Ukraine has demonstrated significant progress in strengthening business integrity. According to the assessment conducted by the Organisation for Economic Co-operation and Development (OECD) within the fifth round of monitoring under the Istanbul Anti-Corruption Action Plan, Ukraine received a score of 68.8 out of 100, reflecting a positive reform dynamic. At the same time, the report outlines key areas for further improvement.
Among the main achievements is the approval by the National Securities and Stock Market Commission of the “Corporate Governance Code: Key Requirements and Recommendations.” The document provides guidance in the area of comprehensive environmental, social, and corporate governance (ESG), incorporating best international practices. The Code is advisory in nature and may be applied in both state-owned and private companies as a benchmark for enhancing transparency and accountability.
The monitoring team highly commended the work of the Business Ombudsman Council, an advisory body to the Cabinet of Ministers of Ukraine that reviews complaints from business entities regarding the actions or inaction of state authorities and helps settle disputes at the pre-trial stage. Experts praised the Council’s transparent reporting and the adequacy of its powers to protect entrepreneurs.
Ukraine also became one of the first countries in the world to introduce public disclosure of information on ultimate beneficial owners (UBOs) of companies, making such data publicly available in the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Associations. The report states that Ukrainian legislation complies with international standards — it defines the concept of a beneficial owner; establishes the obligation for companies to submit up-to-date information on their UBOs to state authorities; requires disclosure of a broad range of UBO-related data; and ensures free public access to this information through a centralized online register. At the same time, the OECD recommends improving mechanisms for verifying submitted data.
The assessment also covered state-owned enterprises such as Naftogaz, Energoatom, Ukrzaliznytsia, Ukrenergo, and Ukrhydroenergo. The monitoring team noted that Ukraine had improved its legal framework for managing state-owned enterprises, aligning it more closely with OECD standards. These companies have implemented risk management procedures and anti-corruption programs that meet required indicators. The programs include provisions on gifts and hospitality, rules for preventing and managing conflicts of interest, counterparty due diligence, regulations on charitable donations, sponsorships, political contributions, and internal responsibilities for implementing the compliance program.
The report emphasizes that under martial law, Ukraine must strike a balance between transparency and security, as some information remains temporarily undisclosed for national security reasons. The main challenges concern the strengthening of practical implementation and enforcement of legislation.
It should be recalled that the assessment focused on Ukraine’s anti-corruption and integrity system across nine key areas: Anti-corruption policy, Conflict of interest and asset declarations, Whistleblower protection, Business integrity, Transparency in public procurement, Judicial independence, Independence of the prosecution service, Specialized anti-corruption institutions, and Liability for corruption offenses.
A distinctive feature of the fifth round was the use of performance indicators defined in the Monitoring Methodology. The assessment of these indicators is based on compliance criteria aligned with international standards and best practices, and also takes into account the recommendations provided by the OECD during the previous monitoring round. This evaluation system ensures objectivity, consistency, and transparency of conclusions.
Information on Ukraine’s progress in the areas of anti-corruption policy, conflict of interest and asset declarations, as well as whistleblower protection, is available on the NACP website.
The full text of the report from the fifth round of monitoring under the Istanbul Anti-Corruption Action Plan is available via the provided link.
Background: The OECD Anti-Corruption Network for Eastern Europe and Central Asia (ACN) is a regional program of the OECD Working Group on Bribery, established in 1998. Its mission is to support member countries in preventing and combating corruption through country reviews, practitioner networks, and tailored technical assistance.
The Istanbul Anti-Corruption Action Plan is a regional peer review program launched in 2003 within the ACN framework. It supports reforms by analyzing and monitoring the implementation of recommendations that promote international best practices and standards.
The Action Plan covers ten participating countries of the OECD Anti-Corruption Network: Ukraine, Armenia, Georgia, Kazakhstan, Kyrgyzstan, Moldova, Mongolia, Tajikistan, Azerbaijan, and Uzbekistan. Ukraine joined the program in 2003 and has undergone five monitoring rounds. All previous reports are available on the ACN website.
In March 2024, the OECD published the Report on Anti-Corruption Reforms in Ukraine following the fifth monitoring round under the Istanbul Action Plan. During 2023, Ukraine underwent a shortened review covering five of the nine areas: Anti-corruption policy, Asset declarations, Judicial independence, Specialized anti-corruption institutions, and Liability for corruption offenses. The report confirmed that Ukraine has made substantial progress in various areas of anti-corruption reform and integrity building.
