In 2025, the National Agency on Corruption Prevention (NACP) fully transitioned to implementing anti-corruption policy through a sectoral approach. This involves a comprehensive, cross-sectoral analysis of specific areas of public policy, accounting for the interconnections between regulatory frameworks, management decisions, and their practical application.
«The sectoral approach entails the integrated and interconnected application of NACP powers, such as the strategic analysis of corruption risks, anti-corruption expertise of draft and existing legal acts, and work with anti-corruption authorized units and anti-corruption programs. This approach allows us to move away from the fragmentary detection of violations toward systemic preventive anti-corruption efforts within specific sectors. It enables the identification of corruption risks and their root causes, assessment of the cumulative systemic impact of legal acts and management decisions on state processes, and the formulation of targeted recommendations to minimize risks. These recommendations assist both anti-corruption officers in their activities and agencies in drafting their anti-corruption programs,» explained Serhii Hupiak, Deputy Head of the NACP.
In 2025, the NACP's analytical and expert focus remained on sectors critical to national resilience.
Socio-Humanitarian Sphere and Recovery
Throughout 2025, the NACP Directorate for the Implementation of Anti-Corruption Policy in the Recovery and Socio-Humanitarian Spheres monitored 2,165 normative legal acts and prepared 69 anti-corruption expertise reports, identifying 174 corruption-producing factors.
Anti-corruption expertise covered the regulation of several socially sensitive areas. In particular, the NACP contributed to eliminating corruption-producing factors in normative legal acts regarding:
- Lump-sum financial assistance in the event of the death of a volunteer: Identified risks were related to the possibility of commission members intentionally delaying decision-making.
- Provision of housing for family-type children's homes, orphans, and children deprived of parental care: NACP recommendations eliminated potential abuses during the distribution of state housing assistance.
- Subventions for creating modern educational spaces in general secondary education institutions: Risks regarding the non-transparent identification of subvention recipients and unregulated procedures for its redistribution were eliminated.
- Placement of electronic communication facilities and structures on land plots and other real estate property of state and communal ownership during martial law: Risks were identified that could have led to uncontrolled logging on high-value lands, falsification of object condition assessments, and the use of "technical impossibility" as a formal ground for refusing to conclude agreements.
- Uncontrolled logging on agricultural lands classified as high-value: The proposed logging procedure created conditions for abuse through the potential manipulation of the designated purpose of the logging activities.
Based on the results of this work, the NACP provided 238 recommendations to the developers of legal acts to eliminate potential corruption abuses, 98% of which were considered.
The results of anti-corruption expertise were considered during the strategic analysis of corruption risks within the sector.
Specifically, in collaboration with the State Audit Service of Ukraine and the Basel Institute on Governance, with support from Switzerland, the Agency prepared a study titled “Corruption Risks during the Construction, Reconstruction, and Capital Repair of Civilian Objects for the Recovery of Ukraine.” The analysis demonstrated that a significant portion of the risks are systemic in nature and are caused by fragmented legislation, the lack of unified rules for selecting recovery objects, weak independent control, and insufficient digitalization of processes.
Together with the Specialized Environmental Prosecutor's Office of the Prosecutor General's Office, the Basel Institute on Governance, and WWF-Ukraine, the Agency prepared a study titled "Corruption Risks in Forestry." Within the study, 12 corruption risks were identified that could facilitate offences during logging, timber sales, and state supervision (control) activities. These include potential corruption abuses during changes to the designated purpose of forest plots, their provision for long-term temporary use, determining timber quality classes, timber transportation, and conflicts of interest among officials performing state forest guard functions.
Furthermore, the NACP verified the status of implementation of recommendations to eliminate corruption abuses in the system of the Medical and Social Expert Commission, which were proposed in November 2024 and provided to the Cabinet of Ministers of Ukraine, the Ministry of Health of Ukraine (MOH), and the relevant committee of the Verkhovna Rada. The analysis, conducted based on information from the MOH and non-governmental organizations, showed that despite the implementation of some measures, several recommendations require additional regulatory and organizational decisions, particularly regarding the update of health assessment rules, refinement of digital systems, and increased transparency in the work of expert teams.
Economy and Law Enforcement Sphere
The Directorate for the Implementation of Anti-Corruption Policy in the Spheres of Economy and Law Enforcement, as part of its monitoring of legal acts, analysed 1,820 normative legal acts, conducted 47 anti-corruption expertises of normative legal acts, and 1 anti-corruption expertise of an existing legal act. In particular, the anti-corruption expertise covered the regulation of:
- assessing the level of public trust in bodies conducting criminal proceedings;
- activities of the Public Control Council under ARMA;
- authorization for conducting customs brokerage activities;
- procedures for providing grants to businesses.
At the request of the Ministry of Justice of Ukraine, the NACP conducted an anti-corruption expertise of the Law of Ukraine “On Bodies of Self-Organization of Population (OSN),” which identified corruption-producing norms related to the lack of clarity in the procedure for creating and operating OSNs and their potential dependence on local self-government bodies. The NACP's recommendations were fully considered by the Ministry of Justice when forming its position.
Within the framework of anti-corruption expertise of draft and existing legal acts in the field throughout the year, NACP specialists identified 106 corruption-producing factors and provided 132 recommendations, 99% of which were adopted.
The Agency also prepared two comprehensive studies of corruption risks: in the field of justice and during the reform of customs authorities.
The analytical study “Corruption Risks in the Field of Justice,” implemented jointly with experts from the OSCE project in Ukraine, is based on a systemic analysis of legislation, judicial procedures, and the practices of judicial governance bodies. The study identified 10 key corruption risks, particularly those related to the selection, qualification assessment, and disciplinary liability of judges, their secondment and appointment to administrative positions, as well as the regulation of conflicts of interest and recusal procedures.
The study “TOP 10 Corruption Risks in the Reform of Customs Authorities” allowed for the identification of risks affecting the objectivity of personnel decisions in the State Customs Service of Ukraine, specifically during competitions for leadership positions, re-attestation, integrity checks, and lifestyle monitoring of officials. Based on the results of the study, 30 recommendations were formulated and considered by the selection commission during the organization of the stages of the competition for the Head of the State Customs Service.
The NACP paid special attention to monitoring the implementation of recommendations provided within the framework of previously conducted studies.
Specifically, based on the analysis of the implementation of recommendations from the study “Corruption Risks in the Procedure for Suspending/Restoring the Registration of Tax Invoices/Adjustment Calculations in the Unified Register of Tax Invoices,” an updated draft report was prepared, identifying 5 corruption risks. Monitoring conducted with the involvement of the Business Ombudsman Council, business representatives, and the public sector indicated certain positive shifts; however, the majority of recommendations remain unimplemented.
Similarly, monitoring the implementation of recommendations from the study “Corruption Risks during Public Procurement under Martial Law” recorded only partial changes. The lack of systemic solutions to eliminate structural corruption risks indicates a continued high level of vulnerability in the system, particularly due to limited competition and the expanded practice of applying exceptions to competitive procedures.
The Agency carried out similar work in the field of security and defence. More details about it can be found here.
The NACP also devoted significant attention to cooperation with anti-corruption authorized units (officers) as a key link in implementing anti-corruption solutions at the level of government bodies and organizations. The results of anti-corruption expertise and strategic analysis of corruption risks were aimed at unifying risk management approaches and improving the preparation of anti-corruption programs, which should help increase the institutional capacity of these authorized units.
«Anti-corruption authorized officers must become effective specialists who ensure the organization and coordination of corruption risk management within a government body, facilitate the timely identification of 'bottlenecks,' initiate the introduction of effective safeguards, and act as independent professional advisors to leadership on integrity issues. To this end, the NACP will focus on strengthening the institutional capacity and independence of these authorized officers, expanding coordination and methodological support, and implementing transparent approaches to evaluating the effectiveness of their activities,» emphasized Serhii Hupiak.
Thus, the sectoral approach to minimizing corruption risks applied by the NACP allows for the integration of preventive anti-corruption safeguards directly into state and management processes, increasing their transparency and resilience.
The results of the NACP's work in the field of full audits can be found here.
