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Four years of NACP 2.0: restoration and simplification of the declaration filing process and increase of efficiency of inspections

09.01.2024

Mid-January marks the fourth anniversary of the "rebooted" National Agency on Corruption Prevention (NACP) - NACP 2.0. On January 15, 2020, Oleksandr Novikov took office as the NACP's Head. Accordingly, on January 15, 2024, his powers will be terminated, and a new Head of the National Agency will be elected soon. With this publication, the NACP launches a series of materials on the results of the work of the current NACP team over a four-year period.

One of the main functions of the National Agency is to ensure electronic declaration of public officials and verification of declarations. The Agency worked to improve and simplify the declaration process during 2020-2023, even despite the year-and-a-half-long suspension of mandatory declarations and the ban on inspections caused by the war. All the changes implemented by the National Agency were aimed at facilitating the declaration process and making declarants aware of the key principle that public service and corrupt practices are incompatible.

In 2020, the NACP began to improve the procedure for conducting full audits of declarations and processing their results, and adopted a new version of the relevant Procedure. Transparency in the selection of declarations was ensured and a system of automated distribution of powers between authorized persons to conduct full audits was introduced. The uninterrupted operation of the Register of Declarations was ensured, a new, more convenient declaration form was developed and the rules for its completion and submission were approved for the first time. 

In 2020-2021, there was a fundamental change in the approach to selecting and conducting full audits - the NACP focused on identifying facts of non-declaration of assets rather than errors in declarations. Subsequently, the NACP differentiated between false and inaccurate information in declarations (up to 100 subsistence minimums). The declarations of top officials were selected for full verification: The President of Ukraine, members of the Government, judges of the Constitutional Court of Ukraine, the Supreme Court, MPs, etc. The effectiveness of full audits compared to previous periods has increased from 12% to 25%, meaning that every fourth audited declaration revealed violations that entail criminal or administrative liability.

In 2020, 443 full audits were conducted, which revealed inaccurate information worth UAH 496.4 million. The constitutional crisis caused by the decision of the Constitutional Court of Ukraine No. 13-r dated 10/27/2020 prevented the completion of full audits. 

In 2021, 1,043 full audits were conducted, which revealed inaccurate information worth almost UAH 1.3 billion, of which UAH 810.7 million was in declarations selected based on the results of the improved logical and arithmetic control system. 

In the two months of 2022, before the full-scale invasion of Russia, the NACP completed 124 full audits and found inaccurate information worth more than UAH 600 million. 

Mandatory filing of declarations and full inspections were suspended during the war until October 12, 2023. However, the NACP did not stop its work in this area: it continued to improve the process of filling out and submitting declarations, optimized the process of their verification, introduced a mechanism for automated verification of declarations, etc.

In particular, in 2022, the NACP developed and implemented a special function in the Declaration Register called "Data for Declaration", which allowed declarants to receive free of charge, automatically, in a form adapted to the declaration form, data from six registers to fill in a draft declaration, including income, real estate, cars, and encumbrances.

As part of the implementation of the State Anti-Corruption Program for 2023-2025 (SAСP), the NACP further simplified the declaration filing procedure. In 2023, the NACP managed to increase the amount of information to which it has automated access from 31% to 75% by expanding information cooperation with other agencies. As a result, the amount of data in the "Data for Declaration" function was increased, enabling declarants to obtain information for filling out declarations from 11 registers and databases.

In addition, in 2023, after the renewal of the obligation to declare and the NACP's authority to conduct inspections, there was a conceptual change in the principle of selection and verification of declarations - a risk-based approach was introduced. From now on, the selection for verification and the verification itself are based on the risk assessment calculated using the improved LAC. The declarations with the highest risk rating are selected for full review, while for "non-risky" declarations, which account for about 30% of all submitted declarations, an automated review procedure has been introduced. This approach makes it possible to cover almost all submitted declarations with various financial control tools, and to select declarations with signs of illicit enrichment or unjustified assets for full verification, which should significantly increase the efficiency of full verification of declarations.

Declarations are primarily a tool for ensuring transparency of the authorities, which allows every citizen to observe changes in the property status of officials, analyze this data and, for example, make decisions on electing a deputy to the council in their region. That is why back in September 2022, the NACP declared the need and readiness to open the Register of Declarations for public access. However, only after a lot of work, public pressure and the adoption of the Law of Ukraine on the restoration of mandatory declaration and the NACP's financial control powers, on December 10, 2023, the National Agency was able to open access to the public part of the Register, applying the necessary security measures defined by law.

"As a result of the NACP's proactive actions and effective response to the challenges of time in 2020-2023, the declaration process has become much simpler and clearer, and financial control measures have become more effective," said Artem Sytnyk, Deputy Head of the NACP.

Declaration of income and assets of public officials is one of the most effective ways to ensure public sector accountability and prevent corrupt practices.

Updated explanations on current issues of declaration are available here.

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