European integration - Transparency International Ukraine

How Ukrainian Cities Are Taking the European Integration Test

Андрій Боровик — Mon, 13 Jul 2026 08:18:36 +0000

On July 1, Transparency International Ukraine’s Transparent Cities program presented the findings of its study Fighting Corruption and Ethical Conduct: How Ukrainian City Councils Pass the European Test for Integrity.

Our analysts examined 10 regional centers and Kyiv, looking at how city councils put anti-corruption mechanisms in place, whether they keep their documents current, how they work with the NACP’s tools, and how far integrity is becoming part of everyday governance.

Presenting these findings is a good occasion to talk about what European integration actually means for each individual city — not just at the level of negotiations in Brussels.

A great deal of the conversation today revolves around benchmarks — what Ukraine needs to do to meet the interim targets and, in time, close the negotiations on the relevant clusters. More often than not, these discussions come down to a single question: which laws parliament must pass and what the Cabinet of Ministers must do.

But the way the European Union and the European Commission assess countries does not rest on laws or the regulatory framework alone. Passing a law is not the whole of a reform. As I often say, an adopted law is roughly 20% of a reform. It is the same with European integration: sound legislation matters, but it is only part of the journey. What comes next is far harder work — implementation.

And when we talk about European integration, we should not fix our eyes on the center alone and wait to see exactly how it will deliver everything. In reality, we will all be the ones putting these changes into practice — through everyday work, not least at the level of local self-government.

That is exactly why this study places the emphasis on European standards — on which of their elements are already present in Ukrainian cities, and where the work still needs to be strengthened.

What matters is that we look not only at whether a document formally exists — whether it has been adopted — but at how it works in practice. We want to know how far these mechanisms have become so routine that there is no longer any need to keep reminding people about them.

Ukrainian cities have things to be proud of — examples worth showing to our colleagues in Europe. In some places there are solid codes of ethics; in others, anti-corruption policy is handled well, budget spending is reported transparently, or communication with citizens is genuinely effective.

But it cannot yet be said that all of this adds up to a single system — often these are just strong individual pieces. That is why, once the study’s findings are out, it is especially important to talk about how to make these practices systemic.

European integration is not some abstract story about a state somewhere far away. For an ordinary citizen, the state often shows itself through any interaction with what lies outside their private space — and the lens for that is frequently contact with the local authorities.

So the way local self-government bodies work, how they engage with residents, how open they are, and how well thought-out their mechanisms for spotting potential risks are — all of this shows how ready we truly are.

This is about more than the capacity to integrate with Europe. It is also about how well we will be able to handle reconstruction projects, work with a range of stakeholders, and meet the challenges the country already faces.

This study helps bring out both the good practices and the areas where all of us still have work to do. That is why it can be read as a kind of self-assessment. After all, many of us are city residents, and each of us judges, in one way or another, how well local government works.

Transparency International Ukraine has been studying cities since 2017. At first we analyzed the level of transparency, and over time, accountability as well. In that period, Ukrainian cities have come an enormous way from where they were to where they are now.

Last year we refocused our research — no longer on transparency and accountability alone, but on how they connect to European integration. Because, as experience shows, not every city has fully grasped yet that European integration is about them too.

Local self-government in 2014 and local self-government in 2026 are two different worlds. This became especially clear in 2022, when in many cities it was the local authorities, local initiatives, and residents who together put up the first resistance to the Russians.

Today it is important not to devalue that journey. But it is just as important to look honestly at where isolated good practices already exist and where they still need to be turned into a system. Because local self-government is the very stuff a state is made of.

This research 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 authors and does not necessarily correspond with the position of the Embassy of the Kingdom of the Netherlands in Ukraine or the Government of Sweden.

The post How Ukrainian Cities Are Taking the European Integration Test first appeared on Transparency International Ukraine.

New European Parliament Resolution: What Will Determine Ukraine’s Progress on Its Path to the EU

TI Ukraine — Thu, 09 Jul 2026 14:24:00 +0000

On July 8, the European Parliament approved a resolution on Ukraine’s progress toward EU membership by 460 votes. Some of the proposals submitted by Transparency International Ukraine were reflected in the final document.

In it, MEPs endorsed the adoption of the plan of 10 priority reforms — the so-called “Kachka-Kos plan” — as an important step toward strengthening the rule of law, advancing judicial reform, and reinforcing anti-corruption efforts. They noted, however, that the plan is only 15% implemented and urged Kyiv to accelerate its delivery. The European Parliament also underscored the Verkhovna Rada’s key role in adopting reforms on time and called for their consideration to be sped up.

Importantly, the European Parliament not only acknowledged certain progress by Ukraine — noting, in particular, the work of the anti-corruption agencies and the adoption of the law on public procurement — but also clearly identified the areas where reforms must be carried through. The key tasks include:

maintaining the involvement of international experts in judicial reform;
guaranteeing the institutional and operational independence of the NABU and the SAPO, free from political interference and pressure on the anti-corruption bodies, coupled with a demand to immediately end unjustified pressure from the SSU and other security services;
revising the CPC provisions on the automatic closure of proceedings once the pretrial investigation time limits expire, on shortened investigation periods, and on abuse of procedural rights;
improving asset declaration verification procedures and focusing the NACP’s efforts on checking top officials in high-risk areas;
fully implementing the ARMA reform, including by adopting the necessary secondary legislation.

Progress on these issues will determine the pace at which Ukraine advances within the first negotiating cluster, Fundamentals, and will strengthen partners’ confidence in its further European integration.

The European Parliament separately stressed the need for systematic and substantive consultations with civil society, for civil society’s proposals to be taken into account in decision-making, and for any political pressure on civil society organizations to be prevented.

This publication has been produced with financial support from Norway. The contents of this publication are the sole responsibility of Transparency International Ukraine and can in no way be taken to reflect the views of the Government of Norway.

The post New European Parliament Resolution: What Will Determine Ukraine’s Progress on Its Path to the EU first appeared on Transparency International Ukraine.

Support, balance, and working together toward results — what I discussed with partners at URC 2026

Андрій Боровик — Wed, 01 Jul 2026 07:26:24 +0000

This year’s Ukraine Recovery Conference (URC 2026) in Gdansk, Poland, was a special one for us in the sector. Above all, because two major developments took place just before the conference, and they shifted the focus of our conversations with international partners in a meaningful way.

The first was the opening of the Fundamentals negotiating cluster, which effectively launched Ukraine’s official EU accession process. For the Transparency International Ukraine team, this is an enormously significant step. Fighting corruption is an inseparable part of this stage of the negotiations. So once the cluster opened, a number of changes we’ve been advocating for years became binding conditions for Ukraine’s further progress toward the EU.

The second development was the adoption of the new Law on Public Procurement. It’s directly linked to the first, since procurement is one of the chapters within that same Fundamentals cluster. The new law — which we call the “third procurement revolution” — is a real step toward harmonizing Ukrainian legislation with EU requirements. We discussed this in detail with partners at our side event, Trust by Design: How EU-Aligned Procurement Underpins Ukraine’s Recovery.

But there’s still a great deal of work ahead, and that, too, was a recurring theme in our conversations in Gdansk.

Ahead of the conference, we prepared, as we do every year, a short report on Ukraine’s progress in fighting corruption. I discussed its key points actively with international partners, both on discussion panels and in the hallways. But beyond the facts laid out in the report, my colleagues and I also talked with conference guests about how to actually implement the anti-corruption reforms Ukraine so urgently needs. The new context — direct negotiations on EU accession — is changing both the approach and the vision going forward.

Here are the three main messages I brought to our European partners and Ukrainian officials, given Ukraine’s new status.

Passing strong legislation matters, but implementation is the hardest part

The decision to open Cluster 1 and tie key rule-of-law and anti-corruption reforms to the Ukraine Facility Plan is extremely important for Ukraine. But beyond legislative change, the real challenge now is implementing what’s been promised.

The closer the deadlines get, the greater the temptation will be to pass a law that formally checks the box without delivering genuine transformation. This is exactly where our European partners can help — if they focus not just on whether a law was voted through, but on whether it actually strengthens institutions, accountability, and the rule of law.

2. It’s essential to preserve the role of international experts in selection processes during EU integration

One of the most successful innovations in Ukraine’s reforms has been involving international experts in the selection of judges and heads of anti-corruption and oversight bodies. The experience of NABU, SAPO, and the HACC proves how critical it is to support independent appointments based on candidates’ integrity and professionalism.

But the situation is changing, and we’re seeing a growing number of attempts to weaken these safeguards. International participation — including the decisive vote of experts delegated by international partners in assessing candidates’ integrity for top positions — must be preserved throughout Ukraine’s entire EU accession process.

3. A balanced approach: highlight where progress is lacking, and support where there are successes

Progress across different reform areas will inevitably be uneven. The EU should keep pressing for change where processes have stalled — and this applies above all to the rule of law and the fight against corruption. Despite the government’s stated readiness, real movement over the past year has been so limited that experts have even started talking about a crisis.

A balanced approach to supporting reforms has always been a key factor in their success, and it remains essential to maintaining momentum in the negotiations. The principle of meeting conditions still holds. But so does the principle of recognizing success. Ukraine needs both.

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

My colleagues and I also talked with conference guests about how to actually implement the anti-corruption reforms Ukraine so urgently needs. The new context — direct negotiations on EU accession — is changing both the approach and the vision going forward.

Andrii Borovyk

The post Support, balance, and working together toward results — what I discussed with partners at URC 2026 first appeared on Transparency International Ukraine.

What Does Opening the First EU Cluster Mean?

TI Ukraine — Mon, 29 Jun 2026 15:21:42 +0000

After Ukraine opened its first negotiating cluster, “Fundamentals,” further progress toward the EU now depends on how well it carries out reforms in the rule of law, the fight against corruption, public administration, and democratic governance.

What these reforms will mean for Ukrainians, how the EU will judge Ukraine’s progress, and how the country can move past the crisis triggered by the authorities’ attempt to undermine NABU and SAPO’s independence — Andrii Borovyk, Executive Director of Transparency International Ukraine, discussed these questions with Raion.Zakordon.

After Ukraine opened its first negotiating cluster, “Fundamentals,” further progress toward the EU now depends on how well it carries out reforms.

Fundamentals cluster: the main test on the road to the EU

Accession talks for every candidate country rest on 35 negotiating chapters. Thirty-three of them are grouped into six thematic clusters, while the other two are handled separately.

Andrii Borovyk calls “Fundamentals” the heart of the whole enlargement methodology, since it embodies the EU’s core values. It opens first and closes last, and without progress here, movement on other fronts can stall.

“When we talk about this cluster, the conversation centers on the rule of law and building a state governed by law, but it also has quite specific parts — the negotiating chapters where we need to keep showing progress. Of course, only if we want to,” the expert explains.

Each chapter has its own number and name, including:

Chapter 23 (Judiciary and Fundamental Rights): court reform, judicial independence, and a real fight against top-level corruption.
Chapter 24 (Justice, Freedom and Security): overhauling law enforcement, fighting organized crime, and bringing order to customs and borders.
Chapter 5 (Public Procurement): moving all public and defense tenders onto strict European standards.
Chapter 32 (Financial Control): protecting EU funds and auditing the budget (the work of the Accounting Chamber and the State Audit Service).
Chapter 18 (Statistics): transparent, accurate economic and population data that meet Eurostat standards.

When we talk about this cluster, the conversation centers on the rule of law and building a state governed by law, but it also has quite specific parts — the negotiating chapters where we need to keep showing progress.

Andrii Borovyk

What benchmarks are, and how the EU will measure Ukraine’s progress

To avoid the mistakes of past enlargements, the EU has changed how it evaluates reforms. Andrii Borovyk recalls that several countries saw scandals over the rule of law or corruption after joining. In Romania, for example, specialized anti-corruption bodies were set up and went after a “big fish” — a former prime minister. Later, the authorities cut back these bodies’ independence, and people took to the streets.

That’s why the EU adopted a new enlargement methodology. As a result, the Fundamentals cluster includes strict requirements on the rule of law and anti-corruption efforts, and these will be watched especially closely.

Progress will be measured through “benchmarks” — conditions Ukraine must meet. They come in two types: interim benchmarks, which apply only to the two most important chapters of the first cluster — 23, Judiciary and Fundamental Rights, and 24, Justice, Freedom and Security — and closing benchmarks for each chapter.

The European Commission will prepare intergovernmental reports assessing how well these conditions are met.

“There will be constant monitoring, and essentially any change in legislation, any event in Ukraine that touches these areas, will be under very close watch,” Andrii Borovyk stresses.

Passing laws is only the first step. What follows is tracking how they’re implemented and enforced.

“We may see in EU reports that Ukraine has made solid progress fighting corruption, backed by indicators such as the number of cases and court verdicts. The same goes for recovering criminal assets. The EU will ask: ‘You passed the legislation? Well done! Now show us how you’re applying it.’ So we’ll need to show how much was recovered in specific cases. It’s a massive, complex process, and without constant communication between all branches of government, making progress will be very, very hard,” the expert adds.

Each year, the European Commission also publishes an Enlargement Report on every candidate country, including Ukraine, scoring each negotiating chapter. Converted into numbers, the scale runs from 1 (no progress) to 5 (full alignment with EU standards).

“According to last year’s Enlargement Report, Ukraine’s average score now stands at 2.4. But these results may not tell the whole story, since something is always improving somewhere while something else is slipping,” the Executive Director says.

Among the recent improvements, he points to the comprehensive public procurement law that the Verkhovna Rada passed in late May. Ukraine’s President signed it on June 24.

Ukraine is still waiting for the European Commission’s final assessment of this law, but Andrii Borovyk believes it clearly brings the country closer to EU standards, marking “moderate, maybe even good, progress” in this area.

In the anti-corruption field, the top priority is preserving anti-corruption institutions and expanding their powers. For instance, anti-corruption bodies need the ability to investigate cases involving members of parliament without waiting for the Prosecutor General’s permission. They should also gain access to independent, professional expertise.

Ukraine must also keep delivering strong results on corruption cases. Andrii Borovyk notes that this area is in better shape, since the number of verdicts and cases handled by the High Anti-Corruption Court keeps growing each year.

There will be constant monitoring, and essentially any change in legislation, any event in Ukraine that touches these areas, will be under very close watch.

Andrii Borovyk

Why Ukraine’s EU integration has slowed down

Andrii Borovyk names several reasons the reform process has slowed over the past 12 months:

Waning US attention to reforms after the presidential election, given its role as a key partner for Ukraine;
The law the Verkhovna Rada passed in July 2025, which curbed the independence of the NABU and the SAPO;
“Fatigue” among lawmakers.

“We keep hearing that a few dozen, maybe close to a hundred, MPs want out. I think all branches of government need an honest conversation to find common ground. Civil society is always ready to help, and it already does — its representatives step in as technical experts drafting documents or preparing independent assessments of the process itself,” the expert says.

Beyond winning the war, he adds, Ukraine needs a second political goal to rally around: EU membership.

“Ambitions need to wait, and everyone should work toward this goal, moving as one group. It sounds philosophical, but you can’t wave a magic wand like in Harry Potter to get this done. It’s all hard work,” Borovyk adds.

In the expert’s view, civil society’s attention may be the best defense against political pressure. During wartime, when elections are impossible and political accountability is hard to enforce, he urges Ukrainians not to lose their political memory.

“Unfortunately, our political memory isn’t always strong, so ‘old politicians’ often end up back in power anyway. But last July, when parliament passed something we — and the EU — completely disagreed with, we showed we could respond with peaceful protest. I wouldn’t want that to become routine, and I really hope parliament and the president don’t repeat such strange moves.”

Ukraine is the first country in the world fighting for survival while pursuing two paths at once — defending its independence and nationhood on the front line, and integrating into the EU.

“I don’t know of any other country that’s done this. I don’t know of any country that tried to carry out reforms during a war. We’re not always happy with them, and there have been far fewer over the past 12 months than at the start, but this is very hard, and without it, joining the EU will be difficult,” Borovyk concludes.

Ambitions need to wait, and everyone should work toward this goal, moving as one group. It sounds philosophical, but you can’t wave a magic wand like in Harry Potter to get this done. It’s all hard work.

Andrii Borovyk

What reforms will actually mean for Ukrainians

The reforms Ukraine must carry out to join the EU directly affect every Ukrainian’s life. Meeting all the required criteria, Andrii Borovyk believes, will improve the justice system, the work of state bodies, and public administration overall.

“How will it affect people’s lives to have professional, honest courts with strong technical capacity? When you go to court without thinking, ‘Why bother, it’s all bought and paid for’ — that’s already a major impact,” the expert reflects.

The goal of these reforms is to build a regulated legal environment — for running a business, say, or protecting conservation areas from illegal construction.

“As a result, whatever field a Ukrainian works in will better align with the rule of law. People will know how to act and what to expect if a ruling turns out unfair — and that will still happen sometimes, since not every EU member state is perfect either. What matters is that everyone can expect a fair ruling in a dispute,” Andrii Borovyk adds.

The next step in the negotiation process is the final approval of benchmarks for the first cluster. Ideally, negotiations on the remaining five clusters would open as soon as possible after that.

Then comes the long work of carrying out reforms, where Ukraine must not just change laws but prove they work.

Transparency International Ukraine, together with colleagues from other organizations, tracks this process by publishing annual “shadow reports” assessing Ukraine’s progress against its commitments. These reports cover the state of anti-corruption efforts, the rule of law, justice, and public procurement.

“These documents aren’t meant to criticize the authorities — they’re meant to show where we currently stand and which direction we should be heading on the path to EU integration. The reports don’t represent the European Commission’s position, though in our case, it helps fund and support their preparation. Some candidate countries don’t have anything like this, but how could Ukraine not have shadow reports, given how enormous and relentless civil society and journalist activity here is? We’re constantly held up as an example in many other countries,” Andrii Borovyk explains.

These documents aren’t meant to criticize the authorities — they’re meant to show where we currently stand and which direction we should be heading on the path to EU integration. The reports don’t represent the European Commission’s position, though in our case, it helps fund and support their preparation.

Andrii Borovyk

The post What Does Opening the First EU Cluster Mean? first appeared on Transparency International Ukraine.

Progress in Ukraine’s Anti-Corruption Efforts. June 2026 update

Віка Карпінська — Thu, 25 Jun 2026 06:55:59 +0000

This document is a publication of Transparency International Ukraine (TI Ukraine). It analyses measures taken to strengthen Ukraine’s anti-corruption ecosystem during the period from September 2025 to June 2026.

This paper supplements the previous report and is published ahead of the Ukraine Recovery Conference in Gdansk and in the context of a critical juncture in Ukraine’s EU accession process: the member states have agreed to open Cluster 1 — Fundamentals, which sets out, among other elements, clear expectations for rule of law and anti-corruption reforms which must be completed for EU Accession.

The reporting period was marked by a combination of institutional progress and growing systemic risks. Anti-corruption enforcement institutions, such as the National Anti-Corruption Bureau’s (NABU), the Special Anti-Corruption Prosecutor’s Office (SAPO), and the High Anti-Corruption Court (HACC), continued to expand on their impressive track record by progressing in high-level cases, including in the highly sensitive energy and defence sectors. The reform of the Asset Recovery and Management Agency (ARMA) commenced with a competitive selection of its new leadership.

At the same time, targeted pressure on NABU detectives intensified, the National Agency on Corruption Prevention’s (NACP) mandatory external audit remains blocked, and Parliament has yet to address critical legislative gaps identified by the European Commission and featured in the IMF requirements, as well as in the top priorities outlined in the Kachka-Kos joint statement of December 2025.

The adoption of the new Law on Public Procurement marks a significant step toward EU alignment in that sector, though substantial implementation work lies ahead.

TI Ukraine continues to work closely with Ukrainian institutions and international partners to support the anti-corruption reform agenda and will provide further analysis as the situation develops.

Status of Key EU Recommendations Implementation

Ukraine has implemented several of the EU’s key recommendations and aligned its public procurement sector with European standards:

The ARMA reform entered the implementation phase following Law No. 4503-IX.
The NABU and the SAPO continued expanding their track record; both the SAPO and the HACC adopted institutional development strategies.

The HACC substantially increased the pace of case completion, reducing average case-processing time from 618 to 405 days.
The new Law on Public Procurement (draft law No. 11520) has been adopted.
The State Audit Service received broader powers to oversee the use of international partners’ funds.
The Roadmap for Strengthening Public Procurement Oversight for 2025–2027 has been approved.

However, a number of other substantial recommendations remain outstanding:

Expanding the NABU’s jurisdiction to all high-risk public positions.
Strengthening safeguards against circumvention of the NABU’s exclusive jurisdiction by the SBI, SSU, National Police, and ESBU.
Empowering the SAPO to investigate MPs without prior approval of the Prosecutor General.
Amending the CPC to remove automatic closure of criminal proceedings upon expiry of pre-trial investigation deadlines, and extending the statute of limitations for corruption offences in line with European standards — both specified in the Kachka-Kos plan.
Improving the declaration verification system, including introduction of a risk-based approach focused on high-ranking officials as required by the February 2026 IMF Memorandum and European Commission.
Adopting a new Anti-Corruption Strategy and the State Anti-Corruption Programme.
Carrying out the selection procedure for Accounting Chamber members.
Bringing into line the legislation on public-private partnerships and concessions with the EU acquis.
Continuing the defense procurement legislation update.
Ensuring the comprehensive reform of the State Audit Service.

Overall, the progress is mixed: meaningful advances, including the ARMA reform, continued growth in the NABU, SAPO, and HACC track record, and the adoption of the new Law on Public Procurement, are contrasted with growing risks to the independence of anti-corruption institutions, a widening gap between declared commitments and legislative action, persistent deficiencies in the criminal-law and asset-recovery framework, and stalled reform of the Accounting Chamber.

Meaningful advances, including the ARMA reform, continued growth in the NABU, SAPO, and HACC track record, and the adoption of the new Law on Public Procurement, are contrasted with growing risks to the independence of anti-corruption institutions, a widening gap between declared commitments and legislative action, persistent deficiencies in the criminal-law and asset-recovery framework, and stalled reform of the Accounting Chamber.

The post Progress in Ukraine’s Anti-Corruption Efforts. June 2026 update first appeared on Transparency International Ukraine.

15 out of 100: Limited Progress on the Kachka-Kos Plan

TI Ukraine — Tue, 23 Jun 2026 10:23:51 +0000

An expert coalition has presented the findings of the second Membership Check monitoring of Ukraine’s progress on 10 priority EU integration reforms. According to the think tanks’ joint assessment, the country’s overall progress has risen only marginally, to 15 out of a possible 100 points.

As the first negotiating cluster, Fundamentals, opens, Ukraine is still showing extremely slow progress in implementing the reforms set out in the EU integration Kachka-Kos plan. According to the Membership Check expert monitoring, overall implementation of the tasks reviewed has grown by just 6 points since the first round and now stands at only 15 out of a possible 100.

This is the second such assessment of Ukraine’s progress in meeting these commitments to its European partners; the first was published in April 2026, when Ukraine scored 9 out of 100.

At this stage of the monitoring, Transparency International Ukraine experts again took part in assessing the points of the plan that are critical to effective anti-corruption work in Ukraine. In particular, the organization’s analysts assessed in detail the implementation of key goals in judicial and anti-corruption reform, criminal justice, and competitive selection for positions in law enforcement bodies.

“Ukraine’s progress on the Kachka-Kos plan is rather modest so far — we are seeing only isolated changes, while the overall pace of reform lags behind the expectations of the public and our partners. The opening of the Fundamentals cluster could energize this process, since implementing the plan is a basic EU integration requirement. Whether these changes happen in time now depends on the political will within the country,” says Kateryna Ryzhenko, Deputy Executive Director of Transparency International Ukraine for Legal Affairs.

Ukraine’s progress on the Kachka-Kos plan is rather modest so far — we are seeing only isolated changes, while the overall pace of reform lags behind the expectations of the public and our partners.

Kateryna Ryzhenko

Goal 1. Criminal justice (2.5/20 — up 0.5)

Government track: The draft law developed by the Ministry of Justice to deliver on elements of this point of the plan was sent back for revision following a meeting of the government committee. It is currently being refined together with the NABU and the NACP, but the document has still not been published for public consultation or registered in parliament.
MP initiatives: Two draft laws have been registered in the Verkhovna Rada — No. 15333 (on improving the efficiency of proceedings after the expiry of pre-trial investigation deadlines) and No. 15334 (on improving investigative jurisdiction and international cooperation).

Goal 2. Ensure that NABU has effective access to impartial, timely and high-quality forensic examinations (2/10 — up 1.5)

Providing the NABU with effective access to impartial and timely examinations is still stalled by the lack of a shared vision among the agencies.

The Ministry of Justice has begun work on amendments to the Law on Forensic Examination to strengthen safeguards for forensic examination activities.
The NABU has submitted its comments, but significant disagreements remain between the ministry and the Bureau over the concept for establishing such an expert institution.

Goal 7. International experts in the HQCJ selection (1.5/10 — up 0.5)

The issue of expanding international experts’ participation in the Selection Commission for members of the High Qualification Commission of Judges (HQCJ) remains frozen.

Draft Law No. 13382, intended to restore international experts’ participation in selecting HQCJ members, has been stalled in the Verkhovna Rada since June 2025.
According to the Cabinet of Ministers, another legislative initiative has now been drafted and is undergoing consultations with the European Commission. This document has not yet been officially registered or published.

Goal 9. Adopt the Anti-Corruption Strategy and the SAP by the end of June 2026 (1.5/5 — up 1)

The plan required the Anti-Corruption Strategy and the State Anti-Corruption Program (SAP) to be adopted by Q2 2026, but the deadlines have already been missed.

Blocked in parliament: Three competing draft laws are awaiting consideration in the relevant parliamentary committee. The most ambitious, and the one consistent with EU integration requirements, is Draft Law No. 15230 from the head of the Anti-Corruption Committee.
SAP delay: The State Anti-Corruption Program was developed in parallel, but the NACP will release its draft for public consultation only after parliament finally votes on the Strategy.

Goal 10. Strengthen internal control and whistleblower protection (1/10 — up 0.5)

There are already initial practical steps in building up internal control and efforts to adapt the Ukrainian system to European standards, although the core legislative framework is still awaiting final approval.

The State Audit Service has stepped up its checks, Internal Audit Standards in line with the European GIAS requirements have entered into force, and a whistleblower portal is operating, though it still needs technical improvements.
Several strategic goals have been incorporated into Draft Laws No. 15230, No. 15230-1, and No. 15230-2, On the Principles of State Anti-Corruption Policy for 2026–2030, which are currently awaiting consideration in the relevant committee.

The organization’s analysts assessed in detail the implementation of key goals in judicial and anti-corruption reform, criminal justice, and competitive selection for positions in law enforcement bodies.

Other goals of the plan: the overall picture according to experts

In the other reform areas reviewed, the situation also remains unsatisfactory:

Selection of the Prosecutor General (0.5/10 — up 0.5): there has been virtually no progress in revising the competitive selection procedures, with only one MP draft law registered.
Selection for senior positions in the prosecution service (0.5/10 — no change): transparent competitive appointments have still not been restored, and new government initiatives risk dragging out the process through lengthy consultations.
SBI reform (1/10 — no change): the relevant draft laws have not been presented for broad discussion, creating the risk that new leadership will be selected under the old procedures.
New CCU judges and HCJ members (1/5 — no change): the competitive procedures are continuing with delays, and key vacancies under certain quotas remain unfilled.
Judicial integrity and enforcement proceedings (3.5/10 — up 1.5): the legislation adopted does not take into account the EU’s recommendations on checks of the integrity declarations of Supreme Court judges, although there is some positive movement on digitalizing enforcement procedures.

This baseline evaluation covers the “Kachka-Kos plan” — a set of equivalent reforms defined in December 2025. Alongside Transparency International Ukraine, which focused on key anti-corruption areas, the study involved the MEZHA Anti-Corruption Center, European Pravda, the ANTS National Interests Advocacy Network, DEJURE Foundation, New Europe Center, Centre of Policy and Legal Reform, and the Anti-Corruption Action Centre.

In the other reform areas reviewed, the situation also remains unsatisfactory.

The post 15 out of 100: Limited Progress on the Kachka-Kos Plan first appeared on Transparency International Ukraine.

Public Procurement as a Foundation of EU Accession: What Ukraine has Already Done and What is Still Expected of Us

Іван Лахтіонов — Mon, 22 Jun 2026 08:00:59 +0000

Public procurement falls under the first negotiating cluster, “Fundamentals,” which was opened in Luxembourg a few days ago. This cluster is the set of core reforms by which the EU judges whether a candidate country is ready to join the Union. It includes chapters on the independence and effectiveness of the judiciary, the fight against corruption, the transparency and accuracy of data, and public procurement and financial control.

Why did public procurement end up in Fundamentals? As things stand, up to two trillion hryvnias pass through Prozorro each year — roughly half of Ukraine’s entire 2025 budget. Public procurement is therefore the foundation of how effectively the country spends its money. And the European Union is not only a political union but an economic one. So economic indicators and reforms weigh just as heavily on the decision to admit Ukraine as those concerning, say, the rule of law and justice. From this angle, it is equally clear why financial control belongs in Fundamentals — it is the oversight of how effectively the budget is spent.

Just before the negotiations opened, Ukraine took an important step toward European integration in this area: it passed the new Law on Public Procurement. Its purpose was to bring our procurement legislation into fuller alignment with the European directives. Fuller — because we had already implemented a substantial part of this harmonization under the Association Agreement between Ukraine and the EU.

Now we are waiting for feedback from the European Commission on how well the adopted law meets its requirements. In this piece, we look at what is expected of us next.

Final alignment of legislation

So we are still awaiting feedback on the newly adopted Law on Public Procurement. But under the Ukraine Facility we have a firm deadline by which our rules in this area must fully comply with the EU directives — September 2027.

This stage should not be underestimated. Within the European integration framework, the public procurement chapter also covers public-private partnerships (PPPs) and concessions. These have been somewhat overlooked lately, because international partners focus specifically on public procurement in their key requirements. Yet PPPs and concessions are no less important for European integration.

We updated our dedicated PPP law a year ago. However, in last year’s EU Enlargement Report on Ukraine, the European Commission pointed to a number of its inconsistencies with the directives. Yet Ukraine has so far done nothing to remove them. The final deadline here is the same as the previous one — September 2027.

We also have a great deal of work to do on defense procurement legislation, which likewise belongs to the procurement chapter. Here we are essentially only at the start of the journey — by the end of the year we must draft a concept note on updating the relevant law in line with the EU directives. This document should map out where our current legislation differs from the European framework and describe how we plan to close those gaps. The final deadline for aligning defense procurement legislation has not yet been announced.

In addition, we need to transpose into our legislation the EU directive on procurement by monopolies in certain economic sectors. Our main law on the subject reflects it only in part — for instance, we have a definition of such contracting authorities and thresholds for them. But the bulk of the transposition still has to be carried out. The deadline here, too, is September 2027.

Practical implementation

However, harmonizing the rules is only the first step. Next, their practical implementation has to be ensured. This means, in particular, the secondary legislation that has to spell out the detailed rules and instructions for applying the law, which sets only the general framework. For the new Law on Public Procurement, we need to develop more than 40 such documents. These include, for example, methodologies for estimating the estimated value of procurements — which will help prevent overpayments — and detailed regulations for new European procedures such as the innovation partnership, designed for procuring technological solutions. A separate matter is making the technical changes to the electronic system to adapt it to the updated rules. The deadline for this work will be set once the President signs the adopted law and it is published — from that point we will have nine months to make all the necessary preparations for it to take effect. But will that be enough time? Given the shortage of financial and human resources, there is a real chance that not everything will be done in time. That is why priorities need to be chosen now.

We are already being urged to plan clearly for updating the secondary legislation and for the technical rollout of changes in Prozorro: among its conditions for granting Ukraine macro-financial assistance, the European Commission has singled out the development of a Public Procurement Development Strategy for 2027–2030. This should set out clear indicators and deadlines for gradually adapting the sector to the new law and — beyond secondary legislation and the technical rollout — plan communication activities and training for stakeholders.

Similar work needs to be done in the area of public-private partnerships. Under the law passed last year, the government must bring its regulations into line with it by September 2026. This involves updating more than 30 pieces of secondary legislation governing, among other things, how a private partner is selected, how the effectiveness of a PPP is assessed, the engagement of advisers, the provision of additional state support, the calculation of concession payments, and so on. Yet the regulatory base is being updated at an extremely slow pace.

For now, the government has simply pushed some of the changes back. For example, the requirement to use Prozorro to select a concessionaire has been postponed until early 2027. This functionality has not yet been built into the system.

This state of affairs with drafting PPP regulations is due partly to a shortage of specialists in the Ministry of Economy unit responsible for this area. International partners, the European Commission in particular, are not actively pushing us toward further changes until we fully align the underlying law itself with the directives.

Protecting business rights and oversight

In the list of accession criteria that European Pravda published in March this year, strengthening oversight and legal protection belonged to the second set of tasks for closing the negotiations — those concerning the practical implementation of legislation. But this is a sizable and weighty set of tasks that can fairly be treated as a separate strand of work. It also partly overlaps with the chapter on financial control.

Let us start with legal protection. The European Commission has set the requirement to ensure the effective functioning of a system of legal remedies, in particular in the areas of PPPs, concessions, and defense procurement — that is, to introduce the right to appeal to the Antimonopoly Committee of Ukraine.

On the other hand, the new Law on Public Procurement introduces the right to appeal for a large share of procurement transactions made through Prozorro Market, where businesses previously had no way to defend their rights. The law also replaces some procurements that could be conducted directly during the war with negotiated procedures, which likewise allow for appeals.

So European integration through these reforms will significantly increase the workload on the AMCU, and strengthening the body’s institutional capacity will only become more pressing. In 2025, the AMCU board that reviews complaints about violations of public procurement law had 6 of the 10 commissioners provided for by law. The body has not announced a competition for the remaining posts, but it will need to, so that the AMCU can handle its expanded range of tasks.

Another important area is the work of the State Audit Service as the main oversight body in public procurement. It is the body that carries out preventive control — monitoring procurements. Here we have seen positive movement over the past year: auditors have finally been given access to the personal data of offenders so that they can hold them to account. To the same end, the deadlines for going to court have been extended. Auditors have also received expanded powers to oversee EU funds and have developed a Roadmap for strengthening procurement oversight overall. All of this was part of the Ukraine Facility conditions.

A comprehensive overhaul of procurement monitoring remains a challenge. This concerns its preventive nature, its focus on material violations, and the obligations that auditors impose on offenders in their monitoring conclusions, which should be proportionate to the seriousness of the violations. Beyond this, within the financial control chapter we have commitments regarding other functions of the State Audit Service. In particular, for 2026 we received clear condition for part of the European Commission’s macro-financial assistance — to separate the audit and inspection functions within the body.

The opening of the first negotiating cluster should by no means be seen as a finish line. It is rather the start of an enormous amount of work. The reforms within the public procurement and financial control chapters are only a small part of the first cluster — and in the negotiations we will have six such clusters, 35 chapters in all.

There is already word that other clusters may open as early as July, which would let Ukraine advance on several negotiating tracks at once. However, the public procurement and financial control chapters alone are enough to show that a quick conclusion to the negotiations should not be expected. We have plenty of reforms that have stalled in place, and plenty more that have not really even begun.

That said, it is important to keep in mind that all these changes are needed not only so that Ukraine becomes an EU member. First and foremost, we advocate for these reforms and help the state implement them in order to make it stronger. We need effective public procurement and sound financial control so that a budget constrained by the war is spent wisely. To keep it from being plundered, we are pushing to strengthen the anti-corruption bodies. And the same motivation should apply to every reform we implement in the course of the negotiations. Because the European Union is not an end in itself. We want to be in the EU because it is a civilizational choice and a matter of worldview — to be an effective, democratic, and strong state.

This material was made possible with the support of the MATRA program of the Embassy of the Kingdom of the Netherlands in Ukraine.

The post Public Procurement as a Foundation of EU Accession: What Ukraine has Already Done and What is Still Expected of Us first appeared on Transparency International Ukraine.

The “Fundamentals” of Fighting Corruption: What the Opening of EU Negotiations Will Change

Андрій Боровик — Mon, 15 Jun 2026 15:51:39 +0000

Today in Luxembourg, the EU member states officially opened the first negotiating cluster on Ukraine’s accession to the EU. To the general public this may sound like just another diplomatic event. But behind that formality lie years of work by the government, state bodies, and civil society — hundreds of recommendations and concrete commitments on whose fulfillment the country’s future depends.

In recent days, Ukrainians have read and heard a great deal about the so-called “Fundamentals” cluster. But what is this cluster? How does it affect European integration, and what does it have to do with fighting corruption? Let me try to explain.

To the general public this may sound like just another diplomatic event. But behind that formality lie years of work

Andrii Borovyk

Why Fundamentals is not a technical annex but the basis of the negotiations

Cluster 1 — Fundamentals of the Accession Process — brings together, among others, the chapters that matter most to us: the rule of law, the fight against corruption, public procurement, and financial control. This is no random set of topics, because it is precisely these areas that determine whether a state is governed by the rule of law, whether it can be trusted as a partner, and whether the rights of its citizens and businesses are protected.

The EU’s logic is simple: Cluster 1 is the first to open and the last to close, because it lays the foundation for legal certainty within the country and, ultimately, shapes the trust that other partners place in it. In other words, it determines whether a country is ready to join the European family.

Even if Ukraine meets all the requirements in the other five clusters — on energy, transport, agriculture — membership in the EU is impossible without closing the commitments under Fundamentals.

For us at TI Ukraine, this means one thing: rule-of-law reform and anti-corruption reform are no longer a “parallel track.” They are the main road to the EU.

Andrii Borovyk

What Ukraine has actually done to fight corruption over the past year

Critics like to record failures — and there are grounds for that. But an honest analysis requires acknowledging real achievements as well. And however difficult it is right now to pass new reforms, let alone implement them, there have indeed been concrete gains.

The most recent: in late May, the Verkhovna Rada passed the new Law on Public Procurement. This is a step the European Commission had been awaiting for several years, since the new law is intended to align our procurement rules with European ones.

Beyond that, a notable anti-corruption achievement is that the NABU, the SAPO, and the HACC continue to markedly improve their performance. The number of verdicts is rising, as is the number of cases involving ministers, heads of central executive bodies, members of parliament, and representatives of the judiciary.

Moreover, after the new law took effect, the ARMA completed a large-scale inventory of assets for 2017–2025, so it is finally clear how much property is under the Agency’s control. And by the end of 2025 alone, the body concluded more asset management agreements than in the previous two years combined. Following a drawn-out selection process for its new head, the Economic Security Bureau has entered an active phase of reform now that a director has been appointed. And finally, the NACP has drafted a new Anti-Corruption Strategy 2026–2030 — so there are now three draft laws before the Verkhovna Rada that should set this crucial document in motion.

Each of these steps is the result of long-running cooperation between civil society, the government, MPs, international partners, and the anti-corruption institutions themselves. But the key is for each of these examples to see the full cycle of change completed.

Andrii Borovyk

Where the risks remain — and why NABU’s investigations change the rules of the game

But I have to be candid — many systemic problems remain. Let us consider them through examples.

The average time to hear a case at the HACC has reached a record 618 days. The mandatory external assessment of the NACP has not been carried out for more than four years. For several years now, the Accounting Chamber has operated with six of its eleven positions vacant — the competition has still not been fully launched, even though the relevant item kept appearing and disappearing from parliament’s agenda throughout last year and half of this one. The current State Anti-Corruption Program has been only half implemented.

And all of this against the backdrop of a latent political crisis triggered by last year’s attempts to neutralize the independence of the NABU and the SAPO. Those attempts failed, which ultimately gave rise to high-profile anti-corruption investigations such as Operation Midas and the Dynasty mansions case.

This genuinely effective work by the anti-corruption bodies unexpectedly, for many, set off a different narrative in the socio-political space: that high-profile anti-corruption cases supposedly undermine the state’s capacity and damage its international image. But this, of course, is an utterly manipulative claim.

First, because all of NABU’s and SAPO’s actions took place within the legal framework: the notices of suspicion were authorized by prosecutors after the evidence base had been gathered, those facing charges were able to mount a defense, and the process was open to the public. Second, removing from office those involved in corruption schemes in energy and defense during the war cleanses the public administration system rather than weakening it. So such investigations should clearly work in favor of the state’s internal capacity.

And given Ukraine’s European integration potential, it is worth recalling that in all our key commitments to our partners, strengthening the anti-corruption institutions is written in as a mandatory condition of support. Because our European partners view the fight against corruption as an investment in the country’s security, not an obstacle to it.

At a meeting in Kyiv, Marta Kos said plainly that our officials must avoid any thought of rolling back reforms — especially in the areas of anti-corruption, judicial reform, and the independence of key institutions. What is that, if not confirmation of support for our anti-corruption bodies?

Quality work by the NABU and the SAPO is a signal of the system’s institutional maturity, clear to everyone who follows Ukraine. And that should be remembered on Bankova, Hrushevskoho, and the other capital streets where Ukrainian politics is made.

In all our key commitments to our partners, strengthening the anti-corruption institutions is written in as a mandatory condition of support. Because our European partners view the fight against corruption as an investment in the country’s security, not an obstacle to it.

Andrii Borovyk

What comes next, and how realistic membership is

Here I will recall that, as of now, there are no official timelines for Ukraine’s accession to the EU. And this is an honest position: the speed of our progress depends not on dates on the calendar but on the consistency of reforms. As Commissioner for Enlargement Marta Kos noted, the reforms Ukraine has already carried out — including under the Ukraine Facility — must come together into a single negotiating process. But for that, they must be real, not declarative.

For us at TI Ukraine, the opening of Cluster 1 is not a cause for celebration but the start of a new stage of responsibility. Negotiations with the European Union create an external framework, but only internal political will can fill it with substance. And the consistency of that will is perhaps the most important indicator by which the EU will assess Ukraine in the coming years. The European Union has opened the first doors for us — and now the question is whether we can walk through them.

This publication has been produced with financial support from Norway. The contents of this publication are the sole responsibility of [grant recipient’s name] and can in no way be taken to reflect the views of the Government of Norway.

Negotiations with the European Union create an external framework, but only internal political will can fill it with substance. And the consistency of that will is perhaps the most important indicator by which the EU will assess Ukraine in the coming years.

Andrii Borovyk

The post The “Fundamentals” of Fighting Corruption: What the Opening of EU Negotiations Will Change first appeared on Transparency International Ukraine.

The EU Opens Its Key Negotiating Cluster with Ukraine

TI Ukraine — Mon, 15 Jun 2026 14:52:20 +0000

On June 15, in Luxembourg, Ukraine officially moved to a new stage of European integration: negotiations opened on the first and most important cluster, “Fundamentals of the accession process” (Fundamentals).

This is a historic event that changes the entire logic of our European integration. Anti-corruption reforms are now no longer just friendly recommendations from Brussels but firm negotiating conditions. And here, unfortunately, we still have a great deal of unfinished “homework.”

What’s inside Fundamentals?

This cluster consists of five key areas (chapters) against which the EU will examine Ukraine under a microscope:

Chapter 23 (Judiciary and Fundamental Rights): Court reform, judicial independence, and a genuine fight against high-level corruption.
Chapter 24 (Justice, Freedom and Security): An overhaul of law enforcement, combating organized crime, and order at customs and on the borders.
Chapter 5 (Public Procurement): Moving all government and defense tenders onto strict European standards.
Chapter 32 (Financial Control): Protecting European money and auditing the budget (the work of the Accounting Chamber and the State Audit Service).
Chapter 18 (Statistics): Transparent and accurate data on the economy and the population, to Eurostat standards.

Andrii Borovyk, Executive Director of TI Ukraine: “The Fundamentals cluster is the first to open in the negotiations and the last to close. This means that in the course of our European integration, it will be impossible to defer anti-corruption reforms in favor of progress in technical areas. What is more, EU Commissioner Marta Kos has stressed that the pace of negotiations will now be set not by calendar dates but by the consistency of reform implementation — and the fight against corruption is an unquestionable priority.”

The Fundamentals cluster is the first to open in the negotiations and the last to close. This means that in the course of our European integration, it will be impossible to defer anti-corruption reforms in favor of progress in technical areas.

Andrii Borovyk

Where is Ukraine stalling on reforms?

We can identify five critical points in the fight against corruption that need to be fixed right now:

Case-hearing timelines at the HACC. The hearing of cases at the High Anti-Corruption Court sometimes reaches a record 1,885 days (five years and two months). The reason: the Rada has still not passed a law that would stop lawyers and defendants from deliberately dragging out proceedings.
NACP verification of asset declarations. The automated check launched in late 2023 has effectively exempted senior officials from thorough manual review. The IMF requires this to be fixed by the end of June 2026, but there has been no movement. In addition, the NACP does not publish its logical and arithmetic control (LAC) rules, and the mandatory external audit of the agency has not been carried out for more than four years.
Limited autonomy of the SAPO. The head of the Specialized Anti-Corruption Prosecutor’s Office still cannot independently open cases against MPs or fully initiate extraditions — that is the exclusive prerogative of the Prosecutor General. The government even removed the first of these provisions from the draft Anti-Corruption Strategy.
Crisis at the Accounting Chamber. The country’s principal audit body is operating at half capacity: 6 of its 11 positions are vacant. Parliament missed the deadline (April 2026) for forming the Advisory Group of Experts for the selection competition. As a result, Ukraine risks not receiving part of its tranches from the EU and the IMF this year.
Procurement and public-private partnership. The law on public-private partnership (PPP) has still not been aligned with EU rules. And by the end of 2026, Ukraine must develop a concept for reforming defense procurement — EU funding also depends on this.

The authorities must eliminate all these risks as quickly as possible, because what is at stake is financial stability and the speed of our accession to the EU.

What comes next?

The authorities must eliminate all these risks as quickly as possible, because what is at stake is financial stability and the speed of our accession to the EU.

Andrii Borovyk, Executive Director of TI Ukraine: “We are already seeing that some commitments are being met late. And some — particularly those concerning the autonomy of the SAPO and the Accounting Chamber — show signs of systemic stalling rather than technical delays. By opening this cluster, our European partners are telling us: your EU membership is in your hands — take it.”

The European Commission will deliver its first official verdict on how Ukraine is handling the new conditions in late autumn 2026, in its annual Enlargement Report. Transparency International Ukraine continues to monitor the situation and will set out the results of this analysis in its third Shadow Report for the European Commission.

We are already seeing that some commitments are being met late. By opening this cluster, our European partners are telling us: your EU membership is in your hands — take it.

Andrii Borovyk

The post The EU Opens Its Key Negotiating Cluster with Ukraine first appeared on Transparency International Ukraine.

Ukraine Risks Losing Part of EU Financial Assistance Over Unfinished HACC Competition

TI Ukraine — Wed, 10 Jun 2026 12:55:06 +0000

TI Ukraine Deputy Executive Director for Legal Affairs Kateryna Ryzhenko discussed the problem of implementing these Ukraine Facility milestones on Hromadske Radio.

In response to a Radio Liberty inquiry, a European Commission spokesperson confirmed that two milestones linked to tranches Ukraine has already received remain unfulfilled. The fourth and fifth tranches have been “suspended” as a result — nearly €300 million under the fourth and over €380 million under the fifth.

The outstanding milestone in the fourth tranche concerns increasing HACC staffing levels, while the fifth tranche requires the entry into force of legislation on the review of judges’ integrity declarations and verification procedures. The final deadlines for fulfilling these conditions are June 30 and September 29, 2026 respectively.

“Of the two milestones, one we can potentially still fulfill — the draft law on judges’ declarations, although questions remain about the text of the law. The second milestone — the HACC judges we were supposed to appoint more than a year ago — is a different matter. The competition is now in its final stretch, but we are unlikely to complete the appointments before the deadline. And so there is a real chance we will lose the funds we were supposed to receive for fulfilling this recommendation,” said Kateryna Ryzhenko.

She identified several factors behind the failure to select and appoint HACC judges on time:

“The first factor is the general shortage of human resources in our country. This is no secret — many people are fighting, many have left, and many, unfortunately, are not ready, are unable, or are not in a position to participate in a competition for judicial appointments. There were also serious questions about the competition that took place a year ago. Many candidates dropped out at early stages, never even reaching the interview.”

As a result, a repeat competition had to be launched, which consumed more time, Ryzhenko noted: “And so we now face a potential situation where we do not receive the money for this.”

On May 29 the High Qualifications Commission of Judges (HQCJ) completed the dossier review and interview stage for 22 candidates for HACC judicial positions and published the competition rankings.

The next step lies with the High Council of Justice, which may endorse the candidates or decline to submit a nomination to the President of Ukraine — even after a completed competition — if doubts remain about a candidate’s integrity or professional ethics, or if other circumstances emerge that could negatively affect public trust in the judiciary following their appointment.

Of the two milestones, one we can potentially still fulfill — the draft law on judges’ declarations, although questions remain about the text of the law. The second milestone — the HACC judges we were supposed to appoint more than a year ago — is a different matter. The competition is now in its final stretch, but we are unlikely to complete the appointments before the deadline.

Kateryna Ryzhenko

The post Ukraine Risks Losing Part of EU Financial Assistance Over Unfinished HACC Competition first appeared on Transparency International Ukraine.

Ukraine May Integrate into the EU Before Full Membership

TI Ukraine — Mon, 08 Jun 2026 15:09:37 +0000

On June 15, EU member states are set to vote on opening the first negotiating cluster at an intergovernmental conference in Luxembourg — and Ukraine’s EU integration process is poised to accelerate significantly in the near term.

EU Commissioner for Enlargement Marta Kos stated that the remaining five clusters could also be opened by mid-July. “The absolute priority right now is to open all the clusters,” Kos said.

She also acknowledged that EU member states have rejected the previous complex and lengthy approach to EU integration — the so-called “reverse enlargement” — in favor of an intermediate model under which candidate countries, including Ukraine, will be able to enjoy the benefits of membership before formally joining.

The driver of this shift, according to Kos, has been Ukraine itself, alongside the willingness of key EU member states to support its accession. This was also the essence of German Chancellor Friedrich Merz’s proposal for a special format for Ukraine — an approach that could ultimately extend to other candidate countries as well.

“Today’s statements by the Commissioner indicate that our path to the EU now depends on us more than ever before. There can be no excuses for failing to adopt EU integration laws or carry out reforms. The list of requirements and necessary steps will be quite clear. The EU is opening the road to membership — our task is to give sceptics no grounds for future objections and to implement the necessary changes consistently,” said TI Ukraine Executive Director Andrii Borovyk.

On June 15 EU member states are to vote on opening the first negotiating cluster, “Fundamentals,” which covers, among other things, the rule of law and anti-corruption. TI Ukraine has been tracking Ukraine’s progress in these areas for three years and providing recommendations for their improvement through its Shadow Reports for the European Commission.

Today’s statements by the Commissioner indicate that our path to the EU now depends on us more than ever before. There can be no excuses for failing to adopt EU integration laws or carry out reforms.

Andrii Borovyk

The post Ukraine May Integrate into the EU Before Full Membership first appeared on Transparency International Ukraine.

The Third Procurement Revolution: What to Expect from the New Public Procurement Law

Іван Лахтіонов — Fri, 05 Jun 2026 07:32:50 +0000

The Public Procurement Law was last comprehensively updated in 2019. Since then, Ukraine has navigated COVID, four years of full-scale invasion, Cabinet of Ministers regulation, and over 45 rounds of amendments. The need to stabilize the sector and modernize the law had long been overdue. At the same time, full alignment of Ukraine’s procurement rules with European directives is a core requirement of EU integration.

Draft Law No. 11520 — the new Public Procurement Law — passed by the Verkhovna Rada on Wednesday, May 27, to the sound of an air raid alert, addresses both imperatives.

This is not just another set of minor adjustments. This is a complete overhaul — a massive document whose sheer scale even those who worked on it did not fully grasp until they saw the printed version handed in for signature. This is, without exaggeration, another procurement revolution. Above all, it is a revolution that brings Ukraine a significant step closer to the EU.

The DOZORRO team at Transparency International Ukraine has been involved in developing this document since 2024. We stopped counting the substantive changes we advocated for somewhere around the fortieth proposal. Equally impossible to count are the hours of working group discussions with stakeholders, in which we worked to find the best solutions and figured out how to transpose European rules into Ukrainian realities.

Admittedly, this third iteration of the Public Procurement Law has not received as much public attention as the first two — for understandable reasons. The army and its needs are, and must remain, the top priority. Yet efficient procurement means saving money that can go to the military, while also keeping the state functioning — the very state our soldiers are defending at the front. And every step toward EU integration builds trust and support from our partners, and in the long run, charts a course toward a peaceful European future.

Reform, EU integration, and money

Adopting a law fully harmonized with European procurement directives has been a partner requirement for years. It has been the top recommendation in the EU’s Enlargement Report on Ukraine for three consecutive years. It was included as a benchmark in the Ukraine Facility, and the World Bank made it a condition for a USD 3.5 billion loan and for unlocking the next support program.

From an EU integration standpoint, public procurement falls under the first negotiating cluster — Fundamentals. This is, in other words, one of the reforms partners expect from Ukraine first.

The new law introduces a number of sound European practices and partially reorients the approach. Chief among these are new procurement methods — for example, open framework agreements that can cover not only goods but also services and works, innovation partnerships, and joint procurement. European rules are, in many respects, considerably more flexible.

However, the working group made a deliberate effort to preserve the achievements of Ukrainian procurement, since in some areas our practices actually exceed European standards. Notably, while paper-based tenders still exist in the EU, the new law retains Ukraine’s 100% digitalization. For certain provisions, a gradual transition and separate methodologies were built in — detailed guidelines to be developed by the Government. This applies, for example, to non-price criteria, which have been rarely used in Ukrainian procurement practice.

Everyone involved in drafting this document worked hard to ensure it was not merely a translation of European directives into Ukrainian, but a genuine update of the rules — one designed to increase the efficiency of Ukrainian procurement and, in part, to make life easier for those who conduct and participate in it.

Changes contracting authorities (did not) see coming

Over the past four years, procurement professionals have had an eventful and unpredictable working life. The wartime procurement regulation — the Government resolution governing procurement during the state of war — was amended more than 45 times. That means, on average, nearly every month brought new rules that required adjusting processes and workflows. Understandably, yet another round of changes is not something contracting authorities greet with enthusiasm. But the new law is precisely intended to bring stability to the sector.

It preserves the Cabinet of Ministers’ authority to set procurement-specific rules during martial law. However, any exceptions to the competitive tender requirement will now require approval from the relevant Verkhovna Rada committee. This should serve as a meaningful safeguard, ensuring that such exceptions are introduced sparingly and only when genuinely necessary. Broadly speaking, sector regulation should be governed by the Law — and that will deliver the predictability and stability the sector needs.

In many ways, the new law is designed to make life easier for contracting authorities, in large part thanks to the flexibility of European approaches. It raises thresholds and denominates them in euros — meaning that, in practice, more transactions can be made directly. Procurement through Prozorro Market also becomes optional for above-threshold procurements. In recent years, food, medical goods and medicines, and New Ukrainian School supplies could only be procured through the electronic catalogue. Going forward, contracting authorities will be free to choose whichever method works best for them. And for those who do prefer the catalogue, it will now cover services as well. Similarly, the new procedures are not mandates — they are simply additional options. The core toolkit for contracting authorities, and the principles for using it, remain fundamentally unchanged: direct procurement for lower-value transactions, and the option to use the marketplace or open tenders for higher-value contracts.

Another long-awaited development: contracting authorities will be able to engage outsourced procurement specialists. This is especially significant for small contracting authorities — a village kindergarten, for example, where procurement is typically handled by an accountant with minimal additional pay. The numbers bear this out: as Deputy Director of the Ministry of Economy’s Public Procurement Department Tetiana Mishta noted at last year’s Prozorro Awards, 90% of contracting authorities in Ukraine are small entities. Previously, procurement could only be conducted — and responsibility borne — by an in-house designated officer. That work can now be contracted out to professional procurement specialists. The law also makes it explicitly clear that designated officers bear no responsibility for direct procurement, only for publishing reports on it.

Significant changes for businesses

First and foremost, businesses will now be able to challenge decisions before the Antimonopoly Committee of Ukraine in procurement categories where this was previously unavailable, which in 2025 accounted for nearly every second competitive procurement, covering all those conducted through Prozorro Market.

Companies will also benefit from more favorable conditions for participating in tenders: more time to prepare bids, machine-readable tender documentation, the ability to submit alternative proposals, and more situations in which contracting authorities are permitted to allow corrections to bids compared with the previous Law.

Special attention was given to the construction sector, which accounts for over 20% of the total contract value in Prozorro in 2025–2026. Tender documentation in this sector is now required to be published in cost-estimate software formats, making it easier for businesses to prepare their submissions.

The law also introduces a series of safeguards against contracting authorities imposing excessive requirements on bidders. For fuel procurement, any additional documents beyond those required by national standards are now prohibited. The Law also bars contracting authorities from requiring personal identity documents as part of bids.

Also, contracting authorities are prohibited from announcing a new procurement identical to a previous one before canceling the original. This protects businesses from situations where a contracting authority simply abandons a procurement in which an unwanted bidder won.

What comes next?

It is important to understand that adoption of the law is not the finish line. We still need to receive feedback from the European Commission on its compliance with EU requirements — and further amendments will almost certainly be required. Ukraine has committed to full harmonization with European rules by September 2027.

Additionally, the law enters into force in nine months, the window available to develop secondary legislation and implement the necessary technical changes in Prozorro.

A separate priority is communicating the changes. It will be essential for the Ministry of Economy to find the resources to explain to contracting authorities that these are not changes made solely for EU integration — they are changes made for them. Most importantly, contracting authorities need detailed, practical guidance on working under the new rules before they take effect. The same message needs to reach businesses and other stakeholders.

To sum up: a less prominent but no less historic shift in Ukrainian public procurement has begun. It is gratifying that this is yet another example of successful collaboration between the state and civil society. Is this a perfect law? Of course not — there is always room for improvement. But the people who wrote it genuinely did everything in their power to address as many existing problems and pain points as possible, and to truly strengthen public procurement in Ukraine. The recent news pointing to the potential opening of the first negotiating cluster with the EU as early as June suggests we are on the right path. Since procurement falls squarely within that cluster, the timing of this Law could not be better.

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.

The post The Third Procurement Revolution: What to Expect from the New Public Procurement Law first appeared on Transparency International Ukraine.

EU Macro-Financial Assistance Conditions: What Needs to Change in Procurement and Financial Control

Катерина Русіна — Mon, 01 Jun 2026 07:30:35 +0000

On May 28, the Verkhovna Rada ratified a memorandum with the EU on the provision of EUR 90 billion in assistance through the end of 2027. The funds will go toward both defense needs and broader economic support.

In April, the EU approved the allocation of the first half of this loan:

EUR 28.3 billion to support Ukraine’s defense industrial capacity — including for weapons procurement;
EUR 8.35 billion through the Ukraine Facility, partially covering reconstruction, education, and other non-military needs;
EUR 8.35 billion through macro-financial assistance, which will most likely be available for general budget expenditures.

To receive all three tranches, Ukraine has committed to maintaining effective democratic mechanisms, multi-party parliamentarism, human rights (including minority rights), and anti-corruption efforts — including a commitment not to reverse anti-corruption measures introduced under EU or IMF support instruments. Additional commitments cover transparency, accountability, effective management of public assets, central bank independence, and economic policy more broadly.

The macro-financial assistance tranche — the first portion of which amounts to EUR 8.35 billion and will be disbursed in three installments — carries its own specific conditions. These are designed to ensure Ukraine mobilizes domestic revenues, improves public expenditure efficiency, and strengthens public financial management. Many requirements accordingly address the tax system, customs, budget planning, and investment management.

There are also measures concerning procurement, the Accounting Chamber, and the State Audit Service — here is a closer look at each.

Appoint the three missing experts to the accounting chamber selection commission

Six of the eleven positions on the Accounting Chamber are currently vacant. A competition for new members formally launched a year and a half ago but has since stalled entirely: the Verkhovna Rada has not approved the composition of the Advisory Group of Experts (AGE) that is to conduct the process. The group is to comprise six members — three from the Ukrainian side and three from international partners. While the international nominees were selected relatively quickly, parliament has yet to settle on its own representatives.

This is not Ukraine’s first such commitment. In February 2026, completing the competitive appointment procedure for Accounting Chamber members appeared as a requirement in the memorandum with the IMF — and Ukraine has already missed the declared intention to form the advisory group by the end of April this year.

The formation of the AGE will now also be a condition of EU macro-financial assistance.

Develop and present a new Public Procurement Strategy for 2027–2030 to the European Commission

The current public procurement reform strategy covers 2024–2026. In practice, however, it has been largely nominal: the Government did not adopt an action plan for its implementation in 2026, and even the steps planned for earlier periods were only partially completed — in part because many of them logically follow the update of the primary legislation, a process that stretched over two years.

But on May 27, parliament finally adopted the new Public Procurement Law. Over the coming years, Ukraine will need both to implement it in practice — adopting around 40 pieces of secondary legislation and making the necessary technical upgrades to Prozorro — and to complete legislative harmonization. A robust sector development strategy will be essential to planning this work properly and navigating the challenges ahead.

Prepare a concept note on a defense procurement law

This marks what may be the first time the European Commission has set specific timelines for harmonizing defense procurement legislation with European standards. The Ukraine Facility previously covered only the reform of public procurement, public-private partnerships, and concessions — with a deadline in the third quarter of 2027.

Based on the wording of the condition, the concept note is to be developed this year. A separate challenge here — and throughout the broader harmonization of defense procurement legislation — will be establishing which body is responsible: the Ministry of Economy, which sets procurement policy; the Ministry of Defense, which does so for the defense sector; or parliament.

Prepare structural changes at the state audit service

The European Commission is calling on Ukraine to develop proposals for a clear organizational and managerial separation between inspection and audit functions within the State Audit Service.

These two activities differ in purpose, procedure, and methodology. Audit is oriented toward helping the entity under review systematically improve its operations — trust and cooperation are essential here, enabling auditors to provide the most useful recommendations possible and ensuring those recommendations are properly implemented. Inspection, by contrast, involves a detailed examination of financial and operational activities for legal violations, with the possibility of liability for those found at fault. This is not a partner trying to help — it is a controller looking for errors.

Currently, auditors and inspectors work within the same thematic departments — for example, the local budget oversight department or the construction sector oversight department. When an audit uncovers indications of violations, inspectors from the same unit may initiate an inspection of the same entity, even though this practice is inappropriate. It undermines confidence in audits, makes them less effective, and blunts their focus.

The need to separate these two forms of oversight has already been recognized in the Public Financial Management Reform Strategy for 2026–2030, which envisages the separation of audit and inspection functions within the State Audit Service by the end of 2027. Under the further development of the state internal financial control system, the State Audit Service’s audit function is expected to increasingly serve as an independent external assessment of management systems — complementing the internal audit conducted directly within government bodies.

On one level, the macro-financial assistance conditions relating to procurement and financial control may seem relatively modest — particularly compared with what is being asked on the tax side. That impression, however, could be misleading. Ukraine has been unable to appoint the Advisory Group of Experts to finally launch the Accounting Chamber competition for over a year. Initiating the reform of defense procurement legislation is also a substantial undertaking.

The fact that the European Commission has included these reforms among the conditionality is a signal that they genuinely matter. But for them to become true priorities, they will require awareness of that need — and political will — at multiple levels within the country.

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.

The post EU Macro-Financial Assistance Conditions: What Needs to Change in Procurement and Financial Control first appeared on Transparency International Ukraine.

Verkhovna Rada Adopts New Public Procurement Law

TI Ukraine — Wed, 27 May 2026 09:27:35 +0000

Parliament passed Draft Law No. 11520 at its second and final reading, harmonizing Ukraine’s public procurement framework with EU directives.

The adoption of the new Law on Public Procurement is, first and foremost, a World Bank requirement for Ukraine to receive its next loan tranche. Full harmonization of procurement legislation with EU directives is also a Ukraine Facility requirement, with a Q3 2027 deadline, and a broader EU integration benchmark.

Before the final vote, important technical amendments were introduced and several potentially corrupt provisions were removed from the text.

“The version adopted today is the result of painstaking work and compromise between EU directives and Ukrainian realities, as well as the interests of various stakeholders. At the same time, we await feedback from the European Commission on the adopted text, which will likely require further refinement,” explains Ivan Lakhtionov, Deputy Executive Director of TI Ukraine for Innovative Projects.

Work on the new law has been underway for quite some time. TI Ukraine’s DOZORRO experts participated in working groups on its development and secured over 40 significant amendments to the document.

The new law will enter into force nine months after publication. Until then, the sector will continue to be governed by Cabinet Resolution No. 1178.

“It is important to understand that today’s work is not finished — this is more of a first step. Beyond the likely European Commission comments, there are a number of provisions in the law that need further refinement, to say nothing of the secondary legislation and technical changes required for implementation,” Lakhtionov added.

The Law on Public Procurement was last comprehensively updated in 2019. Draft Law No. 11520 introduces updated thresholds, new procedures, and an appeals mechanism within Prozorro Market. It combines EU directive requirements with approaches developed during the war, including anti-corruption safeguards in construction.

Earlier, DOZORRO explained how the new law will change public procurement thresholds.

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.

The version adopted today is the result of painstaking work and compromise between EU directives and Ukrainian realities, as well as the interests of various stakeholders

Ivan Lakhtionov

The post Verkhovna Rada Adopts New Public Procurement Law first appeared on Transparency International Ukraine.

Parliament Backs Bill to Join OECD Anti-Bribery Convention

TI Ukraine — Wed, 27 May 2026 08:05:13 +0000

On May 26, 2026, the Verkhovna Rada passed Draft Law No. 15056 as a basis, which enables Ukraine to accede to the OECD Convention.

The bill addresses certain inconsistencies in existing legislation and is a condition for the entry into force of the law on Ukraine’s accession to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Joining the Convention is an important step toward EU integration that will allow Ukraine to become a full OECD member and strengthen international cooperation in corruption investigations. The changes will enable more effective responses to cases of bribery involving both foreign and domestic officials.

However, the draft law’s proposed introduction of “autonomous” criminal liability for legal entities will not, in our view, be fully effective without additional changes. To improve the bill ahead of the second reading, we recommend:

extending the grounds for liability to cover criminal offenses under Article 364 (abuse of power or official position) and Article 191 (misappropriation, embezzlement, or seizure of property through abuse of official position) of the Criminal Code. This is necessary because legal entities are involved in schemes that enable abuse of office and misappropriation;
applying “autonomous” corporate criminal liability also to cases where such offenses are committed against domestic officials. Currently, this mechanism applies only when the misconduct involves officials of foreign states.

We have previously highlighted these shortcomings in the proposed mechanism.

The draft law should accordingly be refined ahead of the second reading to ensure that the national “autonomous” corporate criminal liability framework not only complies with the OECD Convention’s requirements but is also effective in combating corruption involving domestic officials.

The post Parliament Backs Bill to Join OECD Anti-Bribery Convention first appeared on Transparency International Ukraine.

Accession to the OECD Anti-Bribery Convention: Analysis of Draft Law No. 15056

Віка Карпінська — Fri, 22 May 2026 07:36:32 +0000

On March 6, 2026, President of Ukraine Volodymyr Zelenskyy registered Draft Law No. 15056, which concerns Ukraine’s accession to the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. The draft law amends the Criminal Code of Ukraine, the Criminal Procedure Code of Ukraine, and the Law of Ukraine on Corruption Prevention. Once this law takes effect, Ukraine will officially accede to the Convention.

Acceding to this Convention of the Organization for Economic Cooperation and Development (OECD) is one of Ukraine’s key steps toward European integration — one the European Commission also noted in its latest EU Enlargement Report. The Commission observed that, through the law on improving the mechanisms for holding legal entities liable for bribery of foreign officials, Ukraine had already begun aligning its legislation with the Convention’s provisions. The need to strengthen corporate liability for bribery, however, remains.

Aligning national legislation with the Convention’s requirements will also allow Ukraine to become a full member of the OECD and open new channels for close international cooperation in investigating corruption offenses.

On May 7, 2026, the draft law was approved by the relevant Law Enforcement Committee, which recommended that parliament adopt it as a basis and in full, subject to the necessary technical and legal refinements.

Key takeaways:

Adopting the draft law is a prerequisite for Ukraine’s accession to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
The amendments will enable a more effective response to bribery of both foreign and domestic officials.
However, the draft law does not allow autonomous criminal liability of legal entities where domestic officials are bribed, or for offenses under Articles 364 (abuse of office) and 191 (misappropriation of property) of the Criminal Code of Ukraine.

What we propose

Expand the “autonomous” criminal liability of legal entities so that it covers not only proceedings under Articles 369 (bribery of an official), 369-2 (trading in influence), and 209 (money laundering) of the Criminal Code, but also Articles 364 and 191. This “autonomous” liability should also apply where such acts are committed against domestic officials.

Aligning national legislation with the Convention’s requirements will allow Ukraine to become a full member of the OECD and open new channels for close international cooperation in investigating corruption offenses.

The current situation

Even after the amendments introduced by Law of Ukraine No. 4111-IX of December 4, 2024, several problems remain in current legislation that could hinder the effective prosecution of legal entities.

Under Article 96-3(3) of the Criminal Code, which sets out the grounds for applying criminal-law measures to legal entities, a legal entity bears liability after its reorganization only if a natural person was also prosecuted alongside it for bribery (Article 369), trading in influence (Article 369-2), or legalization (laundering) of criminally obtained property (Article 209).
A conflict remains between the definition of officials in Article 18(4) (which defines the special subject of a criminal offense) and paragraph 2 of the Note to Article 364 of the Criminal Code (which gives a special definition of an official), because the latter omits any mention of officials of local self-government bodies and municipal enterprises.
Ukraine can prosecute corruption offenses only against members of international parliamentary assemblies in which it itself participates. It cannot prosecute members of other assemblies for corruption.
Because of an imprecision in Article 309(1)(9-1) of the Criminal Procedure Code, which lists the rulings of an investigating judge that may be appealed, it is currently not expressly permitted to appeal an investigating judge’s ruling that imposes restrictions on a legal entity’s activities.
The Law of Ukraine on Corruption Prevention lacks a definition of an authorized person of a legal entity that is harmonized with the Criminal Code.

Even after the amendments introduced by Law of Ukraine No. 4111-IX of December 4, 2024, several problems remain in current legislation that could hinder the effective prosecution of legal entities.

What does the draft law propose?

The draft law proposes several distinct amendments to the Criminal Code, the Criminal Procedure Code, and the Law of Ukraine on Corruption Prevention that would broaden the scope of liability for bribing officials on behalf of and/or in the interests of legal entities, and would clarify certain imprecisions previously left by the legislator.

Amendments to Article 96-3(3) of the Criminal Code will prevent legal entities from escaping criminal liability through their reorganization, even where law enforcement has been unable to identify the specific individual responsible for bribery (Article 369), trading in influence (Article 369-2), or legalization (laundering) of criminally obtained property (Article 209).
Paragraph 2 of the Note to Article 364 of the Criminal Code would be clarified to add officials of local self-government bodies and municipal enterprises to the list of officials. This would resolve the conflict between paragraph 2 of the Note to Article 364 and Article 18(4), which define this list of officials.
The status of an official under Article 18(4) and paragraph 2 of the Note to Article 364 would be extended even to members of international parliamentary assemblies in which Ukraine does not participate. This would make it possible to prosecute those who bribe such foreign (international) officials with whom Ukraine has no direct connection.
Article 309(1)(9-1) of the Criminal Procedure Code would be clarified to specify that, at the pretrial investigation stage, what may be appealed are an investigating judge’s rulings granting or denying restrictions on a legal entity’s activities — rather than final decisions imposing temporary restrictions on a legal entity’s activities and/or temporary restrictions on the acquisition of rights and/or benefits. This will fix the imprecision previously left by the legislator.
Article 61 of the Law of Ukraine on Corruption Prevention would also add a definition of an authorized person of a legal entity, a concept previously found only in paragraph 1 of the Note to Article 96-3 of the Criminal Code.

Conclusions

We have no substantive objections to the proposals put forward by the authors of presidential Draft Law No. 15056, now before parliament.

However, this draft law could serve as a foundation for a more comprehensive regulation of the procedure for prosecuting legal entities.

TI Ukraine therefore supports the adoption of this draft law, with further refinement to expand the “autonomous” criminal liability of legal entities.

TI Ukraine therefore supports the adoption of this draft law, with further refinement.

The post Accession to the OECD Anti-Bribery Convention: Analysis of Draft Law No. 15056 first appeared on Transparency International Ukraine.