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Anti-Corruption Expertise: NACP Provided Recommendations to Eliminate Corruption Risks in the Areas of Housing for Internally Displaced Persons, Property Relations and Reintegration of Defenders

16.09.2025

In August 2025, the National Agency on Corruption Prevention (NACP) monitored 400 draft normative-legal acts (NLAs). Anti-corruption expertise was conducted for 14 draft NLAs. As a result, 46 corruption-prone factors were identified in the draft NLAs, and 62 recommendations were provided for their elimination.

In the draft Cabinet of Ministers of Ukraine resolution “On Approving the Procedure for Providing Assistance for the Purchase of Residential Real Estate for Internally Displaced Persons (IDPs) from Temporarily Occupied Territories,” NACP identified a number of corruption-prone factors, including:

  • a non-transparent procedure for the creation and operation of the Commission on Providing Assistance for Housing Acquisition for IDPs from temporarily occupied territories;
  • the absence of a clearly regulated procedure for providing assistance to IDPs for housing acquisition, which may create difficulties for service recipients and increase the risks of corruption or unjustified refusals.

NACP sent recommendations to the Ministry of Community Development and Territories of Ukraine to eliminate these corruption risks.

Following the anti-corruption expertise of the draft Cabinet of Ministers resolution “On Amendments to the Regulation on the Cabinet of Ministers of Ukraine Award for the Development and Implementation of Innovative Technologies,” NACP found that the competitive selection procedure for the award is non-transparent, creating risks of corruption.

NACP provided recommendations to the Ministry of Education and Science of Ukraine, the document’s developer, whose implementation will help eliminate these corruption risks.

Anti-corruption expertise of the draft Cabinet of Ministers resolution “On Approving the Procedure for Transferring State and Communal Property under the Right of Usufruct and Monitoring Its Use” revealed corruption-prone factors related to uncertainties in the procedures for submitting applications and monitoring the use of property under usufruct (a real right to use another’s property with the right to collect income from it, provided its integrity and operational purpose are preserved). Specifically:

  • granting excessive discretionary powers to authorized bodies (the ability to request additional documents from applicants not provided for in the draft NLA);
  • officials of authorized bodies can independently determine “other control measures” over property use, creating risks of unjustified refusals to transfer property or terminate its usufruct rights.

NACP provided several recommendations to reduce corruption risks and ensure transparent rules for transferring state and communal property, including:

  • removing ambiguous wording from the NLA;
  • defining an exhaustive list of documents required for property transfer;
  • establishing clear control boundaries.

The procedure for transferring state and communal property under the right of usufruct and monitoring its use was approved by the Cabinet of Ministers of Ukraine resolution No. 1103 of 08.09.2025, taking all NACP recommendations into account.

NACP also conducted anti-corruption expertise of the draft Cabinet of Ministers resolution “On Amendments to the Procedure for Conducting Recovery (post-isolation, reintegration) Measures, Adaptation, and Support (Assistance) for Persons Deprived of Personal Freedom Due to Armed Aggression Against Ukraine After Their Release.”

The draft resolution aims to provide released persons with medical examinations, social and administrative services, and necessary anti-epidemic measures to restore their health.

A number of corruption-prone factors were identified:

  • absence of a clear mechanism to control compliance of reintegration centers with established requirements and undefined consequences for non-compliance;
  • the provision “reintegration centers of other components of Ukraine’s security and defense sector” is not regulated;
  • there is a risk of abuse by other components of the security and defense sector when reimbursing costs related to reintegration and recovery measures for released persons.

NACP provided the Ministry of Defense of Ukraine (MoD) with the necessary recommendations, which were fully incorporated into the Cabinet of Ministers resolution No. 940 of 06.08.2025.

 

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