According to the results of the Organisation for Economic Co-operation and Development (OECD) assessment within the fifth round of monitoring of the Istanbul Action Plan, Ukraine has demonstrated significant progress in the area of ‘Specialised Anti-Corruption Bodies,’ receiving 92.7 points out of 100. This is one of the highest scores among all participants and a noticeable increase compared to the previous result (78.6 points in 2023).
The report notes that Ukraine has established a comprehensive anti-corruption structure to detect, investigate and prosecute high-level corruption. The National Anti-Corruption Bureau of Ukraine (NABU) investigates corruption offences committed by high-ranking officials, the Specialised Anti-Corruption Prosecutor's Office (SAPO) conducts procedural management and supports public prosecution, and the High Anti-Corruption Court (HACC) administers justice in relevant cases.
The monitoring team noted that the legislation clearly defines the jurisdiction of NABU and prohibits the transfer of proceedings under NABU's jurisdiction to other authorities. At the same time, the OECD recommends strengthening the practical implementation of these rules.
An important achievement during the reporting period was the strengthening of the independence of the SAPO through its separation as a separate legal entity under public law.
Compliance with the criteria for selecting the head of the anti-corruption investigative body, NABU, was also noted: the legislation establishes the stages of the competition, information about them is open, announcements are published online, any candidate who meets the requirements can participate, and the selection is based on professional experience, skills and integrity.
Progress has also been noted in meeting the criteria relating to the functioning of the body responsible for identifying, tracing and managing assets derived from corruption and other crimes. The National Agency of Ukraine for the Identification, Investigation and Management of Assets Derived from Corruption and Other Crimes (ARMA), which is responsible for these functions, plays an important role in international cooperation, assisting foreign authorities in the search for and recovery of assets.
Ukraine also meets the requirements for publishing detailed statistics on the work of anti-corruption bodies, from the number of criminal proceedings to cases referred to court, broken down by level and type of position.
The report outlines areas that need further strengthening. In particular, ensuring NABU's access to timely and impartial forensic examinations and independent information gathering tools; improving procedures for resolving disputes over jurisdiction; and strengthening the independence and transparency of ARMA's activities.
The only area where Ukraine currently shows low scores is ‘Accountability for corruption offences’ — 39.1 points out of 100 (compared to 34.2 points in 2023).
The monitoring team notes the consistency of the practice of bringing to justice for active (offering, promising or providing an undue advantage to a public official) and passive bribery (acceptance of an offer, promise or receipt of an undue advantage by a public official) in the public sector, abuse of influence, cases of abuse of influence, illegal enrichment, as well as the practice of recognising assets as unjustified and confiscating them as state revenue.
Ukraine collects and publishes statistical information on the prosecution of corruption and corruption-related offences, including the number of criminal proceedings, the number of cases referred to court, the number of cases resulting in a conviction, and the types of penalties imposed. At the same time, the OECD recommends establishing more comprehensive accounting and publication of data on the application of confiscation measures.
A separate achievement during the reporting period is the improvement of mechanisms for holding legal entities accountable for corruption offences. The OECD calls for continued work in this area, as well as for strengthening confiscation tools and ensuring that the time limits for their application do not prevent the recovery of proceeds from corruption.
It should be noted that the assessment focused on Ukraine's system for preventing and combating corruption in nine key areas: ‘Anti-corruption policy’, ‘Conflict of interest and asset declaration’, ‘Whistleblower protection’, ‘Business integrity’, ‘Transparency of public procurement’, ‘Independence of the judiciary,’ ‘Independence of the prosecution service,’ ‘Specialised anti-corruption bodies,’ and ‘Accountability for corruption offences.’
A distinctive feature of the fifth round was the use of performance indicators defined in the Monitoring Methodology. Compliance criteria based on international standards and best practices are used to assess the achievement of indicators, and also include recommendations provided by the OECD during the previous monitoring round. This assessment system ensures the objectivity, consistency and transparency of conclusions.
Information on Ukraine's progress in the areas of anti-corruption policy, conflict of interest and asset declaration, whistleblower protection, business integrity, transparency of public procurement, independence of the judiciary, and independence of the prosecution service is available on the NACP website.
The full text of the report on the results of the fifth round of monitoring of the Istanbul Anti-Corruption Action Plan is available at the link.
