Identified problems and recommendations

• Dual regulation and unclear delineation

The draft law creates a separate category of “complaints regarding the handling of appeals.” Unlike Article 16 of the current Law on Citizens’ Appeals, the bill sets out no special procedure for handling such complaints. At the same time, Article 21 of the bill provides a mechanism for challenging decisions, actions, or inaction by an entity handling appeals, including challenging a response to an appeal, failure to respond, or failure to process an appeal.

The problem is that a response to an appeal is not a substantive decision. It does not affect a person’s rights, freedoms, legitimate interests, or obligations — so there is nothing to appeal. The guarantees of participation in decision-making, the obligation to justify administrative acts, and the right to effective legal protection are already provided for in the Law on Administrative Procedure. A response under the Law on Appeals should therefore not be subject to challenge. These provisions should be deleted.

In substance, “complaints regarding the handling of appeals” are already subsumed within the general appeals mechanism. Treating them as a separate category is unjustified and risks confusion in practice.

Clear delineation between the Law on Appeals (to be adopted) and the Law on Administrative Procedure (which already governs complaint procedures) is essential — for applicants, public authorities, and the legal system as a whole. The proposed provisions are not warranted and should be removed.

• List of subject entities is inconsistent with the Constitution

The draft law over-extends the range of entities obliged to handle appeals. Article 3 defines the “entity handling an appeal” as a state authority, other state body, Autonomous Republic of Crimea authority, local self-government body, their officials and civil servants, and “other entities within whose competence the issues raised fall.”

This is inconsistent with Article 40 of the Constitution of Ukraine, which clearly defines the addressees of appeals (state authorities, local self-government bodies, and their officials and civil servants). Retaining the current wording risks:

• blurring the boundaries of public accountability
• imposing public-law obligations on private actors without justification
• creating legal uncertainty for applicants as to whether their appeal must be considered and what consequences follow. After all, the bill over-extends the list of entities obliged to handle appeals while leaving the category of “other entities” undefined.

The words “other entities within whose competence the issues raised fall” should either be deleted or replaced with “other entities exercising public administration functions, providing public services, or performing other public tasks.”

• Guarantee of in-person reception

Article 40 of the Constitution of Ukraine guarantees personal reception as a form of direct appeal and an element of the constitutional right to appeal. Under Article 64(2) of the Constitution, this right may not be restricted under any circumstances. Accordingly, Article 17 of the draft law must not permit the cancellation, suspension, or effective replacement of in-person reception with other forms of communication.

Personal reception cannot be substituted. Video conference reception should be treated exclusively as an additional, voluntary option:

• available only at the request of or with the consent of the applicant,
• without depriving them of the right to in-person reception, and
• only where both parties have adequate technical capacity ensuring identification, confidentiality, full recording of the appeal, and equal procedural standing.

To prevent abuse and the de facto narrowing of a constitutional right, the draft law should explicitly require entities handling appeals to provide in-person reception, with remote formats available only as supplementary and voluntary alternatives for the applicant.

• The 15-day fast-track rule Article 16 of the bill reinstates the rule allowing appeals that “require no additional study” to be processed within 15 calendar days. Given the volume of appeals handled by state authorities and local self-government bodies, this provision is unnecessary and, in TI Ukraine’s view, creates grounds for deferring consideration of appeals beyond 15 days rather than ensuring faster processing. 

Conclusion

TI Ukraine welcomes the advancement of Draft Law No. 11082 on Appeals as a necessary and long-overdue step toward modernizing state-citizen interaction mechanisms and aligning national legislation with EU standards.

Adopting the new law is justified given the obsolescence of the 1996 Law on Citizens’ Appeals and the need to clearly delineate its scope from the Law on Administrative Procedure — in line with European Commission recommendations on good governance, legal certainty, and effective legal protection.

At the same time, the draft prepared for the second reading contains systemic flaws that could undermine its positive potential and generate legal uncertainty in practice. In particular:

• the list of entities handling appeals must be brought in line with the Constitution
• “complaints regarding the handling of appeals” must not be defined as a separate category of appeals
• the draft law must explicitly require entities handling appeals to provide in-person reception.

Not every mayor actually talks to residents

Another warning sign is how mayors report to their communities. By law, a city’s top official must meet with residents twice a year, look them in the eye, and honestly account for what has been done. In practice, this obligation is routinely reduced to a formality — dense slide decks, departmental wrap-ups, polished promotional videos, or scripted live streams.

Our check of 100 of the largest communities was stark: one in five mayors simply ignored the obligation to report to residents for 2024. In many other cities, reporting consisted only of a text posted on the website — no public meeting, no opportunity for questions. A genuine dialogue took place in fewer than one in four cases. Even a legal requirement is not always enough to move city councils.

Among the 20 regional centers, only Lviv and Khmelnytskyi held open public meetings, presented budget execution reports for the prior year, and explained where community tax revenues went in 2025. 

Five years of full-scale war — and still no clear picture on humanitarian aid

Across several cities studied, we found persistent gaps in areas that became critical after the full-scale invasion and should have been systematized by now: humanitarian aid, compensation for damaged property, services and information for IDPs and defenders, social services, shelter locations, healthcare, and energy consumption data. These are the areas where cities show the least structured, least consistent approaches.

Humanitarian aid is the starkest example. Only 3 of the 50 largest cities — Mykolaiv, Chernivtsi, and Shostka — publish the full range of required information on aid flows and distribution. Meanwhile, 20 cities publish none of the requested categories: no thematic page, no reports, no distribution criteria, no list of recipients.

This problem is solvable. Mykolaiv, Chernivtsi, and Shostka have each built dedicated pages with key information on humanitarian aid — eligibility rules, priority groups, and reporting. Even in wartime, cities can create clear, structured communication when they treat it as a governance priority.

Across all our research, one pattern holds: city governments that think strategically — with baseline policies, programs, and a coherent development logic — are better positioned to survive crises, build new ecosystems, and sustain what they have created. 

When initiatives are treated as standalone projects, sometimes as a favor to international partners, the system quickly loses coherence, frustrating residents and officials alike.

In one regional center, international partners helped fund an app intended to consolidate the city’s digital services. The city never integrated it into its own management infrastructure, and after a few years of developer support, the project effectively shut down.

Separately, a local open data portal — also created with international support — has gradually lost functionality for lack of proper governance. Its most recent datasets date from 2023. The resource formally exists but no longer serves as a source of current information for residents, businesses, or researchers.

The result: cities accumulate tools but never build a system.

What needs to change 

The question local governments must ask is not whether communities will integrate into the EU, but how ready a given city is to start now. The coming years are the critical window for that preparation.

Our research shows that most problems stem not from a lack of technology or resources, but from the absence of a systematic approach to resident communication and to organizing information and services. 

The European approach to governance is grounded in the principles of good governance, codified in the Council of Europe’s 12 Principles — benchmarks for building transparent, effective, and accountable public institutions that serve citizens. They cover everything from fair elections and the rule of law to transparency, accountability, ethics, and sustainable development.

Cities need to start with the foundations: restructure official websites, create dedicated thematic pages for key topics, build a complete publication cycle for council activity, strengthen digital tools for social services and vulnerable groups, and make the site’s search function an actual navigation tool rather than a decorative feature.

Genuine public engagement requires local authorities to go out and speak with their taxpayers — to report, explain, and build mature, accountable relationships. The principle is simple: go where your audience is. If you actually want to reach people and be accountable to your community, follow your audience rather than waiting for residents to monitor city council websites around the clock. Developing social media channels, using engagement tools, working with local media, and proactively going to people — this is demanding, constant work. The payoff is visibility, respect for the council’s representatives, and a calmer public environment. 

We have already developed recommendations and self-assessment tools that let local authorities see themselves through a resident’s eyes. That matters, because change in this area does not begin with large budgets — it begins with recognizing the problem and being willing to rethink how you work.

EU integration is not about hanging an EU flag on city hall. It is about cities where authorities speak not only about their successes but also about their problems — and begin building spaces that genuinely work for people. A city is truly ready for European transparency standards when its resident can find needed information, access assistance, or check how community funds were spent in two taps on a smartphone. Trust is built from transparent digital tools and honest dialogue — and without trust, no community can thrive. Especially in wartime.

This material is made possible with the support of the MATRA Programme of the Embassy of the Kingdom of the Netherlands in Ukraine, and with the financial support of Sweden within the framework of the program on institutional development of Transparency International Ukraine.

Content reflects the views of the author(s) and does not necessarily correspond with the position of the Embassy of the Kingdom of the Netherlands in Ukraine or the Government of Sweden.

On average, cities implemented all criteria at 23.1%.This result is significantly lower than in previous studies focused on openness and e-services. However, city councils share responsibility for this outcome with the Ministry of Digital Transformation, since the scores were also affected by technical infrastructure issues on the Unified Open Data Portal.

Kyiv ranked first with 44.3 out of 100 points. Next came Lutsk (40), then Kropyvnytskyi and Lviv (35.3 each). The lowest results were recorded by Odesa (0), Poltava (0), and Chernihiv (9.9).

“Kyiv owes its leadership to two factors. First, in 2024, the city authorities approved a key administrative document that incorporated the Ministry’s updated recommendations and began systematically populating the Kyiv City State Administration account on data.gov.ua based on those recommendations. Second, unlike Lutsk, Kropyvnytskyi, Lviv, and Dnipro, Kyiv now publishes its datasets exclusively on the Unified State Open Data Web Portal, so it does not face delays in transferring data from a local portal to data.gov.ua, which affected other cities’ scores,” notes Yuliia Sysoieva, Senior Analyst at the Transparent Cities program.

The assessment results revealed a significant gap between Ukraine’s high rankings in international and national open data ratings and the real implementation in major cities. In the Digital Transformation Index of Territorial Communities, some cities report nearly 100% publication of mandatory datasets, while Open Data Maturity 2025, which assesses countries’ institutional maturity in open data across Europe (policy, quality, reuse, and impact), places Ukraine in a high position.

In reality, however, of the 270 “EU integration” datasets that were expected to be available in city accounts on data.gov.ua, cities had published 148 (55%). Only 51 datasets had resources updated on time, and only 6 datasets fully complied with all key requirements of the Ministry of Digital Transformation (4 from Kyiv, 1 from Dnipro, and 1 from Lviv). One reason for this outcome is that Dnipro, Kropyvnytskyi, Lutsk, and Lviv city councils—leaders by number of published datasets—use their own open data portals, while regular monthly transfer of data from those portals to data.gov.ua is currently not taking place.

Among the problems that, according to analysts, are preventing the open data sphere from developing properly are:

• uncoordinated state policy at the national level;
• outdated architecture of the data.gov.ua portal, resulting, among other issues, in data upload problems and irregular transfer of data from local portals;
• a fragmented approach by local self-government bodies to data publication, which significantly worsens accessibility;
• untimely data updates;
• low data interoperability (non-unified dataset structures and data resource structures);
• weak linkage between data and services, meaning open data does not fulfill its core function—supporting tools for residents and evidence-based management decisions.

“We understand that low city scores are often linked not only to local government actions, but also to national-level decisions, technical infrastructure, and policies for which, in particular, the Ministry of Digital Transformation of Ukraine is responsible. So, on the one hand, we call on cities to do everything within their authority and capacity to improve the quality and accessibility of their own policies and data. On the other hand, we are working closely with the Ministry to remove systemic barriers and adopt changes at the national level. The Ministry is actively working to improve the situation,” said Olesia Koval, Transparent Cities Program Manager.

For representatives of city councils that were not included in the pilot study, analysts developed a special form to help them independently assess how well a city complies with open data standards and identify weak points that require improvement. Experts are also preparing to scale the methodology and plan to increase the number of cities assessed.

In December 2025 the program presented results from the second block of the European City Index. Experts assessed how well city e-services comply with European standards. Kyiv showed the highest result, with 70 out of 100 possible points. Lviv (63 points) and Kharkiv (58 points) also ranked among the top three. 

Research methodology

The methodology of the Euroindex provides for a shift from one-off annual measurements to continuous monitoring. Analysts will record changes in transparency and accountability of city councils several times a year. That will be a step-by-step research with thematic blocs — openness of city councils, e-services, open data, use of budget funds, prevention of corruption, and so on. Each step will be supported by a separate methodology, with simultaneous announcement of results. 

Within the electronic services block, the emphasis was placed on the requirements of the Ukraine Facility Plan, primarily with regard to the reforms outlined in the sections Decentralization and Regional Policy, Digital Transformation, and Human Capital. In particular, this concerned reforms such as Digitalization of Public Services, Advancing Decentralization Reform, Strengthening Citizen Engagement Tools in Local Decision-Making Processes, and Improving Social Infrastructure and Deinstitutionalization. The provisions of the EU Digital Decade 2030 program were also taken into account, as it defines four key areas of the European Union’s digital transformation by 2030: digital skills, digital infrastructure, digital business, and digital public services.

The term electronic services may refer to a very broad range of online resources, from simple informational websites to large-scale online platforms engaging millions of users each month (online marketplaces, social media, content-sharing platforms, app stores, etc.). Within this study, however, the scope was significantly narrowed. The analysis focused on whether city councils provide access to services that function either as built-in interactive elements of websites or mobile applications (such as interactive maps, interactive dashboards, and web forms) or as standalone interactive online services (primarily information and analytical systems, mobile applications, and chatbots). In other words, the assessment did not examine the mere availability of informational content, but rather the availability of functional tools enabling interaction with data and the execution of specific actions.

Information on cities’ performance against electronic services–related indicators was collected by analysts in October 2025. In certain cases (protective shelters, barrier-free facilities, remaining stocks of medicines, etc.), it was essential that services provided access to data that were up to date as of 2025. In other cases, data currency was deliberately not verified, or it was taken into account that data updates depend on user activity rather than on municipal authorities.

The assessment criteria did not require all services to be initiated or funded by local self-government bodies. Over recent years, central executive authorities, businesses, civil society organizations, and charitable foundations have initiated the development of dozens of interactive online services in Ukraine that enable access to a wide range of services. Accordingly, the methodology allowed for the fact that city councils may not design services “from scratch” but instead ensure citizens’ access to solutions developed with state funding, private investment, or international grants.

The pilot sample included city councils of ten regional capitals (Dnipro, Zaporizhzhia, Kropyvnytskyi, Lutsk, Lviv, Odesa, Poltava, Kharkiv, Khmelnytskyi, and Chernihiv), as well as the city of Kyiv. The selected cities represent various levels of transparency, cover all macro-regions of Ukraine, and reflect different wartime contexts (rear-area cities and cities included in the List of Territories of Potential Hostilities). 

The level of development of the electronic services ecosystem was assessed against 40 criteria. The final score was calculated by summing all points awarded to a city across these indicators. The maximum possible score a city could receive was 100 points.

The analysts examined: 

• whether the city has a valid, approved, and up-to-date informatization program; 
• whether access is ensured to services that enhance the transparency of municipal operations, improve service delivery in the areas of safety, education, healthcare, transport, utility services, environmental protection, etc., or function as tools of e-democracy; 
• the availability of a comprehensive mobile application aggregating digital mobile services that help address citizens’ everyday needs;
•  the publication of information on administrative and social services available for online ordering;
• the possibility to book appointments online with Administrative Service Centers, structural units responsible for social protection, as well as the availability of online services for assessing the quality of services provided by these bodies.

The analysis of indicators related to administrative and social services was based on the provisions of the Laws of Ukraine on Administrative Services and on Social Services, as well as the Order of the Ministry of Social Policy of Ukraine on Approval of the Classifier of Social Services. These indicators did not place emphasis on distinguishing between state and municipal services.

Important note. During the assessment, analysts verified whether a single point of entry existed — namely, a dedicated specialized website of the city council or a separate thematic section on the official website of the local self-government body, consolidating accurate links to available electronic services. However, unlike the previous stage — the openness assessment — analysts continued to record the presence or absence of electronic services even in cases where such a single point of entry could not be identified. Otherwise, cities would not have received a comprehensive analysis of their strengths and weaknesses, and experts would have lacked a basis for developing recommendations and road maps for change. Nevertheless, in future monitoring rounds, Transparent Cities analysts plan to apply the single point of entry principle and expect that most local self-government bodies will consolidate links to all recommended services in one place on their official websites.

Research results

The average level of implementation of 40 indicators in the Electronic Services block stands at 49.8%. 

Kyiv achieved the highest score, with 70 out of 100 possible points. One position below is Lviv with 63 points, followed by Kharkiv with 58 points. The lowest scores were recorded for Poltava (27 points), Chernihiv (32 points), and Lutsk (43 points).

The leadership of Kyiv and Lviv was predictable. In the UN Local Online Service Index 2024, which assesses e-government in the most populous city of each of the 193 UN Member States, Kyiv ranked 13th and was classified among cities with a very high LOSI score. Lviv, in turn, was shortlisted as a finalist of the World Smart City Awards 2025 in the Governance & Economy Award category. Within the Transparent Cities study, however, the key factor that led to a substantial gap between these two cities was Lviv’s lack of a comprehensive mobile application. As a result, Lviv was unable to score any points against the indicators related to this component, accounting for a total of 14 points.

By contrast, Kharkiv’s third-place ranking was far less predictable. Prior to the full-scale invasion, Kharkiv significantly outpaced other IT locations in Ukraine in terms of the number of IT specialists, second only to the Kyiv hub. In 2020, the city also won the Best Digital City category at the Smart City Awards held as part of the Kyiv Smart City Forum. However, Kharkiv is now a frontline city and one of the regional capitals most affected by the war; only 4% of Ukrainian IT professionals currently live and work there, compared to 14% in 2021. The study shows that the city authorities have managed not only to maintain electronic services developed before the war but also to create new ones (such as the Open Kharkiv mobile application). This capacity for continuity and innovation is what enabled Kharkiv to achieve such a strong result.

In addition to Kharkiv, the study included another city designated as a territory of potential hostilities — Zaporizhzhia. While the municipalities received different scores, both demonstrate, despite the extremely challenging conditions of war, a clear willingness and capacity to develop their own electronic services ecosystems. In the summer of 2025, the municipal enterprise Center for Information Technology Management launched the Digital Zaporizhzhia online platform. The ambition behind this initiative is significant: to consolidate all of the city’s digital services and offerings in one place, thereby applying a European approach to the disclosure and arranging of information. 

An analysis of whether city councils have current, approved informatization programs showed that only three regional capitals lack such a program — Poltava, Chernihiv, and Lutsk. In Poltava and Chernihiv, no references to an informatization program could be found at all. In Lutsk, a draft SmartLutsk program for 2025–2029 has been published on the city council’s website; however, as of October 2025, it had not yet been approved. Notably, these three cities also recorded the weakest results in the study. The cases of Poltava and Chernihiv demonstrate that, in the absence of a strategic document defining priority areas and objectives for the digital development of a territorial community, such development becomes fragmented and the continuity of achievements cannot be ensured. Two examples illustrate this lack of continuity. First, the Poltava Open Data Portal, established with the support of Germany and Switzerland, remains operational, yet the most recent statistical data available on the platform date back to 2023. Second, with support from the Netherlands, the ePoltava mobile application was developed; however, due to unresolved legal inconsistencies between the city authorities and the developer, access to the application has been unavailable since 2023. 

Strengths and weaknesses

All 11 cities covered by the study provide access to electronic services for real-time tracking of municipal public transport, as well as to electronic local petition platforms. Also, all regional capitals offer online enrolment services for kindergartens and enable parents to monitor waiting lists remotely.

All cities included in the study, with the exception of Kropyvnytskyi, have introduced cashless fare payment in municipal public transport (via QR codes, contactless NFC payments, or virtual transport cards), as well as the option to book appointments with Administrative Service Centers online.

Nine out of the 11 regional capitals provide communication through electronic contact centers —analytical and communication systems designed to receive, process, and monitor the handling of citizens’ requests concerning issues that require prompt response. The only exceptions are Kropyvnytskyi and Poltava.

Research methodology

The methodology of the European Cities Index (the Euroindex) provides for a shift from one-off annual measurements to continuous monitoring. Analysts will record changes in transparency and accountability of city councils several times a year. That will be a step-by-step research with thematic blocs — openness of city councils, e-services, open data, use of budget funds, prevention of corruption, and so on. Each step will be supported by a separate methodology, with simultaneous announcement of results. 

Analysts collected data in September 2025. They checked whether the information is relevant for the whole 2025, except for several indicators, where the 2024 data was included as well (regulatory activities, comprehensive programs for defenders, etc.). The pilot sample included 10 regional centers (Dnipro, Zaporizhzhia, Kropyvnytskyi, Lutsk, Lviv, Odesa, Poltava, Kharkiv, Khmelnytskyi, Chernihiv) and the city of Kyiv. Pre-selected cities of various transparency levels represent all Ukrainian macro-regions and war contexts (rear cities, cities included in the List of Territories of Potential Hostilities). 

Openness and public engagement were assessed through 40 indicators. Analysts checked published information about the meetings of city councils, their executive committees, and selected standing committees. In this part, they considered only the meetings of the council and its bodies held in the second quarter of 2025. They also analyzed the publication of key strategic documents of the council, the functionality of website search tools, and accessibility for users with visual impairments, and the availability of complete, up-to-date, and accurate information on regulatory policy, management of humanitarian aid, compensation for damaged or destroyed property, and information for vulnerable population groups. 

Important: The assessment required the presence of stable thematic sections/pages where all relevant reference information is collected and continuously updated, as well as correct links to internal and external documents/resources.

How well do major cities meet European standards of openness?

When assessing openness and public engagement in Ukrainian cities, analysts relied on the premise that genuine transparency does not begin with merely formal disclosure, but with the logic, completeness, and accessibility of information for residents. If a citizen can find the necessary information in just a few clicks — whether on council meetings, regulatory policy, recovery efforts, or humanitarian assistance — this signals a certain level of institutional maturity.

The study covered two key dimensions: openness (availability and relevance of information) and public engagement (accessibility and structure of information, communication with residents, inclusiveness during times of crisis). The program’s experts aimed to identify and describe the barriers to practical access to essential information and to verify whether Ukrainian cities are moving toward European standards of digital governance.

The average performance across the 40 indicators of Openness and Public Engagement is 53.5%. 

Dnipro achieved the highest result — 66 out of 100 points. One position lower is Odesa with 64 points, followed by Lviv with 63 points. The lowest results were recorded in Poltava (38), Kharkiv (44), and Lutsk (45). Kyiv ranked in the middle of the sample with 53 points.

Dnipro and Lviv demonstrated consistency in their approaches. In the Openness and Public Engagement categories of the 2024 Transparency Ranking, both cities were among the top ten: Dnipro implemented 93.1% of indicators in these areas, while Lviv achieved 87.5%. This year, both regional centers also showed strong results: Dnipro met 28 out of 40 indicators (the highest score in the sample), and Lviv — 27. 

Odesa succeeded in improving its performance compared to the 2024 Ranking, where the implementation level for these categories stood at 58.3%. In this year’s pilot assessment, the city implemented 27 indicators, matching Lviv. 

Lutsk, by contrast, ranked among the top five cities in 2024 with an implementation level of 91.7% in openness and public engagement. However, during this year’s assessment, the city met 20 out of 40 indicators. The most significant challenge was a set of six indicators related to the announcement of meetings of the city council, executive committee, and standing committees — criteria that were refined to match European standards. 

In 2024, Poltava implemented 51.4% of the indicators in these categories — the lowest result among the cities in the sample — and again demonstrated the weakest performance in this study, implementing only 16 indicators.

Two cities with the status of territories of potential hostilities — Kharkiv and Zaporizhzhia — took part in the study. Despite facing similar challenges, these regional centers performed differently in meeting openness requirements. Zaporizhzhia implemented 24 indicators, while Kharkiv met 19. These results are consistent with the performance of frontline cities in the 2024 assessment. 

Overall, all analyzed cities demonstrated fairly average results. Even those that outperformed others did not exceed two-thirds of the maximum possible score, indicating substantial room for improvement. 

Strengths and weaknesses 

All cities included in the study publish decisions of the city council and executive committee, as well as orders issued by the mayor. All 11 cities also arranged livestreamed council sessions in the second quarter of 2025 (detailed recommendations on appropriate broadcasting formats are available in the program’s extended analytics). Performance was weaker when it came to broadcasting meetings of the executive committee — only seven cities ensured livestreams, while Kyiv, Lviv, Kharkiv, and Chernihiv did not provide broadcasts of all meetings. Lutsk was the only city that did not publish all recordings of meetings of the designated standing committees. 

Regulatory policy also proved to be an area with relatively strong results. Nine cities properly published their Plans for Preparing Draft Regulatory Acts of the City Council and Executive Committee, and eight published structured links to the regulatory acts themselves.

None of the cities in the sample published aggregated, structured statistics on decisions regarding compensation for damaged or destroyed real estate in a dedicated section. Analysts examined whether cities disclosed consolidated figures on the number of decisions granting compensation, the number of approvals and refusals, and the total amounts disbursed. Some information is available — for example, the final paragraphs of Lviv’s commission minutes contain the number of adopted decisions, while Odesa provides information on the number of decisions, refusals, approvals, and suspended reviews. However, no city published data on the total amount of compensation paid. The only city that ensured the presence of commission documents on compensation within the relevant section was Chernihiv. 

Another highly problematic area was the publication of information on the management of humanitarian aid. All 11 cities failed the corresponding indicators. Eight cities did not even create a dedicated section on this topic. The absence of a structured section on humanitarian-aid management during a full-scale invasion is a critical shortcoming, and the program has previously issued recommendations on this matter — which remain relevant. In Dnipro, Kyiv, and Chernihiv, where at least thematic sections existed, the required information (the Procedure for receiving and distributing humanitarian aid and the List of Recipients among city-council subordinate entities) was not added.

European approach to information publication

Program experts examined whether Ukrainian municipalities adhere to Europe-wide governance approaches in their handling of public information. An essential element of these approaches is the “single entry point” principle. This requires that city-council websites maintain convenient, regularly updated thematic sections containing all necessary information and correct links to documents and resources. The principle is aligned with the European practices discussed further.

The “single entry point“ principle was assessed across nine topics. Analysts searched for dedicated sections or pages on the Charter of the territorial community; the Rules of Procedure of the city council; regulatory activity of local self-government bodies; local taxes and fees; citizen access to council sessions; the eRestoration program and the work of compensation commissions for damaged/destroyed property; humanitarian aid; information for defenders; information for internally displaced persons (IDPs). 

The only city that met this principle fully was Kyiv. Lviv came close: its official website contains thematic pages for eight of the nine required topics, lacking only a page dedicated to humanitarian aid. The websites of these cities display a high level of openness and an effort to build meaningful public engagement through logical and user-friendly structuring of information. 

All 11 cities had a dedicated page for the Charter of the territorial community. A complete, up-to-date, approved version of the Charter was available in 10 cities. A best practice is to specify the exact dates of amendments and provide links to the corresponding decisions, as implemented in Kyiv. Only in Kharkiv was the Charter outdated on the dedicated page (although analysts found a decision on amendments that had not been reflected there). 

Most regional centers (10 out of 11) ensured the availability of unified pages on eRestoration and compensation processes, as well as on regulatory policy. Kropyvnytskyi offered a well-organized regulatory-policy section with clear subsections for reporting, planning, performance evaluation, etc. The website of Khmelnytskyi did not include a dedicated section on eRestoration, while Poltava lacked a page on regulatory policy. Both cities were in the process of transitioning to updated website versions during the assessment. Analysts evaluated the current state at the time, but this transition offers Poltava and Khmelnytskyi a favorable opportunity to incorporate program recommendations into the structure of their new websites.

The most problematic topics — absent as unified sections in eight cities — were humanitarian aid and citizen access to council sessions. A dedicated page outlining the algorithm for accessing council sessions is a prerequisite for a straightforward path from a citizen’s intention to attend a meeting to the practical ability to do so. Program analysts have detailed what proper disclosure of this information should entail. 

Among thematic indicators, analysts assessed two related to informing and engaging specific population groups — defenders and internally displaced persons. The program defined several priority topics that must be consolidated on accessible, well-structured pages. For defenders, these topics include rehabilitation, professional reintegration, financial support, assistance for family members, and available benefits. 

Eight cities provided a dedicated resource with at least three of these components. Dnipro, Zaporizhzhia, and Kharkiv organized this content in the form of a guide, which is a user-friendly approach. In contrast, Poltava, Lutsk, and Kropyvnytskyi did not meet the requirements of this indicator: in Lutsk, the city-council website and the website of the Social Policy Department contain separate, equally weighted pages for defenders that are not cross-linked — contradicting the single-entry-point principle; in Kropyvnytskyi, relevant information is posted as news items, making it significantly harder to locate.

For IDP pages, analysts looked for information on housing, employment, services, humanitarian aid, and the work of the IDP Council. Seven cities provided all or most of this information in a structured format. Dnipro, Zaporizhzhia, Poltava, and Kharkiv received no points: in Dnipro and Zaporizhzhia the information was scattered across several parallel pages, while in Kharkiv only ungrouped announcements for IDPs were published.

Key findings and recommendations

Viewing openness through the lens of European benchmarks highlighted the issue of formalistic approaches taken by local self-government bodies in publishing information. Cities that provided superficial or literal compliance with legal requirements and program recommendations were less likely to achieve high scores in the assessment of openness and public engagement. Program analysts placed themselves in the position of a resident interested in the work of their city council or seeking specific information, but without the time, resources, or skills to sift through all public communications of the council or mayor. 

The analysis revealed several key problems in municipal practices. First, the organization of official web resources of local self-government bodies is often inadequate. The “single entry point” principle is applied inconsistently, and significant gaps persist in the structuring of essential information. 

Second, despite the conditions of full-scale war, many cities continue to manage humanitarian aid in a fragmented manner. Communications on aid received and distributed by city councils remain unstructured and difficult to locate. This situation complicates coordination between authorities, residents, and partners, reducing the overall effectiveness of assistance.

Finally, all of the above issues related to citizen-oriented openness have a direct impact on the social sphere. Untimely and non-transparent communication complicates access to critically important information and services for internally displaced persons, defenders and their families, low-income households, and other vulnerable population groups. 

The program recommends that all cities (not only those included in the pilot study) take the analytical findings into account and revise their approaches to resident engagement by: 

• Reviewing the organization of the official city council website and key specialized web resources. Optimize the structure of web platforms and ensure the presence of dedicated sections/pages on key topics where all relevant documents, links, and communications are consolidated in a format that is logical and user-friendly. 

• Placing greater emphasis on transparent disclosure of information on humanitarian-aid management. Ensure the presence of a dedicated section or page on the city council website that provides up-to-date information on humanitarian aid, available programs, procedures for receiving assistance, reports on resource distribution, and information about responsible departments. The information must be presented in an accessible format and updated regularly.

• Communicating in a timely, clear, and accessible manner with internally displaced persons, defenders, citizens requiring material support due to Russian aggression, and other vulnerable groups. 

• Ensuring consistent publication of the full information cycle on the work of the council. Maintain structured archives for all elements — from announcements to minutes — for sessions of the city council, the executive committee, and standing committees. These elements should be interlinked logically and published within the required deadlines (announcements must include a preliminary agenda and a link to the livestream; livestreams or video recordings must be published no later than the day after the meeting; video titles must correspond to the meeting number and date; minutes and adopted decisions must be published on time with recorded voting results). 
• Reviewing the performance of search tools. Ensure that users can quickly locate information across documents, news, and other sections using keyword searches and logical filtering options.

Testing city councils for compliance with European standards in openness and public engagement is the first step in assessing a city’s ability to be both human-centered and community-centered. These skills — navigational logic, clear structures, and rapid access to essential, high-quality information — will form the foundation for subsequent research.

The program will prepare tailored recommendations for each city council included in the study, which will serve as roadmaps for improving the real openness of local self-government bodies toward citizens. The indicator-by-indicator results for each city are available at the link. 

This research was prepared within the framework of the program on institutional development of Transparency International Ukraine, which is carried out with the financial support of Sweden, as well as with the support of the MATRA program of the Embassy of the Kingdom of the Netherlands in Ukraine.

Transparency International Ukraine is an accredited representative of Global Transparency International. Since 2012, TI Ukraine has been helping Ukraine grow stronger. The organization takes a comprehensive approach to the development and implementation of changes for reduction of corruption levels in certain areas. 

TI Ukraine launched the Transparent Cities program in 2017. Its goal is to foster constructive and meaningful dialogue between citizens, local authorities, and the government to promote high-quality municipal governance, urban development, and effective reconstruction. In 2017–2022, the program annually compiled the Transparency Ranking of the 100 largest cities in Ukraine. After the full-scale invasion, the program conducted two adapted assessments on the state of municipal transparency during wartime. In 2024, the program compiled the Transparency Ranking of 100 Cities, and in 2025, it launched an updated format for assessing city councils — the European City Index.

Leaders vs. outsiders in budget and procurement transparency

In 2024, none of the 100 Ukrainian cities achieved maximum transparency in the Budget and Procurement area*. Moreover, 79 municipalities failed to meet even half of the criteria. Vinnytsia achieved the best result — 82.4% compliance. Second place went to three cities — Kyiv, Mykolaiv, and Chernivtsi, each with 67.6%. Lutsk and Mukachevo shared third place with 64.7% each.

On the opposite end of the spectrum were Novoiavorivsk (8.8%), Svitlovodsk (11.8%), and Pryluky (14.7%). Such low levels of openness in budget matters undermine public trust and may indicate risks of misuse or inefficient use of community resources.

What have cities done well?

Despite the overall low level of transparency in the Budget and Procurement area, some aspects were handled relatively well. Ukrainian cities performed best with the basic elements of budget transparency: 86 out of 100 published interim quarterly, semi-annual, and annual reports on budget execution.

At the same time, 66 cities fully ensured sufficient competition in procurement — an established best practice of municipal governance, while another 28 achieved it partially. Even during wartime, local governments strive to uphold the principles of open competition. Transparent and efficient procurement procedures not only enable the rational use of budget funds but also strengthen public and donor trust.

Sixty-one city councils also recognized the importance of engaging with investors and building a reputation as reliable and open partners for business, especially crucial in the post-war period when investment will drive recovery. These municipalities either published an up-to-date city investment profile or maintained a dedicated investor section on their official websites. However, 39 cities did not demonstrate sufficient openness toward investors, which may hinder their future economic activity and recovery processes.

Weaknesses in budget transparency

Only 5 out of 100 cities — Vinnytsia, Dnipro, Mykolaiv, Mukachevo, and Sheptytskyi — approved a unified methodology for analyzing construction costs. This methodology should have addressed wartime realities, when material prices fluctuate, and risks of inflated estimates grow. Instead, 95 cities failed to introduce a systematic approach to controlling budget expenditures in construction.

Meanwhile, 87 cities did not hold open budget hearings in 2023. Only 5 cities organized an open event with timely announcements, live online streaming, and published minutes — Vinnytsia, Mykolaiv, Khmelnytskyi, Chernivtsi, and Mukachevo. Another 7 held hearings but did not fully comply with the requirements (Dnipro, Zaporizhzhia, Kalush, Lviv, Myrhorod, Slavuta, and Chortkiv). The lack of open budget discussions in most cities means that residents have little access to shaping local spending priorities — and, therefore, little ability to influence decisions that directly affect their lives. This gap between authorities and citizens not only reduces trust but also undermines the transparency and effectiveness of budgetary decisions.

Only one-third of the cities studied had an internal control and audit body. Sixty-seven municipalities lacked such an institution altogether, including several large cities. Without an internal audit, councils lack self-monitoring tools and fail to identify abuses early. Still, four cities — Kyiv, Kolomyia, Lutsk, and Stryi — demonstrated successful practices that could serve as examples for others.

In addition, 72 city councils out of 100 did not publish the structure of their departments, enterprises, and institutions along with their USREOU codes. This information is essential for residents to see how departments spend their tax money and how councils manage municipal property through privatization and leasing. By withholding it, most cities essentially obscured the chain of budget fund managers, preventing effective public oversight. However, eight councils set a worthy example — Vinnytsia, Dnipro, Kyiv, Korosten, Kremenchuk, Lviv, Mykolaiv, and Mukachevo.

Recommendations for city councils 

Publish detailed structures of council departments (e.g., divisions, directorates), indicating which are budget holders. Link this to information about municipal enterprises and institutions under the council’s authority, and provide their USREOU codes. 

• Engage citizens in budgeting by timely announcing and conducting open budget hearings. This procedure is an important aspect of the council’s accountability to citizens. Even under martial law, hearings can be held online, provided that the public has the opportunity to attend, ask questions, and submit proposals.
• Develop a methodology for analyzing or monitoring construction material prices to ensure transparency in procurement related to reconstruction. Procurement contracts for repair, new construction, reconstruction, restoration, or major repair must include documents containing information about material prices. 
• Establish an independent body for internal control and auditing of city council divisions, and ensure the publication of inspection results. Sharing the results will help build public confidence in local authorities and ensure control over the effectiveness of the city council’s work and the use of budget funds.

For publishing budget holder structures, Kyiv and Mykolaiv provide strong examples. For open budget hearings, Mukachevo (announcement, live-stream, minutes) stands out. In developing a methodology for monitoring construction material prices, Sheptytskyi offers the most relevant example. For sharing information on the work of internal control and audit bodies, Kyiv (regulations, reports) and Kolomyia (regulations, reports) serve as best practices.

The Budget and Procurement area remains one of the key priorities for strengthening municipal transparency. The 2024 results (39.6% transparency) highlight both positive developments and deep systemic gaps. Transparent management of public finances is not only a requirement of good governance and European integration but also a vital condition for trust, efficiency, and resilience of cities, especially in wartime. Therefore, city councils should give priority attention to improving transparency in this area and implement the recommendations outlined above.

*The Budget and Procurement area was assessed by program analysts using 10 criteria, including: reporting by local self-government bodies on budget execution; publication of semi-annual and quarterly (interim) budget execution reports; holding open budget hearings; the city council’s consideration of the mayor’s annual report on the implementation of state regulatory policy by executive bodies; the existence of an internal control and audit body for council departments and publication of its findings; adoption of a unified methodology or procedure for monitoring construction material prices; and other related indicators.

Only 12 out of 100 cities published a list of humanitarian aid recipients with their legal entity codes (USREOU) on their websites. It is crucial that this information be available on the official local government website to ensure its accuracy and relevance. This approach promotes transparency in how aid is received, processed, and distributed, and strengthens public trust. Chernivtsi stands out as a model of good practice, publishing updated lists in a dedicated “Humanitarian Aid” section, with direct links to recipients’ profiles in the Humanitarian Aid Registration System. 

Mykolaiv has gone a step further with a dedicated website about humanitarian aid —a unique tool offering not just the annual report on the received humanitarian aid, but also donor statistics, audit information, and a step-by-step guide to the aid journey from request to delivery. This is an exemplary case of proactive transparency in humanitarian aid management. 

Among regional centres, only Zaporizhzhia, Mykolaiv, and Chernivtsi met both transparency criteria. Odesa published both a report and distribution criteria but did not provide a full recipient list. Dnipro, Kropyvnytskyi, and Lutsk published only summary reports. Vinnytsia and Khmelnytskyi published only the recipient lists. Meanwhile, no proper information on humanitarian aid was found on the websites of Zhytomyr, Kyiv, Ivano-Frankivsk, Lviv, Poltava, Rivne, Sumy, Uzhhorod, Kharkiv, Cherkasy, or Chernihiv.

“Lack of public information on humanitarian aid creates corruption risks and undermines trust in authorities and their decisions. City councils that don’t prioritize transparency and systematic aid management have fewer chances of attracting investors or effectively coordinating wartime assistance,” said Olesia Koval, Transparent Cities Program Manager.

The review shows that most municipalities have yet to ensure proper transparency in managing humanitarian aid. This fosters public distrust, speculation, and potentially abuse. In wartime, when Ukraine relies heavily on international support, ignoring transparency in this area is extremely risky. Local authorities must use all available tools to prevent abuse and improve coordination between donors and recipients.

Best European Integration Practices Among Cities

Lutsk stands out for fully meeting all indicators in the area of HR policy and integrity. The city also demonstrates strong performance in openness and public relations. One of its key achievements was the development and implementation of the Anti-Corruption Program for 2024–2026. To this end, Lutsk created a dedicated working group and held public consultations. All related documents—the minutes, the full program text, and the 2024 progress report—are available on the city website. This approach reflects the priorities outlined in the European Commission’s report (Section 2.4), which highlights the need to strengthen integrity, including through sectoral or local anti-corruption strategies based on risk assessments.

Vinnytsia is also consistently implementing transparent practices. For example, its anti-corruption action plan helps raise awareness among city council staff on issues of transparency and accountability. In 2024, the Vinnytsia City Council reported on training sessions it conducted—covering topics such as electronic declarations and recent changes in anti-corruption legislation. According to the EU Facility Plan, the capacity of public administration is critical for implementing the Plan. Systematic training of personnel on integrity, asset declaration, and anti-corruption law is a key tool for building lasting capacity at the local level.

Pokrov, with a population of just 34,000 (based on mobile operator data) and a budget of UAH 536 million, emerged as a leader primarily due to its high level of city council openness and its effective response to war-related challenges. One notable achievement is the municipal energy plan for 2024–2026, adopted by fewer than a quarter of the cities studied. This plan is especially important for Ukraine’s European integration, particularly in the context of the negotiation cluster Green Energy and Sustainable Development. Having a municipal plan that addresses wartime challenges supports the city’s energy security and improves its capacity to provide residents with energy and utility services.

Mykolaiv also fully met the European criteria in the area of openness and was one of nine cities to properly publish, on its official website, the structure of city council departments, indicating the subordination of enterprises, institutions, and organizations, along with their Unified State Register of Enterprises and Organizations of Ukraine (USREOU) codes. This level of detail helps citizens and businesses better understand how local government functions and reinforces the accountability of local authorities.

Finally, another city classified as a potential hostility area that ranked among the leaders in the European integration assessment is Zaporizhzhia. Like Pokrov and Mykolaiv, the city showed its strongest results in the areas of openness and response to war-related challenges. The official city council website includes a dedicated section with up-to-date information for entrepreneurs on operating a business under martial law. It brings together details on available support programs, grant opportunities, current taxes, and rates—all of which help small and medium-sized businesses navigate crisis conditions. This approach aligns with the reform directions outlined in the negotiation cluster Competitiveness and Inclusive Growth, particularly regarding business environment development. At the same time, transparent communication with the community about business opportunities meets the expectations of the EU Facility Plan (Section 3).

Challenges on the Path to European Integration

On average, cities fulfilled 46.7% of the European integration criteria—meaning a significant portion of the indicators remains either partially addressed or completely overlooked. Still, there are areas where we see progress. Most cities now use the DREAM system for accountable reconstruction management, publish government decisions, make public their Activity Plans for drafting regulatory acts, hold public hearings, discussions, or consultations, and share up-to-date information on doing business under martial law. You can find more detail on these indicators in the City Transparency Ranking 2024 policy brief.

At the same time, several other requirements remain a serious challenge for many municipalities.

The most problematic requirement for city councils has been holding budget hearings. In most cities, this practice is either absent or implemented superficially—only six cities implemented it fully. Both the Ukraine Facility Plan (Sections 2 and 9) and the European Commission’s report (under the Democracy and Public Administration Reform section) emphasize that citizen participation in decision-making and transparency in the budget process are essential conditions for the country’s sustainable recovery. It is budget hearings specifically—where all public recommendations must be formally considered at a city council session—rather than consultations or discussions (which most municipalities typically hold), that serve as one of the most effective mechanisms for public influence over budget allocation.

Citizen participation in local governance is impossible without a clear understanding of who makes decisions and manages budget funds. Transparency in this area is a necessary precondition for responsible governance. Residents should clearly know the structure of the local self-government body, which municipal enterprises and institutions report to whom, who receives funding, and who is accountable for implementing specific projects. The fact that only nine cities have fully published the structure of their city councils and subordinate organizations indicates an unwillingness to involve the public, media, civil society, or businesses in decision-making processes.

Information on the accessibility of buildings for people with disabilities is another requirement that most communities continue to overlook. Meanwhile, ensuring inclusive access is one of the key goals in the Ukraine Facility Plan (Section 7.2) and a priority in the European Commission’s report (Chapter 23). With the number of people with disabilities rising—among both civilians and veterans—public policy, including local strategies, must guarantee real inclusion and access to infrastructure.

In addition, the Transparent Cities program assessed whether information on building accessibility was available in open data format—that is, machine-readable and published both on the websites of local self-government bodies and on the National Open Data Web Portal. The European Commission’s report (Section 18) emphasizes the importance of data and statistics, as well as the administrative capacity of authorities to provide them. Another indicator that falls under these requirements—but was, unfortunately, poorly implemented by Ukrainian cities—is the publication of a list of municipal land plots available for transfer into private ownership.

European standards are not abstract principles—they are reflected in everyday governance decisions made at the local level. Many EU requirements are already embedded in the Transparency Ranking, and every city that adopts these practices not only improves its score but also directly contributes to bringing the country closer to EU membership.

The Transparent Cities program of Transparency International Ukraine recently presented the results of the City Transparency Ranking. In 2024, five cities were classified as transparent: for the first time since the full-scale invasion, Chernivtsi, Vinnytsia, and Lutsk made it into the top three, joined by 2023 leaders Mukachevo and Lviv. Twenty-two cities received the status of partially transparent, while the remaining 72 remained in the non-transparent category (We excluded Ternopil from the ranking). Kyiv was classified as partially transparent, scoring 51.5 points and placing 26th overall.

KEY AMENDMENTS TO THE UPDATED DRAFT LAW

Until recently, four draft laws aimed at regulating supervision of the legality of actions taken by local self-government bodies were registered in the Verkhovna Rada of Ukraine. The first and principal of these was Draft Law No. 4298 (already adopted at first reading), followed by three more: Nos. 13124, 13150, and 13150-1. Subsequently, the Verkhovna Rada also adopted Draft Law No. 13150 as a basis. This draft law, in particular, provides for the following:

• Administrative supervision of the legality of regulations of regional councils shall be exercised by the Cabinet of Ministers of Ukraine or a central executive authority designated by it
• Administrative supervision of local acts adopted by village, settlement, city, and district councils shall be exercised by regional state administrations
• In the cities of Kyiv and Sevastopol, pending the adoption of a separate law, administrative supervision shall also be exercised by the Cabinet of Ministers of Ukraine
• Administrative supervision bodies shall be obliged to respond within 60 days of the entry into force of an act of a local self-government body
• If violations of legislation in local self-government acts are identified, local state administrations or the Cabinet of Ministers shall require that violations be eliminated or corrected within 20 working days.
• If the request is ignored, the supervisory authority has the right to initiate a lawsuit to cancel the act of the local self-government body.
• The establishment of a Unified State Register of Local Self-Government Acts  is proposed.

In addition, the draft law expands the powers of the heads of local state administrations, granting them the authority to coordinate the activities of territorial bodies of ministries and other state institutions, demand the annulment of unlawful orders issued by the heads of these bodies, and appeal to the Cabinet of Ministers in cases where ministries ignore such demands. However, there is no clear division of powers between different supervisory bodies, and there are no rules that would prevent duplication of functions of supervisory entities. Furthermore, there are no procedural specifics for judicial appeals against local government acts under the supervision procedure. 

STATE CONTROL OR SUPERVISION?

At present, the provisions of this draft law introduce the concept of “state control” over local self-government, which is inconsistent with Article 8 of the European Charter of Local Self-Government concerning administrative supervision of local authorities, as well as Articles 19 and 140 of the Constitution of Ukraine. Abovementioned legal acts do not provide for state control or management of local self-government — only supervision of legality. It is clear that local self-government bodies must not be subordinated to state administrations, as such subordination would threaten their autonomy.

In its current version, Draft Law No. 13150 does not address the reform of local state administrations at all; rather, it focuses exclusively on the mechanism of supervision by regional state administrations over local self-government acts. The authors of the draft propose controversial amendments to the current Law of Ukraine “On Local Self-Government in Ukraine”. In particular, they suggest that the bodies and officials exercising state control over local self-government acts should be subordinated to authorities responsible for ensuring the rule of law, mainly regional state administrations. 

Such an approach would lead to an excessive and insufficiently regulated concentration of administrative influence by regional state administrations over local self-government bodies and their officials. This violates the requirements of Article 8 of the European Charter of Local Self-Government, which stipulates that […any administrative supervision of local authorities may only be exercised according to such procedures and in such cases as are provided for by the constitution or by statute]. The proposed model of state control would apply to all acts of local self-government authorities, both in respect of their own and delegated powers. This could ultimately undermine the autonomy of local self-government and dismantle the achievements of the decentralization reform.

UNIFIED REGISTER OF LOCAL SELF-GOVERNMENT REGULATIONS

A potentially positive innovation in Draft Law No. 13150 could be the proposal to establish a Unified State Register of Local Self-Government Acts. This would involve the creation of a state information and communication system designed to collect, store, process, and maintain acts adopted by local self-government bodies and officials, which would serve as a tool for administrative supervision. The Cabinet of Ministers is designated as the administrator of this register. However, this proposal also contains latent risks: excessive state control over local self-government and the potential for manual entry of acts into the register. The draft proposes that the register be composed of two independent subsystems — one for open information and another for information with restricted access. Yet the current Law of Ukraine “On Local Self-Government in Ukraine” does not include the concept of “information with restricted access” in relation to all acts of local self-government bodies. Evidently, such an innovation would unjustifiably reduce the transparency of both the acts of local self-government bodies and the institutions of local self-government as public authorities. The draft law is set to enter into force twelve months after the termination or cancellation of martial law.