Summary

In 2024–2025 and Q1 2026, over three-quarters of monitoring procedures in competitive procurement began after the contract had been published. Yet control gradually shifted to earlier stages. In 2025, the share of monitoring procedures launched between the determination of the winner and the publication of the contract more than doubled compared with 2024, from 10.8% to 23.8%. The time to the start of monitoring after contract publication also shrank: from 35 to 11 days for competitive procurement and from 41 to 20 days for direct procurement.

However, in 2025, only about 5% of monitoring procedures in competitive procurement took place entirely within the optimal period defined by the study, between the determination of the winner and the publication of the contract. Overall, auditors were starting control earlier, but completing it before the contract was concluded proved extremely difficult. The median duration of monitoring was 16–17 calendar days, while the period between the determination of the winner and the conclusion of the contract may be as short as 5 days.

To make control more preventive, conditions must be created for completing monitoring before the contract is concluded. One option is to consider how to streamline the monitoring process.

Another solution could be to suspend procurement for the duration of pre-contract monitoring. This would allow auditors to complete control and the contracting authority to remedy any violations identified before the contract is concluded. Still, it must be clearly defined when the procurement is unblocked, and safeguards against deliberate delays must be put in place.

General statistics

We examined public procurement monitoring activities launched in 2024, 2025, and Q1 2026. The analysis is based on data from the electronic procurement system as of April 2026. During the period under review, the State Audit Service and its interregional territorial bodies (hereinafter, state financial control bodies, SFCBs) launched 24,009 monitoring procedures. We excluded 68 repeat procedures for procurement that had already been monitored. We also excluded 2 monitoring procedures of defense procurement in which much of the information was restricted. The final sample thus comprised 23,939 monitoring procedures.

During the period under review, auditors monitored open tendering, simplified procurement, negotiated procedures, and direct contracts, as well as several requests for suppliers’ proposals. In total, 7.8 million procurements using these methods, excluding requests for proposals, were announced in the system in 2024–2025 and Q1 2026. Monitoring therefore covers approximately 0.31% of them by number.

This ratio should, however, be interpreted with caution. The total number of procurements includes a large share of below-threshold procurement, which is mostly not worth monitoring given its low value. Besides, monitoring in a given year may concern procurement announced earlier. The coverage rate should therefore be treated as an indicative, approximate figure rather than an exact ratio, both overall and in the breakdowns by year and procurement method below. Moreover, the State Audit Service generally does not monitor requests for suppliers’ proposals, as it considers that it lacks the authority to do so. This should change when the new Law on Public Procurement takes effect in spring 2027. Under it, marketplaces will replace the e-catalog, and auditors will be able to monitor such procurement.

A similar caveat applies to value. The total estimated value of procurement under the methods listed above was almost UAH 3.17 trillion. The value of procurement covered by monitoring was almost UAH 420 billion, or 12.85%. These figures exclude direct natural gas procurement by Gas Supply Company Naftogaz Trading LLC within Naftogaz Group.

By number of procurements, monitoring coverage remains low for the vast majority of methods. Open tendering accounts for the lion’s share of all monitoring procedures, yet only 3.21% of announced open tenders are covered. For simplified procurement, the figure is 0.95%. The negotiated procedure stands out at 5.2%, but until recently, wartime procurement rules did not allow contracting authorities to use it. As a result, there were only 173 such procedures during the period under review. 

By value, coverage is substantially higher and better reflects the focus of control. Notably, auditors are increasingly targeting procurement with larger budgets year by year. In 2024, monitoring covered 14.88% of open tendering and just 2.69% of simplified procurement by value. By Q1 2026, these figures had risen to 21.87% and 14.93%, respectively. Since coverage of these procedures by number remains roughly unchanged, this growth in value terms points to deliberate prioritization: auditors are focusing more and more on higher-value procurement. Direct above-threshold procurement, meanwhile, remains a category with consistently low coverage, at about 5% by value. 

Construction work (CPV division 45) was monitored most often: 8,259 procurements, or 34.5% of all monitoring procedures. This group also had the largest total estimated value: UAH 237.79 billion, or 56.74% of the total estimated value of monitored procurement. For construction, we analyzed data at the CPV division level. For other procurement items, we used the class level (four-digit codes), which allowed a more granular analysis.

Apart from construction work, fuel and timber account for a significant share of monitoring procedures by number. By value, the largest shares go to road maintenance and to individual uniforms, mostly for the military. Among the most common and most expensive types of monitored procurement, individual uniforms have one of the lowest shares of procurements with violations found (33.72%), while fuel has the highest (80.73%).

Analysis of monitoring in competitive procurement

To assess how preventive monitoring is, we need to know at what stage of procurement it begins and when it ends relative to key procurement events. We therefore defined the key events against which we assessed the start and end of monitoring: the determination of the winner (publication of the notice of intent to conclude a contract) and the publication of the contract.

When monitoring begins

In this study, we distinguished three main periods in which monitoring begins:

1. before the winner is determined;
2. from the day the winner is determined, i.e., the notice of intent to conclude a contract is published (inclusive), until the contract is published. For short, we call this “between the determination of the winner and the publication of the contract” or simply “after the determination of the winner”;
3. after the contract is published (including that day). For short, we call this “after the publication of the contract.”

Most often, auditors started monitoring after the contract was published: 15,738 procedures, or 75.15% of the total. 

The second most common period was “between the determination of the winner and the publication of the contract,” with 3,871 procedures (18.49%). These began in the optimal period defined in the study, when the procurement already has a result but contractual obligations have not yet arisen. Of these, 1.48% began more than 20 days after the winner was determined, i.e., in cases where the conclusion of the contract dragged on.

The third largest group consists of procedures launched before the winner was determined: 1,332 (6.36%). Among them, we also singled out 327 procedures (1.56%) that began at least 60 days after the procurement was announced. This separates procedures that genuinely started soon after the announcement from those where the procurement sat in the system for a long time without a winner.

Open tendering largely shapes the overall trend, so we looked at simplified procurement separately to check whether monitoring there starts at the same stages. There were 962 monitoring procedures in simplified procurement, or 4% of all monitored procurements. Of these, almost 78% began after the contract was published, 186 (19.3%) after the winner was determined, and only 29 (3%) before the winner was determined. Thus, in simplified procurement too, monitoring mostly starts after the contract is concluded.

We also tried to assess when monitoring began relative to the first payment under the contract. We thank the Fiscal Policy Research Center NGO for the payment data. However, this information is available for only 48.11% of procurements in which monitoring began after the contract was concluded. Based on the available data, we can only say this: of the procedures that started after the contract was published, at least 30.41% began before the first payment and at least 17.7% after it.

A year-by-year analysis shows that monitoring start dates are gradually moving to earlier stages of procurement. The share of procedures launched before the winner was determined grew one and a half times, to over 7%. The share launched after the determination of the winner but before contract publication more than doubled, to over 20%.

The trend toward earlier monitoring is observed in both open tendering and simplified procurement. It is more pronounced for tenders: the share of procedures launched before contract publication rose from 15.4% in 2024 to 31.8% in 2025 and 34.4% in Q1 2026. That is more than a twofold increase in two years. The shift is slightly smaller for simplified procurement: 16.7% in 2024, 26.4% in 2025, and 20.4% in Q1 2026. 

Meanwhile, the share of monitoring procedures involving protracted procurements remains fairly stable. These are cases where, when monitoring began, one of two things was true. Either no winner had been determined although 60 or more days had passed since the procurement was announced, or the contract had not been published although 21 or more days had passed since the winner was determined. In open tendering, the combined share of such procedures even rose slightly, from 3.1% in 2024 to 3.9% in 2025 and 4.3% in Q1 2026. An early-stage start should therefore not be equated with a swift response, since the stages themselves sometimes last unusually long. Auditors may be choosing such procurements precisely because of the delays, for example because they expect deadline violations there. It would be worthwhile, though, to assess how effective this monitoring is: whether it detects significant violations and whether those violations are then remedied.

Preventiveness by region

The Western Office Department in Ivano-Frankivsk Region has the highest share of monitoring procedures launched before contract publication: 55.87%. In other words, this body starts most of its monitoring before the contract is published, a result unique among all the bodies studied. The central office of the State Audit Service (36.34%) and the departments in Zakarpattia (34.2%), Zaporizhzhia (30.5%), and Vinnytsia (29.1%) Regions also perform well above average. At the bottom are the departments in Kherson (9.67%), Ternopil (12.04%), Volyn (12.11%), and Luhansk (12.58%) Regions. There, over 87% of procedures start after the contract is published. 

Monitoring is initiated fairly evenly across the central and interregional territorial bodies. The State Audit Service of Ukraine accounts for the most procedures, but the figures for regional bodies do not differ much. Regional departments also conduct similar volumes of monitoring.

Preventiveness by monitoring grounds

SFCBs launched most monitoring procedures, 16,441 (78.5%), on their own initiative. Another 3,509 (16.76%) followed triggered risk indicators. All other grounds (requests from public authorities and civic associations, media reports) together account for less than 5%.

Monitoring launched on auditors’ own initiative was more preventive. The share of such procedures that started in the optimal period rose markedly, from 11.49% in 2024 to 31.34% in 2025. In contrast, only 2.5–7% of procedures based on triggered risk indicators began between the determination of the winner and the publication of the contract. This difference may be partly explained by the fact that some risk indicators could only be triggered at later stages of procurement, after the contract was published or amended.

How late monitoring begins after contract publication 

Across the sample, the median time from contract publication to the start of monitoring was 18 days, but the figures differ sharply from year to year. In 2024, the median was 35 days. In 2025, it shrank more than threefold, to 11 days, and in Q1 2026, to just 7 days. In most cases, this time ranged from 0 to 240 days, though there were extreme cases: the latest monitoring began 2,141 days (almost 6 years) after the contract was published. Note, however, that some long lead times may be due to the publication of contract amendments. These include supplementary agreements extending the contract term, which could, among other things, trigger automatic risk indicators.

Even where monitoring begins after the contract is published rather than before, the sooner it starts, the more scope remains to make a real difference. Among such procedures, start times shift earlier every year. The share launched within the first week after contract publication rose from 13.81% in 2024 to 41.79% in 2025 and 50.69% in Q1 2026. The share started in the second week also grew slightly, while later starts are now less than half as frequent. 

When monitoring ends

Monitoring duration may depend on the procurement item (reviewing documents in works procurement usually takes longer), its complexity, and the number of lots. It may also depend on whether auditors need additional explanations and documents from contracting authorities. Yet our analysis shows that duration does not vary with the stage at which monitoring began: the median is 16–17 days for all categories.

Given that the period between the determination of the winner and the conclusion of the contract may be as short as 5 days, completing monitoring before the contract is concluded is almost impossible, even if it starts fairly early.

Unsurprisingly, 88.49% of completed monitoring procedures ended after the contract was published. At least 22.29% of procedures were completed before the first payment, and at least 20.34% after it. Recall that we have first-payment data for slightly less than half of the procurements with contracts in our sample, so this breakdown cannot be made for the remaining procedures.

Monitoring ends at early stages much less often: 3.55% of procedures end before the winner is determined, and 5.72% after the winner is determined, including on that day. Almost another 2% were completed after the procurement had been canceled, and 0.18% were not completed for various reasons. 

The trend is positive, though slow. The share of procedures completed after contract publication is falling, from 91.1% in 2024 to 86.82% in 2025 and 85.2% in Q1 2026. Meanwhile, the share completed after the determination of the winner but before contract publication grew from 4.17% in 2024 to 8.09% in Q1 2026. This stage is among the most important for monitoring. Key decisions on the winner have already been made, but the contract has not yet been concluded, so it is still possible to stop a contract that would be concluded in breach of the rules.

In sum, most monitoring both begins and ends after the contract is published, when violations are rather difficult to remedy. Auditors are trying to increase the share of preventive monitoring, but this control measure takes longer than the period between the determination of the winner and the conclusion of the contract. Completing monitoring in the optimal period is therefore extremely difficult. 

Above all, the share of procedures that began after the determination of the winner but ended after the contract was published rose substantially, from 6.35% in 2024 to 17.69% in 2025. The share of procedures conducted entirely within the optimal period also grew: 336 (3.74%) in 2024, 526 (5.37%) in 2025, and 156 (7.17%) in Q1 2026. Still, even with this growth, the share remains too small to speak of a systemic shift to preventive control. This category also includes procurements in which the contract was never signed. 

Little monitoring overall is conducted in the optimal period, but practice varies significantly among SFCBs. The undisputed leader by share of such procedures is the Western Office Department in Ivano-Frankivsk Region, at 11.24% (110 procedures). That is more than double the sample average of 4.86%. Other standouts are the departments in Zaporizhzhia (8.95%), Zakarpattia (8.5%), and Vinnytsia (7.23%) Regions and the State Audit Service (6.27%). At the other end are the departments in Volyn (0.78%) and Luhansk (1.32%) Regions, the Eastern Office (1.97%), and the department in Kherson Region (2.12%). For these bodies, a full monitoring procedure in the optimal period is a rarity.

Frequency of violations detected in competitive procurement monitoring 

Auditors detect violations in 62.31% of monitoring procedures, and this figure has been largely stable over the years. 

Violations were found in 69.3% of procedures launched before the winner was determined, though this category is relatively small. For procedures launched after the determination of the winner and after the publication of the contract, the figure is lower but almost identical: 61.7% and 61.9%, respectively.

The downside of late monitoring is that some violations can only be remedied by terminating the contract. Termination means losses for businesses that have already started performing the contract. It also means delays for contracting authorities, which may now be unable to meet their needs on time. We cannot comprehensively verify how many contracts contracting authorities terminated specifically to comply with obligations imposed by auditors. However, even an aggregate analysis shows that they do face this problem. At the time of the study, 29.15% of the 11,700 contracts in competitive procurements where auditors found violations had been terminated. Where monitoring found no violations, only 4.82% of contracts had this status. By comparison, 3.12% of contracts have been terminated to date in completed competitive procurements that were announced in 2024–2025 or Q1 2026 and were never monitored. This comparison shows the scale of the difference between procurements with and without monitoring. The results should be interpreted with due regard to how the samples were formed, though. For monitoring procedures, we used the publication date of the decision to start monitoring; for procurements, the date the procurement was announced. The two datasets are therefore slightly offset in time. Comparing them gives an approximate but telling picture.

Sample of monitoring procedures conducted in the optimal period

Of the 1,018 monitoring procedures conducted in the optimal period, violations were found in 670 procurements (almost 66%). For most of these lots (almost 70%), the contracting authority canceled the procurement for the lot and no contract was concluded at all. In the group without violations, by contrast, cancellation was the exception (9.48%). Even more tellingly, 405 (87%) of the 465 canceled procurements were canceled before the monitoring conclusion was published. In these cases, the contracting authority canceled the procurement without waiting for the state auditors’ conclusion. This may suggest that the very launch of monitoring influences the contracting authority’s subsequent decisions on the procurement. 

To find out which violations auditors identified and which remedies they required, we extracted and grouped this information from the monitoring conclusion files using Claude and ChatGPT. Most often, in about 70% of cases, auditors identified violations in the review of tender proposals and determination of the winner. Contracting authorities failed to reject bidders whose proposals did not meet technical or qualification requirements, did not confirm experience in performing similar contracts, or contained incomplete and contradictory documents. The opposite also occurred. Bids were rejected without sufficient grounds, bidders were not given the chance to correct discrepancies, or a bidder with a weaker or improperly prepared proposal was declared the winner. Such violations significantly affect the outcome of procurement, and it is important to detect them before the contract is concluded.

Another large group of violations concerned the preparation and publication of documents, found in about 40% of procedures. Tender documentation did not comply with the Law and Procurement Specifics No. 1178. It contained excessive or unlawful requirements, improperly defined qualification criteria, and errors in technical requirements and draft contracts. In two cases, contracting authorities set “virtually impossible contract deadlines” in the tender documentation. Auditors also recorded untimely or incomplete publication of information; no justification for technical and quality characteristics or for the estimated value; breaches of the procedure for amending tender documentation; failure to provide complete explanations and documents at the auditors’ request.

Some conclusions contained several obligations at once or alternative remedies. Examples are “publish the documents or, if this is impossible, reject the tender proposal” and “prevent similar violations in the future.” In such cases, each obligation was counted in every relevant category. The total number of entries in the table may therefore differ from the actual number of SFCB conclusions.

The largest group consists of cases where the conclusion set no specific obligation because the contracting authority had already canceled the procurement during monitoring (215 cases, or 32.09%). 

Among auditors’ direct requirements, the most common is cancellation of the procurement: 197 cases (29.4%). It was sometimes listed as an alternative to other obligations.

As for actual compliance, information published in the electronic procurement system shows that contracting authorities reported fully remedying the violations in 151 of the 197 cases (76.65%).

However, in at least:

• 2 cases, the conclusion was challenged in court even though the contracting authority had canceled the procurement;
• 25 cases, the contracting authority disputes the conclusion and is challenging it in court;
• 1 case, the contracting authority had already concluded the procurement contract, so the e-procurement platform offered no technical means to cancel the procedure. Since the violation could not be remedied, explanatory work was conducted with the procurement officer;
• 5 cases, contracting authorities took other actions instead of cancellation. In one of them, to avoid derailing the project, the contracting authority concluded a supplementary agreement. Under it, the contractor undertook to cover, at its own expense, the risks of the construction work and of inflation, because the bidder had not set aside funds for them in the contract price;
• 2 cases, proceedings to impose administrative liability were opened;
• 24 cases, the outcome is unknown, as the system contains no information on either remedying the violation or opening proceedings.

The next most common requirements after cancellation are the two mildest forms of response: economic training and explanatory work (13.43%) and prevention of violations in the future (12.54%). Almost half of these were the only obligation in the conclusion, not an add-on to others. 

Contracting authorities were required to cancel the decision on the winner in 37 cases (5.52%). Six of these conclusions were challenged; in 2 cases the outcome is unknown, and in the rest the violations were remedied. Auditors required rejection of a bidder’s tender proposal in 25 procedures (3.73%). Here, 2 conclusions were challenged and 1 outcome is unknown; in the rest, the violations were fully remedied. Auditors also required termination of the contract in 21 cases (3.13%). This resulted in 1 court claim, 1 administrative proceeding, and 3 unknown outcomes; in the remaining cases, contracting authorities remedied the violations. In some of these termination cases, monitoring had formally ended before the contract was published, judging by the dates. In fact, the contracting authorities had already concluded the contract and simply failed to publish the information on time, hence the requirement to terminate it. In the other cases, termination appeared as an alternative: auditors stated up front that if the contract had already been concluded, it should be terminated.

Excluding cases where the contracting authority canceled the procurement before monitoring ended, about 57% of all obligations in optimal-period conclusions are specific actions that actually change the course of the procedure. These are cancellation of the tender, annulment of a decision, and rejection of a bid.

Analysis of monitoring of procurement without using the electronic system 

Procurement without using the electronic system differs fundamentally from other procurement methods, including in what it allows monitoring to do. Here, monitoring can begin only after the contract has been signed and a report on it published in the electronic system. We therefore analyzed such procurement separately and excluded it from the overall time calculations. 

Procurement without using the electronic system accounts for 2,998 monitoring procedures, or 12.52% of the total sample. Of these, at least 1,486 (49.56%) concerned above-threshold procurement. Another 11 procedures were still ongoing at the time of the study (April 2026).

The median time from publication of the procurement contract report to the start of monitoring more than halved. It fell from 41 days in 2024 to 20 days in 2025 and 19 days in Q1 2026. The distribution of start times confirms this trend: auditors are now more than twice as likely to start monitoring within two weeks of the report’s publication.

Yet even with this acceleration, almost half of monitoring procedures for direct contracts still begin three weeks or more after the contract report is published. Such a late start significantly limits their practical value. If the contract has already been performed by the time of the check, remedying the violations found will be virtually impossible. Control then merely records the problem but can no longer solve it.

The duration of the procedures themselves remains steady: 15 days in 2024–2025 and 16 days in Q1 2026. Add the 19–20 days of waiting between contract publication and the start of monitoring, and the entire control process in most cases ends no earlier than 34–36 days after the contract is published.

Of the 2,987 completed procedures, 1,792 (60%) found violations. In 2024, auditors detected violations in almost half of procedures (49.1%). In 2025–2026, the share exceeded 70%: 71.9% and 72.7%, respectively.

As of the data download (April 2026), almost half of the contracts (815, or 45.5%) in procurements where monitoring found violations remained active. Another 600 contracts (33.5%) had been performed, and 377 (21%) terminated.

Conclusions

In 2024–2025 and Q1 2026, the vast majority of monitoring procedures in competitive procurement, over three-quarters, began after the contract had been published. In other words, control mostly records violations when the scope for real intervention is significantly limited or nonexistent. Over this time, though, the State Audit Service began stepping in early much more often. The share of procedures launched after the determination of the winner and before contract publication rose from 10.81% (2024) to 23.8% (2025). Still, even a start at this stage does not always allow monitoring to be completed before the contract is published. By law, monitoring may last up to 15 working days, and the study data broadly confirm a similar duration. The median was 16–17 calendar days, and some procedures took longer. Reasons include a complex procurement item, large volumes of information to process, and the time needed to obtain additional explanations and documents from contracting authorities. The mandatory period between the determination of the winner and the conclusion of the contract, by contrast, has been 5 days in recent years.

Auditors conducted only 1,018 monitoring procedures (4.87%) entirely within the optimal period defined in this study. Their share grew from 3.74% in 2024 to 5.37% the following year. These procedures found violations about as often as those conducted at other stages of procurement (60.08% versus 62% in 2025). In about 70% of cases, auditors identified violations in the review of tender proposals and determination of the winner, which significantly affect the procurement outcome. This shows that an earlier start does not necessarily mean a lower likelihood of detecting violations. And it is early monitoring that potentially offers more opportunities to stop contracts with such violations from being concluded.

Auditors also began launching monitoring sooner after contract conclusion. In 2024, they stepped in on average 35 days after the contract; in 2025, after just 11. 

Procurement without using the electronic system accounts for a relatively small share of the sample: 2,998 monitoring procedures (12.52%). For this type of procurement, preventive control is objectively impossible, as monitoring can begin only after the contract is published. Still, the State Audit Service now also starts monitoring direct procurement earlier, though the change is smaller than for competitive procurement. The median time from publication of the procurement contract report to the start of monitoring fell from 41 days in 2024 to 20 days in 2025.

Recommendations

Given the above, it is important to find solutions that make monitoring within the optimal period possible. 

The new Law on Public Procurement, which takes effect in spring 2027, already extends the minimum period between the determination of the winner and the conclusion of the contract to 10 days for most types of procurement. This will give auditors more time to complete monitoring before the contract is concluded. However, this alone may not suffice. Pushing the period out further would delay all procurement, although only a few percent of procedures are monitored.

Auditors could also look at ways to streamline the monitoring process so that control takes less time. Such changes are unlikely to fully solve the problem of completing monitoring before contract conclusion, but they will still improve the situation. A shorter monitoring period could also be considered for procurement through marketplaces (the future equivalent of Prozorro Market), as this stage will involve fewer documents to review. Auditors should then be able to extend monitoring up to the general time limit if they need to analyze additional materials during the review. 

Finally, procurement could be suspended during pre-contract monitoring, as happens when a complaint is filed against a contracting authority’s decision. Auditors could then complete monitoring and, if they find a violation, issue an obligation to remedy it before the contract is signed and the business begins performing it. Implementing such changes, however, requires clear rules on how the procurement is unblocked. It also requires safeguards against deliberate delays, for example allowing a procurement to be suspended for monitoring only once.

Research team:

Team lead: 

Ivan Lakhtionov, Deputy Executive Director of TI Ukraine for Innovative Projects

Authors:

Viktoriia Hermasheva, Projects Assistant, TI Ukraine

Kateryna Rusina, Project Manager at DOZORRO

Accounting Chamber 

Despite the high assessment of progress in reforming the country’s main financial audit body, the key recommendation has remained unchanged since last year. The European Commission calls for strengthening the political and financial independence, and administrative capacities, of the Accounting Chamber.

As for financial independence, it is not entirely clear what further steps are expected. At the end of 2024, officials of the Accounting Chamber, including state auditors, were excluded from the scope of the Civil Service Law. Their salaries and bonuses were established directly in the sectoral law, shielding them from government influence. Moreover, in January 2025, Parliament amended the Budget Code to introduce a special procedure for considering the Accounting Chamber’s budget requests by both the government and Parliament. 

Regarding political independence, the European Commission most likely expects implementation of the adopted legislation. In particular, this refers to finally launching the competition to appoint members of the Accounting Chamber. More than ten months after the new law entered into force, the Ukrainian Parliament has yet to form the commission required to start the selection process. TI Ukraine has called on MPs to consider the expertise and reputation of candidates and establish the Selection Committee to unblock the competition. The new law reduced the number of members of the Accounting Chamber to eleven, leaving six vacancies. For the Chamber to perform its functions effectively, Parliament must urgently address this staffing issue.

Unfortunately, the report does not specify concrete steps expected in this regard.

In terms of administrative capacity, more than one-third (35%) of auditor positions remain vacant. After the approval of the Selection Procedure in January 2025 and the re-appointment of existing staff as state auditors, the Chamber held only two competition rounds in July 2025. As a result, just fifteen auditors were appointed, about 3% of the total staff. Under such conditions, ensuring effective performance remains in doubt, especially given the significant expansion of its control powers, which the European Commission also notes.

European experts further highlighted progress in monitoring the implementation of audit recommendations and in developing specialized IT tools. These likely refer to last year’s legislative changes, as their implementation is not yet complete. The Chamber, in particular, must develop procedures for monitoring the execution of its decisions. 

Despite progress in improving national legislation, full compliance with international standards remains a challenge. The Commission emphasizes that the Accounting Chamber must not only continue applying approved audit methodologies but also establish quality assurance mechanisms to regularly evaluate the effectiveness of its audits. This would guarantee compliance with international standards of transparency and accountability.

The European Commission recommended that the Accounting Chamber should:

• Strengthen the political and financial independence, and administrative capacities, of the Accounting Chamber, including by forming and operationalizing its Board.
• Prioritize effective implementation of audit methodologies based on International Standards for Supreme Audit Institutions.
• Develop robust quality assurance mechanisms to regularly evaluate the effectiveness of audits and ensure compliance with international standards of transparency and accountability.
• Select audits for the 2026 work plan based on risk and impact assessments.
• Increase the number of audits of consolidated financial statements of public-sector entities and budgets in 2026.

State Audit Service

The European Commission assessed public procurement control — one of the core functions of the State Audit Service of Ukraine — as weak, especially at early stages before contract signing. The report notes that only in a few cases are detected violations effectively corrected, particularly in large-value contracts.

The Commission therefore recommends that Ukraine strengthen control measures over procurement procedures, reinforce the monitoring function, and focus on risk-based preventive control and effective responses to identified breaches. Similar recommendations were previously made by TI Ukraine. This issue is particularly critical for EU-funded procurement, as the Commission refers to the Ukraine Plan in this context.

The State Audit Service is mentioned not only in relation to procurement control but also in the protection of the EU’s financial interests. The Commission noted partial alignment of Ukrainian legislation with the EU acquis in this area. 

This direction has become especially important after the launch of the Ukraine Facility, a macro-financial assistance program providing €50 billion in grants and loans for Ukraine’s recovery, reconstruction, and modernization between 2024 and 2027. Accordingly, the Commission recommended that Ukraine fully align its legislation with the EU Directive on combating fraud affecting the financial interests of the European Union.

In September last year, the government authorized the State Audit Service to act as the Anti-Fraud Coordination Service. Since then, it has officially coordinated cooperation among state authorities to protect the financial interests of both Ukraine and the EU.

Under the Ukraine Facility framework, Ukraine also committed to amend its legislation by the end of 2025 to strengthen the Service’s capacity in safeguarding the EU’s financial interests (through harmonization with international standards) and to improve the efficiency of procurement monitoring. However, as of early November, these changes had not been adopted, and the Commission urged Ukraine to fulfill this commitment. 

Previously, TI Ukraine warned that performing the Anti-Fraud Coordination Service’s functions could face legal obstacles. The State Audit Service must assist the European Anti-Fraud Office (OLAF) in conducting administrative investigations and inspections in Ukraine. Yet, its officials lack sufficient powers to access documents and data held by businesses or individuals that may be needed for investigations under the Ukraine Facility. 

In this context, the Commission also mentions the need to develop and implement a National Anti-Fraud Strategy to protect EU funds. This task lies with the State Audit Service, but there is currently no public information confirming that such a strategy has been adopted.

The European Commission recommended that the State Audit Service should:

• Amend financial control legislation to strengthen the national system of public financial control, including the role and powers of the State Audit Service in protecting the EU’s financial interests.
• Align national legislation with the EU Directive on combating fraud affecting the financial interests of the European Union.
• Develop and implement a National Anti-Fraud Strategy to protect EU funds.

Despite the relatively positive assessment of Ukraine’s progress in aligning its financial-control framework with European standards, reforms must continue. Adoption of laws alone is not enough — they must be effectively implemented.

Parliament must finally establish the AGE to launch the competition for members of the Accounting Chamber. At the same time, the Chamber should continue applying modernized approaches, use a risk-based methodology for planning, regularly assess the effectiveness of its audits, and improve monitoring of the implementation of its recommendations.

The State Audit Service, in turn, should prioritize preventive, risk-based control measures and continue fulfilling its commitments to protect the EU’s financial interests, by further harmonizing Ukrainian legislation with the EU acquis. 

This material is made possible with the support of the MATRA Programme of the Embassy of the Kingdom of the Netherlands in Ukraine. Content reflects the views of the author and does not necessarily correspond with the position of the Embassy

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Brief conclusions:

Transparency International Ukraine generally views the innovations in this draft law positively, as it strengthens accountability for violations of the requirements regarding the disclosure of information on the use of public funds.

• Courts will be able to impose fines for administrative violations in the procurement field within one year from the date the violation is detected (up from six months).
• The penalty for failing to disclose information on spending.gov.ua regarding the use of public funds will range from UAH 850 to 1,190. Publishing unreliable, inaccurate, or incomplete information, or failing to publish it on time, is also considered an offense subject to the same fine. The State Audit Service will issue reports and impose fines.
• The State Audit Service and its territorial bodies will be able to collect personal data for handling administrative violation cases, including from the Unified State Demographic Register.

We emphasize that strengthening accountability for violations in this area will not, by itself, resolve the underlying complex issues. It is crucial to continue with the reform. The next step in this area could be the establishment of a unified reporting system for public finance expenditure to minimize duplicate reporting across different systems or at least the disclosure of information already available to the state (such as work acceptance certificates).

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Extended time limit for imposing fines

Currently, courts can impose administrative penalties for procurement-related offenses within six months of their detection. Once the amendments come into force, courts will be able to impose penalties for procurement violations within one year of detection (still, as before, no later than two years from the date of a violation). This provides state auditors with more time to prepare a report under Article 164-14, Parts 3-6 of the Administrative Code and allows the court more time to consider the case.

Also, a longer period — within one year from the date of the violation — is provided for imposing fines under two articles:

• Article 188-19 of the Administrative Code of Ukraine, for failing to provide or respond timely to a request or submission from an MP of Ukraine, as well as for providing false or incomplete information in response to such a request or submission;
• new parts 12 and 13 of Article 212-3 of the Administrative Code. We are referring to the non-disclosure or untimely disclosure of information that must be made public under the Law of Ukraine on the Open Use of Public Funds (hereinafter referred to as the Transparency Law), as well as the publication of unreliable, inaccurate, or incomplete information.

New penalties for violating the transparency requirements regarding the use of public funds

When preparing the draft law for the second reading, the authors increased the fines for new administrative violations and streamlined the text to eliminate conflicts between the new and existing provisions.

As for fines, non-disclosure or late disclosure of information under the Transparency Law, as well as the disclosure of unreliable, inaccurate, or incomplete information, will incur a fine ranging from UAH 850 to 1,190. For repeat offenses within a year, if the person has already been fined for any of these violations, the fine will range from UAH 1,190 to 1,700.

Responsibility, as before for non-disclosure of information, and now for other violations, will lie with the supervisors of managers and recipients of state and local budgets, as well as enterprises, the offices of the Pension Fund, and the State Social Insurance Fund of Ukraine for Unemployment.

In addition, as planned, violations of the Transparency Law may result in inspections conducted by state auditors.

The State Audit Service will prepare reports and impose fines for violations of the Transparency Law

As originally planned, cases of offenses related to non-compliance with the Transparency Law are removed from the jurisdiction of the courts. Instead, these cases will be handled by state financial control bodies — the State Audit Service and its territorial offices.

In our initial analysis, we noted the gap in draft law No. 10255 regarding the lack of clarity on who would be responsible for drawing up reports on violations of the Transparency Law. Previously, this task was handled by authorized officials of the Secretariat of the Verkhovna Rada Commissioner for Human Rights or their representatives (excluding violations related to legislation on the bar). It seemed unusual that the draft law does not propose granting this authority to the State Audit Service under Article 255 of the Administrative Code, especially since the Office of the Commissioner can only issue reports for cases that the court will consider.

Fortunately, the authors of the draft law addressed this issue and granted the appropriate powers to the State Audit Service under Article 255 of the Administrative Code, as we had suggested.

Strengthening the powers of the State Audit Service and expanding access to personal data

As planned, the rights of state financial control bodies are being clarified and expanded, with corresponding changes to other legislation. State auditors will be able to:

•     collect and receive personal data of individuals in cases specified by law, for the purpose of conducting proceedings in administrative offense cases;
•     receive not only documents, materials, and information, but also restricted information. The final version of the draft law further emphasizes the right to access such information, while ensuring compliance with information protection requirements;
•     use information, documents, and other data in the exercise of their powers, including personal data from the Unified State Demographic Register. Additionally, as provided for in the second reading, they will have access to documents contained in or created using the tools of the said Register.

Currently, the general rule is that the procedure for third parties to access personal data held by public information managers is governed by the Law of Ukraine on Access to Public Information. As outlined in the draft law, an exception to this rule has been added: it will not apply to state financial control bodies when conducting proceedings in administrative offense cases.

Additionally, as planned, supervisors of managers, recipients of budget funds, and enterprises will be required to provide information on compliance with the requirements of the Transparency Law within five business days from the date of receiving a request from the state financial control body.

Information about public finances will not be subject to restrictions

As an additional guarantee that information about the use of public funds remains accessible, it has been included in the list of information that cannot be classified as restricted access.

In our initial analysis, we warned that narrowing the scope of information about the activities of state and municipal unitary enterprises, as well as business entities with a state/municipal share, to only include information on their use of public funds is a bad idea. This approach could result in the loss of public access to the rest of the information about their activities, as is currently provided. We noted that it would be better to list information about the public finances of these entities as a separate item, in addition to information about their activities.

Fortunately, by the second reading, the authors of the draft law addressed this concern by ensuring that information about the use of public funds by various entities cannot be classified as restricted while maintaining the existing requirements for information about the activities of enterprises.

Also, as planned, the duration for keeping information on the use of public funds from the state budget, the budget of the Autonomous Republic of Crimea, and local budgets in the public domain has been extended from three to five years.

Conclusions

In summary, the adoption of the revised draft law No. 10255 can be viewed positively, as most of our previous comments on it were taken into account. Conflicts and risks of disrupting the architecture of existing norms have been eliminated.

A key change in the second reading was the extension of the time frame for imposing fines for violations in the field of procurement. This extension should help the courts hold those responsible accountable in a timely manner.

The authority to receive personal data should strengthen the position of the State Audit Service; however, in our opinion, the legislation still lacks a clear procedure for granting state financial control bodies access to personal data.

The next step in this area could involve creating a unified system for reporting on the expenditure of public finances, or at least ensuring the disclosure of information already available to the state. As noted by TI Ukraine in the study titled Three Times Less: How to Improve Reporting Under Contracts, there is a problem with procuring entities reporting to three independent systems, while crucial information about public funds, such as work acceptance certificates, remains unpublished. Increased responsibility alone does not solve this problem; it only preserves the existing situation.

This material is funded by the European Union. Its content is the sole responsibility of Transparency International Ukraine and does not necessarily reflect the views of the European Union.

Select 6 members of the Accounting Chamber under the new rules

The new law reduced the number of the Accounting Chamber members to 11, so, 6 positions in the body remain vacant. In order for the Accounting Chamber to perform its functions efficiently, the parliament must address this personnel issue as soon as possible. The law contributes to this: it stipulates that the competition shall start automatically from the date of its entry into force.

At the first stage, the Verkhovna Rada, with the assistance of the Cabinet of Ministers, shall appoint 6 members of the advisory group of experts within 30 days, who will select candidates for the position of the Accounting Chamber members. In the first 8 years, three of them will be determined based on proposals from international organizations that have assisted Ukraine for at least 5 years in the fields of financial control, corruption prevention, or the Accounting Chamber reform. Such an advisory group will be appointed each time a new member or members of the Accounting Chamber are selected. Its powers will remain in effect until the vacancies it is appointed to cover are filled. 

After the announcement of the competition is published, potential candidates will have 30 days to submit their documents for participation. Then they will be handed over to the advisory group and the main selection stage will begin, which can last up to 9 months. During this time, experts, based on the results of tests, interviews, and background checks, must select at least two candidates for the post of the Accounting Chamber member and submit a list of recommended candidates for appointment to the parliament.

Overall, the appointment of new members of the Accounting Chamber may last for 11 months. It is important that this process be not delayed at any stage. The prolonged absence of a full body of members weakens its ability to properly perform its functions. 

At the same time, it is essential that the competition be transparent, and what is defined in the law is observed in practice:

•     the procedure for the work of the advisory group, the procedure for the preliminary selection of candidates, as well as the criteria and methods for assessing candidates are published before the start of the selection;
•     meetings of the advisory group are streamed;
•     the results of tests and interviews and a list of recommended candidates for appointment are published. 

Harmonize the powers between the Accounting Chamber and the State Audit Service

One of the issues that remained unresolved after the adoption of the law is the overlapping the functions of the Accounting Chamber and the State Audit Service of Ukraine. 

These bodies have similar powers in the areas of control over the management and use of public funds. In particular, the state financial audit of the State Audit Service contains features inherent in the audit of compliance and efficiency conducted by the Accounting Chamber. At the same time, the scope of activities of both bodies extends to the same entities: ministries and other executive bodies, extra-budgetary funds, budgetary institutions, and state-owned enterprises. It is inefficient to finance two bodies with duplicative powers.

In addition, the new law added another point of intersection of the bodies’ functions, as it entrusted the Accounting Chamber with the authority to audit the funds of local budgets. 

The issue of overlapping functions of control bodies must be eliminated. The authors of the law agree, and the European Commission emphasizes this. Therefore, we expect that in 2025, steps to coordinate the activities of the Accounting Chamber and the State Audit Service will begin to be taken. It is important that this process take place with the participation of all stakeholders—parliament, government, as well as representatives of the control bodies, so that the changes meet both legislative requirements and practical needs of the field.

Plan audits for 2025

In mid-November this year, the Accounting Chamber approved a list of audit topics for the next year. These include audits of the use of funds for defense, protection and restoration of critical infrastructure, social protection, the reform of public administration and a number of bodies (Supreme Court, HACC, BES, SSU, State Committee for Television and Radio-Broadcasting of Ukraine).

However, these topics need to be compared with the real capacity of the body, given the limited composition, and the audit plan for 2025 should be approved.

The new law prohibits unscheduled audits, both by parliamentary decisions and upon the initiative of the Accounting Chamber. Therefore, we expect that a risk-based approach will finally be used to plan audits in 2025. Interestingly, this aspect was already standardized by the body in the Procedure for the Annual Planning of the Accounting Chamber’s Activities back in December 2023. However, according to the head of the body, it was to be applied only when planning activities for 2025.

We are waiting for the approval and publication of the plan because this will show the priorities of the Accounting Chamber for the coming year.

Establish a system for monitoring the implementation of recommendations

Until recently, neither the law nor the Rules of Procedure of the Accounting Chamber provided for the body’s constant monitoring of how the recommendations provided by it to the entities under control are implemented. As a result, stakeholders, in particular the parliament and the public, did not have access to objective information about the implementation of the decisions and recommendations of the Accounting Chamber. This limited the possibility to properly assess the effectiveness of both the institution and the entities under control.

The new law solves this problem by obliging the entities under control to inform the Accounting Chamber on a quarterly basis about the implementation of recommendations, and the body is obliged to constantly monitor and analyze the implementation of its decisions, as well as publish information on the results of these activities. An open system for monitoring the implementation of the Accounting Chamber’s recommendations might be of help.

It will allow not only to monitor the progress of recommendation implementation, but also to respond promptly to their improper implementation or non-implementation. In this case, the Accounting Chamber will be able to appeal to the committees of the Verkhovna Rada to respond to the actions or inaction of the entities under control. At the same time, the public system will ensure the accountability of the body to all stakeholders, including parliament, government, and the public. It will also help to identify systemic problems in the areas of control of the Accounting Chamber that may need to be improved not only at the level of specific entities, but also at the regulatory level.

The improvement of such a system is one of the tasks of the body’s Development Strategy for 2019–2024. According to the interim implementation report, the Accounting Chamber approved documents last December that defined the principles of the system, its components, streamlined procedures for monitoring and informing stakeholders about its results for appropriate response. Almost a year has passed, yet the system has not been implemented.

Therefore, we expect that the Accounting Chamber will soon complete the deployment of a system for monitoring the implementation of recommendations, which will be an important step towards increasing transparency not only in its activities, but also in the field of external public audit in general.

Conclusion

The adoption of the new law on the Accounting Chamber was a long-awaited change. However, it is not a reform per se; it is only the start of a long journey to improve the operation of the body. Currently, we require that all the innovations of the law be put into practice and the issues that the law did not cover be regulated. 

Over the next year, we expect specific primary steps from both the parliament and the government, as well as from the Accounting Chamber itself:

1. Conduct a competitive selection of members of the Accounting Chamber under new transparent rules to enhance the independence and professionalism of the body. 
2. Start harmonizing the functions of the Accounting Chamber and the State Audit Service so that the state does not finance the activities of two bodies with duplicated powers. 
3. Apply a risk-based approach to audit planning to concentrate resources on critical and risky areas to ensure effective management of public finances in wartime.
4. Introduce a system for monitoring the implementation of the recommendations provided by the Accounting Chamber to increase the accountability of the entities under control and the effectiveness of the institution itself. 

The implementation of these priorities will be the cornerstone of successful reforming and enhancing confidence in the Accounting Chamber. We will actively monitor the implementation of innovations, providing recommendations and analyzing key stages, because the supreme audit institution of the country is an integral part of the democratic system, which shall ensure the efficiency, accountability, effectiveness, and transparency of public administration.

The article was co-authored with Andrii Shvadchak, legal advisor at TI Ukraine

This publication was prepared as part of the Digital Transformation Activity, funded by USAID and UK Dev.