In November 2025, the National Agency on Corruption Prevention (NACP) monitored nearly 400 draft regulatory acts (RA). It conducted an anti-corruption assessment of seven drafts, which identified eight corruption-prone factors and provided ten recommendations for their elimination.
NACP experts identified a number of corruption-prone factors in the draft resolution of the Cabinet of Ministers of Ukraine (CMU) ‘On Approval of the Procedure for the Storage of Assets Taken Over by Asset Recovery and Management Agency.’ (ARMA).
NACP found that the draft regulatory act has vague provisions regarding the grounds for storing different types of assets. In particular, the document does not contain a clear list of conditions for engaging specialized organizations, which means that this procedure will in fact depend on the subjective decisions of ARMA employees.
In addition, the draft does not specify a uniform and transparent mechanism by which ARMA will decide on ordering expert opinions or consultations on assets with specific characteristics, which creates risks of inconsistent application of the rules and possible abuse.
The agency provided a list of recommendations, including establishing clear and comprehensive grounds for applying protective measures to immovable property, detailing the procedure for engaging specialized organizations, and removing provisions that could lead to different interpretations and unfounded decisions. Eliminating these shortcomings is necessary to ensure that the asset storage procedure is transparent, predictable, and protected from corruption risks. ARMA is currently finalizing the draft resolution.
NACP also conducted an anti-corruption review of the draft resolution of the CMU ‘On Approval of the Procedure for Submitting and Considering Applications from Internally Displaced Persons for the Provision of Real Estate for Their Residence, Information About Which is Contained in the Information and Analytical System of Real Estate Objects for Providing Internally Displaced Persons with Housing.’ The identified corruption-prone factors are related to the lack of a transparent procedure for submitting and reviewing such applications, which creates risks of corruption abuses. The NACP provided recommendations for their elimination. The document is currently being finalized by the developer, the Ministry of Development of Communities and Territories of Ukraine.
NACP experts identified another corruption-prone factor in the draft resolution of the Cabinet of Ministers of Ukraine ‘On Amendments to the Procedure for Military Training of Ukrainian Citizens under the Reserve Officer Training Programme.’ It is related to the non-transparent procedure for concluding a contract between a citizen enrolled in reserve officer training and the rector of the higher education institution where reserve officers are trained, or the head of a higher military educational institution (HMEI). There are also no clear requirements for the subject and content of such a contract. The NACP provided the developer of the resolution, the Ministry of Defence of Ukraine, with a recommendation, the implementation of which will ensure a transparent procedure for the military training of reserve officers.
During the anti-corruption review of the draft resolution of the CMU ‘On Amendments to the Specifics of Defence Procurement for the Period of Martial Law,’ experts found that the document uses wording that does not comply with the principle of legal certainty and does not establish clear and comprehensive grounds or criteria for the planning of defence procurement by all state customers in the field of defence. The NACP provided the Ministry of Defence with recommendations to eliminate the corruption factor and promote more effective planning of defence procurement.
