September 1, 2026, marks the 10th anniversary of the institution of electronic asset declaration for public servants in Ukraine. On this exact day, the Unified State Register of Declarations of Persons Authorized to Perform Functions of the State or Local Self-Government (the Register of Declarations) officially launched its operations.
The launch of the electronic declaration system was not merely a transition from paper to digital format. It became an integral part of Ukraine's systemic anti-corruption reform and the fulfillment of the state's international obligations.
Over the decade of its operation, the Register of Declarations has evolved from a database running on rented equipment, launched under severe time and resource constraints, into a powerful, secure digital system with advanced analytical tools that serves as one of the key instruments for financial control and corruption prevention.
Why declare assets
The obligation for public servants to declare assets is enshrined in the UN Convention Against Corruption, as well as documents of the World Bank, the Organisation for Economic Co-operation and Development (OECD), and other international organizations. Asset declaration registers have been established and operate in many countries. And while there is no single universal standard, all such registers serve two primary goals: preventing illicit enrichment and managing conflicts of interest among public servants.
Prior to 2016, public servants in Ukraine submitted paper declarations containing only six sections. Declarations of certain categories of officials were required to be published on the websites of state and local government bodies or in official print publications.
The introduction of electronic declaration fundamentally changed this model: the list of declarable assets and data was significantly expanded, and a publicly accessible unified state register of declarations was created. This not only simplified public access to information regarding officials' assets, income, and financial obligations to facilitate public scrutiny over changes in their financial status, but also laid an unprecedented foundation for the automated analysis of registered data and the further development of the financial control institution itself.
Challenges of the first electronic declaration campaign
The legislative foundation for launching electronic declaration and creating the Register was the Law of Ukraine "On Prevention of Corruption," adopted in October 2014. Subsequently, in March 2015, the National Agency on Corruption Prevention (NACP) was established.
Ukraine had to simultaneously establish a new state body, design a fundamentally novel declaration system for the public service, and ensure its launch within a tight deadline. This took place amidst significant socio-political tension as well as serious institutional and technological challenges.
Due to the NACP's lack of its own IT infrastructure at that time, the Register of Declarations began operating in a remote data centre using rented hardware. The initial launch of the Register on August 15, 2016, occurred without the required security certificate, resulting in temporary suspension of access to the system. Only on August 31 did the system receive the necessary certificate, and at midnight on September 1, the full-scale launch of the Register and the first electronic declaration campaign for the year 2015 officially commenced.
As this was the first interaction with the new system for public servants, the initial phase of declaration demonstrated an immense load on both the Register and NACP staff. Users' technical unpreparedness for the widespread use of electronic digital signatures, alongside continuous cyberattacks and attempts to destabilise the system, required round-the-clock technical support and emergency response from specialised NACP units. The Agency’s team worked virtually around the clock, guiding declarants through the unfamiliar procedure while simultaneously maintaining the operation of the Register itself.
During the second declaration campaign (for 2016), due to operational challenges within the system, the Verkhovna Rada of Ukraine passed Law No. 1975-VIII on March 23, 2017, "On Amendments to Certain Laws of Ukraine Concerning Peculiarities of Financial Control over Certain Categories of Officials." The deadline for this campaign was extended by one month, until May 1, 2017.
Technological modernisation and automation
Given that the annual number of declarants in Ukraine reaches approximately 800,000 people, processing such a vast amount of data required the implementation of innovative technological solutions.
In September 2018, the NACP put into operation the logical and arithmetic control system (LAC)—a tool that allows the Register's software to assess risks in declarations by identifying discrepancies between the information provided in a declaration and data from other registers. Based on the LAC results, a risk rating score is calculated. Declarations with the highest risk rating scores are selected for verification first. Initially, data verification was conducted against data from 10 registers. By December 2019, the Agency had gained automated access to 16 state registers and databases required for such analysis.
That same year, construction began on the NACP's own Data Processing Center (DPC), followed in 2020 by the modernisation of the software and hardware platform. The Register was migrated to the Agency's own servers, which increased its resilience to peak loads, and thanks to the modernisation, it became more user-friendly for declarants and other users.
Trials by constitutional crises
Over 10 years, in addition to technological crises related to the operation of the Register, the anti-corruption system in Ukraine repeatedly faced other critical situations regarding e-declaration and the execution of financial control measures, which resulted in the blocking of key anti-corruption mechanisms.
One of the first such challenges was Decision No. 1-r/2019 of the Constitutional Court of Ukraine, dated February 26, 2019, which declared Article 368-2 of the Criminal Code of Ukraine, providing for criminal liability for illicit enrichment, unconstitutional. As a result, all criminal proceedings under this article were closed.
The solution to overcoming this crisis was Law of Ukraine No. 263-IX, passed by the Verkhovna Rada on October 31 of that same year. It reinstated criminal liability for illicit enrichment by adding Article 368-5 to the Criminal Code.
The next constitutional crisis arose in 2020.
On October 27, the Constitutional Court of Ukraine issued a decision declaring unconstitutional many provisions of the Law of Ukraine "On Prevention of Corruption" that regulated the execution of financial control measures, as well as Article 366-1 of the Criminal Code of Ukraine, which provided for criminal liability for declaring false information. As a consequence, the operation of financial control mechanisms, particularly full verifications of declarations, was blocked, and criminal liability for declaring false information was effectively terminated.
A specific consequence of the Court's decision was the closure of public access to the Register of Declarations. On October 28, the NACP complied with the court decision and closed access to its public section. The judicial decision resulted not only in restricted access to the Register's data, but also in significant risks for public scrutiny over officials' assets, the work of journalists, and anti-corruption organizations.
However, as early as October 30, thanks to the consolidated position of society and international partners, as well as prompt decisions by the President and the Government, access to the public section of the Register was restored pursuant to Order of the Cabinet of Ministers of Ukraine No. 1363-r, dated October 29, 2020.
By the end of 2020, the modernized Register was put into permanent operation.
In December, the Verkhovna Rada of Ukraine also passed Law of Ukraine No. 1074-IX, dated December 4, 2020, which restored criminal liability for declaring false information by adding a new Article 366-2 to the Criminal Code of Ukraine. Subsequently, Law of Ukraine No. 1079-IX, dated December 15, 2020, restored the powers of the NACP, including the conduct of full verifications of declarations.
Challenges of the full-scale invasion
On February 24, 2022, public access to the Register was once again temporarily restricted, this time for security reasons; declaring assets became voluntary, and full verifications were temporarily suspended.
Following the restoration of mandatory declaration—with exceptions for a certain category of declarants—by the Law of Ukraine No. 3384-IX dated September 20, 2023, "On Amendments to Certain Laws of Ukraine Concerning the Procedure for Submitting Declarations of Persons Authorized to Perform Functions of the State or Local Self-Government Under Martial Law," the public section of the Register was made accessible to citizens again on December 10, 2023.
This posed a significant challenge both for declarants, who were required to submit declarations for three reporting periods, and for the NACP, which had to conduct their verifications.
Nearly 1.9 million declarations were submitted to the Register almost simultaneously. On January 1, 2024, full verifications of declarations commenced.
Current state: more automation, less manual work
Today, the Register of Declarations is a high-tech ecosystem integrated with key state databases and digital services.
Despite the difficult conditions brought by martial law, the NACP continuously improves the Register's systemic tools. For instance, in May 2022, the Agency introduced the "Data for Declaration" function, which allows a declarant to pull information from state registers needed to complete the declaration. This marked a new approach to declaring: the state not only monitors compliance with declaration rules, but also assists citizens in fulfilling them correctly.
In March 2024, it became possible to retrieve information regarding declarable assets of family members using the "Diia" application.
The next step in simplifying the declaration process was the implementation of a partial automated pre-filling feature for draft declarations, allowing the system to transfer part of the data stored in state information resources directly into a draft declaration.
Furthermore, the NACP constantly refines its automated declaration analysis tools. The logical and arithmetic control system now functions as a comprehensive risk-oriented tool that helps the NACP process a vast volume of declarations and pinpoint those requiring detailed verification. At the same time, automated analysis does not replace human experts: final conclusions regarding signs of false information, unjustified assets, illicit enrichment, or other violations are drawn based on the results of relevant financial control measures, particularly full verifications of declarations conducted by authorized NACP officials.
Ten years is about more than just technology
Behind the ten years of the Register's operation lie not just servers, software code, or figures in reports. Behind them are hundreds of thousands of public servants who learned to declare their assets, journalists and civic activists who used open data daily, NACP specialists who advised declarants and verified declarations, IT teams who repeatedly saved the system from critical situations, and ultimately, a fundamental shift in the very perception of transparency and accountability in the public service.
