-thirds of countries (122) have serious problems with corruption, scoring less than 50 points.

Transparency International has developed global and universal guidelines for all governments. These tips will help ensure an effective fight against corruption, help avoid armed conflicts and guarantee the safety of citizens of different countries.

Address the threats that corruption and illicit finance pose to peace and security core business of political leaders, and an integral focus of both foreign and domestic policy.

Reinforce checks and balances and promote separation of powers to insulate against corrupt control and ensure that no branch can consolidate authority. Governments must sufficiently resource anti-corruption agencies and oversight institutions, and pay special attention to risks within defense and security institutions, as identified in the Government Defense Integrity Index (GDI).

Share and uphold the right to information, so the public knows where public spending is going and how resources are distributed, leaving this open to scrutiny from journalists and civil society. In cases of sensitive information, there must be rigorous and clear guidelines for withholding it, including in the defense sector.

Limit private influence by regulating lobbying and promoting open access to decision-making so that policies are determined by fair and public processes. This means establishing public registers of lobbyists so that the public can scrutinize who is lobbying and identify conflicts of interest.

Combat transnational forms of corruption to stop kleptocrats and protect the common good. Top-scoring countries need to clamp down on corporate secrecy, foreign bribery and complicit professional enablers. They must also take advantage of new ways of working together, initiated after the Russian invasion of Ukraine, to make sure that illicit assets can be effectively traced, investigated, confiscated and returned to the victims.

CPI: How It Works

Corruption Perceptions Index (CPI) is a ranking calculated by the global organization Transparency International since 1995. The organization itself does not conduct its own surveys. The Index is calculated based on 13 studies of reputable international institutions and think tanks.

The key indicator of the Index is the score, not the rank. The minimum score (0 points) means that corruption effectively replaces the government, while the maximum (100 points) indicates that corruption is almost absent. The index assesses corruption only in the public sector.

CPI considers the point of view of businesses, investors, market researchers, etc. CPI reflects the opinion of the private sector and its perception of corruption in the public sector.

It is important to keep in mind that CPI measures perception of corruption, not the actual level of corruption. A higher score in one country than in another does not mean that the former has less corruption than the latter — it means that the former is perceived as less corrupt.

The CPI methodology received a seal of approval from the European Commission for its reliable statistical approach.

CPI covers perception of corruption in the public sector by experts, including: bribery, embezzlement of public funds, nepotism in the civil service, capture of the state, the government’s ability to implement integrity mechanisms, effective prosecution of corrupt officials, excessive bureaucracy, availability of adequate laws on financial disclosure, prevention of conflicts of interest and access to information, ensuring the protection of whistleblowers, journalists and investigators.

Ukraine in a 10-year retrospective: ups and downs

Since 2012, Ukraine’s performance has improved significantly. It is among the 26 countries that have recorded statistically significant growth over the 10-year perspective. The list also includes Armenia, Angola, Greece, and Italy. 

This improvement is due to the changes that occurred immediately after the Revolution of Dignity. Since 2018, Ukraine’s steady growth has stopped. Despite the positive changes, there were some negative events that outweighed anti-corruption achievements. This trend can also be clearly seen in the results of 2021.

Of course, we cannot state there were no positive anti-corruption developments over the past year. Last year, all NACP’s powers were restored, the institution of whistleblowers was saved, the  laws on the work of the ARMA and the NABU were updated, dozens of HACC sentences were passed, the civil forfeiture instrument began functioning. However, as we can see, all these anti-corruption positives were not enough for a growth in the Corruption Perceptions Index.

The Index data was also positively influenced by the launch of an electronic register of political party reporting Politdata by the National Agency on Corruption Prevention (NACP). The register started functioning in the spring of 2021, but the long-awaited electronic reporting for political parties has not yet been fully operational, and this crucial process was suspended by law back in the spring of 2020 due to the COVID-19 pandemic. 

In 2020-2021, parliamentary parties received almost UAH 1.5 bln of taxpayer funds, but how they were spent remained a mystery. In November 2021, the President vetoed the law on pseudo-renewal of political party reporting and returned it to the Verkhovna Rada, which TI Ukraine and more than 60 other civil society organizations called for.

All the listed changes are the completion of the processes planned before 2021. However, the negative manifestations over the past year have sometimes become systemic, and only the active resistance of MPs, officials, media representatives, the public, and the international community really interested in Ukraine’s progress made it possible to minimize the downfall of Ukraine’s indicator in the CPI.

+6 points in 10 years is not a good enough result for a country whose leaders have set the fight against corruption as one of the priority goals of their activities.

Global trends in corruption perception in 2021

The CPI 2021 reveals that last year, there was again no significant change in the counteraction and the fight against corruption at the level of all 180 countries considered in the study. Over the past decade, slow dynamics have been typical for most of the world — yes, two-thirds of all countries have not yet passed the threshold of 50 points out of 100. The scale of the problem is enormous: the average CPI remains unchanged at a score of 43 out of 100 for the tenth year running. 27 countries, such as Cyprus, Lebanon (24 points), and Honduras (23 points) are at historic lows in their score.

This year, Finland has joined the permanent leaders of the CPI Denmark and New Zealand, having improved its indicator by 3 points in a year and now having 88 points out of 100 possible.

The bottom countries are those with an unstable political situation, military conflicts, and where governments only partially control the territory of the state — Somalia (13), Syria (13), and South Sudan (11).

Malawi has shown the largest increase in points (+5) — 35 points, 110th place in the ranking. In recent years, local law enforcement agencies have effectively investigated several cases of high-profile corruption. This led to verdicts in several high-profile cases related to the “Cashgate” scandal. The same year, Malawi’s Anti-Corruption Bureau arrested the energy minister and two other officials on suspicion of corruption related to a government oil contract.

Since 2012, 25 countries improved their CPI scores, including Italy, Seychelles, and Armenia, but over the same period the scores of 23 countries dropped (for example, Saint Lucia, Cyprus, and Syria). The indicators of other countries did not change significantly from 2012 to 2021.

In 2021, as part of the CPI study, Transparency International identified a pattern between the level of corruption and the state’s provision of human rights and freedoms. Since 2012, civil liberties in 90% of countries have stagnated or declined. While some authoritarian governments are good at controlling specific types of corruption at lower levels, this is usually accompanied by an expanding kleptocracy at the highest levels of government and anti-corruption laws being used to target their political enemies.

Corruption and impunity also contribute to a dangerous climate for human rights activities. Of the hundreds of human rights defenders murdered in 2020, 98% occurred in the 23 countries with high levels of public sector corruption (with a CPI score below 45). 

Transparency International calls on the public to demand that governments act on their own anti-corruption and human rights commitments. Many of the anti-corruption successes in recent history have been due to the tireless, coordinated efforts of ordinary people, who have taken great personal risks to make change happen.

Transparency International has developed global and universal recommendations for all governments. These tips will help put an end to the vicious cycle of corruption, human rights violations, and democratic decline. All of them will be useful for Ukraine as well.

• To uphold the rights needed to hold power to account. Governments should roll back any disproportionate restrictions on freedoms of expression, association, and assembly introduced since the onset of the pandemic. Ensuring justice for crimes against human rights defenders must also be an urgent priority.
• To restore and strengthen institutional checks on power. Public oversight bodies such as anti-corruption agencies and supreme audit institutions need to be independent, well-resourced, and empowered to detect and sanction wrongdoing. Parliaments and the courts should also be vigilant in preventing executive overreach.
• To combat transnational forms of corruption.Governments in advanced economies need to fix the systemic weaknesses that allow cross-border corruption to go undetected or unsanctioned. They must close legal loopholes and ensure that the corrupt and their accomplices cannot escape justice.
• To uphold the right to information in government spending. As part of their COVID-19 recovery efforts, governments must make good on their pledge contained in the June 2021 UNGASS political declaration to include anti-corruption safeguards in public procurement. Maximum transparency in public spending protects lives and livelihoods.

Why has Ukraine’s score grown?

Ukraine’s assessment was formed based on 9 different surveys, and in all of them, Ukraine’s indicators either did not change or increased in comparison with СРІ-2019.

The largest increase is observed in the data of Global Insight Country Risk Ratings — by 13 points. This study examines the risks of people/companies in the country facing bribery or other corrupt business practices, from large contracts to day-to-day work.

The CPI can show the actual changes across the country rather slowly — sometimes it takes several years. Thus, the score of 2020 indicates the positive development that has occurred in Ukraine in the last two years, especially until the spring of 2020, and does not take into account the resonant events of recent months.

In general, an improvement or deterioration of 3 points is not considered a statistically significant result. This means that such a score should be perceived as the result of several years as evidence of planned changes in the fight against corruption in the country.

Ukraine’s index in 2020 has improved due to launching of the High Anti-Corruption Court with appropriate jurisdiction and restart of the National Agency on Corruption Prevention. The restart of the NACP began with the election of a new head of the Agency with the participation of the representatives of the international community. 

It is these events that have finally “completed the chain” of creating the anti-corruption infrastructure in Ukraine that previously could only partially work. 

The positive results of Ukraine in 2020 were also affected by the anti-corruption changes introduced during the “turbo-mode” of the Verkhovna Rada of the IX convocation. These are, in particular, the new legislation on the right to exercise covert investigative actions independently for the NABU, returning responsibility for illicit enrichment, strengthening of protection of whistleblowers, and necessary changes in the field of public procurement. The improvement of our position was also influenced by small-scale privatization, anti-corruption initiatives of the Honcharuk government, and the long-awaited test launch of the NACP electronic register of political parties’ accountability. 

All these changes were undoubtedly reflected in the Corruption Perceptions Index of Ukraine. But over the past year, risks have emerged that could significantly push us back in the fight against corruption. In particular, the delay in the implementation of full-fledged judicial reform is even more poignant today. 

Throughout 2020, there was constant pressure on anti-corruption institutions: attempts to dismiss the NABU director in circumvention of the law, interference by the authorities and individuals in the investigation and trial of high-profile corruption cases, in particular through the involvement of the judiciary. At the end of the year, the crisis of constitutional justice occured, which was accompanied by the inability of the state leadership to fully overcome it.  

Besides, there were also attempts to disrupt and level anti-corruption achievements in the field of public procurement. In particular, both the government and the Parliament are trying to amend the legislation and implement the localization in public procurement that, according to the research of experts, drives the domestic economy to a dead end and contradicts Ukraine’s international obligations.

The issue of attacks on activists became even more urgent in 2020. Four years in a row we have been observing the systemic pressure on civil society, which has moved from the regional level to the national, but the guilty are often not punished. 

Thus, if we do not stop all these negative processes and trends, next year our indicators in the Corruption Perceptions Index may change significantly and drastically.

In early 2020, Transparency International Ukraine provided 5 recommendations, which could improve Ukraine’s performance in the CPI. As the year’s end, none had been fully implemented, two had been partially implemented and three had not been implemented at all.

Recommendations the authorities partially implemented (2)

Improve the effectiveness of political corruption prevention systems

On July 16, the NACP launched the long-awaited trial operation of the electronic register of reports of political parties Politdata. As of the beginning of 2021, the register has not been put into commercial operation, it is yet to be launched. 

The effectiveness of state control over the financing of political parties still has some gaps. For example, the downside is that the analysis of the financial statements of candidates/parties in local elections (sometimes not even published and with no full access to them by the NACP) is entrusted to territorial election commissions, which consist of candidates from the political parties themselves. The effectiveness of state control is weakened by the fact that reports of different types are submitted to different state bodies in different ways. And the deadlines for reporting by parties to the NACP are constantly being extended due to the ongoing quarantine.

Liability for violations in this area also remains unbalanced. For failure to submit election reports, one can expect fewer penalties than for inaccurate reporting. There was no improvement in accountability, such as withdrawal from the election campaign or an increase in fines. 

Introduce an open and accountable process of public property privatization

Due to small-scale privatization, the Ukrainian budget received UAH 3.03 billion in 2020. This is 6 times more than planned. Such achievements became possible due to the restructuring of the process of preparation of objects for auctions, the proactive position of the Ministry of Economic Development and Trade, and the State Property Fund of Ukraine. It is a question of establishing open virtual rooms of the data on the facilities put up for sale which have replaced inefficient paper “Bulletin of privatization”. 

However, the significant legislative changes, which would have a positive impact on the privatization process, never happened. In addition, in the spring of 2020, holding auctions for the privatization of large facilities was banned by the Parliament until the end of quarantine. Although the SPFU continued to prepare such facilities for privatization (this process lasts 11-12 months for each company), the ban postponed auctions for facilities already ready for sale, including the United Mining and Chemical Company.

The number of state-owned enterprises is still excessive. Only some of them work and are profitable, while most are unprofitable or even exist only on paper. During 2020, significant progress in the disclosure of information on the activities of SOEs did not happen. This is partly because state-owned enterprises are managed by more than 90 different authorities. 

The only portal where you can find aggregate information about the activities of most state-owned enterprises is the Portal of State-Owned Enterprises of Ukraine developed jointly with the Ministry for Development of Economy, Trade, and Agriculture of Ukraine Prozvit. The information there, however, is incomplete and is often submitted by management entities with a long delay.

Not implemented (3)

To form an independent and professional judiciary

This recommendation is an extremely high priority and, unfortunately, repetitive. In fact, no progress has been made on judicial reform in two years. 

Last year, the President and Parliament tried several times to start a painful process of change. And although the deputies adopted the first Presidential draft law in 2019, on March 11 the Constitutional Court of Ukraine declared key provisions of that law unconstitutional. The next attempt to launch the reform was also initiated by the President through Draft law 3711. But it has been mercilessly criticized by the Venice Commission and the expert community and is awaiting finalization and second reading.

High integrity composition of the High Council of Justice, elected with the participation of the international community and community experts, remains a current requirement of the IMF, and a recommendation of the Venice Commission and the public. However, this did not in any way affect any steps towards reformatting this body. The composition of the High Qualification Commission of Judges is also awaiting updating, but it is unknown when such a restart will finally take place and whether best practices in tendering procedures will be taken into account.

Ensure the independence and capacity of anti-corruption bodies 

The threat to independence and the strengthening of political influence on anti-corruption institutions have been relevant since the beginning of the anti-corruption reform, but these issues became especially acute in 2020. 

Thus, last year the MPs only on the third attempt managed to appoint their representatives to the board on the selection of the head of the Specialized Anti-Corruption Prosecutor’s Office. Unfortunately, some of the elected members of the commission from the Parliament do not meet the requirements of the law and have no proven experience in anti-corruption activities. And only in January 2021 submission of documents from candidates began. We emphasized the need for transparent and fair competition for the selection of the SAPO head in the recommendations for 2019.

At the same time, the issue of appointing a new head of the SAPO is becoming more relevant with each regular high-profile anti-corruption investigation. Due to the imperfection of the law on the prosecutor’s office and limited powers of the SAPO acting head, the Prosecutor General Iryna Venediktova had the opportunity to repeatedly interfere in the course of high-profile NABU-SAPO investigations undermining the independence of these institutions. Thus, the Prosecutor General did not miss the opportunity to study and even influence the proceedings in the high-profile corruption cases of 2020 (cases against Maksym Mykytas, Oleh Tatarov, Oleh Bakhmatiuk, etc.).

Independence and impartiality of the State Bureau of Investigation in 2020 also became more relevant. Following the relevant legislative changes, the SBI is under significant control of the President, although this is contrary to the Constitution of Ukraine. A series of debatable actions and scandals primarily characterized the work of the Bureau last year. 

It is worth mentioning that the decision of the Constitutional Court of Ukraine on the powers of the President to establish the National Anti-Corruption Bureau of Ukraine, to appoint its chairman, to form a public council. This decision was a significant institutional blow to the NABU, but attempts to get out of this situation still failed. Unfortunately, the Verkhovna Rada failed to amend the NABU law within three months and clearly define a new procedure for appointing its leadership. 

Not a small blow to the anti-corruption system, in general, was the decision of the CCU of October 27, 2020 which canceled a significant part of anti-corruption reform. Thus, precisely because of the recognition of Article 366-1 of the Criminal Code of Ukraine as unconstitutional, the NABU was forced to close dozens of cases concerning lies in declarations and their deliberate non-submission. The HACC also had to close cases and even overturn sentences under this article.

It is worth noting that thanks to the same decision of the CCU in 2020, the authorities needed to re-process our recommendation for 2019, which concerned the NACP. For example, The Verkhovna Rada had to pass a law again on the restoration of the powers and rights of the Agency, their respective features in relation to judges and judges of the CCU, etc.

No fewer problems are observed with the independence and full-fledged work of the Asset Recovery and Management Agency. In 2020, MPs did not vote for the much-needed legislative changes, which aim to improve the implementation of functions for the management of assets seized in criminal proceedings by the ARMA (Draft law 3335). Instead, the committee supported an alternative draft law (No 3335-1), which provides for a significant narrowing of the ARMA’s capacity to manage the seized property and does not solve the Agency’s existing problems. At the same time, the ARMA has remained without a leader for more than a year, because during this time the Parliament has not managed to decide on its representatives to the relevant selection board.

Under such conditions, the question of an independent audit of anti-corruption bodies was not on the agenda at all, which is bound to cause concern. After all, a full-fledged independent external audit can clearly answer the question of the effectiveness of the bodies and eliminates all allegations about the need for an anti-corruption system in general.

To deprive the Security Service of Ukraine of its powers in the sector of economic corruption crime prevention

This recommendation of Transparency International Ukraine is also not implemented for the second year in a row. In its current form, the Security Service of Ukraine has uncharacteristic functions. It is primarily about investigating economic and corruption crimes.

There is a draft law in the Parliament, designed to finally implement such a reform. However, the Service itself and its head support the preservation of powers in their current form, as Ivan Bakanov has repeatedly stated publicly.

The future of the Bureau of Financial Investigations promised by the authorities also remains uncertain. In September 2020, the relevant law was passed in the first reading, but the draft law is not ready for the second reading. We should emphasize here that the establishment of a new politically independent agency to investigate serious economic and financial crimes is one of the requirements for obtaining the EU macro-financial support.

World trends of 2020

CPI is important because it allows you to compare data from different countries using a single approach. And this approach does not take into account the specifics of each country but considers the global context. 

Since 2012, 26 countries have significantly improved their performance in the Index (e.g., Ecuador, Greece, Guyana, Myanmar, and South Korea), and 22 countries have significantly reduced their performance (e.g., Lebanon, Malawi, Bosnia, and Herzegovina, Malta, Poland, and Guatemala). The performance of nearly half of other countries has not changed over the past 10 years, indicating a halt in governments’ efforts to tackle corruption’s root causes.

СРІ 2020 found that persistent corruption undermines health care systems and promotes a retreat from democracy in the wake of the COVID-19 pandemic. Over the past year, reports of corruption during the pandemic have spread across the globe, from bribes for testing and treatment to public procurement of medicine. During a pandemic, governments’ measurements often lacked transparency, restricted civil rights, and served the private interest rather than the public good. 

It is noteworthy that countries with widespread corruption are the least prepared to deal with such crises. However, a fair recovery can be achieved if decisions are made in the public interest rather than powerful players.

Instead, countries with high CPI scores invest more in health care, make it more accessible to all, and are less likely to violate the rule of law or democratic norms or institutions in response to the crisis. 

Transparency International has developed global and universal recommendations for all governments to reduce corruption and respond more effectively to future crises. 

It is required: 

• to ensure the independence, capacity, and funding of oversight and anti-corruption institutions so that resources reach those who need them;
• to ensure open and transparent contracting to combat wrongdoing, identify conflicts of interest, and ensure fair prices;
• to protect democracy and promote the development of civil society to create the conditions for accountability of governments;
• to publish relevant data and guarantee access to information so that the public receives simple, accessible, timely, and meaningful information.

CPI research: how it works

The Corruption Perceptions Index (CPI) is an index compiled by the global organization Transparency International since 1995. The organization itself does not conduct any surveys. The index is calculated based on 13 studies of reputable international organizations and think tanks.

The key indicator of the Index is the number of points, not the place in the ranking. The minimum score (0 points) would mean that corruption effectively replaces the government, while the maximum score (100 points) would indicate the near-complete absence of corruption. The index only assesses corruption in the public sector.

CPI includes the point of view of business representatives, investors, market researchers, etc. It reflects the private sector’s point of view and its perception of corruption in the public sector.

It is important to remember that the CPI measures perception itself, not the actual level of corruption. Comparing a country with a higher score to the one with lesser does not mean that the former is less corrupt than the latter. This means that the former is perceived as less corrupt.

The CPI methodology has received a stamp of approval from the European Commission for its reliable statistical approach.

CPI covers the perception of corruption in the public sector by experts, in particular: bribery; embezzlement of public funds; nepotism in the civil service; seizure of state power; the government’s ability to implement integrity mechanisms; effective prosecution of corrupt officials; excessive bureaucracy; availability of appropriate laws on financial disclosure, prevention of conflicts of interest and access to information; ensuring the protection of whistleblowers, journalists, and investigators.

Why CPI?

– CPI covers more countries than any other single source.

– CPI compensates for the error in different sources, using the average of the results of at least three different sources.

– The CPI scale from 0 to 100 is more accurate than other sources, as some have a scale of 1 to 5 or 1 to 7, so many countries get the same results.

– The CPI balances different perspectives on corruption in the public sector and has a neutral approach to different political regimes.

For reference

Transparency International is an anti-corruption organization founded in 1993 in Berlin by Peter Eigen, former director of the World Bank. Delia Ferreira Rubio is currently the chairman of the TI board. Transparency International is found in more than 110 countries of the world. The organization is best known for the Corruption Perceptions Index and the Global Corruption Barometer. According to the  Global Go To Think Index Tank Report for 2017, Transparency International ranked 3rd out of 143 independent think tanks in the world. And in first among 67 world analytical institutions dealing with the topic of Open and Good Governance.

Transparency International Ukraine is an accredited chapter of the global movement Transparency International with a comprehensive approach to the development and implementation of change to reduce corruption.  

TI Ukraine administered and transferred the ProZorro, ProZorro.Sale and eHealth systems to the government. Our innovation and expert center has also implemented the City Transparency Ranking and is building the DOZORRO community to monitor public procurement.

Media contacts: Olesia Koval, koval@ti-ukraine.org, 093-808-82-78.

Why has Ukraine’s score deteriorated?

Ukraine’s score is based on 9 different sources. In three, it improved slightly, in three, no change has happened, in the remaining three, its score decreased.

The biggest loss is the loss of 13 points in the research Global Insight Country Risk Ratings. The risk in question is whether people and companies in the country are likely to encounter bribery or other corrupt business practices in their economic activity, including public contracting and everyday work. 

It should, however, be noted that, similar to other indices, the CPI can be slow to reflect what is happening on the ground in many countries. It sometimes takes months, if not years, to account for real-world events in the CPI. Even when countries address corruption issues head-on, sometimes they experience worse scores on the CPI, at least initially, as scandals come to light.

The CPI is based on research for the past two years. Since the beginning of 2017, reforms and anti-corruption struggle in Ukraine started somewhat rolling back. The authorities made increasingly active attempts to restrict the independence of anti-corruption agencies, stalled the launch of the High Anti-Corruption Court, came up with arbitrary legislative restrictions. Not to mention the political bias of the NACP, the failed judicial reform and the lack of the proper reform of anti-corruption agencies. 

Not only did the authorities hardly listen to the advice of the civil society and international partners, they sometimes actively obstructed the required changes. During the past two years, the government ignored most recommendations, some of which were critically important for the country. 

It should be noted, however, that Ukraine’s lowest score was in 2013 (25 points) — the last year of Yanukovych and his regime in the country. Since the Revolution of Dignity, Ukraine has been gaining points steadily, if slowly. The previous administration was evidently not determined enough to fight against corruption, which led to their loss at the presidential and parliamentary elections.

Countries which fight against corruption successfully are those which observe the rule of law, ensure independence of oversight agencies and where society has a negative attitude to abuse of power and public funds for personal gain.

The new team headed by the President effectively received their power, together with responsibility, in August 2019, thus the results of their work will be reflected in the next CPI. We urge the President and the Parliament majority to remember about separation of powers, formalized in the Constitution of Ukraine, and the rule of law. The balance of the legislative, executive and judicial powers and the powers of the President should be maintained regardless of the political needs and interests of private individuals. 

At the beginning of 2019, Transparency International Ukraine provided 12 recommendations which could have improved Ukraine’s CPI score. As of the end of the year, only 6 were completely or partially implemented, and even that happened in the last quarter of 2019. 

Fully implemented recommendations (2)

Monopoly of the SBU for wiretapping (lawful interception of telecom networks) has been abolished, as has public monopoly for forensic reviews, which renders stalling of the investigation in this part impossible. 

The Verkhovna Rada has also established the procedure of serving special subjects with charges. This formal moment used to be abused quite a lot by the defense, as they demanded personal presence of the Prosecutor General or his deputies. 

Yet, the Criminal Procedural Code retains the provisions which negatively affect the quality and effectiveness of pretrial investigations, especially when it comes to corruption-related crimes. For instance, detectives are restricted in the duration of the investigation, which may lead to less comprehensive findings. 

On June 6, 2019, the Constitutional Court of Ukraine abolished discriminatory electronic declarations for anti-corruption activists. The Court concluded that this restricts the constitutionally guaranteed freedom of political and civic activity and may be used as a tool of persecution. 

Partially implemented recommendations (4) 

On October 18, the law rebooting the NACP came into effect. The Agency got rid of its formerly collegiate decision-making, and its Head was selected with the participation of international experts. At the end of the year, the NACP obtained automatic access to three registers required for verification of e-declarations. 

However, when the acting Head was in the office, full verification did not take place. There is also no technical possibility yet to distribute declarations for verification automatically among the authorized Agency staff. Thus, adequate automatic verification of declarations and lifestyle monitoring are yet to be implemented. The Head of the National Agency was appointed on January 15, 2020.

After the off-schedule parliamentary elections, the new draft law in the sphere of public procurement was passed on September 19, 2019. The new Law of Ukraine “On Public Procurement” will come into effect on April 19, 2020, and is harmonized with EU standards. However, the issue of effective procurement monitoring by the State Audit Service remains important. The results of procurement monitoring leave much to be desired as both sanctions and monitored tenders are quite few. 

The Parliament provided an opportunity for privatization of 500 state-owned enterprises through the electronic system of auctions ProZorro.Sale. In October 2019, the Parliament abolished the prohibition for privatization of a number of state-owned enterprises. 

In October 2019, the Code of Bankruptcy Procedures came into effect and the Cabinet of Ministers Directive on electronic auctions for sale of property of insolvent enterprises through the ProZorro.Sale system was passed. 

The practice of open budgets is noticeably growing. Among other things, there is a public budget portal for citizens, administered by the Ministry of Finance of Ukraine.

Last year, the Government approved the composition of supervisory boards in the following state-owned enterprises: Seaport Administration of Ukraine, Boryspil International Airport, Ukrzaliznytsia, Ukrhydroenergo. However, the process of creation of supervisory boards under utility companies in local communities did not accelerate. Among the biggest Ukrainian cities, only Chernivtsi, Ternopil and Mariupol city councils passed the respective regulations on the creation of supervisory boards. 

Recommendations which have not been implemented (6)

Ensuring the effective work of the beneficial owners register

A working group made up of representatives of public institutions and experts has been created, but the verification mechanism has not yet been launched. 

Increased oversight of political party funding

The legislation on regulation of political advertising and restriction of its volume has not yet been passed. Liability of parties for violation of the campaign laws has not increased, either. The Parliament has formalized the obligation of parties to file public e-reporting; yet, it is yet to be implemented.

In December 2019, the President signed the new Electoral Code. The document stipulates changes in the electoral system and deposits for the candidates and parties at elections of all levels. For instance, the deposits for local councils have been raised almost times forty (compared to 2015). 

Change in the formation of judicial governance bodies

The Parliament has supported the draft law on the activity of judicial governance agencies. This initiative was supposed to regulate problematic issues in the activity of the High Qualification Commission of Judges of Ukraine and the High Council of Justice. However, the law does not provide for a reboot of the HQCJ. And the Council itself will still be making a number of final decisions. The document also does not stipulate engagement of representatives of the public in the reboot of judicial governance agencies.

Restoring the credibility of the Specialized Anti-Corruption Prosecutor’s Office

After having been elected, the President and his team held a meeting with heads of the NABU and the SAPO, urging them to cooperate and work effectively. Afterwards, there was no public tension between the two institutions. However, restoring the credibility of SAPO and its leadership is only possible based on the results of the High Anti-Corruption Court and guilty verdicts for officials guilty of grand corruption.

Stripping the SBU and the National Police of the powers to investigate economic crimes

No significant steps were made towards this in 2019. The authorities expressed the intention to do this — for instance, in August 2019, the MIA announced the dissolution of the Economy Protection Department under the National Police. However, this is nothing but a symbolic step, since the relevant provisions of the Criminal Procedural Code remain in force. It is also necessary to strip the SBU of its uncharacteristic functions of a pretrial investigation agency and have the agency focus on counterintelligence and analysis. 

It should also be noted that there have been incomplete attempts to pass a draft law on creation of the Bureau of Financial Investigations. 

Punishing those guilty of attacks on anti-corruption activists

In 2019, there were attempts to reinforce the investigation, but it is slow in over 50 cases of attacks and pressure against activists and does not meet the society’s expectations. A vivid example of this is the investigation of the tragic death of Kateryna Handziuk, where the society is yet to get the answers it demands. 

Global trends 2019

What is important about CPI is that its unified approach makes it possible to compare the data from different countries. While this approach disregards the peculiarities of each country, it takes into account the global context. For instance, the previous Index demonstrated that low levels of democracy and freedom tend to go hand in hand with high levels of corruption.

Overall, CPI 2019 demonstrates a global negative trend. The index shows a staggering lack of political integrity, which leads to a high level of corruption, including the negative impact of big money on politics. More than two-thirds of countries score below 50 on the CPI, with an average score of just 43. The situation has been similar in the recent years. 

Since 2012, only 22 countries significantly improved their CPI scores (e.g., Greece, Guyana, Estonia) and 21 countries significantly decreased their scores (e.g., Canada, Australia, Nicaragua). The remaining countries made little or no progress in the fight against corruption in recent years.

Notably, corruption is more pervasive in countries where big money can flow freely into electoral campaigns and where governments listen only to the voices of wealthy or well-connected individuals. Curbing corruption is only possible when the influence of big money on politics is restricted and there is broad consultation in policy decisions.

Countries that perform well on the CPI also have stronger enforcement of campaign finance regulations and broader consultation in policy decisions. Conversely, countries with lower CPI scores experience an uneven balance of power, where a few wealthy individuals control government purse strings and decision-making.

Transparency International has made global universal recommendations to curb corruption effectively. Apart from the above-mentioned oversight of party funding, separation of power and reinforcing checks and balances, it is necessary to:

• Manage conflicts of interest and address “revolving doors”;
• Regulate lobbying activities by promoting open and meaningful access to decision-making;
• Empower citizens and protect activists, whistleblowers and journalists.

CPI research: how does it work?

Corruption Perceptions Index (CPI) is an index compiled annually since 1995 by the global organization Transparency International. The organization itself does not conduct any surveys, instead relying upon 13 surveys and assessments of reputable international organizations and think tanks.

The key figures of the Index are the scores, not the ranks. The minimum score (0 points) means that corruption basically replaces the government, while the maximum score (100 points) means that there is almost no perceived corruption. The Index only assesses corruption in the public sector. 

CPI sources use survey data from investors, business people, market analysts, etc., and the CPI reflects the private sector’s opinions and perceptions of corruption in the public sector.

It’s important to remember that CPI measures perception of corruption, not its actual level. The fact that country X has a higher score than country Y does not necessarily mean that country X is less corrupt: it means that the former is perceived as less corrupt.

In 2017, the CPI received the European Commission’s stamp of approval for its sound statistical approach.

The CPI measures the perception of public corruption, namely the following aspects: bribery, diversion of public funds, use of public office for private gain, nepotism in the civil service, state capture, the government’s ability to enforce integrity mechanisms, the effective prosecution of corrupt officials, red tape and excessive bureaucratic burden, the existence of adequate laws on financial disclosure, conflict of interest prevention and access to information, and legal protection for whistleblowers, journalists and investigators.

Why do we still need the CPI?

– The CPI covers more countries than any of the individual sources alone;

– The CPI compensates for eventual errors among sources by taking the average of at least 3 different sources and as many as 13;

– The CPI’s scale (0-100) introduces more precision in comparison to other sources that may have scales of 1-5 or 1-7 (and where many countries are equally ranked);

– The CPI reconciles different view points on the issue of public sector corruption and is more neutral when handling different political regimes.

For reference

Transparency International is an anti-corruption organization founded in 1993 in Berlin by former World Bank director Peter Eigen. Currently, the chair of the Board is Delia Ferreira. Transparency International operates in more than 100 countries worldwide. The organization is best known for its Corruption Perceptions Index and Global Corruption Barometer. According to Global Go To Think Index Tank 2017, Transparency International ranked 51st out of 173 global think tanks and was the leader among 65 think tanks working on issues of open and good governance. 

Transparency International Ukraine is an accredited chapter of the global movement Transparency International with a comprehensive approach to development and implementation of changes for reduction of the corruption levels. TI Ukraine has administered and transferred to the government such electronic systems as ProZorro, ProZorro.Sale, eHealth, and E-Data. Our other ongoing projects include the City Transparency Ranking and building of the DOZORRO community for control over public procurement.

For media inquiries: Olesia Koval, koval@ti-ukraine.org, 093-808-82-78.