Index 267: Customs Officers’ Rotation Procedure and the Dot-Chain Supply Management System for the Armed Forces of Ukraine

Index 267: Customs Officers’ Rotation Procedure and the Dot-Chain Supply Management System for the Armed Forces of Ukraine

29 August 2025
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Between June 16 and 29, six reforms were included in the Reform Index, all of which received positive evaluations from experts. The key development in this issue is the regulation governing the rotation of customs officers, which scored +1.5 points (on a scale from -5 to +5). Also highlighted in release 267 is the regulation on the operation of the Dot-Chain system, which digitizes the process of supplying goods to the Armed Forces of Ukraine. The overall Reform Index score stands at 0.6 points, down from +1 point in the previous issue.

Graph 1. Dynamics of the Reform Index

Graph 2. Values of the Reform Index and its Components in the Current Assessment Round

Customs officers’ rotation procedure, +1.5 points

To modernize the State Customs Service (SCS), the Ministry of Finance approved a procedure for rotating customs officers. From now on, an officer may be temporarily reassigned — for no more than three months — either within the same customs office or to another one, depending on their professional skills and experience. Such rotations will be carried out only with the employee’s consent, formally recorded in their service contract.

During a rotation, an officer may be assigned to a vacant position, fill in for an employee who is temporarily absent, or exchange posts with another officer. The total duration of all rotations for a single employee may not exceed six months in a year. Throughout a rotation, the salary is calculated based on the officer’s permanent position, not the temporary one.

Information about the Reforms Index project, the list of Index experts and the database of the regulations assessed are available here.

Expert commentary

Vitalii Nabok, policy and data analyst at the Institute for Analytics and Advocacy

“The order of the Ministry of Finance, which entered into force on June 27, 2025, restores the rotation of customs officers as one element of reform in this area.

Overall, staff rotation in public service is rare and applies only to specific categories of employees. Its regulation remains partial. For example, the Law ‘On Public Service’ does not regulate rotation, while the Labor Code of Ukraine refers only to the possibility of transferring employees. Under the Ministry of Finance order, rotation is defined as the temporary reassignment of a customs officer to another position within the same category. It may be used to balance workloads or to address temporary tasks needed to ensure the functioning of the customs authority.

First, the rotation procedure can be complicated for employees (involving changes of workplace, sometimes residence, colleagues, etc.) and financially burdensome (in cases of reassignment to a different location). A decline in work quality can also be expected during the adaptation period. Moreover, the order does not provide compensation mechanisms for employees reassigned to another customs office, which will negatively affect their motivation.

The reform’s intent is that periodic rotations should help reduce corruption risks by preventing the formation of informal ties in different parts of customs operations. However, this goal is not mentioned in the order itself. Rotation is also unlikely to become a regular practice: it can currently be applied only to those who have given consent in their contract with the customs service.

In addition, the procedure does not provide employees with the right to refuse a rotation or appeal a rotation decision. The head of the SCS decides on rotation when there is a need (balancing workload or resolving temporary tasks) and must base the decision on proper justification. This may be done on their own initiative or at the request of the head of an independent structural unit of the SCS apparatus. Accordingly, there is little likelihood that staff prone to corruption violations will be rotated if higher-level leadership is involved in the schemes. Instead, there is a risk of frequent rotations at the level of customs managers with the status of ‘acting head.’ This means that a customs officer, while on rotation, may effectively not be held accountable for negative outcomes in the authority’s performance.

In summary, customs officers’ rotation is unlikely to resolve corruption problems within customs. Rotation may also be burdensome for the employees concerned, due to the need for adaptation and the lack of financial compensation, which will affect work quality in the new post. At the same time, rotations may become a tool for poor management practices by customs leadership, without legal consequences.

Therefore, rotations should be formally regulated as a form of civil servant reassignment in the relevant Law ‘On Public Service’ and in the Labor Code of Ukraine, with appropriate compensation mechanisms. It is also advisable to introduce planned, periodic horizontal rotations to allow employees to gain new experience and to prevent corrupt practices. Finally, restrictions on rotations should be established for those holding ‘acting head’ status.”

Supply management system for the Armed Forces of Ukraine, Dot-Chain, +1 point

On June 27, the Cabinet of Ministers approved a resolution of the Ministry of Defense on the digital platform DOT-Chain. From now on, unit commanders will be able to order directly not only foodstuffs for rear support, but also necessary weapons and equipment (FPV drones, electronic warfare (EW) complexes, combat modules, robotic systems, etc.), bypassing unnecessary bureaucratic procedures. In practice, a commander logs into the DOT-Chain system, selects drones, modules, or other equipment from the available catalog, and the request automatically goes to the Defense Procurement Agency. The Agency then signs contracts with manufacturers, while the State Rear Operator is responsible for delivering the order to the specific military unit. In this way, service members gain access to a catalog of weapons with technical specifications, prices, and supply forecasts. 

All documents — from invoices to violation reports — are generated immediately in electronic form and in compliance with Ministry of Defense standards. The system automatically collects and analyzes data, filling gaps where processes had previously not been automated, and synchronizes with other state resources.

Expert commentary

Nelli Stelmakh, expert of the Defense Procurement Reform Project, servicewoman of the Armed Forces of Ukraine

“The adoption of this resolution is a logical and necessary step in the development of the DOT-Chain system, since state bodies and enterprises are obliged to act only within their powers and in the manner defined by the laws of Ukraine. The resolution formalizes the use of the information and communication system. It sets out the powers and responsibilities of all its users, including the Ministry of Defense, military units as end users, other defense-sector institutions, manufacturers, and suppliers.

The DOT-Chain system has been fully operational since February 2025, although in practice, it began to be used earlier. It has already proven effective in the area of food supply for the Armed Forces. The system reduces paperwork, records all user actions, and makes the process transparent.

At the same time, for further development, it is essential to ensure compatibility and interoperability between DOT-Chain and other information systems that have already been or will be introduced within Ukraine’s Defense Forces. The resolution clearly specifies who is responsible for establishing this interaction, thereby creating the foundation for scaling the system to other types of supply, including clothing and gear, weapons, and military equipment.

The DOT-Chain Defence module is particularly promising. It is currently in pilot mode and covers the procurement of FPV drones and other types of UAVs. In my view, introducing this subsystem will significantly reduce delivery times and enable feedback from end users—military units. This is important because at the centralized level, it is not always possible to accurately forecast the specific needs of units in the short term.

I assess the resolution very positively, as it:

  • Regulates the use of DOT-Chain beyond the Ministry of Defense
  • Reduces the burden on bodies responsible for decentralized procurement
  • Lowers corruption risks
  • Increases the speed and transparency of troop supply

Among potential risks, I see above all limited funding and possible disruptions in the interoperability of different information systems. At the same time, I sincerely hope that the pilot project will be scaled up as soon as possible. This would greatly help procurement officers, especially at the decentralized level, and accelerate the supply of end users—military units.”

Reform Index from VoxUkraine aims to provide a comprehensive assessment of reform efforts by Ukraine’s authorities. The Index is based on expert assessments of changes in the regulatory environment in six areas: Governance, Public Finance, Monetary system, Business Environment, Energy, Human Capital. Information about the Reforms Index project, the list of Index experts and the database of the regulations assessed are available here.

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