In the third quarter of 2025, the National Agency on Corruption Prevention (NACP) monitored over 1.3 thousand draft normative legal acts (NLAs). 45 draft NLAs underwent anti-corruption expertise, which resulted in the identification of 116 corruption-generating factors and the provision of 147 recommendations for their elimination, most of which were considered by the drafters.
Among the draft NLAs that were subject to anti-corruption expertise, a significant share consisted of documents in the fields of defense, reconstruction, economy, and law enforcement.
Specifically, an anti-corruption expertise was conducted on the draft resolution of the Cabinet of Ministers of Ukraine "On the implementation of an experimental project regarding the procurement of defense goods for the needs of the National Guard by the State Enterprise of the Ministry of Defence of Ukraine 'Defence Procurement Agency'." This draft was developed to increase the efficiency of defense procurement and the quality of supplies for the National Guard of Ukraine through the use of the digital system "DOT-Chain," administered by the Ministry of Defence (MoD).
The NACP identified corruption risks related to possible abuses during the selection of nomenclature, volumes of defense goods, and control by the MoD State Enterprise "Defence Procurement Agency" over contract execution and the targeted use of funds. The NACP provided the Ministry of Internal Affairs with recommendations, the adoption of which will ensure the transparent implementation of the draft NLA.
Expertise was also carried out on the draft resolution of the Cabinet of Ministers of Ukraine "On the implementation of an experimental project on granting the right to use technologies developed within the Ministry of Defence system for scaling up the production of defense goods." The NACP found corruption risks in the part concerning the conclusion of agreements between the MoD and businesses on the use of technologies. For example, the content of notifications and the requirements for them, as well as the methods of their submission, were not clearly defined, which could create opportunities for abuse during their consideration by MoD officials.
Furthermore, one of the criteria for concluding an agreement is the status of a verified supplier of the MoD State Customer Service. However, the draft does not define how the supplier verification takes place or the documents that regulate it, which could create prerequisites for corruption offenses. The NACP recommended that the Ministry of Defence finalize the draft to eliminate corruption-generating factors.
In the draft resolution "Some issues of the State Fund for Regional Development," the Agency found corruption-generating factors in the procedure for the distribution of funds for the implementation of public investment projects. These include:
- the absence of a clear list of directions to which funds can be allocated;
- an untransparent mechanism for the creation and functioning of the commission that evaluates and prioritizes such projects;
- the absence of a clear procedure for forming lists of projects in each region.
The NACP sent recommendations to the Ministry for Communities, Territories and Infrastructure Development of Ukraine regarding the elimination of these corruption-generating factors.
In the draft NLA "On the implementation of an experimental project regarding new construction, reconstruction, capital repair, technical re-equipment of structures, systems, and networks for water supply to settlements," the NACP identified corruption-generating factors that could lead to the untransparency of procedures for the construction, reconstruction, technical re-equipment, etc., of water supply facilities envisioned by the experimental project. The project developer, the State Agency for Restoration and Development of Infrastructure of Ukraine, took into account the Agency's recommendations provided in the anti-corruption expertise conclusion.
At the same time, the National Agency cautioned the developer that using experimental projects as a method of normative regulation creates risks for further corrupt abuses. This is confirmed by the Agency's analytical research, as such projects are implemented outside standard legislative requirements, using simplified procedures.
In addition, in the third quarter of this year, the Government adopted the relevant resolutions, taking into account the NACP's recommendations:
- dated 13.08.2025 No. 971 "Some issues of the State Fund for Regional Development";
- dated 03.09.2025 No. 1073 "On the implementation of an experimental project regarding new construction, reconstruction, capital repair, technical re-equipment of structures, systems, and networks for water supply to settlements."
NACP also conducted an anti-corruption expertise on the draft resolution of the Cabinet of Ministers of Ukraine "On the approval of the Procedure and Methodology for assessing the level of public trust in state bodies that ensure the fulfillment of criminal proceeding tasks." The goal of the project is to create a unified mechanism for systematic public opinion monitoring, increase trust in the bodies conducting criminal proceedings, and ensure effective dialogue with the public.
The following corruption-generating factors were identified: the use of terms that violate the principle of legal certainty and non-compliance with the norms of current legislation regarding the settlement of conflicts of interest.
The Agency provided the developer with a series of recommendations to minimize corruption risks, particularly regarding the introduction of a transparent mechanism for determining the winner and the harmonization of the document's provisions with current legislation concerning the definition of "conflict of interest." The draft NLA is currently being finalized.
You can familiarize yourself with the detailed results of the anti-corruption expertise of NLAs on the NACP website by following the link, or by going to the section "About NACP" – "NACP Activity Results" and clicking on the relevant sub-section.
We remind you that in August, the NACP provided recommendations for eliminating corruption risks in the areas of housing for IDPs, property relations, and the reintegration of defenders.
