Detection and tracing: more requests, fewer assets found

In 2025, ARMA received 9,468 requests to detect and trace assets — a 20% increase over 2024 (7,865). 

The number of assets actually found, however, fell across several categories. ARMA located 29,049 land plots, down from 107,066 in 2024 — a figure we flagged at the time as an anomaly. Other categories rose: detected funds reached UAH 36.5 billion against UAH 8.3 billion, corporate rights UAH 58.5 billion against UAH 35.9 billion, and virtual assets stood out most of all — 1.29 million USDT against 2,400 USDT, a roughly 530-fold increase.

One section is genuinely new: ARMA publicly acknowledges the structural gap between assets traced and assets seized. Only 2% of the property ARMA traces is later seized. The report explains, among other things, that the information ARMA compiles on traced assets cannot be used as evidence in criminal proceedings.

The Agency separately notes that some tracing requests come in proceedings where confiscation — or even the option of special confiscation — is not envisaged at all. The information on traced assets is then used by the prosecution under Article 93 of the Criminal Procedure Code of Ukraine, which governs the rules for gathering evidence and nothing more. In other words, in certain cases ARMA functions as a property-records service for law enforcement.

ARMA also sent 639 international requests in 2025, against 383 in 2024 (up 66%). The numbers are striking, but they raise questions about the quality of each request and the effectiveness of the institution’s foreign track as a whole. The report does detail what was found abroad: 366 properties, 88 vehicles, $5.9 million, and corporate rights worth the equivalent of UAH 924.86 million. How much of this was seized, and which of these decisions foreign competent authorities recognized, remains unknown. 

Such decisions by foreign actors do not depend on ARMA alone, of course. But to analyze the state of asset recovery — a function the Agency does hold — the missing piece is information on whether those assets were actually seized abroad.

Asset management: more new agreements, but the revenue still comes from the old ones

Last year we noted that ARMA had concluded only 7 management agreements against 33 announced competitions. In 2025, there are already 40 management agreements under 38 rulings. On paper this is a breakthrough — yet 27 agreements carried over from previous years remain the main source of revenue for the state budget.

A single agreement — with Ukrnafta over the assets of Ukrnaftoburinnia, signed back in June 2023 — brought UAH 1.074 billion to the budget out of UAH 1.54 billion from management agreements overall. That is roughly 70% of the year’s revenue from one asset. All 38 new agreements signed in 2025, by contrast, account for just 2.5% of revenue (UAH 38.7 million).

The figures on asset sales in 2025 are also contradictory. The Agency organized 184 auctions, of which only 41 succeeded (about 22%). Nearly four out of five auctions produced no result. This calls for a separate explanation — on how the lots were assembled, and on starting prices and the appeal of the assets. 

The key thing left out of the report: as of its publication, the new mechanisms for selecting managers through Prozorro still had not been launched, even though they were supposed to be operating by January 30, 2026. This means that, overall, the transfer of assets to managers under the new rules is significantly delayed.

Oversight of managers: more activity, but the quality questions remain

In 2024, ARMA carried out only 10 on-site inspections of managers — one of the key figures we criticized. In 2025, there are already 38 on-site inspections and 348 desk reviews, for 386 oversight actions in total. These produced 27 orders to managers and 5 established instances of mismanagement.

In terms of trend, this is a marked improvement. In absolute terms, though, 38 on-site inspections against the 34,062 assets ARMA has placed under management, worth UAH 10.7 billion, is still a modest figure. 

The report also fails to show how the inspection results were interpreted: how many orders led to an actual change in a manager’s conduct, and how many agreements were terminated for ineffectiveness. And the scandalous case of KAMparytet, which subleased shopping centers at prices three times higher than its declared income, is not mentioned in the report at all, even though the case was discussed separately at the parliamentary Anti-Corruption Committee, and in 2026 the Agency confirmed the violations and announced its intention to terminate the agreements with the company. 

Inventory: ARMA finally has a definitive count of the assets it manages 

The transitional provisions of the new ARMA law required the body to identify, within six months, all assets placed under its management before the law took effect. The Agency reports that, following a full inventory, its records now cover 60,274 assets, of which 20,753 have high management potential. This figure also includes assets being prepared for competitive procedures or already identified as attractive for management and sale.

Even so, the Agency still does not use the term “asset pool,” which would make it possible to see how many units of property actually form part of an operating business that can be grouped under that concept. In practice, this makes it quite hard to tell from the report how many economically attractive businesses lie behind the figure of 20,753 assets. 

In 2025, 1,703 assets were handed to managers under agreements, while across all years ARMA has transferred 34,062 assets in total. These 1,703 assets are valued at UAH 5,354.31 million, against UAH 10,737.53 million for all assets combined. So nearly 5% of the assets placed under management in 2025 account for roughly 50% of the total value. One hypothesis here is that in earlier years the assets transferred for management were largely low-value.

In all, the body of assets ARMA is empowered to act on amounts to 94,336 units. Of these, 34,062 have already been transferred to managers under agreements (1,703 in 2025), and 60,274 have not (20,753 of them with high management potential). 

Handling “complicated” assets proved a separate problem: of 100 appeals ARMA made to prosecutors about its inability to manage such assets effectively, only 32 received a reply, and just 5 of those were resolved favorably. In other words, 95% of the cases where ARMA has already deemed an asset problematic to manage remain unresolved once the prosecution is brought in. And this problem should be resolved by amending the Criminal Procedure Code of Ukraine, as we have stressed before.

***

Over the past year, the volume of activity inside ARMA has grown substantially. The Agency is drafting secondary legislation, running asset inventories, tracing assets, and shaping recovery policy. Not every task has been completed, but the progress is visible. 

Even so, in watching ARMA’s performance, we would like to see real results in the effectiveness of asset recovery. That can be traced, in particular, by comparing the outcomes of tracing, seizure, effective management, and confiscation. Beyond that, the data available in the report does not make clear how the new system for selecting managers actually works, since not a single auction of that kind has taken place since the law was adopted. And in any case, the management agreements covered in the report were all concluded under the old procedures. 

That is why we see the key task for ARMA today as changing the very logic of how it traces and manages property. In our opinion, the next report should demonstrate not just the volume of work done, but concrete achievements across the system as a whole. All the more so since invoking the old rules will no longer make any sense. 

How do things stand now?

Most articles in the CPC section devoted to international cooperation have not been amended since the Code was adopted in 2012. At that time, digitalization was not a global priority, and the practice of international cooperation had not become widespread enough to reveal the weaknesses in its legal regulation. 

As a result, the provisions currently in force lag in many respects behind technological progress and the new legal approaches to mutual legal assistance — particularly when it comes to confiscating assets located in foreign states and dealing with participants in criminal proceedings who are abroad.

The exchange of materials in international cooperation. Current legislation permits requests and case materials to be exchanged in paper form during international cooperation. This significantly slows down Ukraine’s interaction with partner states in the fight against crime, since it requires a considerable amount of time.

The protection of information in international cooperation. Information processed within such cooperation currently has no clear safeguards against disclosure — especially where the cooperation does not require opening criminal proceedings in Ukraine.

The international wanted list. The CPC does not expressly define the moment from which a person is considered to be on the international wanted list.

The enforcement of HACC judgments. Although the HACC hears high-level corruption cases as a specialized court, certain matters arising in the enforcement of its judgments — such as a convicted person’s parole or the replacement of the unserved part of a sentence with a more lenient one — still go before local courts under the rules of Article 539 of the CPC, rather than before the HACC.

The confiscation and special confiscation of property abroad. The CPC does not contain a sufficiently detailed mechanism for establishing the location abroad of property subject to confiscation or special confiscation. The engagement of ARMA to trace and seize property abroad when enforcing confiscation decisions is also currently unregulated.

Questioning from abroad. Witnesses or victims located abroad can be questioned only from the premises of a court at their place of residence, which means that a corresponding request must be sent each time to the competent authorities of the foreign state through mutual legal assistance. Only for the duration of martial law or a state of emergency has it become possible to question a witness or victim directly by videoconference from any location.

What does the draft law propose?

Draft Law No. 14292 proposes a fairly broad package of changes. Among the key positive updates:

• permission to make wider use of electronic communications for international cooperation requests;
• regulation of the protection of information and materials in international cooperation;
• a more detailed set of grounds for refusing or postponing mutual legal assistance requests, and of the procedure for executing them;
• improvement of the procedure for recognizing and enforcing judgments, as well as for confiscating property abroad;
• the introduction of the ability to question persons located abroad by videoconference or from the premises of a Ukrainian diplomatic mission, regardless of whether martial law or a state of emergency has been declared in the country.

Which provisions need refining?

Despite its generally positive thrust, the document contains a number of procedural gaps, legal ambiguities, and risks that could negate the intended effect in practice.

For the mechanisms it establishes to work smoothly, the document should be refined in the respects described below.

Confiscation of property abroad: the right direction, but a weak procedural design

The amendments to Articles 535 and 568 of the CPC are intended to ensure the enforcement of judgments insofar as they concern the confiscation or special confiscation of property located abroad. This is an important step, particularly in countering organized crime, and corruption in particular. There are two problematic points whose resolution could improve this process.

In the proposed wording of Article 535(7) of the CPC, the drafters would require the court to draw up a petition for the recognition and enforcement, in a foreign state, of a Ukrainian court’s conviction insofar as it concerns the confiscation or special confiscation of property. However, the drafters failed to take into account that special confiscation may be imposed not only by a court’s verdict but also, under Article 96-1(2) and (3) of the CC, by rulings on release from criminal liability, on the closure of criminal proceedings, on extended confiscation, on the imposition of coercive measures of a medical or educational nature, and on the imposition of criminal-law measures on a legal entity. The aforementioned provision of Article 535(7) of the CPC should therefore also include a reference to the rulings listed in Article 96-1(2) of the CC.

In addition, the draft law would require those enforcing the judgment (chiefly the State Enforcement Service) to notify the court of any property discovered abroad that is subject to confiscation or special confiscation.

This innovation is consistent with EU Directive 2024/1260, under which the tracing and identification of property subject to freezing and confiscation must be possible even after a final court decision. Yet, although the draft law offers such an option, the point at which criminal property — or property subject to confiscation — is discovered should not be deferred all the way until the court’s final decision. 

The reason is that state enforcement officers cannot match law enforcement agencies or ARMA in detecting and tracing property, especially abroad — they lack sufficient powers and resources for this. 

As noted earlier, it is law enforcement agencies during the pre-trial investigation, and ARMA, that have the most tools for tracing and identifying assets subject to confiscation. Even they, however, do so fairly rarely, and the reason is that Article 91 of the current CPC in no way requires the location of property subject to confiscation or special confiscation to be proved within criminal proceedings. Largely because of this, in most cases such property ultimately goes unnoticed by the enforcement service.

Therefore, to adapt the provisions of EU Directive 2024/1260 to Ukrainian realities, it would be sensible, first, to supplement Article 91 of the CPC with provisions requiring the prosecution to prove the location of assets subject to confiscation or special confiscation. Second, to establish that, when enforcing court decisions on confiscation for the laundering of criminal property or for corruption, ARMA may be engaged to identify property that may be confiscated. Article 535(7) of the CPC should also include a reference to the rulings listed in Article 96-1(2) of the CC.

2. The international wanted list, the digitalization of summonses, and the removal of procedural obstacles for persons abroad

One of the draft law’s provisions concerns placing a suspect on the international wanted list. In Article 291 of the CPC, the drafters propose to draw a clear distinction between a domestic search within Ukraine and an international one, and to establish that a suspect is deemed wanted precisely from the moment the investigator or prosecutor issues a decision to that effect.

This will help settle long-standing debates about the moment from which a person is considered placed on the international wanted list and will allow courts to follow a single line of application. 

At the same time, the amendments to this article will not resolve another, more acute problem. It concerns cases where suspects or the defendants are abroad and the defense, invoking Article 135(7) of the CPC, argues that they may be reached solely through the diplomatic-channel procedure. Currently, under this provision, a summons for a person residing abroad is served through international cooperation mechanisms.

HACC case law reasonably explains that a person’s mere presence abroad does not require summoning them through diplomatic channels, since such channels should be used only if the person has formally arranged permanent residence, registered with a consulate, deregistered their residence, and the like. If no such facts are established during the criminal proceedings, the person is summoned in the ordinary manner.

 Even so, the debate over this issue continues, owing to lawyers’ inconsistent reading of the said Article 135(7) of the CPC. This is precisely why the measure under the State Anti-Corruption Program to simplify the procedure for summoning, in criminal proceedings, persons who reside abroad and are citizens of Ukraine has not yet been implemented.

It would therefore be best to specify clearly in Article 135(7) of the CPC that a person located abroad may also be summoned through electronic means of communication — official email addresses, messengers, and social media (provided that the person’s use of them is documented).

3. Matters concerning the enforcement of HACC judgments should remain within that court’s jurisdiction 

The draft law also proposes amendments to Article 539 of the CPC. In this article, the drafters seek to clarify that the question of parole, or of replacing the unserved part of the sentence of a convicted person who has been transferred to serve their sentence abroad, is decided by the Ukrainian court that delivered the verdict. 

This provision carries no risks; however, while amending this article of the CPC, the legislator could also resolve the problem of matters relating to the enforcement of HACC judgments being decided by courts other than the HACC. Thus, by amending Article 539 of the CPC, the legislator could solve two problems at once.

The HACC has special subject-matter jurisdiction over corruption-related criminal proceedings. Yet most matters relating to the enforcement of its judgments are decided by local courts — in particular, at the person’s place of serving the sentence or place of residence. 

Local courts are entitled to grant parole to persons convicted by HACC judgments, to substitute their punishment, and to release them from it altogether. Such situations are not uncommon. For example, in 2024 the Shevchenkivskyi District Court of Kyiv granted parole to a person convicted by the HACC — an accomplice in the bribery case involving the director of the Rzhyshchiv Military Forestry State Enterprise — so that he could serve in the military. And in 2025 the Voznesensk City-District Court released from punishment the head of a private company who had been convicted of misappropriating UAH 787 million of an NBU loan and of participating in the Yanukovych–Kurchenko criminal organization.

Matters relating to the enforcement of HACC judgments should be decided by that very court, since they can substantially affect the actual extent of the punishment imposed on those convicted of corruption-related criminal offenses — and therefore its deterrent, punitive, and rehabilitative effect.

Article 539 of the CPC should therefore be supplemented with a separate clause under which matters relating to the enforcement of a HACC judgment will be decided by the HACC alone. 

4. Eliminating the risks associated with the extradition procedure 

The draft law’s amendments also touch on extradition. The drafters spell out the procedure for submitting extradition requests, the handling of situations where several states request a person’s extradition, the application of preventive measures to such persons, and so on. Some of the proposed innovations require clarification.

The draft law adds to Article 575 of the CPC a mechanism for confirming that an extradition request remains valid. Under it, the court must respond to the Ministry of Justice on whether the request remains valid, and a failure to provide such a response becomes grounds for withdrawing it. Yet the drafters set no deadline at all for providing this response.

This creates a risk that, because the response deadline is undefined, the Ministry of Justice may mistakenly treat such an extradition request as withdrawn — even though the court has provided no response at all.

It is therefore important to add to the new Article 575(7) and (8) of the CPC clear deadlines for the court’s response, and to provide that it is a negative response from the court — not the absence of one — that constitutes grounds for withdrawing such a request.

In addition, to align the rules on simultaneous requests for a person’s surrender, the new clause 5-2 of Article 589(1) of the CPC should be supplemented with a further ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

Thus it is necessary, first, to add to the proposed Article 575(7) and (8) of the CPC clear deadlines for courts to respond to the Ministry of Justice, and to provide that it is a negative response from the courts — not the absence of one — that constitutes grounds for withdrawing an extradition request. Second, the new clause 5-2 of Article 589(1) of the CPC should be supplemented with the following ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

Conclusions

Transparency International Ukraine recommends adopting Draft Law No. 14292 in the first reading as a basis, with refinement ahead of the second reading, since adopting it in its current wording would leave gaps that would diminish the effect of the changes made.

In our view, the following recommendations should be taken into account during this refinement:

• Supplement Article 91 of the CPC with provisions requiring the prosecution to prove the location of assets subject to confiscation or special confiscation. 
• Establish that state enforcement officers may engage ARMA to identify property that may be confiscated when enforcing judgments or rulings for the laundering of criminal property (Article 209 of the CC) or for corruption (Note 1 to Article 45 of the CC). 
• Add to Article 535(7) of the CPC a reference to the rulings listed in Article 96-1(2) of the CC.
• Specify clearly in Article 135(7) of the CPC that a person located abroad may also be summoned through electronic means of communication — official email addresses, messengers, and social media (provided that the person’s use of them is documented).
• Add to Article 539 of the CPC a separate clause under which matters relating to the enforcement of a HACC judgment will be decided by the HACC alone. 
• Add to the proposed Article 575(7) and (8) of the CPC clear deadlines for courts to respond to the Ministry of Justice, and provide that it is a negative response from the courts — not the absence of one — that will constitute grounds for withdrawing an extradition request. 
• Supplement the new clause 5-2 of Article 589(1) of the CPC with the following ground for refusing extradition: the surrender of the extradited person to one of the requesting states.

How it used to be

Before Law No. 4503-IX took effect, the procedure for accepting assets was governed solely by the ARMA law, and only in general terms. The old model suffered from a number of problems, such as:

• the absence of a unified mechanism for prior asset identification — the ARMA effectively accepted “whatever was offered” for management, with no opportunity to fully assess whether it could manage the asset effectively;
• vague deadlines for accepting assets, which generated conflicts between prosecutors and ARMA over the moment of actual transfer and the shift of responsibility for the asset’s preservation;
• the absence of a procedure for examining (inspecting) the asset with the participation of the prosecutor or persons authorized by them, which created the risk of accepting assets in poor condition for management without proper documentation.

How it is now

The new Procedure introduces a substantially different model, built on the following key elements.

1. Asset identification as a precondition for acceptance

While the Procedure itself does not regulate identification (which is the subject of a separate secondary act), it does take its results into account. Paragraph 7 of Section I provides that, if the investigating judge’s ruling contains no reference to the transfer of the asset to ARMA management, the Agency conducts the asset’s identification at the prosecutor’s request to determine whether it can be managed effectively.

2. Clear deadlines for processing requests

These provisions align with the third paragraph of Article 19(1) of the Law, which sets a general 10-day deadline for accepting an asset, with the option of extending it to 30 business days.

3. A differentiated approach based on asset type

For the first time, the Procedure provides detailed regulation of how an asset is accepted for management:

• movable and immovable property — with mandatory examination (inspection) at the asset’s actual location, with the participation of persons proposed by the prosecutor;
• securities — through the appointment of a securities account administrator and engagement with a depository institution;
• non-cash funds — through payment instructions, with the option of placing them on a deposit account;
• cash funds — through the cash desk of a state bank branch;
• bank metals — through an individual safe deposit box at a state bank.

4. Asset examination as a mandatory element

Subparagraph 1 of paragraph 4 of Section II introduces a mandatory procedure for inspecting the asset with the participation of “at least one of the persons proposed by the prosecutor in the request” (an investigator, detective, or specialist). This is a fundamental innovation intended to ensure proper documentation of the asset’s condition at the moment of transfer and to reduce the risk of subsequent disputes between the prosecutor and ARMA over the asset’s condition at the time of acceptance.

5. The option to call in the police

The Procedure expressly grants ARMA Interregional Territorial Department staff the right to call in police officers, under a joint order issued by ARMA and the Ministry of Internal Affairs, “where there are reasonable grounds to believe that there is a threat to the life and health of individuals and to public safety.” This is an important safety safeguard, given that assets are often in the actual possession of suspects or persons linked to them.

What problems may arise?

Overall, the greatest challenges are likely to arise where there are discrepancies between the actual and the legal condition of the seized property. Paragraph 6 of Section I of the Procedure provides that the prosecutor may submit proposals to the draft acceptance and transfer act within four business days, which ARMA must then review within one day. However, the Procedure does not specify what is to be done if ARMA rejects the prosecutor’s proposals. This creates a risk of “endless approvals,” where the 10-day deadline is formally observed, but the actual transfer of the asset drags on through iterative revisions, which is inconsistent with the very nature of seizure.

In addition, the Procedure assumes that an opinion on the feasibility of managing the asset already exists at the time of the prosecutor’s request. Yet it does not address the situation where, during the asset’s examination at its actual location, the property is found to differ substantially from the data on which that opinion was based. 

There is also uncertainty regarding the timing of the actual asset inspection. For example, no rule covers the case where a person proposed by the prosecutor cannot participate within the timeframe set by ARMA, leaving it unclear whether the inspection may proceed in their absence, and if so, on what conditions.

The ARMA accordingly needs to work all of this out in cooperation with the prosecution authorities, and these issues can be effectively resolved by drawing on the general principles of criminal proceedings and the relevant departmental standards. Where needed, the Procedure can be amended to formally regulate ways of overcoming these challenges.

Conclusion

The Procedure for ARMA’s Acceptance of Seized Assets for Management, approved by the joint order of the ARMA and the Prosecutor General’s Office, is a necessary step in implementing Law No. 4503-IX. It closes one of the key gaps in the secondary regulation of the new model for handling seized assets.

At the same time, practice may reveal individual problems that will require amendments to some of its provisions, so the ARMA should monitor this and respond promptly — including by initiating changes to the regulations.

Institutional and organizational matters

This category is anchored by the revised ARMA Regulation. The Law of June 18, 2025, introduced substantial clarifications regarding the Agency’s powers and organizational structure, and the Cabinet of Ministers brought the Regulation in line with the amended law accordingly.

The Regulation now expressly provides that ARMA disposes of assets under management through electronic auctions conducted on the state and municipal property privatization platform (Prozorro.Sale), in the manner and within the timelines established by the Cabinet of Ministers. It also provides that the Agency shall notify the prosecutor of the need to transition to asset disposal where, in the course of monitoring management effectiveness, circumstances are identified that preclude preservation of the asset’s economic value.

In connection with this last power, it is critically important that the corresponding prosecutorial authority be regulated — either through joint departmental instruments or through amendments to the Criminal Procedure Code — so that prosecutors can respond effectively to ARMA’s referrals on issues arising in the management of seized assets.

Amendments have also been made to the Regulation on ARMA authorized officers. Pursuant to the ARMA Law, authorized officers may now access assets transferred to ARMA for management, as well as seized assets in the identification stage, upon presentation of their official credentials — without restriction. This will enable the Agency to effectively exercise its authority to assess whether, and by what means, it can efficiently manage any given seized asset.

In addition, ARMA approved by internal order the Regulation on the Internal Control and Risk Assessment Department of ARMA’s Central Office and the Regulation on the Internal Security Department of ARMA’s Central Office. 

The Internal Control and Risk Assessment Department coordinates ARMA’s institutional oversight and risk management framework, conducts audits and investigations to identify violations in the area of asset tracing, preservation, and management, monitors the lawfulness of procurement and the use of budgetary funds, and prepares policy proposals on the detection, tracing, and management of seized and confiscated assets. The Internal Security Department is charged with safeguarding the integrity of ARMA personnel: it prevents corruption-related misconduct, conducts internal investigations, monitors compliance with ethical standards and conflict-of-interest rules, investigates reports of staff involvement in unlawful conduct, organizes pre-appointment vetting of candidates, and advises staff on ethics.

Accountability matters

The Regulation on the Public Oversight Council (POC) defines the status, mandate, and operating procedures of the Council as a standing collegial body exercising civil oversight at ARMA. The Council oversees ARMA’s activities, monitors the effectiveness of the Agency’s operations, reviews draft regulations, controls the lawfulness of manager selection and the progress of asset disposal, and facilitates ARMA’s engagement with civil society. The Council comprises nine members serving on a voluntary, unpaid basis. Sessions are held no less than quarterly, and its decisions are recommendatory in nature.

In the area of asset management, the Council has the following powers: 

• exercising civil oversight over the lawfulness and transparency of asset manager selection, by delegating its representatives directly to selection procedures; 
• monitoring the lawfulness and transparency of asset disposal and the effectiveness of the management of assets transferred to ARMA. 

The Head of ARMA may involve POC representatives in asset management effectiveness reviews and, where a complaint is received from an asset owner, in establishing grounds for a further review — up to and including membership of the relevant commission. POC representatives are correspondingly obliged to maintain the confidentiality of commercial and other legally protected information obtained in the course of such oversight activities.

The Council Formation Procedure establishes a competitive selection process through open-ranking online public voting. Candidates are nominated by civil society organizations active in anti-corruption, criminal justice or business protection for at least two years, and are subject to an extensive list of eligibility restrictions — including former ARMA employees, individuals with conflicts of interest, and foreign nationals. Voting must be conducted online for no fewer than three days, and the nine candidates with the highest vote tallies are deemed elected.

Previously, public oversight functions were performed by the Public Council at ARMA, which held a broad range of powers, including participation in the inter-agency asset disposal commission, oversight of budgetary expenditure, anti-corruption review, and the right to delegate representatives to competitive selection commissions. The new framework establishes the POC as a standing elected collegial body with enhanced powers in the area of asset management. The predecessor council has accordingly ceased to exist, while the new Council has yet to be constituted.

Additionally, the government approved the composition of the commission for conducting an independent external assessment (audit) of ARMA’s performance. Under the revised framework, all members of this commission are nominated by development partners, with a view to strengthening independence and eliminating undue influence from appointing entities.

Asset identification and intake

In this area, regrettably, no secondary legislation has yet been adopted. The government has yet to enact instruments governing how ARMA will store seized assets transferred to it for management, how valuators of seized assets will be selected, and what methodology will be applied to determine the feasibility of managing a given asset. 

In coordination with the Prosecutor General’s Office, instruments must be adopted to regulate asset identification and intake into management.

Interaction between law enforcement authorities and ARMA was previously ad hoc, which meant that assets that were objectively difficult to manage could be transferred to the Agency. The identification stage was introduced specifically to address this problem. On the other hand, there had been difficulties with prosecutors signing asset transfer and acceptance records; it is therefore significant that the Law now establishes deadlines for executing such records and mandates that these processes be regulated by joint orders of ARMA and the PGO at the secondary legislation level.

Separately, the appraiser selection procedure has yet to be aligned with the Law. A specific competitive selection procedure for valuation entities previously existed; however, the Law streamlined the process by providing that valuation entities are to be selected in accordance with the Law on Public Procurement. A draft instrument published on ARMA’s website specifies that valuation entities will be selected through open tender procedures in accordance with Article 15 of that Law, and that the corresponding framework agreement will be concluded for a term not exceeding one year. 

Selection of asset managers

We have previously addressed the updated framework for selecting managers of seized assets under the amended Law. On February 5, however, the government finally adopted the secondary legislation defining several important procedural nuances. TI Ukraine participated in the drafting of the asset manager selection instruments — our priority was to ensure that the substantive provisions and safeguards we developed were preserved through the subsequent clearance and adoption process. Fortunately, the structural logic and the safeguards were retained, and the text prepared with our involvement underwent primarily editorial revisions. 

The government has introduced its own definition of “related person” through four categories: related persons under the Tax Code, close persons under the Anti-Corruption Law, affiliated persons under the Joint-Stock Companies Law, and persons in civil-law or employment relationships with the owner or suspect where such relationships terminated fewer than five years before the announcement. 

For both simple and complex asset selection procedures, one open question remains: whether it is appropriate to cap the maximum manager’s remuneration at 100% of asset management profit. However, no sufficiently justified alternative approach was identified during the drafting process. Accordingly, unless the resolutions are amended, participants will be able to enter auctions at a starting remuneration level of 100%. 

Implementation of the selection procedures in the Prozorro system is ongoing, and initial steps have already been taken. 

Simple assets

For the pre-qualification of prospective managers, the resolution clarified the announcement timeline: it remains in effect from the date of publication until the date of the subsequent announcement, but no later than December 1 of the following year. Amendments to the announcement are prohibited throughout its validity period.

The resolution separately provides that the electronic system automatically calculates abnormally low tenders and notifies both the participant and ARMA — a mechanism not found in the Law, which merely defined the concept of an abnormally low tender and set deadlines for justification.

Pursuant to our proposals, the simple asset manager selection rules now include:

• a key safeguard providing that ARMA and the auction winner enter into a contract on the exact terms and at the exact remuneration level specified in the announcement and the winner’s tender, which neither the contracting authority nor the manager may vary unilaterally,
• the auction mechanics: the Prozorro system automatically evaluates tenders, including identification of abnormally low ones, and notifies both participants and ARMA. The correct sequence of participant actions is specified — the starting point is the highest remuneration level, each participant may lower the price by at least one step per auction stage, and where tenders are equal, the participant who submitted later proceeds first; 
• the necessary procedural detail: how tenders are submitted and recorded by the electronic system; the impossibility of submitting a tender after the established deadline; a participant’s right to submit only one tender, or to withdraw or amend it; the register of submitted tenders and its content; and separate provisions on the publication of information and documents. 

Additionally, the rules governing simple asset manager selection have the potential for improvement if future amendments were to:

• remove asset-specific details from the pre-qualification announcement, given that pre-qualification is not conducted in respect of specific assets — which are unknown at that stage;
• by analogy with the complex asset selection procedure, define what constitutes adequate justification for an abnormally low tender, and provide for publication of documents confirming a winner’s refusal to execute a management agreement;
• introduce a safeguard ensuring that the list of documents ARMA requires from pre-qualification participants is non-discriminatory and does not include documents not required by law;
• include in the auction announcement information on the owner of the seized asset and any suspect or accused in the relevant criminal proceedings, or any respondent in civil forfeiture proceedings (where applicable), so that participants and the public may assess any connection between such persons and the auction winner.

Complex assets

The new selection rules for complex asset managers focus on ensuring a transparent, non-discriminatory and clearly defined process. A key objective was to distinguish between the commission’s pre-auction document review and the automated evaluation of tenders (remuneration levels) in the auction itself, among participants admitted thereto — an area where the Law contained certain inaccuracies. 

Pursuant to TI Ukraine’s proposals, the following measures were incorporated: 

• a document deficiency cure mechanism: where the commission identifies deficiencies, it must issue a single request to the participant to remedy the documents within 24 hours;
• requirements for justifying abnormally low tenders: the resolution provides that adequate justification must include calculations demonstrating cost reductions, favorable conditions or increased revenue relative to the indicative plan;
• substantive limitations on additional qualification requirements: these must not restrict competition, create discrimination or confer advantages on specific entities, and must be proportionate to the management needs of the particular asset;
• regulation of cases where ARMA amends an announcement: the Agency has the right to make amendments prior to the deadline for document submission. To ensure non-discriminatory treatment, the document submission period is automatically extended so that at least ten days remain from the date of amendment until the deadline;
• a specific provision addressing the scenario where ARMA fails to issue clarifications in time: the Prozorro system automatically suspends the procedure and does not advance to the next stage; to reinstate the procedure, ARMA must publish its response and simultaneously extend the document submission period by at least seven days.

The government also elaborated on a number of procedural aspects of the selection process. ARMA prepares in advance a list of possible additional qualification requirements relating to participants’ experience, facilities, permits and licenses, which it transmits to the commission. The commission then decides whether to apply these requirements no later than two business days before the announcement is published. 

The resolution further clarifies the post-announcement procedure: the day after the document submission deadline, ARMA notifies the commission of the participants and transmits the relevant materials. Participation by joint ventures is regulated separately, with consolidated aggregation of their indicators.

To further improve the regulation of complex asset manager selection, it may be advisable to: 

• include in the auction announcement information on the owner of the seized asset and any suspect or accused in the relevant criminal proceedings, or any respondent in civil forfeiture proceedings (where applicable), so that participants and the public may assess any connection between such persons and the auction winner;
• add a clarification specifying that the list of information and/or documents required for the 24-hour deficiency cure must correspond to the requirements set out in the selection announcement, so that no new requirements are introduced at the proposal review stage;
• by analogy with the public procurement framework, introduce a safeguard ensuring that ARMA’s list of required documents does not include documents not required by law.

The resolution also regulates the operation of the Commission for the selection of the manager of complex assets. It provides for roll-call voting with each member’s position recorded in the minutes, individual written assessments by each member for each qualification requirement in respect of each participant separately, recusal and conflict-of-interest procedures with a mandatory disclosure obligation no later than the next business day, the right to record a dissenting opinion in writing, the option of remote sessions, and the commission’s right to invite participants to sessions and to send them written requests.

Procurement of asset management services

The ARMA Law provides that where no manager of a simple or complex asset is identified following a repeat selection procedure conducted under Article 21-3 or 21-4 of the Law, the Agency shall procure asset management services through an open tender procedure in accordance with the Law on Public Procurement. Participation in such procurement is open to business entities meeting the qualification requirements set out in Article 21-3(7) and Article 21-4(5) of the ARMA Law, except for participants who refused to execute a management agreement following simple or complex asset manager selection procedures.

The government resolution regulates the process for determining the estimated value of the procurement item — that is, the projected expenditure on engaging a manager, which serves as the basis for budget planning and tendering. 

Four instruments are established for calculating the estimated value, arranged in a hierarchy. The primary methods are market consultations (sending requests to market participants to ascertain current prices and possible management approaches) and the market price comparison method (a minimum of three price proposals, from which abnormally high and low figures are excluded, with the remaining proposals averaged). Where fewer than three proposals remain after filtering, historical procurement price analysis with inflation and exchange rate indexation is applied.

The fallback instrument is calculation on the basis of an approved indicative asset management plan — applied either where none of the preceding methods yields a result, or where the figures obtained exceed the planned values by a factor of two or more. The formula incorporates expected monthly management income, minimum storage costs, and the manager’s base remuneration at 10% of profit, multiplied by twelve months. The Procedure thus provides a methodological framework for a reasoned determination of the cost of management services in the most complex cases where market-based selection has not produced a result.

That said, the Procedure has certain shortcomings that it would be advisable to address in any future revision:

• insufficient safeguards against inflation of the estimated procurement value. In particular, for the market price comparison method to be applied effectively, requests to business entities should be identical in content for all recipients and should include all material conditions of service delivery, thereby enabling the solicitation of relevant pricing information and the formulation of proposals. As currently drafted, there are no requirements as to the content of the request. The class of economic operators to whom requests will be sent is framed rather broadly and is not entirely appropriate for management services — requests are directed primarily to “manufacturers, official representatives, and dealers,” whereas the procurement item is management services; 
• no provision for publication of any information on how ARMA determined the estimated value of the procurement; 
• the current definition of estimated value is rather broad — it encompasses “all possible costs associated with engaging a manager” and does not include the criterion of service delivery “on specific conditions,” in contrast, for example, to the definition of estimated value under the Ministry of Economy Order No. 275 of February 18, 2020. 

Attention should also be drawn to technical shortcomings in the Procedure. The market consultation process should yield not only “optimal procurement item requirements” but also the estimated value itself. Additionally, paragraph 8 of the Procedure should apply only “where the historical procurement price analysis method is used,” rather than in all cases of estimated value determination. 

The formula for calculating estimated value on the basis of historical procurement prices incorporates a “historical period price” figure. It is not, however, specified how a single historical period price is derived, given that the method generally draws on multiple sources. If the arithmetic mean is to be used in the formula, a provision to that effect — together with other relevant details — must be included.

Asset management and oversight

In this area, only the Procedure and Timelines for Developing, Approving, and Amending the Indicative Asset Management Plan, and the Procedure for Monitoring the Effectiveness of Asset Management, have been developed to date. The government has not yet adopted model management agreements.

The Procedure for Developing and Approving the Indicative Asset Management Plan elaborates on the mechanics of this document, which serves as the foundation for all subsequent manager selection procedures. Whereas the Law merely referenced the existence of the plan and its mandatory content, the resolution establishes specific drafting timelines: 20 business days for simple assets and 30 business days for complex assets, running from the date of execution of the transfer and acceptance certificate. For complex assets, an additional 20-business-day benchmark is introduced to maintain compliance with the statutory timelines for transferring an asset into management. 

The resolution also specifies the information sources for preparing the plan: the management feasibility assessment, the asset inspection report, valuation and expert findings, inventory data, and publicly available sources ranging from Prozorro to statistical services of foreign states. A notable new requirement is the mandatory approval of the plan by the National Security and Stock Market Committee (NSSMC) where the asset comprises a share in the capital or shares of a professional capital markets participant — with the NSSMC afforded ten business days for that purpose.

Regarding amendments to the plan, the resolution introduces several important procedural mechanisms. First, a manager may initiate amendments, but not earlier than 30 calendar days after taking the asset over — a safeguard against premature revision of planned performance benchmarks. The manager’s submission must include a list of proposed amendments, a reasoned justification with supporting calculations, and a risk analysis. ARMA must consider the submission within ten business days and communicate its decision within the following five business days; any refusal must be reasoned. Second, where amendments to the plan are made after the manager selection announcement has been published — for both simple and complex assets — the proposal submission period is automatically extended so that at least seven calendar days remain from the date of the amendment. Once the proposal submission deadline has passed, no further amendments to the plan are permitted — an important guarantee of the stability of competition conditions.

The government has also approved the Expenditure Approval Procedure for asset managers. This instrument establishes the mechanism for ARMA to approve the expenditures that managers incur in the effective management of seized assets and that are reimbursed from management revenues. The Procedure defines five categories of expenditure subject to approval: the manager’s remuneration; costs of asset maintenance and security; insurance costs; costs of professional services (consulting, legal, valuation, etc.); and other costs provided for in the indicative management plan and agreement. The overriding requirement is that all expenditures be economically justified, efficient and directed toward achieving the objectives of asset management.

The Procedure establishes a detailed approval process: the manager submits a cost estimate for the forthcoming reporting period, together with a justification, a market price analysis and a projected economic return calculation. ARMA conducts a comprehensive review — legal, financial-economic and technical — within 15 business days, and issues a reasoned decision to approve or refuse. Significantly, expenditures not approved by ARMA or exceeding approved amounts without supplementary authorization are not reimbursable. The procedure also mandates that the manager file reports on actual expenditure, with a comparison of planned against actual figures.

The Procedure for Monitoring the Effectiveness of Asset Management represents a substantial expansion of the conceptual apparatus compared to its predecessor: it introduces definitions of material agreement terms, management effectiveness criteria, complaints and complainants, and — critically — the concepts of potential and actual conflicts of interest on the part of the manager, with a clear distinction between them. Moreover, new management effectiveness criteria are now approved by a separate ARMA order, grounded in four principles: profitability, preservation of operational capacity, financial stability and economic viability — a dimension entirely absent from the previous procedure.

The architecture of oversight modalities has also been significantly restructured. The previous procedure provided for two forms: a desk review (conducted on ARMA premises) and a field review, with the desk review as the primary modality and field reviews reserved for cases arising from desk reviews or exceptional circumstances. The new procedure restructures the system entirely: it introduces a documentary review (equivalent to the former desk review, conducted no less than monthly, within up to seven business days), a field review (no less than quarterly, within up to 14 business days), and an additional complaint-triggered review (within up to seven business days). The field review is no longer derivative of the documentary review but is conducted independently on a regular basis. The minimum composition of the review commission has also changed, from three members under the previous procedure to four under the new one.

A fundamentally new element is the procedure for reviewing complaints lodged by asset owners. It provides for the establishment of a standing working group for complaint review, including two POC representatives; grants the authorized unit the right to conduct an additional review without mandatory prior notification to the manager; and establishes clear requirements as to the content of complaints and supporting documents. The participation of the POC has simultaneously been expanded — its representatives may be included in the review commission during additional complaint-triggered reviews. 

Procedural safeguards for managers have also been strengthened. The advance notice period for field reviews has been extended from two to five business days, and managers have been afforded more time to submit objections — five business days rather than three. The review report is now also sent to the manager’s email address as specified in the agreement, which was not previously required. Finally, the new procedure expands the grounds for action: in addition to the existing grounds of deficient management and attempts to dispose of assets, a new ground has been added — the identification of circumstances precluding preservation of an asset’s economic value — which triggers a distinct set of measures pursuant to Article 21-6 of the Law.

Asset disposal

The government has not adopted any new instruments on asset disposal. It should be noted that the ARMA Law specifies that asset disposal, with certain exceptions, is to be conducted through electronic auctions on the Prozorro.Sale electronic trading platform.

Although disposal was already conducted through that platform under the previous procedure, there are grounds for further regulatory improvement.

One such ground concerns the inability of former owners to acquire an asset — an issue illustrated by the sale of land on the Borzhava resort. Prohibiting this would align with international standards. For example, a new FATF guide on recovering assets obtained through crime notes that allowing criminals to regain their assets through auctions, even at market price, may undermine confiscation goals (such as deterrence) and damage the reputation of authorities. Some states conduct relevant checks on buyers. This is stated more directly in paragraph 40 of the Preamble to EU Directive 2024/1260 of April 24, 2024, which provides that the state should take measures to prevent assets from returning into the ownership of convicted persons or persons associated with them.

The allocation of assets into lots also warrants attention. In the Borzhava case, ARMA structured the disposal into just three lots: the first comprising 245 land plots, the second comprising 208 land plots, and the third comprising the lower terminal with a chairlift, the upper terminal of a ski lift, and 41 land plots. ARMA’s explanation — that the lots were formed taking into account the adjacency and size of the plots to maximize the commercial attractiveness of each lot and minimize the time to receipt of disposal proceeds — is far from persuasive, given that all prior auctions had been unsuccessful, save for the price-reduction auctions.

Maintenance of the seized assets register

The new Regulation on the Seized Assets Register was adopted by the Ministry of Justice rather than ARMA. This instrument substantially expands the scope of data recorded in the Register with respect to asset management activities. The previous instrument captured only proceeds from asset management and disposal. The new Regulation provides for detailed recording of the entire management lifecycle: the results of manager selection; the material terms of the management agreement, including remuneration; a link to the agreement itself; monthly management revenues; the amount of reimbursed costs; and the results of management effectiveness monitoring. Asset pools are now also recorded separately, with an indication of the economic, technological or functional unity of the assets comprising the pool. With respect to asset disposal, the Register now records a link to the electronic auction and the asset’s valuation, rather than merely the disposal proceeds.

The timelines and mechanism for entering information into the Register have also changed. The previous Regulation established a deadline of seven business days from receipt of data. The new Regulation has reduced this to the next business day following receipt of information from authorized entities. A right has also been introduced for the authorized official to return incomplete information with an indication of the missing particulars — a data quality mechanism that did not previously exist. The grounds for deletion of personal data have been clarified as well: the new Regulation adds the entry of an acquittal or the termination of criminal proceedings as distinct grounds for deletion, whereas the previous instrument was limited to the lifting of the seizure order.

Conclusions and recommendations

The ARMA reform enacted by Law No. 4503-IX constitutes a genuine systemic step forward — it has materially strengthened the mechanisms for manager selection, management effectiveness oversight, accountability and transparency. As of February 2026, however, the reform has been only partially implemented: a significant portion of the secondary legislation remains outstanding, without which the new mechanisms cannot become fully operational. This creates operational uncertainty and the risk that ambitious legislative changes will remain aspirational rather than effective.

In light of the foregoing, the following steps are recommended:

• adopt joint orders of ARMA and the Prosecutor General’s Office on the asset identification and intake procedures;
• approve the procedure for storing assets accepted into ARMA’s management and the methodology for determining management feasibility;
• adopt model asset management agreements and the expenditure approval procedure;
• align the appraiser selection procedure with the amended Law;
• adopt a revised asset disposal procedure incorporating key new features: a prohibition on asset acquisition by former owners or their related persons (in accordance with FATF standards and EU Directive 2024/1260), and clear lot formation criteria designed to maximize disposal proceeds;
• regulate the corresponding obligations of prosecutorial authorities with respect to the timelines and manner of responding to ARMA’s referrals on the need to transition to asset disposal.

It is also critically important to establish a monitoring mechanism for the implementation of adopted secondary instruments, incorporating the views of key stakeholders, in order to identify practical challenges and operational needs in the processes within the Agency’s remit. 

Overall, the pace of secondary legislation adoption is insufficient, given that the key provisions of the Law were to take effect as of February 2026. Notwithstanding this, provided that high-quality secondary legislation is adopted promptly, there remains a genuine prospect that ARMA will, in time, be able to build greater institutional credibility — both among other government authorities and with the broader public. 

Reform status and implementation of the law

To meet the requirements of the ARMA reform law, a package of subordinate regulations has already been drafted, and a substantial portion has entered into force. The implementation status of the key documents is as follows:

• The government has approved procedures for selecting asset managers for “simple” and “complex” assets, for monitoring the effectiveness of management, and for calculating estimated value.
• The resolution on asset insurance has successfully passed the government committee stage and is being prepared for consideration at a Cabinet of Ministers meeting.
• The procedure for approving template agreements and asset management programs is at the final stage of review within the Cabinet of Ministers Secretariat.

In addition, the meeting noted that the commission for selecting managers for complex assets is being finalized, and central executive authorities have already submitted nominations.

Inventory results and asset classification

This was among the most extensive tasks to be completed in the six months after the updated ARMA law was adopted. According to the Agency, as of December 31, 2025, the Unified Register of Seized Assets contained 102,569 entries. To determine the real volume of liquid assets, ARMA filtered out items without independent economic value, including 28,000 household items from Mezhyhiria and 20,000 items from Medvezha Dibrova.

This claim sparked a serious debate at the committee meeting: participants spent considerable time trying to establish how many assets are actually under ARMA’s management. We find the very reasons for this debate deeply unfortunate, because the same ARMA reform law launched the inventory of remaining assets and introduced the concept of an “asset pool” precisely so that economically meaningful groupings of assets could be identified and transferred for management effectively. 

Committee Chair Anastasiia Radina pointed out that ARMA was unable to produce a single official document confirming the inventory results, relying instead on “working materials” and internal memos. Yaroslava Maksymenko explained that methodological confusion and outdated accounting persist, along with a “clogged” seized assets register filled with small items and limited resources. In fact, a full, in-depth inventory of all 102,000 objects—given current staffing—would take roughly four months.

Ultimately, ARMA proposed fixing as a baseline 44,815 assets transferred since 2017 under 1,435 court rulings received by the Agency as of December 31, 2025.

Overall, the breakdown by asset category is as follows:

• Vehicles and equipment: 22,384 assets (including 19,307 units of railway rolling stock)
• Real estate and land plots: 6,842
• Various types of goods: 6,613
• Movable property and inventory items: 6,162
• Financial assets and corporate rights: 2,814 (including 533 business entities)

As for the economic liquidity of these results, there is still no final assessment. However, an overall review of identified assets showed the following distribution:

• 22,730 assets were deemed potentially manageable or suitable for sale;
• 6,982 items were destroyed, damaged, or located in occupied territories, abroad, or listed as wanted;
• 3,542 assets require procedural follow-up or a change in the method of management through the courts.

In summary, an accounting discrepancy was identified for 11,561 objects. As the Agency explained, this reflects a mismatch between assets transferred in practice and the assets listed in court rulings. In addition, work to define liquid units of assets has not yet been completed. Once identification is finished, the Agency plans to conduct a physical inventory and place assets on its balance sheet. When asked how many assets have been transferred to managers, and how many have been put out to competition, ARMA did not provide an answer.

Overall, Radina sharply criticized the absence of a single administrative act that would formally record the inventory results and establish the final number of assets. ARMA must therefore provide official information with verified figures, clearly distinguishing assets that can be managed, those requiring additional documentation, and the “gray zone” (unidentified property).

Social initiatives: housing for IDPs

Although the committee meeting did not ultimately yield a results-focused discussion of ARMA’s performance, MPs raised several questions they considered important. One concerned developing a mechanism for using seized residential real estate to meet the needs of internally displaced persons. ARMA proposed applying Article 21-1 and transferring such assets to state-sector entities, since commercial competitions for these properties did not attract private investors due to the social burden involved.

Maksymenko, however, pointed to technical obstacles. For example, many apartments are currently occupied by minor children, whose eviction is prohibited by law. In addition, commercial hotels have good-faith tenants whose equipment keeps building infrastructure functioning, and there is no mechanism to relocate people if a court unexpectedly lifts an arrest. The parties agreed to revisit the issue at the next meeting. We previously flagged similar risks related to transferring seized assets for IDP needs in our legal analysis of the relevant draft law.

High-profile asset cases: KAMparytet, Pin-Up, and CHP plants

The discussion of high-profile asset management cases was no less telling.

The first example concerned the KAMparytet management company whose interests, in spring last year, were allegedly advanced by then-ARMA head Olena Duma. Radina cited facts suggesting that the manager sublet shopping centers at prices three times higher than the income it declared to ARMA, leading to direct budget losses. The Agency confirmed the revealed violations and reported that it had begun procedures to terminate the contracts with this manager for inefficiency. 

One MP also expressed outrage at the return of UAH 122 million to Pin-Up owner Ihor Zotkin, described as having a questionable reputation. Yaroslava Maksymenko responded that she was executing a court decision: the plea agreement approved by the prosecutor did not provide for confiscation of these funds, which automatically required returning both the funds and the income generated from their management once the arrest was lifted.

A separate point is worth making here: the amendments allowing confiscation as a punishment when concluding an agreement that provides for release from serving a sentence applied only to corruption offenses. In this case, questions should have been directed not at ARMA’s leadership, but at Prosecutor General’s Office prosecutor Maksym Kapustin, who is listed on the court’s website as the prosecutor who submitted the agreement, and at Pecherskyi District Court judge Oleh Soloviov, who issued the judgment based on that agreement after finding it to be in the public interest. 

As for the management of the Novyi Rozdil and Novoiavorivsk CHP plants, seized in the case involving former MP Dubnevych, MPs emphasized the risk of disrupting the heating season because the current contracts expire in November 2026. They stressed that Naftogaz needs guarantees of continued management now to plan budgets for technical upgrades and modernization. ARMA’s leadership assured the committee that all contracts are being processed, but that extending them through the Cabinet of Ministers takes time.

Financial indicators and budget revenues

One committee member presented an analysis of budget revenues from asset management in the second half of 2025, showing a steep decline:

• July 2025: UAH 102 million
• August 2025: UAH 57 million
• September 2025: UAH 45 million
• November 2025: UAH 29 million

ARMA representatives explained that July’s UAH 102 million was an anomalous one-time spike driven by dividend payments from Ukrnafta and Naftogaz. Subsequent figures, they said, reflect problems with previously concluded contracts for managing seized assets and the genuinely low effectiveness of current management for other assets.

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Taken together, these developments show that ARMA’s reform requires significant resources and systematic, parallel management of several processes—something that still has not happened at the highest level.

Unfortunately, we still have not heard a clear picture from ARMA’s new leadership of how many assets are actually manageable. Confusion over the numbers remains, driven by different accounting approaches. That said, Maksymenko’s and Saienko’s answers were more focused on constructive work rather than populist statements—as was often the case before—which gives some hope that the processes described above will pick up pace.