One of the powers of the National Agency on Corruption Prevention (NACP) is to monitor and control compliance with legislation on conflict of interest. This activity is comprehensive and is carried out in areas such as identifying and documenting violations of conflict of interest legislation, implementing measures to eliminate them, and identifying and eliminating conditions that contribute to the emergence of conflicts of interest.
In 2025, the NACP Department for Monitoring and Control over the Fulfilment of Legislation on Conflict of Interest and Prevention of Corruption (the Department) ensured a systematic and comprehensive approach to identifying and analysing corruption risks by conducting 12 reviews of the organisation of work on corruption prevention and detection in state authorities and local self-government bodies. For comparison, ten such reviews were conducted in 2024.
Despite the diversity of the reviewed entities, typical corruption risks were identified:
- conclusion of procurement contracts in favour of third parties, where goods/services were purchased at inflated prices or services were not provided due to suppliers’ incapacity;
- conclusion of lease agreements under which the tenant effectively uses additional premises free of charge that are not specified in the documentation;
- the likelihood of abuse by officials in determining real estate objects for their subsequent alienation by the State Property Fund of Ukraine;
- unlawful withdrawal of land from communal or state ownership into private ownership based on corrupt and discretionary decisions of local self-government bodies (LSGBs);
- employment of individuals in violation of the procedure for conducting special background checks;
- unlawful notarization of real estate or land without prior identification of documents confirming ownership rights;
- unlawful transfer of confiscated property and land to private companies or individuals through abuses by members of regional commissions and bodies of the State Enforcement Service of the Ministry of Justice of Ukraine;
- insufficient control over the verification of cases of non-submission/late submission of asset declarations by officials and failure to notify the NACP of such cases;
- lack of coordination of anti-corruption measures in subordinate organisations by the authorised unit;
- the formal nature of anti-corruption programs. The vast majority of authorised officers choose training activities and the development of guidance materials.
For example, during the review of the organisation of work on corruption prevention at the State Judicial Administration of Ukraine (SJA), authorised officers of the NACP stated a formal approach to the development of the anti-corruption program. In addition, an analysis of the results of public procurements conducted by the territorial departments of the SJA confirms the existence of systemic problems with transparency and high corruption risks.
During the review of State Enterprise “Forests of Ukraine”, the NACP identified several corruption risks arising from the lack of clear mechanisms for selecting forest land plots for the construction of roads and logging, as well as delays by State Enterprise “Forests of Ukraine” in formalising title documents for the use of forest fund lands.
The NACP also recorded systemic corruption risks at the State Agency of Melioration and Fisheries of Ukraine: use of official powers for personal gain in the management of state property; use of biological resources and seized illegal fishing gear for personal interests; use of the institution of public inspectors to satisfy private interests.
The Agency initiated five internal investigations.
At the end of the year, the NACP completed a review of the Kyiv City Council and the Kyiv City State Administration (KCSA). A number of potential corruption risks related to the unlawful withdrawal of land from communal ownership, the pursuit of personal interests, and the misappropriation of funds were identified.
In 2025, within the framework of exercising its functions on preventing corruption-related offences, the NACP prepared 56 substantiated findings, compared to 13 in 2024. This indicates a significant increase in the effectiveness of this area of activity. It is worth noting that 60%, or 34 findings in 2025, concerned corruption-related criminal offences, meaning that the number of detected corruption crimes increased 2.6 times compared to the previous year. Particularly indicative is the dynamics of the established damage to the state — it increased from UAH 30 million in 2024 to over UAH 434 million in 2025.
Thus, in 2025, based on materials submitted by the NACP, the Office of the Prosecutor General registered criminal proceedings on facts of possible abuse of office by officials of territorial units of State Enterprise “Forests of Ukraine” (Part 2 of Article 364 and Part 2 of Article 366 of the Criminal Code of Ukraine). These illegal actions caused grave consequences for the state, totalling over UAH 2 million.
In addition, based on NACP materials, the State Bureau of Investigation (SBI) registered several criminal proceedings against officials of the State Agency for Land Reclamation and Fisheries of Ukraine, who, by abusing their official position, unlawfully disposed of seized biological resources by transferring them to business entities that had no right to conduct trading activities. The amount of damage to the state is estimated at UAH 2.4 million.
The NACP also submitted to the National Anti-Corruption Bureau of Ukraine (NABU) several substantiated findings on the detection of signs of a corruption-related criminal offence under Part 4 of Article 191 of the Criminal Code of Ukraine regarding officials of one of the regional military administrations (RMAs), who, in violation of current legislation, procured materials for the construction of fortification facilities at inflated prices, thereby causing significant damage to the state.
The information on typical corruption risks obtained during the reviews made it possible to strengthen control and make preventive measures more effective. Based on the results of measures to prevent corruption-related offences, the NACP issued 76 binding orders to eliminate violations of anti-corruption legislation requirements, to conduct internal investigations, and to bring those responsible to liability. In 2024, 35 such orders were issued in this area, which indicates a strengthening of the preventive focus of the NACP’s work.
In addition, the Agency drew up 11 protocols on administrative offences related to corruption against 11 individuals. In 2024, 27 protocols were drawn up against 25 individuals.
In 2025, the number of monitoring and control measures over compliance with legislation on ethical conduct and the prevention and settlement of conflicts of interest initiated by the NACP nearly doubled compared to the previous year. While in 2024 this indicator amounted to 25.6% (53 measures), in 2025 it reached 46% (118 measures). The main sources for monitoring and control measures were media materials and the results of reviews of officials’ asset declarations.
In 2025, the NACP completed 258 monitoring and control measures over compliance with legislation on ethical conduct and the prevention and settlement of conflicts of interest, which is 21% more than in 2024.
“To increase the number of reviews initiated on its own initiative, the department, in cooperation with the relevant NACP unit, updated the rules of logical and arithmetic control. This made it possible to ensure the processing of information from the Unified State Register of Declarations of Persons Authorized to Perform the Functions of the State or Local Self-Government to identify possible violations in the area of conflict of interest and reduced the time spent on ‘manual’ searches for the necessary information in declarations, registers, and databases,” notes Oleksandr Ampleiev, Head of the NACP Department for Monitoring and Control over the Fulfilment of Legislation on Conflict of Interest and Prevention of Corruption.
Within the framework of implementing the Roadmaps for Ukraine’s accession to the EU, the Department focused on regulating certain of its functions: the Procedure for Monitoring and Control over Compliance with Legislative Acts on Ethical Conduct and the Prevention and Settlement of Conflicts of Interest in the activities of persons authorised to perform the functions of the state or local self-government was approved.
Representatives of the Department were also involved in the development of the Anti-Corruption Strategy for 2026–2030 and, following its adoption, will begin work on its implementation. The planned steps are aimed at improving legislation on conflicts of interest. In particular, they provide for strengthening the institutional capacity of the NACP to hold persons liable for violations of legislation in this area.
“In 2026, the Department will focus on further increasing effectiveness through the expansion of IT capabilities for the automated detection of violations. Another priority will be the improvement of the NACP’s internal procedures, which will allow for higher-quality identification and documentation of offences. An additional priority of the Department’s work in 2026 will be strengthening the risk-oriented approach during reviews of the organisation of work on corruption prevention and detection, as well as during monitoring and control measures over compliance with legislative acts on conflicts of interest. It is planned to expand the practice of comprehensive monitoring and to establish closer cooperation with law enforcement agencies for the effective implementation of materials on offences transferred to them,” Oleksandr Ampleiev said.
The results of the NACP’s work in the field of lobbying can be found here.
