The focus of the work of the National Agency on Corruption Prevention (NACP) in the security and defence sector is a systematic approach to strengthening the integrity of the sector through the implementation of international security and defence standards, minimization of corruption risks, elimination of corruption-enabling factors based on the results of anti-corruption expertise of draft regulatory legal acts (RLAs), as well as coordination and provision of methodological assistance to authorized units (authorized persons) for the prevention and detection of corruption in the security and defence sector.
An important component of NACP’s sectoral approach is the implementation of NATO recommendations provided within two flagship projects of the NATO Comprehensive Assistance Package for Ukraine: the NATO Initial Interoperability Requirements for Ukraine (NATO Initial Requirements) and the Strategic Review of Ukraine’s defence procurement system (Strategic Review), aimed at bringing Ukraine closer to the standards of NATO member states.
Throughout 2025, the Department for Integrity Policy Development in the Security and Defence Sector (the Department):
- jointly with security and defence sector bodies, the Government Office for Coordination of European and Euro-Atlantic Integration, and the NATO Representation to Ukraine, developed a unified action plan for the implementation of tasks defined by NATO Initial Interoperability Requirement 0204 “Building Integrity” of the NATO Initial Requirements (Initial Requirement 0204);
- took measures to organise the implementation process of the Strategic Review;
- conducted the study “Corruption Risks in the Procurement of Unmanned Systems and Electronic Warfare Means for the Armed Forces of Ukraine,” which identified 19 corruption risks and provided 50 recommendations for their mitigation.
To coordinate efforts in this area, the Department:
- with the participation of representatives of security and defence sector bodies, civil society, and international partners, including NATO Headquarters, the NATO Representation to Ukraine, the Centre for Integrity in the Defence Sector (CIDS) at the Ministry of Defence of Norway, and the Geneva Centre for Security Sector Governance (DCAF), organised and held more than ten public events on building integrity in the security and defence sector;
- developed a draft of the final performance indicators for the implementation of Recommendations Nos. 13–17 of the Strategic Review, for which NACP has been designated as responsible;
- ensured coordination of the activities of public authorities and the implementation of tasks предусмотрені Initial Requirement 0204.
Considering the defined vector of work, it is the coordinated efforts of the Department together with security and defence sector bodies, in cooperation with international partners, that enable the achievement of the set goals, in particular about attaining Ukraine’s interoperability with NATO in the area of building integrity.
“Therefore, we are working to create a community of authorized units (authorized persons) for the prevention and detection of corruption in the security and defence sector, which will become a platform for implementing unified approaches to building integrity in this area, in particular during the assessment of corruption risks, the development of tools for exchanging practical experience, and the search for joint solutions in the implementation of anti-corruption mechanisms,” notes Marta Ivashkiv, Head of the Directorate of Integrity Policy Making in the Security and Defence Sector.
According to NACP Deputy Head Serhii Hupiak, strategic analysis of corruption risks also remains an effective mechanism for preventing corruption in the security and defence sector.
In 2025, with consultative and financial support from the Centre for Integrity in the Defence Sector (CIDS) at the Ministry of Defence of Norway and the NATO Representation to Ukraine, the NACP conducted and publicly presented the study “Corruption Risks in the Procurement of Unmanned Systems and Electronic Warfare Means for the Armed Forces of Ukraine.” The study identified 19 corruption risks, including the granting of excessive discretion to officials when determining procurement needs for unmanned aerial vehicles (UAVs) and electronic warfare (EW) systems without considering data on their effectiveness on the battlefield; the absence of unified requirements for counterparty due diligence; an imperfect pricing mechanism; uncertainty regarding quality control procedures for UAVs and EW systems; and the lack of oversight over the write-off and loss of UAVs by military units. In addition, the study contains a section devoted to problematic aspects arising during the provision of international military assistance to Ukraine. NACP’s recommendations on minimising corruption risks in the procurement of UAVs and EW systems for the Armed Forces of Ukraine were, among other things, submitted to the Ministry of Defence.
“NACP will continue its work on identifying and eliminating corruption risks in the sector. One of the key tasks for the Department for Integrity Policy Development in the Security and Defence Sector in 2026 is to conduct, jointly with key stakeholders and with the support of international partners, a comprehensive study of corruption risks in the protection of critical infrastructure facilities and the construction of military engineering and fortification structures. A focused approach to identifying and assessing corruption challenges in the security and defence sector and developing risk mitigation measures contributes to strengthening the anti-corruption architecture of the security and defence sector,” Serhii Hupiak noted.
He emphasised that an effective instrument enabling the NACP to carry out systematic and comprehensive monitoring of corruption risks in the security and defence sector is the anti-corruption review of draft regulatory legal acts (RLAs). The results of anti-corruption reviews help to preliminarily identify areas requiring improvement and, in particular, are considered when conducting strategic analysis of corruption risks in this sector.
Thus, in 2025, the Department monitored some draft RLAs in the security and defence sector, including more than 300 submitted for consideration by the Cabinet of Ministers of Ukraine (CMU) and more than 140 submitted for consideration by the Verkhovna Rada of Ukraine (VRU). Based on the results of the analysis, 44 anti-corruption review opinions were prepared, 88 corruption-enabling factors were identified, and 89 recommendations for their elimination were provided to the developers of draft RLAs.
Anti-corruption reviews in the security and defence sector covered, among other things, the regulatory framework governing military medical examinations (MME). While reviewing the draft CMU resolution “On the implementation of an experimental project on organising medical and military medical examinations for members of the defence forces and security forces undergoing long-term treatment in foreign healthcare institutions,” the NACP provided proposals that made it possible to regulate the remote MME procedure and significantly reduce the risks of abuse. At the same time, during the analysis of amendments to the procedure for medical examinations of service members of the security and defence forces, the Agency identified a corruption-enabling factor related to the unclear definition of healthcare institutions authorised to adopt MME decisions, which created conditions for excessive discretion.
The NACP also conducted an anti-corruption review of the draft CMU resolution “On the implementation of an experimental project on the procurement by the state enterprise of the Ministry of Defence of Ukraine ‘Defence Procurement Agency’ of defence-related goods for the needs of the National Guard” using the digital system “DOT-Chain.” The document revealed corruption risks related to potential abuses in forming the nomenclature and volumes of procurement, as well as insufficient clarity of mechanisms for monitoring contract performance and the targeted use of funds.
An anti-corruption review was conducted of the draft CMU resolution “On the implementation of an experimental project granting the right to use technologies developed within the system of the Ministry of Defence for scaling up the production of defence-related goods.” The analysis identified corruption risks in the area of concluding contracts between the Ministry of Defence of Ukraine and business entities, which required additional regulatory clarification to prevent conflicts of interest and abuses.
During the anti-corruption review of the draft CMU resolution “On amendments to the specifics of defence procurement during the period of the legal regime of martial law,” the use of wording that did not comply with the principle of legal certainty and lacked clear and exhaustive criteria for procurement planning by all state customers in the defence sector was identified.
The NACP submitted recommendations to the developers of draft RLAs in the security and defence sector to eliminate corruption-enabling factors. The rate of consideration of these recommendations in 2025 was 100%, indicating their practical relevance and applied nature.
At the same time, the Department ensures coordination and provides methodological assistance on the identification by bodies within the security and defence sector of corruption risks in their activities and the implementation of measures to eliminate them, including the preparation and implementation of anti-corruption programs and, accordingly, the approval of the developed anti-corruption programs.
In particular, priority projects for 2026, aligned with NATO objectives, include improving the process of corruption risk management in the security and defence sector and developing a Model Code of Integrity for security and defence sector bodies.
The defined priority areas of NACP’s work in the security and defence sector, as well as the results of anti-corruption reviews and strategic analysis of corruption risks, are also directly aimed at enhancing the institutional capacity of authorized units (authorized persons) for the prevention and detection of corruption in the security and defence sector, unifying approaches to corruption risk management, and improving the process of preparing anti-corruption programs.
“As the coordinator for Ukraine–NATO cooperation, the NACP ensures a comprehensive approach to the implementation of international standards in the security and defence sector. Our goal is to develop a unified integrity-building strategy and effective anti-corruption tools for the entire defence sector. Ongoing cooperation with international partners, security and defence sector bodies, and civil society accelerates Ukraine’s Euro-Atlantic integration and increases the effectiveness of the state's anti-corruption policy. The activities of our Department are also focused on identifying and assessing corruption risks in the security and defence sector, which enables the implementation, together with stakeholders, of effective measures that create a robust corruption prevention system,” emphasises Marta Ivashkiv.
