Beyond NABU and HACC: Ukraine’s commitments to be met

Recently, three draft laws proposing the approval of the Anti-Corruption Strategy for 2026–2030 were registered in the Verkhovna Rada:

• the main draft, (№15230), submitted by People’s Deputy Anastasiia Radina;
• №15230-1, submitted by the Government;
• №15230-2, submitted by MPs from the “European Solidarity” faction.

They are currently under review by the relevant committees. The future development of state anti-corruption policy for the next five years will largely depend on the final version of the Strategy and how quickly it is adopted.

At the same time, the very need for new anti-corruption measures has not disappeared, as the problems generated by corruption persist.

According to the latest survey by NACP, 72% of the population considers corruption to be a very serious problem. Ukraine scores 36 out of 100 on the Corruption Perceptions Index, lagging behind EU countries, while the level of the shadow economy in the country stands at 31% of GDP.

Is There Progress in Overcoming Corruption?

Against the backdrop of high-profile investigations, it is difficult for the average Ukrainian to assert positive shifts. At the same time, there are arguments testifying to the construction of a system capable of responding to manifestations of bribery. International organizations also pay attention to them.

A few weeks ago, the Organisation for Economic Co-operation and Development (OECD) presented the results of the Anti-Corruption and Integrity Outlook 2026 study, in which Ukraine was comprehensively evaluated for the first time under the Public Integrity Indicators framework.

The report notes that Ukraine’s strategic foundation in the area of anti-corruption and ensuring public integrity is one of the strongest among OECD countries.

Our country ranked among the top three assessed countries in terms of the quality of regulation of lobbying and political finance (control over income and expenditure of funds for parties and electoral activities), as well as judicial integrity.

However, the next stage of reforms should consist not so much in creating new institutions as in ensuring their practical operation, building a culture of integrity, and implementing the principle of integrity by default, where integrity becomes an integral part of the daily operation of state bodies.

What needs to be done to reduce bribery, and what do our international commitments entail in this area?

IMF

The IMF pays special attention to anti-corruption and takes it into account when designing support programs. In December 2025, during the development of a new four-year Extended Fund Facility (EFF) program, the Fund emphasized the importance of a “decisive fight” against corruption in Ukraine, calling it one of the main elements of reforms in the country that will create conditions for preserving state resources, improving the business climate, and attracting larger investments.

The relevant statements were also reflected in the final text of the agreement. Currently, several structural benchmarks being implemented by Ukraine have an anti-corruption focus.

The IMF’s focus in the current program is concentrated on three areas, the execution of which will assist in combating bribery.

The first is strengthening anti-corruption infrastructure and integrity. In this area, there will be a strengthening of the risk-based approach for detecting corruption, a change in the approach to the governance of the National Securities and Stock Market Commission (NSSMC), and staffing reinforcement of the Accounting Chamber.

In particular, the NACP must issue regulatory legal acts streamlining the application of the risk-based approach when verifying asset declarations. This will allow resources to be concentrated on verifying officials with the highest corruption risks, increasing control efficiency and optimizing the Agency’s resource utilization.

Due to leadership changes and the loss of experienced staff, the NSSMC lost part of its capacity to effectively perform its functions. A new law will introduce an updated governance model and the creation of a supervisory board with a majority of independent members.

The composition of the Accounting Chamber, which conducts independent audits of public fund usage, must be reinforced under an updated selection procedure. The Parliament is expected to approve the composition of the Advisory Group of Experts, which will assist in selecting six new auditors.

The second is the reform of the customs and tax systems. In this area, on April 10, 2026, following an open competition, the Government appointed Orest Mandziy as Head of the State Customs Service. On May 14, the new Head launched the recertification process for customs officers to determine their fitness for office and compliance with anti-corruption operational standards.

In addition, the IT systems of the State Tax Service and the State Customs Service are to be consolidated at the Ministry of Finance level in order to cross-check information, identify suspicious transactions, and detect risks.

Furthermore, Ukraine must harmonize its transfer pricing rules with OECD standards and implement the EU Anti-Tax Avoidance Directive (EU ATAD). This will help plug loopholes for aggressive tax planning, profit shifting offshore, and artificial erosion of the tax base.

The third is the corporate governance of state-owned assets. State-owned banks control a significant part of Ukraine’s banking sector and manage billions in state assets.

To minimize political influence over their management, increase the professionalism of supervisory boards, and ensure transparent management of state financial assets, the Government approved a separate resolution improving the nomination process for supervisory board members of state banks.

The new strategy regarding state banks must take into account the changes that have occurred since the start of the full-scale war. One of the key innovations should be extending corporate governance standards currently applied to 100% state-owned banks to all systemically important banks with majority state ownership.

As recent staff-level agreements on the Program review demonstrate, the IMF will continue to seek reforms from Ukraine aimed at strengthening governance and reinforcing anti-corruption institutions.

Ukraine Plan

While the IMF primarily focuses on macro-financial stability and institutional capacity of the state, the Ukraine Plan is effectively a roadmap of reforms accompanying the European Union accession process.

The anti-corruption block holds a special place in this Plan. Its logic is to create a system in which corruption is harder to commit, rather than merely more effectively punished after detection.

We would like to draw attention to how the EU emphasizes anti-corruption policy in the updated indicators of the Ukraine Plan — the largest number of newly added indicators will appear specifically in this sector.

The first direction relates to strengthening the institutional capacity of the anti-corruption infrastructure. The Plan provides for an increase in the judicial staffing of the High Anti-Corruption Court. This decision is of practical importance, as the court’s workload is increasing due to the growing number of proceedings submitted by NABU and SAPO.

The implementation of this indicator has advanced significantly. Following the completion of sessions, the High Qualification Commission of Judges and the Public Council of International Experts admitted 22 candidates to the final stage of the competition, 19 of whom received recommendations for appointment as judges of the High Anti-Corruption Court and its Appellate Chamber. In parallel, the selection of HACC Secretariat staff was underway.

The second block of reforms aims to update the legislative framework of anti-corruption policy. Central to this is the adoption of the new State Anti-Corruption Strategy for 2026–2030 and the State Anti-Corruption Program, which will define specific measures for its implementation.

Simultaneously, the Ukraine Plan provides for changes aimed at increasing the effectiveness of anti-corruption justice. This refers to the reform of the Code of Criminal Procedure, the possibility of single-judge hearings for certain categories of cases by the High Anti-Corruption Court, as well as eliminating procedural barriers to the operation of anti-corruption bodies, in particular by simplifying access to forensic examination results. All these changes are intended to make criminal proceedings more efficient and minimize the risks of judicial delays.

Comparing the indicators of the IMF and the Ukraine Plan reveals a shared logic: the focus is gradually shifting from targeted anti-corruption decisions to building a holistic system of integrity governance based on transparency, digitalization, institutional independence, and effective risk management. It is precisely this approach that defines the quality of public administration in EU countries, and it serves as one of the key benchmarks for Ukraine.

The successful fulfillment of the anti-corruption indicators of the Ukraine Plan and commitments under the IMF program is not merely a technical issue of reforms — it is a matter of international partners’ trust, macro-financial stability, and our European integration.

This publication was made possible with the support of the International Renaissance Foundation within the framework of the project “Economic Recovery Today: Fulfilling Commitments and Shaping the Vision of Ukraine’s Post-War Economy”.