The National Agency on Corruption Prevention (NACP), by Order No. 260/25 dated September 1, 2025, which came into force on October 14, 2025, approved changes to the procedure for conducting a full audit of the declaration of a person authorized to perform state or local government functions (hereinafter – the Procedure).
Changes to the terms “false” and “inaccurate” information
The amounts of information in the declaration that do not correspond to reality have been standardized in the terms “false information in the declaration” and “inaccurate information in the declaration” as defined in the Procedure, as well as the thresholds of false information that entail administrative and criminal liability.
Now, information in a declaration is considered false if it differs from the accurate information by an amount exceeding 150 subsistence minimums (SM) for able-bodied persons established on the date of submission of the declaration, and/or if it contains information that does not allow identifying a family member of the declarant or the declared object. Information in a declaration that differs from the accurate information by an amount not exceeding 150 SM is considered inaccurate.
As a reminder, with the entry into force of the Law of Ukraine No. 4496-IX dated June 17, 2025, “On Amendments to the Code of Administrative Offenses of Ukraine, the Criminal Code of Ukraine, the Criminal Procedure Code of Ukraine, and Other Legislative Acts of Ukraine Regarding Increased Liability for Corruption-Related Offenses,” the threshold of false information subject to administrative liability was increased from 100 to 150 SM, and for criminal liability – from 500 to 750 SM.
New grounds for suspension and termination of full declaration audit
NACP has improved the procedure for conducting full declaration audit, focusing on ensuring the declarant’s right to provide explanations during the audit, and has introduced additional grounds for suspending and terminating a full audit.
Now, a full audit of declarations submitted by persons serving in the military during mobilization, including reservists or those under contract during a special period (except for persons specified in points 1–3 of part 7 of Article 45 of the Law of Ukraine “On Prevention of Corruption”), is suspended until these circumstances cease or martial law is lifted.
Grounds for terminating an audit without approving the results now include a record of the declarant’s death in the State Civil Registry and the presence of information about the person in the Unified Register of Persons Missing under Special Circumstances.
Procedure for protecting declarants’ rights outside the court process
The Procedure has been supplemented with provisions regulating the recognition of a declaration that underwent a full audit as one that was not checked.
If a person whose declaration underwent a full audit believes they were not required to submit such a declaration, or that the declaration should not have been subject to a full audit for other reasons, they may submit a corresponding application to NACP (in paper or electronic form) with supporting documents (copies). The requirements for the application and attachments are defined in the Procedure.
The application is reviewed within 30 calendar days. If approved, the certificate of the full audit results is removed from the official NACP website, meaning the declaration is recognized as not having been checked. A substantiated conclusion on established signs of violations drawn up based on such an audit is revoked. The applicant is notified in case of refusal.
Balance of transparency and data protection
To maintain a balance between the transparency of NACP’s activities and the protection of declarants’ rights, the Procedure now specifies that a certificate of the results of a full declaration audit, removed from the public part of the Declaration Register, shall not be published on the official NACP website during the period of removal.
As a reminder, the list of persons whose full audit have been initiated, as well as the results of the audit, can be found here.
