During the first six months of 2026, the National Agency on Corruption Prevention (NACP) monitored 1,882 draft legal acts, including 153 draft laws and 1,729 draft acts of the Cabinet of Ministers of Ukraine and other regulatory instruments.
Based on the monitoring results, the Agency conducted 101 anti-corruption expert assessments, identifying 288 corruption-producing factors and providing 322 recommendations for their elimination. Notably, 99% of the NACP’s recommendations were taken into account by the developers of these legal acts.
The NACP continued to implement a sector-specific approach to developing and deploying state anti-corruption policy. The Agency's efforts focused on identifying and eliminating corruption-producing factors in draft legal acts at the early drafting stage, which prevents corruption risks before such acts come into force.
Social, humanitarian, and recovery sectors
During the first half of 2026, the Directorate for Anti-Corruption Policy Implementation in Recovery, Social, and Humanitarian Sectors monitored 900 draft legal acts and conducted 46 anti-corruption expert assessments, identifying 142 corruption-producing factors and providing 161 recommendations for their elimination.
For instance, during the anti-corruption expert assessment of the draft resolution of the Cabinet of Ministers of Ukraine “On the Implementation of an Experimental Project on the Removal of Trees, Shrubs, and Other Green Visuals Outside Populated Areas”, the Agency revealed several corruption-producing factors.
Specifically, the draft created risks of logging in violation of environmental legislation, lacked an exhaustive list of grounds for removing green visuals, and envisioned an opaque operational mechanism for the commissions responsible for inspecting and deciding on logging viability.
The NACP provided recommendations to the document’s developer — the Ministry of Economy, Environment, and Agriculture of Ukraine — to eliminate the identified risks, and these recommendations were fully adopted. As a result, the Cabinet of Ministers of Ukraine passed a resolution that ensured clear legal regulation for the removal of trees and shrubs outside populated areas and minimised the risks of corrupt practices.
Another example of effective cooperation was the anti-corruption expert assessment of the draft resolution of the Cabinet of Ministers of Ukraine regarding the implementation of an experimental project to provide internally displaced persons (IDPs) with housing in rural areas.
NACP experts established that certain provisions of the document could facilitate corruption due to the absence of digitised procedures for document submission and housing inspection, vaguely defined powers of officials when making decisions to terminate housing use rights, and the lack of a monitoring mechanism to ensure users comply with established requirements.
Following the expert assessment, the Agency provided recommendations to mitigate these risks. The Ministry of Social Policy, Family, and Unity of Ukraine fully incorporated them, after which the Government adopted the corresponding resolution.
Economic and law enforcement sectors
Within the framework of monitoring draft legal acts, the Directorate for Anti-Corruption Policy Implementation in Economic and Law Enforcement Sectors analysed 807 draft legal acts and conducted 37 anti-corruption expert assessments, identifying 86 corruption-producing factors and providing 101 recommendations for their elimination.
In particular, the NACP identified several corruption-producing factors during its expert assessment of the draft resolution of the Cabinet of Ministers of Ukraine “On Amending the State Ownership Policy”, which envisioned the introduction of a Model Charter for a fuel and energy sector corporate entity in which the state owns more than 50% of shares.
The Agency provided recommendations to the Ministry of Economy to eliminate the duplication of functions between the supervisory board and the head of the legal entity or its founders. Recommendations were also given on clearly defining which corporate body holds the authority to appoint the anti-corruption officer responsible for implementing the anti-corruption program. All recommendations were taken into account by the developer, which will facilitate the implementation of international standards of corporate governance, integrity, and responsible business conduct in line with the Organization for Economic Co-operation and Development (OECD) guidelines and the UN Guiding Principles on Business and Human Rights.
The NACP also conducted an anti-corruption expert assessment of the draft Law of Ukraine “On Amending the Criminal Procedure Code of Ukraine to Improve Guarantees for the Protection of Business Entities During Criminal Proceedings” (No. 12439).
During the analysis, the Agency identified three key corruption risks:
The first risk concerns the lack of legal certainty in the proposed amendments to Article 214 of the Criminal Procedure Code of Ukraine. The bill effectively grants investigators, inquiry officers, and prosecutors discretionary powers to independently assess the sufficiency of data required to enter information into the Unified Register of Pre-Trial Investigations (ERDR). This could lead to the selective registration of criminal offence reports.
The second risk is linked to the proposed Article 41-1 of the Criminal Code of Ukraine, which allows for the exemption of a person from criminal liability for actions committed based on clarifications issued by central executive authorities. At the same time, the bill fails to define the authorised entities, the procedure, or the timeframes for providing such clarifications, nor does it establish criteria for assessing their lawfulness. This creates loopholes for using them as a tool to evade criminal liability. The NACP noted that while the core idea of introducing such a provision is acceptable, the mechanism for its implementation requires substantial refinement.
The third risk relates to the proposed special procedure for entering information into the ERDR by the head of a prosecution body in cases involving crimes in the sphere of economic activity. This could result in inconsistent law enforcement and create risks of excessive discretion.
In addition, the NACP pointed out that the bill significantly narrows the grounds for conducting an urgent search, failing to cover several corruption offences that carry a comparable level of public danger. The absence of a clear criterion for compiling this list indicates that the proposed changes are unsubstantiated.
To assist in refining draft law No. 12439 ahead of its second reading, the NACP has forwarded its recommendations to the Verkhovna Rada Committee on Law Enforcement and the Verkhovna Rada Committee on Anti-Corruption Policy.
Четвертий блок перекладу присвячений оборонному сектору. Тут критично важливо чітко перекласти назви міжнародних угод («Угода про Позику»), урядових програм та специфічних установ (як-от «Агенція оборонних закупівель»).
Переклад виконано з дотриманням усіх попередніх вимог щодо стилю, термінології та правильних лапок.
Security and defense sector
Within the framework of monitoring draft legal acts in the field of security and defense, the NACP analysed 175 draft legal acts and conducted 18 anti-corruption expert assessments, identifying 60 corruption-producing factors and providing 60 recommendations for their elimination.
In particular, the Agency monitored the draft resolution of the Cabinet of Ministers of Ukraine “Certain Issues of Implementing the Loan Agreement for the Support of Ukraine Regarding Provision of Assistance Aimed at Supporting the Defense-Industrial Capacity of Ukraine”. The analysis revealed corruption-producing factors that could have led to the establishment of an opaque procedure for utilising international financial assistance.
During the monitoring process, the NACP established that the draft Procedure for Cooperation between the Ministry of Defense of Ukraine, central executive authorities, bodies of the security and defence sector, and the state enterprise of the Ministry of Defense of Ukraine “Defense Procurement Agency” failed to define a clear procedure for forming an indicative allocation of funds and resources among the security and defence sector bodies.
Specifically, the document lacked the grounds and criteria for making decisions regarding this allocation, which created risks of a subjective approach and violated the principle of legal certainty. Furthermore, since proposals for procurement lists and volumes could only be submitted within the limits of the defined indicative allocation, certain provisions of the draft effectively granted officials of the Ministry of Defense excessive discretionary powers. The draft also failed to specify clear procedures and deadlines for submitting these proposals, which could have resulted in inconsistent application of its provisions.
Following the expert assessment, the NACP provided recommendations to eliminate the identified risks. After the coordination procedures, the Ministry of Defense fully incorporated them, thereby ensuring clear legal regulation of the procedures for implementing the Loan Agreement and minimising the risks of opaque administrative decision-making.
The NACP also conducted an anti-corruption expert assessment of the draft resolution of the Cabinet of Ministers of Ukraine “Certain Issues of International Transfers of Goods During the Period of Martial Law”.
The analysis revealed eight corruption-producing factors that created risks of an opaque mechanism for the international transfer (export) of military goods and dual-use items under the legal regime of martial law.
In particular, these factors concerned the ambiguity of the procedure for obtaining permits for international transfers of goods, the non-compliance of certain provisions of the draft with the requirements of the Law of Ukraine “On State Control Over International Transfers of Military and Dual-Use Goods”, as well as the risks of varying interpretations of the rules and selective application of the document’s provisions.
To eliminate the identified risks, the NACP provided eight recommendations to the Ministry of Defense, which were fully taken into account during the revision of the draft resolution.
