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Special Verification: the Role of NACP, discrepancies in declarations and the right to explanation

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The National Agency on Corruption Prevention (NACP) is one of ten state bodies authorized to conduct special verification of candidates for positions in public service. More details on this can be found here.

During a special verification, the NACP carries out an express analysis of a candidate’s assets, specifically:

  • Accuracy of the data declared by the candidate — whether the candidate has disclosed movable and immovable property, corporate rights, business ownership, funds in bank accounts, cash, cryptocurrency, income from previous years, financial liabilities, etc.;
  • Compliance of expenses with income — this stage includes comparing the value of assets and acquired property with the official income of the candidate and their family members.

If, during a special verification, the NACP identifies false information in the candidate’s declaration amounting to 100 or more subsistence minimums for able-bodied persons (UAH 302,800 in 2025), this may serve as grounds for refusal to appoint or elect the candidate to a public service position.

In addition, based on the results of the express analysis, the Agency may initiate a full verification of the declaration or lifestyle monitoring. If signs of corruption or corruption-related offenses are identified, such as false declarations, unjustified assets, or illicit enrichment of the candidate, the NACP may:

  • submit to the court a protocol on an administrative corruption-related offense;
  • forward materials to pre-trial investigation bodies indicating the commission of a criminal offense;
  • refer materials to the Specialized Anti-Corruption Prosecutor’s Office (SAPO) for filing a lawsuit in court to recover unjustified assets for the benefit of the state.

Important! The authority organizing the special verification is obliged to provide the candidate with an opportunity, within five working days, to submit written explanations regarding discrepancies in the declaration and/or to correct them. Such explanations may significantly affect the assessment of the information recorded by the NACP as a result of the special verification.

Therefore, we recommend that initiators of special verifications make decisions on appointments or refusals not only on the basis of the verification results but also taking into account the candidate’s explanations. A final conclusion should be drawn after the NACP has reviewed the explanation and provided feedback.

As a reminder, special verifications of candidates for positions are a tool for ensuring transparency and accountability in the public sector. Their aim is to prevent individuals who possess assets not confirmed by legal income, who submit false data or documents for appointment, or who have ties with hostile structures, from being appointed to office.

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