Ten points, though in practice there may be more

In December 2025, in Lviv, Ukraine and the EU launched a technical process that allows preparations for closing negotiating chapters to move forward without waiting for Hungary’s veto to be lifted. At the same time, as part of that package of decisions, European Commissioner Marta Kos and Deputy Prime Minister Taras Kachka agreed on a plan of 10 priority reforms in anti-corruption and rule of law.

In reality, however, this list contains significantly more than 10 points.

For example, the first point can reasonably be split into four separate ones, since it covers investigation timelines, limitation periods, safeguards against procedural delays, NABU jurisdiction, and other issues. If we follow the classic route—passing separate laws for each of these matters—we will get stuck in parliamentary corridors for years.

But there is a way to avoid that trap.

Instead of implementing a long list of tasks one by one, they can be consolidated into a single law. In particular, all elements of the first point can be delivered through comprehensive amendments to Ukraine’s Criminal Procedure Code (CPC).

According to our sources, the Deputy Prime Minister’s Office has chosen exactly this route and decided to focus on CPC amendments as the most substantial item in the document.

The road to the EU runs through the CPC

What should these amendments include to genuinely solve these problems? Let us explain through a concrete example.

In criminal proceedings, especially in high-level corruption cases, delays often arise because participants deliberately abuse procedural rights.

For example, in the case against a former official of the Ministry of Agrarian Policy’s state property management department, accused of receiving a $150,000 bribe, defense lawyers systematically and in a coordinated manner failed to appear at court hearings for a month, causing all five hearings to be postponed. The result was not only a breach of reasonable time requirements, but also de facto impunity for those who committed serious corruption offenses.

The Ministry of Justice confirms plans to introduce amendments that would fix this and similar problems. 

Why, specifically, have CPC amendments become the top priority?

“Because the CPC governs criminal proceedings, and therefore its provisions create space for ‘procedural sabotage’—formally lawful actions that undermine the effectiveness of the justice system. One high-quality law amending the CPC can address several of Brussels’ fundamental rule-of-law requirements at once,” says Pavlo Demchuk, Senior Legal Adviser at Transparency International Ukraine. 

Acting Minister of Justice and Deputy Minister for European Integration Liudmyla Suhak agree that CPC amendments are a priority. However, her comments indicate that the government is not ruling out the adoption of several laws.

“On February 2, the Ministry of Justice submitted to the Government a draft law on strengthening the institutional capacity of the NABU and the SAPO (the Specialized Anti-Corruption Prosecutor’s Office) and removing procedural obstacles to effective pre-trial investigation. The draft law proposes expanding the range of persons under NABU jurisdiction, granting the Head of SAPO powers to form joint investigative teams, and enabling extradition requests in NABU cases,” Suhak said.

In addition, the Ministry of Justice is now preparing to draft bills amending the Criminal Procedure Code “that will cover the maximum possible number of measures in this area under the Rule of Law Roadmap,” she added.

What exactly needs to change

First, Ukraine needs the already mentioned mechanisms to counter abuse of procedural rights. In particular, courts must be given tools to respond to bad-faith conduct by parties to proceedings.

This is not a simple task, because in some cases parties use sophisticated tactics: stretching out closing arguments (as in the Nasirov and Chaus cases), unjustified failure to appear at hearings, and similar maneuvers.

“In a significant number of European states, such actions are recognized as abuse, and courts have tools to counter them,” says Pavlo Demchuk.

Not all EU countries have these tools—but those that introduced them clearly did so for compelling reasons.

Ukraine now has those same reasons. “The absence of such safeguards in the CPC not only allows people to evade criminal liability, but it also makes justice as a whole more expensive and more cumbersome,” the expert explains.

In addition, the CPC still contains a problematic provision that allows automatic closure of criminal proceedings when the pre-trial investigation time limit is missed. It is often—though not entirely accurately—referred to as the “Lozovyi amendments.”

There have been countless attempts to fix this. In late 2024, the Cabinet of Ministers registered a draft law to remove these provisions, but it never reached a vote and was withdrawn after the government resigned.

Taras Kachka now proposes dropping that label. “The term ‘Lozovyi amendments’ is so loaded that once it appears in a discussion, everyone reacts reflexively—either positively or negatively—and the substance disappears from the debate,” the Deputy Prime Minister said in an interview with European Pravda.

And indeed, the Kachka–Kos document does not mention Andrii Lozovyi by name; it focuses on the problem itself—automatic case closures—which must be resolved.

Another problematic issue is limitation periods, including when they cease, are interrupted, or are suspended. Here, there is no single clear “European standard.”

“There is no single recognized approach to regulating limitation periods in the criminal legislation of other states. However, international anti-corruption instruments pay considerable attention to this. Moreover, the draft EU Directive says the minimum limitation period should be from eight to fifteen years, depending on the gravity of the offense,” says Pavlo Demchuk.

In Ukraine, where the period is often several times shorter, the need for reform is urgent. “Even so, effective work by investigators and courts to ensure reasonable time limits in pre-trial investigation and court proceedings is just as important,” he stresses.

Ukraine also urgently needs to simplify and accelerate procedures by introducing written proceedings in certain cases, narrowing grounds for panel hearings, and removing excessive formalities such as mandatory participation of attesting witnesses.

For example, cases against MPs for false asset declaration (a non-serious offense) must currently be heard by a three-judge panel, consuming significant judicial resources.

Another example: if even one judge is replaced, the court must restart hearings from scratch, even where the new judge sees no need to do so. At the High Anti-Corruption Court, several top cases have already restarted “from square one.” This significantly delays proceedings and may lead to limitation periods expiring and cases being closed. The CPC could instead provide that replacing judges does not trigger a retrial, except where, for example, the new judge disagrees with earlier rulings.

As a third reform track, TI Ukraine proposes strengthening the capacity of anti-corruption institutions by clarifying NABU jurisdiction, granting additional powers to the Head of SAPO, and ensuring better coordination among institutions, including with the Asset Recovery and Management Agency (ARMA) on the management of seized assets. For example, clear deadlines should be set for transferring proceedings to the NABU following a relevant decision by its director. It should also be specified that NABU jurisdiction extends to the Head of the Presidential Office and their deputies.

Because these “small details,” taken together, undermine the effectiveness of the NABU and the SAPO.

“We have prepared our proposals for CPC amendments and are engaging with different stakeholders. If MPs listen and agree to adopt comprehensive CPC changes, this will move forward the largest requirement in the Kos–Kachka plan,” Pavlo Demchuk explains.

At the same time, this must be defined from the outset: for real change, including a jump in CPI-2026, we need public validation, meaning a public green light for the new package from the European Commission.

Because once Brussels officially confirms that “Ukraine has removed key barriers in justice,” and those changes are effectively implemented, this will change how the country is perceived by investors, international institutions, and Ukrainian citizens themselves.

It converts “process” into “trust.”

List of CPC amendments proposed by TI Ukraine:

• Introduce written proceedings, i.e., allow courts to consider and decide certain procedural issues without the participation of parties and without holding a court hearing.
• Establish, as a core principle of criminal proceedings, the inadmissibility of abuse of procedural rights, and define mechanisms for its enforcement.
• Provide that, where a case is heard by a panel, this applies to the trial stage rather than preparatory proceedings; and reduce exceptions to the single-judge rule by limiting panel hearings to especially serious criminal offenses, rather than tying them to the defendant’s office or status.
• Provide that the absence of one or more defense counsel for a suspect/accused does not prevent a hearing from proceeding; postponement to safeguard defense rights should be allowed only if all defense counsel for the suspect/accused are absent.
• Supplement the CPC with mechanisms for interaction with ARMA when deciding whether to transfer assets to the Agency. 
• Clarify that an investigating judge is barred from participating in the same case at trial only where that judge exercised judicial control with respect to the specific person concerned.
• Ensure the possibility of imposing monetary penalties on both defense lawyers and prosecutors if they fail to appear without valid reasons or fail to report reasons for non-appearance.
• Expand NABU’s personal jurisdiction to include the following positions: Director of the State Bureau of Investigation and their first deputy/deputy; Head of the Office of the President of Ukraine and their first deputy/deputy; head of a regional, Kyiv City, or Sevastopol City state administration and their first deputy/deputy; head of a regional or Kyiv City Military-Civil Administration and their first deputy/deputy; head of a Regional Military Administration or Kyiv City Military Administration and their first deputy/deputy; senior leadership of the Economic Security Bureau of Ukraine and the State Bureau of Investigation; and members of supervisory boards and executive bodies of large enterprises where the state or municipal ownership share exceeds 50%.
• Provide that a pre-trial investigation body must transfer the available materials of relevant criminal proceedings to NABU immediately, and no later than five working days from receipt of the NABU Director’s decision requesting those materials.
• Remove the requirement to involve attesting witnesses during searches and inspections.
• Remove the court’s obligation to close criminal proceedings due to expiry of the pre-trial investigation time limit (Article 284(1)(10) of the CPC of Ukraine).
• Provide that, if a judge on a judicial panel is replaced, the court may, by a reasoned ruling, decide there is no need to restart the trial from the beginning or to repeat all or part of procedural actions.
• Provide that a court may impose time limits on a participant’s closing argument where the speech shows signs of abuse of procedural rights.
• Add that an investigating judge/court may, depending on case circumstances, issue a separate ruling where participants breach procedural duties, perform them improperly, or abuse procedural rights.
• Provide that after drafting and signing the full text of a judgment, the court may limit public pronouncement to the operative part, with mandatory service of the full text on parties the same day. 
• Remove the appellate court’s power to quash a judgment/ruling and order a new trial in the court of first instance.
• Allow the court to request collected pre-trial investigation materials or require prosecutors to submit such materials to the court together with the indictment and plea agreement.
• Make special confiscation mandatory, where legal grounds exist, when approving a plea agreement.
• Grant the Head of SAPO the power to initiate criminal proceedings and approve investigative actions involving Members of Parliament.
• Provide that matters related to the enforcement of judgments convicting a person of a corruption criminal offense are considered by the HACC.
• Grant the Head of SAPO powers in international cooperation (not only via CPC amendments, but also through corresponding ratification laws for international treaties).

Why is this result happening despite government action? 

I’ll admit it: when I saw the first CPI numbers, I felt a certain dissonance. On paper, we’re up. In the reality of 2025, we saw a near-total paralysis of systemic anti-corruption change. Most reforms didn’t just slow down—they moved into the risk zone. Even the critically important transformation of ARMA was accompanied by such delays in Parliament that they resulted in direct financial losses for the state budget.

Instead of systemic steps, we saw an escalation of corruption scandals. At one point, it became hard to shake the impression that key anti-corruption “safeguards” were being deliberately dismantled. How else can one interpret a situation in which people from the president’s inner circle become subjects of NABU and SAPO investigations? 

It’s important to state this honestly: law enforcement activity in these cases is not the result of political leadership’s goodwill or some internal “self-cleansing” of the system. It is solely the result of NABU and SAPO’s professional autonomy. They kept pressing top-level corrupt actors even under direct political and coercive pressure.

So where did this point increase come from? 

A detailed analysis of the CPI components confirms that we are dealing with a unique shift in perception. For years, our organization has explained that the Index does not measure the physical volume of bribes; it measures how corruption is seen and perceived by experts and business — both inside and outside the country. We always want to see steady “pluses,” because they signal partner trust. But last year, even inside the country, there was no sense of progress. On the contrary, we felt a familiar and highly dangerous taste of a return to arbitrariness, where real fighting is replaced by imitation.

External factors also weighed on the situation. We cannot ignore the change in the United States’ focus regarding Ukraine’s reform agenda. The demanding stance of Western allies eased somewhat, while European leaders had to concentrate on their own security. Constant assurances of unconditional support for Ukraine created a dangerous illusion of permissiveness “on the Pechersk hills”—as if, in domestic policy, anything would now be tolerated.

People in the president’s circle felt beyond reach. And society gave a clear response: Ukraine in 2025 is no longer the country it was twelve years ago. The avalanche of public anger moved in a very different direction than the initiators of last July’s reform rollback had expected.

Who actually saved our numbers?

The CPI captures processes dynamically over the last two years. For me, the most telling signal was that Ukraine gained five points at once in the Bertelsmann Foundation’s research—an index that records whether officials face real accountability for corruption. In other words, researchers saw and assessed not politicians’ promises, but real procedural actions by the NABU, the SAPO, and the HACC.

That is the core answer to why the authorities failed to break the anti-corruption vertical in the summer of 2025. If detectives’ work used to be perceived as something intangible, we now have proof: this work is seen and counted by global institutions and by Ukrainian citizens alike. No one would have taken to the streets to defend powerless bodies. Instead, we witnessed the first major social protest of the full-scale war period.

That public resolve had deep meaning. In July, people came out with cardboard signs to defend institutions; by the end of the year, we understood that fighting corruption is a matter of physical security — as basic as heat, electricity, and defense capacity. Citizens preserved NABU and SAPO, and in the fall, those agencies exposed the “Barrier” scheme and the high-profile Mindich case. These investigations literally stopped the state from sliding into the abyss of chaos.

What is more, 2025 proved that political influence is no longer an indulgence. Today, law enforcement can reach any corrupt actor — a challenge even for developed democracies. If cases used to be launched mainly after investigative media reports, anti-corruption institutions themselves have now seized the initiative. This is a fundamentally new quality of the fight.

Breakthrough strategy: what comes next?

Still, we should be realistic: even NABU and SAPO at peak effectiveness cannot radically change the situation without systemic reforms. Politicians may try to play on their own field by their own rules, or sabotage votes for months. But in the end, obligations will have to be met. This is no longer a matter of “good behavior” for the IMF. It is a matter of survival.

We understand it’s impossible to implement all reforms at once because of shortages of resources and human capital. But some steps require not billion-dollar investments, only political will. Transparency International Ukraine has identified six priorities for 2026:

1. Unconditional safeguarding of the independence of anti-corruption institutions.
2. Better results in confiscating criminal assets.
3. Stronger institutional capacity and focus of the NACP.
4. Comprehensive modernization of the Criminal Procedure Code to ensure swift justice.
5. Involvement of international experts in selecting HQCJ members.
6. Full adoption and implementation of the State Anti-Corruption Program.

Delivering on these points will make it possible to convert high-profile notices of suspicion into real convictions. This year’s additional point is progress at the margin of error. But for Ukraine it weighs more: our society has definitively changed its paradigm. 

Corruption has stopped being “background noise” or the government’s internal affair. This intolerance, documented in protests and in action, reshapes not only how the world perceives us, but also the very boundary of what is acceptable inside the state.

The CPI point gained is an advance that can still be used well

What we did not see in 2025 was the comprehensive reform package promised by the authorities. Even though some processes were launched, many recommendations and commitments from the previous year had to be rolled over to 2026.

Last year the Cabinet approved Transformation Road Maps in the areas of the rule of law, public administration reform, and democratic institutions, and parliament finally voted for ARMA reform. But the NACP audit remains blocked; over the course of the year, the Verkhovna Rada still failed to establish a commission for selecting candidates to the Accounting Chamber; and a number of legislative initiatives intended to improve the effectiveness of investigating and adjudicating corruption cases never found the necessary “political will.” 

And, as the final touch on this negative picture, international experts’ participation in the Selection Commission for appointing HQCJ members was terminated. This precedent may be highly damaging for future competitions to staff public institutions. A risk already hinted at in several points from the much-criticized Vlasenko–Buzhanskyi temporary commission report. The episode involving attorney Oleksii Shevchuk points to additional risks. It demonstrates what kind of selection-commission members purely domestic appointing actors are prepared to nominate, with Prosecutor General Ruslan Kravchenko being one such actor.

The progress achieved so far in fighting corruption has been possible primarily because of the commitments Ukraine has undertaken with international partners. These commitments remain the main incentive that can still drive improvements in anti-corruption policy, and, fortunately, society generally supports implementing these changes.

Over recent years, Ukraine has signed a number of agreements and strategic documents shaping its development path, including the Ukraine Facility Plan, the EU Enlargement Report on Ukraine, the IMF program under the Extended Fund Facility (EFF), the Rule of Law Road Map, and the Plan of 10 Priority Reforms in Anti-Corruption and Rule of Law. In one way or another, these documents account for the need to implement reforms that will continue to significantly affect Ukraine’s scores in the Corruption Perceptions Index.

Overall, in TI Ukraine’s view, 6 steps are needed in 2026 to produce real change in the fight against corruption:

• safeguard the independence of anti-corruption institutions;
• improve outcomes in corruption cases, especially in freezing and confiscating illicit assets;
• enhance the institutional capacity and focus of the National Agency on Corruption Prevention; 
• update legislation to ensure swift, high-quality justice;
• expand the involvement of international experts in the selection commission for appointing HQCJ members; 
• adopt an Anti-Corruption Strategy and a State Anti-Corruption Program. 

Unfortunately, we have discussed most of these steps many times before. Now, it is time to complete our overdue homework.

What about the global picture?

CPI 2025 shows that, overall, the corruption situation is worsening. Even in established democracies, corruption is rising amid weakened leadership. And the number of countries scoring above 80 points has fallen from twelve ten years ago to just five this year.

Among Ukraine’s western neighbors, only Poland’s score remained unchanged—53 points and 52nd place in the Corruption Perceptions Index 2025. By contrast, Slovakia (48 points, 61st place), Romania (45 points, 70th place), Moldova (42 points, 80th place), and Hungary (40 points, 84th place) each lost 1 point. That is, despite all of Ukraine’s current challenges, Ukraine became the only country in the region that managed—even if only slightly—to improve its position in the study.

Negative trends are also visible across the European Union and Western Europe: while the average score for these countries was 66 in 2022, it has dropped to 64 this year. 

More broadly, country scores in the Index point to an alarming decline across democratic states. Another troubling pattern has been the growing number of restrictions on freedom of expression, association, and assembly in many countries—and this has not been limited to areas with active armed conflict. 

A lack of visible anti-corruption progress is also evident among Ukraine’s largest partners. In December 2025, the EU agreed its first Anti-Corruption Directive to harmonize criminal legislation on corruption. But the final version of this document turned out to be far from what was expected: many of the adopted provisions that were supposed to ensure zero tolerance for corruption in EU countries were watered down. In addition, some countries took questionable positions. For example, Italy blocked the criminalization of abuse of office by public officials. 

The situation in the United States is even more troubling: in CPI 2025, the U.S. received the lowest score in its history—65. And that is despite the fact that most events of 2025 were not fully reflected in the study. It is therefore already possible to predict that measures by President Trump’s current administration aimed against freedom of expression and toward undermining judicial independence will be reflected even more negatively in future Indexes. 

And, unfortunately, these processes inside the United States will have a tangible impact on anti-corruption progress in other countries, because reductions in U.S. financial support for civil society and humanitarian initiatives have weakened global anti-corruption efforts.

Transparency International Ukraine calls on the authorities to take six priority steps in 2026, including:

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. 

The CPI 2025 result indicates minimal progress amid a slowdown in systemic anti-corruption reform. One additional point does not offset the lack of comprehensive government action and creates a risk of declining trust. The 2026 trajectory will directly depend on the state’s ability to move from reactive steps to a consistent anti-corruption policy.

Background: The Corruption Perceptions Index (CPI) is a ranking calculated by the global organization Transparency International since 1995, based on 13 assessments by reputable international institutions. This year, Ukraine was evaluated on 8 of them, covering January 2023 through September 2025. Because of methodological constraints, many important developments, including the high-profile “Midas Case” investigation, are not reflected in this study.

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.

Why was Ukraine scolded and praised?

Despite changes within the margin of error, a systemic negative trend is emerging in the study’s results. According to experts, Ukraine’s performance declined in five of the eight studies, namely: 

• Country risk rating by the analytical department of The Economist (18 points), which evaluates budget transparency, misuse of funds, bribery, and appointments to public sector positions;
• S&P Global Insights’ country risk rating (32 points), which assesses the risks of bribery in import/export activities, government contract procurement, and general business operations;
• PRS Group’s International Risk Survey (33 points), which focuses on nepotism and patronage, suspicious links between politics and businesses, the exchange of services, and the secret financing of political parties;
• Varieties of Democracy’s survey of Corruption Index experts (33 points), which focuses on corruption in the executive, judicial, and legislative branches of power;
• World Economic Forum Executive Opinion Survey (40 points), which focuses on the distribution of public funds and bribery.

Therefore, to sum up, in many cases our country has performed worse in research focused on political corruption. From this perspective, procurement scandals in the defense and energy sectors, revelations of leaks at NABU, the controversial appointment of Olena Duma as the head of ARMA despite public warnings, and other similar incidents in recent years may have had a negative impact. Moreover, as noted earlier, new cases of government pressure on journalists and activists have been recorded over the past two years.

At the same time, three other studies recorded slight improvements in Ukraine’s scores, helping to partially offset the overall decline:

• Nations in Transit Report by human rights defenders at Freedom House (37 points), which evaluates bureaucracy, protection of whistleblowers, and the implementation of anti-corruption legislation;
• Bertelsmann Transformation Index (51 points), which highlights efforts in preventing corruption, as well as media and legal prosecution of corrupt officials;
• Global Justice Project’s Rule of Law Index (34 points), which evaluates the abuse of official positions for private gain.

In the latter study, where we improved our score by 1 point, the judicial sphere showed the most significant positive change. This improvement is likely attributable to several developments, including the detention of former Supreme Court head Vsevolod Kniazev in May 2023, the resumption of the HCJ in January 2023 and the HQCJ in June 2023, and the initiation of a competition for the Constitutional Court, among other measures.

According to the Bertelsmann Foundation—which recorded a 2-point increase for Ukraine—the processes of digitalization that reduce corruption opportunities, along with the partial de-oligarchization of the country that has weakened the influence of large business representatives, were viewed positively. Experts also observed an intensification of anti-corruption investigations by the NABU and SAPO, which over the past two years have initiated numerous cases against former MPs, the ex-Minister of Agrarian Policy, the ex-head of the SPFU, the SJA, and other top officials.

However, the report does not yet mention the principle of equality before the law for officials—a gap that reflects the general corruption within the law enforcement and judicial systems. Researchers note that, with winning the war as the top priority, anti-corruption efforts have taken a secondary role, and limited access to public data continues to pose significant corruption risks.

A report by Freedom House experts highlights the success of anti-corruption institutions in exposing and legally evaluating corruption in defense procurement (with the defense procurement legislation updated in early 2023). Also, human rights activists noted the reinstatement of mandatory electronic declarations for officials and the postponement of launching the register of oligarchs following comments from the Venice Commission. At the same time, Freedom House warns that certain corrupt officials may attempt to sabotage the state Anti-Corruption Program, which was adopted in March 2023. 

Where should Ukraine look for ways to improve its CPI performance?

The fact that our success in combating corruption is primarily a result of implementing international commitments and European Commission recommendations once again confirms that our country’s European integration is inextricably linked to the fight against corruption.

Ukraine needs to develop ambitious and comprehensive roadmaps for joining the European Union. This year, negotiations with the EU may begin with the first and most complex cluster, “Fundamentals”, which includes Negotiation Section 23 on Justice and Fundamental Rights—covering the fight against corruption. However, for Ukraine, the anti-corruption component will be integrated into every negotiation cluster with EU countries, spanning from agriculture, environment, and social policy to customs, transport, and energy. 

Therefore, the newly developed screening report, along with the European Commission’s enlargement reports—which include numerous European integration requirements—should serve as valuable sources of guidance for improving the corruption situation. They could be the key to Ukraine’s breakthrough in the Index.

Additionally, many reforms are detailed in other documents. For example, the roadmap for the restoration in the Ukraine Facility Plan outlines requirements that must be met to secure monetary assistance from the EU. It is also worth mentioning the measures indicated in the IMF Extended Fund Facility. The implementation of these recommendations ensures the financial and macroeconomic stability of Ukraine and continues to play an important role for us.

But most importantly, the authorities should view the implementation of these requirements as a marathon to strengthen Ukraine—not as a short sprint aimed at securing funds, no matter how high a priority closing budget gaps may be. Simply ticking boxes on reforms will not yield strategic results; we must commit to playing the long game. 

If we succeed, Ukraine may be able to demonstrate an effective fight against corruption, paving the way for genuine EU membership by 2029—a scenario predicted by the EU Enlargement Commissioner regarding Ukraine’s accession prospects.

Where is Ukraine in CPI now

From the perspective of someone unfamiliar with our realities, the situation may not seem so bad, given our current position among 180 countries. We share 105th place with another EU candidate country, Serbia, which also scored 35 points last year. The Dominican Republic is one point ahead of Ukraine on the index, while Algeria, Brazil, Malawi, Nepal, Niger, Thailand, and Turkey scored one point lower. 

Overall, over the past 11 years in the Index, Ukraine has gained 10 points, with the current 35 points being the average result for the region. Looking at other countries striving to join the EU, we see that some are either stalled in their progress, like Georgia, Montenegro, and Turkey, or are rolling back, like Northern Macedonia, Bosnia and Herzegovina, and Serbia. Only Moldova managed to steadily gain another point, while Albania increased its score by as much as 5 points.

The same situation is with Ukraine’s neighbours. Although I’ve already mentioned Moldova, Poland, Hungary, and Slovakia also show the same trend, with the latter even losing 5 points. Not to mention Russia and Belarus, which are steadily heading towards the positions of Afghanistan and Somalia, not only in terms of political regimes but also in the CPI.

So, maybe there’s nothing to worry about if this is the case for everyone? It may not be worth paying attention to, but not for Ukrainians who have been living in full-scale war mode for almost three years. Under such conditions, every setback, any drawdown, or even just a pause or delay in the fight against corruption is a loss of territories and lives. Real lives, because every lost hryvnia could have gone towards the defense. 

Therefore, we are concerned about even the slightest decline in the CPI

I wrote last year about the growing negative trends in the CPI when Ukraine was steadily improving in the Index. Even then, the state of uncertainty for many Ukrainians was evident, and unfortunately, this factor has only increased since.

The essence of my concern was also that I understand the key feature of the Corruption Perception Index. Since this is a large study covering many areas, its overall period simply cannot capture all the key events from the previous year in the fight against corruption. 

In the vast majority of cases, the CPI reflects the factors that influenced the perception of corruption a year and a half before its release, often overlooking events from the fall of the studied year entirely. The current CPI indicator almost certainly did not include the scandal with the MSEC or the procurement of low-quality mines, but it likely took into account the suspicion surrounding Kniaziev, the resumption of e-declarations in 2023, and the January 2024 surveillance scandal involving Bihus.Info journalists.

In other words, the events and issues that alarmed us when discussing the CPI 2023 were directly reflected in Ukraine’s loss of points this year.

Notably, Ukraine last experienced a similar one-point decline based on the 2021 results. It was a landmark moment for us — the pre-war tension, the lingering effects of the COVID-19 pandemic, procurement schemes, and the unpleasant arbitrariness of some officials in anticipation of new election races. 

The feelings are similar now but amplified by the war. There is very little positive news from the front, and even reports of regular strikes on enemy refineries do little to ease internal tension. The increase in the number of corruption cases and convictions in high-profile cases is perceived not so much as evidence of the effective work of anti-corruption bodies, but as a sign of widespread corruption among officials.

All of this unfolds against the backdrop of growing uncertainty about the future of the war, the use of political influence and corruption schemes, and ongoing skirmishes both offline and on social media.

Perhaps not to the full extent, but the Corruption Perception Index has captured all these trends. Therefore, the decline in the study, which focuses primarily on changes in dynamics rather than point successes, serves as a bad signal for our authorities. Ukrainian officials need to pull together and deliver high-quality results on the rear to support the war effort, rather than trying to address situational crises. After all, the stronger the state, the more efficient we become with limited resources. 

Ukraine’s decline in the CPI is a signal for its partners. Our interaction with the world has reached the point where both internal and external perceptions of corruption in Ukraine are increasingly interconnected. Let me note that the Corruption Perception Index largely disregards the feelings and moods of Ukrainians. First of all, the study’s indicators are based on the assessments of global experts, so the decline in the CPI 2024 signals that the internal struggles of Ukrainians are becoming more visible.

As well as the attempts of the country’s leadership to create their personal reality, where all their “excesses” can be justified by war, but at the same time limit institutions and break the rules where their implementation, on the contrary, would have an effect. “We’re at war, for God’s sake, what do you want from us? What reforms?”

This noticeable imbalance also signals a rise in international media coverage of corruption in Ukraine. The further you go, the harder it becomes to refute the facts presented, as reality cannot be denied. 

What actions should we take to improve our CPI score?

In the current Index, Ukraine managed to maintain its position primarily because, even with manual control, there are still attempts at reforms. 

We have heard this word so many times in recent years that, perhaps, for some, it has lost its value and become as “hackneyed” as the word “corruption,” which marks all things unpleasant to the Ukrainian eye. But we cannot deny that Ukraine remains a state not only because of the strength of its defenders on the front line but also because it is striving to reform and change from within. And no matter how hard it is, it sometimes succeeds.

Although real unity is lacking in both the government and parliament, the Cabinet of Ministers continues to draft laws necessary for European integration, while the Verkhovna Rada, at least every second or third attempt, adopts legislative changes required by international commitments. The further we go, the harder these steps are but both MPs and the government continue to fulfill their obligations. 

Unfortunately, that is the bare minimum established in agreements. On their part, MPs do not initiate or do anything beyond the recorded commitments. Why are the authorities even interested in taking these steps? I see several reasons for this.

First and foremost, so that our country still has partners and we can continue to fight for our very existence. It is a significant argument that encourages power branches to do the things they are not really interested in. 

Another reason to proceed with the reforms is because those ticks in the box bring much-needed money to Ukraine. The opportunity to secure financial aid and bridge the huge gap in Ukraine’s budget is what motivates officials to fulfill international commitments. It is not a secret to our partners. No wonder that recommendations in the Ukraine Facility Plan and the IMF Extended Fund Facility are extremely often mentioned and largely complement each other.

Last but not least, positive changes may still happen through the efforts of the few reform-minded forces remaining in the executive and legislative branches. They are scarce, but they exist.

Therefore, no matter how much we talk about the qualitative European integration and implementation of necessary reforms, these talks will never be enough. Behind the talks, we see actions, no matter how slow their progress. These actions, beyond the financial aid they bring, actually strengthen the state — even if we may not feel their impact tomorrow, but only years from now.

***

We have reached a point where, the further we go, the more signals emerge for the authorities that this country urgently needs real, comprehensive changes. The CPI 2024 results are one of that signal.

Corruption exists in Ukraine — that is a fact. It would be significantly lower if the state were more effective. If the authorities prioritized established procedures and built state bodies as comprehensive institutions instead of pushing decisions by force, governance would be more stable and efficient. Unfortunately, that is not the case. 

I would gladly be proven wrong and see that systemic changes are possible because the motivation for them is genuinely strong. I would also like to believe that this year’s one-point decline in the CPI is merely a marginal error. However, from what I see now, I regret to admit that the flaws and threats are more than just marginal errors.

Due to methodological limitations, many events from fall 2024 and early 2025 did not influence the current Index’s results. However, many of these events may intensify the negative trend in how Ukraine’s fight against corruption is perceived, potentially leading to a further deterioration in our CPI score. 

“A one-point drop is not yet a sign of overall decline, but it does mark the onset of stagnation. This is an alarming signal for the authorities, suggesting that we have fallen short in some areas,” notes TI Ukraine’s Executive Director Andrii Borovyk. “Even though a score of 35 is the regional average, we cannot afford to be complacent. Our resilience during the war, the support of our partners, and Ukraine’s European integration process are all at stake. Therefore, the authorities must heed this warning and intensify their genuine anti-corruption efforts.”

In general, the problem of halting progress or even experiencing a decline in the CPI is also common among other countries in the region. Among the EU candidate countries, the following results were recorded: over the year, the scores for Georgia (53 points, 53rd place), Montenegro (46 points, 65th place), and Turkey (34 points, 107th place) remained unchanged. Serbia lost 1 point (35 points, 105th place), while North Macedonia (40 points, 88th place) and Bosnia and Herzegovina (33 points, 114th place) lost 2 points each. Only two candidate countries managed to improve their performance: Moldova’s score increased by 1 point to 43 (76th place), and Albania’s score improved by 5 points to 42 (80th place).

The average score for the European Union this year decreased by 2 points and amounted to 62 points.

Among its neighbors, Ukraine remains ahead of Russia—a 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.