One of the financial control measures carried out by the National Agency on Corruption Prevention (NACP) is verifying the timeliness of declaration submissions by declarants.
During the first half of 2025, the National Agency received about 9.5 thousand notifications regarding cases of non-submission or late submission of declarations following the 2024 declaration campaign.
The leading institutions with the highest number of non-submitted or late-submitted declarations were:
- Local self-government bodies – 22%;
- National Police of Ukraine – 21%;
- Ministry of Defense of Ukraine – 10%;
- State Criminal-Executive Service – 8%;
- State Emergency Service – 8%;
- State Tax Service – 6%;
- Courts and other judicial bodies – 5%;
- State Agency of Forest Resources – 4%;
- Regional State Administrations – 3%;
- Ministry of Justice of Ukraine – 3%.
These notifications are submitted to the NACP within the procedure of verifying the timeliness of declaration submission, as provided by Article 51-2 of the Law of Ukraine “On Prevention of Corruption,” which is implemented in several stages:
- State authorities, local self-government bodies, enterprises, and institutions check whether their employees — former or current, members of competition commissions, or members of the Public Integrity Council — have submitted declarations.
- The authorized anti-corruption units of these institutions inform the NACP about identified cases of non-submission or late submission of declarations.
- NACP examines the information received from authorized units and takes measures to hold officials accountable for non-submission or late submission of a declaration.
Violations of declaration requirements entail administrative and criminal liability:
- For late submission of a declaration without valid reasons, administrative liability is imposed (Part 1, Article 172-6 of the Code of Ukraine on Administrative Offenses) — a fine of 50 to 100 non-taxable minimum incomes of citizens.
- For deliberate non-submission of a declaration, criminal liability applies (Article 366-3 of the Criminal Code of Ukraine). This offense is punishable by a fine of 2,500 to 3,000 non-taxable minimum incomes of citizens, or community service from 150 to 240 hours, or restriction of liberty for up to two years, or imprisonment for up to one year. The court may also prohibit the person from holding certain positions or engaging in certain activities for up to three years.
In addition, a court decision entails entering information about the person into the Unified State Register of Persons who Committed Corruption or Corruption-Related Offenses (Register of Offenders).
NACP emphasizes: a significant number of notifications about cases of non-submission or late submission of declarations may indicate insufficiently effective work of authorized anti-corruption units. The number of such cases can be reduced if employees — both current and former — are timely informed and provided with necessary advice and assistance.
The Agency also notes that some notifications from authorized units are unfounded. This applies to cases where:
- The employee had the legal right to postpone submission of the declaration;
- The person in question is deceased;
- The declaration was in fact submitted on time;
- The employee is not a declarant and is not obliged to submit a declaration;
- The case concerns a “candidate for position” declaration;
- The case concerns a “dismissal declaration” (when a person was dismissed through transfer, or appointed within 30 days to a new position that also requires declaration submission).
The NACP calls on authorized anti-corruption units to apply the law correctly and to send notifications to the Agency only when there are valid grounds.
