White Book of Reforms 2025. Chapter 1. Governance

Their first goal was to keep Ukraine within Russia’s sphere of influence so that Russia eventually seizes it. The second goal was to maintain the corruption rent by preventing the development of new competitive businesses that could drive the “old” ones out of the market unless they invested in new technologies. This rent was used to influence politics both directly (by “buying” politicians and political parties) and indirectly (through influencing public opinion). All of this weakened the Ukrainian state, economy, and society.

Despite these challenges, institutional reforms are ongoing, albeit rather slowly. This Chapter considers changes in central government, while Chapters 2 and 3 discuss decentralization and judicial reform.

Developments in 2014-2019

As in many other areas, significant reforms in governance took place in 2015, then reforms slowed down, and since 2019, they have resumed at a slower pace (Figure 1.1). The main milestones of governance reforms include the deployment of anti-corruption infrastructure, increasing transparency, digitalization, and the public service reform.

Anti-corruption infrastructure

One of the earliest anti-corruption reforms was the requirement for MPs to publish their asset declarations issued by the speaker of Parliament in January 2015. In August 2015, a law stating which assets should be declared by public servants was adopted. Next year, Parliament introduced the special confiscation (according to FATF recommendations) and electronic declarations. The government tried to sabotage implementation of e-declarations at many levels, from delays of the deployment of electronic declaration software to the inclusion of civic activists on the list of persons who should file e-declarations. After protests by anti-corruption activists, the EU and G7, and the decision of the Constitutional Court in June 2019, the latter decision was reversed. 

Since 2016, hundreds of thousands of civil servants have been submitting e-declarations (initially, the reform envisioned that only a few thousand high-ranking officials would do so). The number of declarations exceeds the capacity of the National Agency on Corruption Prevention (NACP), which thoroughly reviews about a thousand declarations per year. The Agency didn’t introduce an automatic review of declarations until late 2023 although this instrument is crucial for ensuring the integrity of people who hold or would like to hold a public office. 

Perhaps the most important development in governance was the introduction of special anti-corruption agencies. The first of them was the National Anti-Corruption Bureau (NABU), which was legally established in October 2014 and tasked with the investigation of top corruption cases. In March 2015, the procedure for the selection of a NABU director was specified, and the first NABU director was appointed in June 2015. In August of the same year, NABU powers were clarified, and its employees were prohibited from participation in political parties. The NABU has become perhaps the most successful anti-corruption institution. However, Ukrainians are quite sceptical about anti-corruption agencies, and many are unaware of their existence.

The National Agency on Corruption Prevention (NACP) was established by the law “On corruption prevention” adopted in October 2014. It was formed in April 2015, and by the end of the same year it completed staffing. At first, the Agency was organized as a committee, with the Agency head being “the first among equals.” It soon became apparent that this design didn’t work. Furthermore, there were rumours that the NACP was not independent, so the Agency was “reloaded” (the law was changed, the new head and staff were selected) in 2019, with the Agency head assuming more responsibilities and decision-making freedom. The NACP “reload” allowed it to restart its operations. The Agency maintains the registry of e-declarations and can punish officials who provide false information in their declarations. It also develops anti-corruption policies and their implementation mechanisms, such as the anti-corruption program for government agencies.

The Special Anti-Corruption Prosecutor Office (SAPO), whose task is to support the NABU and represent high-level corruption cases in courts, was legally established in March 2015, and was de facto organized in September 2015 as a special department within the Prosecutor General’s Office. From the very beginning of its operations, the president and government tried to control the SAPO by interfering with the selection of its head and then with its operations. In 2016, in implementation of the IMF program, Parliament adopted a law that made the SAPO more independent from the Prosecutor General’s Office and its work more transparent (SAPO became a separate legal entity only at the end of 2023). In 2018-2019, the NABU accused the SAPO of leaking details of NABU investigations to corrupt officials. This led to the resignation of the first SAPO head. Despite being selected in August 2020, the new SAPO head was not appointed until July 2022 and only upon insistence of the EU. 

The law on the State Bureau of Investigation (SBI) was adopted at the end of 2015. The SBI is responsible for the investigation of crimes of top officials, judges, and law enforcement officers, including the heads of newly-created anti-corruption institutions. Today it also investigates collaboration of Ukrainian enterprises with Russian ones, as well as Russian war crimes (in 2024, the government created the State Sanctions Registry, which lists people and entities sanctioned because of Russian aggression). The idea to create the SBI emerged back in 2012, but the Bureau began to operate only in 2018. In 2019, the Bureau was “reloaded” because of suspicions that it was dependent on the President’s Office. The SBI still isn’t considered fully independent, and on a few occasions it was accused of pressuring businesses. 

The Agency for Recovery and Management of Assets confiscated from corrupt officials (ARMA) was created at the end of 2015. In February 2016, it received the powers not only to trace “dirty” assets but also to manage them (e.g., to sell or rent them out). Publication of the registry of those assets was a part of the legislative package which Ukraine adopted to obtain a visa-free travel regime with the EU. In 2021, ARMA was “reloaded” because it was used to exert pressure on businesses rather than investigate corrupt officials. However, the current ARMA head appointed in 2023 is also far from perfect, so the Agency may have to be “reloaded” again.

The creation of the High Anti-Corruption Court (HACC) is discussed in Chapter 3. Here we only note that the anti-corruption infrastructure functions effectively only if all its elements — the NABU (investigation), SAPO (prosecution), and HACC (justice) — are operational. Thus, the authorities constantly try to sabotage the work of at least one of these agencies. For example, they resisted the launch of the High Anti-Corruption Court for almost a year (it was launched in 2019), they did not appoint the SAPO head from 2020 to 2022, and in 2024, they almost compromised NABU. 

Needless to say, the creation of this anti-corruption infrastructure was strongly promoted by Ukraine’s international partners — most notably the IMF and the EU. The introduction of reforms was linked to obtaining loans from these organizations as well as other “carrots” such as visa-free travel to the EU. One may also notice that these newly created agencies had to be “reloaded” because Ukrainian governments tried either to capture anti-corruption institutions or to undermine them (for example, although the NABU received the right to conduct independent wiretapping at the end of 2019, it still cannot use this right. It plans to obtain this right after martial law is lifted). Significant effort from both civil society and the international community is needed to ensure the proper implementation of the laws, and the newly created anti-corruption institutions need constant protection from attempts to undermine them.

Anti-corruption institutions and law enforcement in general are only one part of better governance. Many corruption-reducing initiatives were implemented as part of deregulation or changes to the processes of interaction between people, businesses, and the state. These initiatives are discussed in respective Chapters on the energy market, land market, and business environment. Here we examine transparency and digitalization, as well as reforms of (or, rather, attempts to reform) the public service itself.

Transparency and digitalization

The delegation of registration powers from the Ministry of Justice to local authorities in 2015 (see Chapter 2) was one of the first reforms in this sphere. At about the same time, the Cabinet of Ministers equalized the validity of paper and electronic registration documents for real estate. Soon after that, the Ministry of Justice launched an online service: it became possible to obtain information from the enterprise registry online. Since May 2015, agencies that developed legal acts were obliged to publish drafts of these regulations on their websites to collect comments from stakeholders. Prior to that, one could only see a draft law after it was registered with Parliament. Today this is the case only for laws submitted by MPs. 

In July 2015, Parliament opened state registries. Some of them were closed in 2022 for security reasons but later reopened partially or in full (it was necessary to strike a balance between national security and transparency that prevents corruption). 

At the end of 2015, the government opened over 300 datasets and created an open data portal data.gov.ua. Thus Ukraine swiftly climbed up in different open data ratings. In 2021, over 1000 datasets were published by the government. These datasets have many problems: for example, some of them are in a non-machine-readable format, often they lack clear descriptions of their contents, and many are not updated in a timely manner, especially since February 2022. Despite that, people who have data analysis skills usually can make sense of this data. 

Opening of registers enabled creation of services that provide comprehensive information on legal entities and entrepreneurs (e.g., Opendatabot, YouControl, and others). In 2014 Ukraine started opening information on final beneficiaries of firms and banks (this was crucial for the banking sector reform), and in 2017 Ukraine joined the international registry of final beneficiaries. In 2018, the government approved a procedure for interlinking public electronic resources, so that people who need an administrative service had to collect less documents.

A crucial reform in the political sphere was the introduction of state financing for parties that made it into Parliament. The sum of donations to political parties by individuals and enterprises was capped to prevent oligarchs from “purchasing” them (however, there is evidence that some political parties circumvented this law by disguising support from large sponsors as many small contributions from pensioners). The same reform obliged parties to provide quarterly reports on their revenues, expenditures, and assets to the NACP. However, using the COVID pandemic as an excuse, the government suspended this financial reporting until lockdowns were lifted (lockdowns were officially lifted in spring 2023, although they de facto ended at the start of the full-scale invasion). At the end of 2023, mandatory reporting was restored. As of April 2024, the majority of parties filed their reports to the NACP.

Public service reforms

The quality of human capital has long been a significant issue in the public sector. This problem has two major elements: salaries and selection procedure. The salary system has two drawbacks: first, a significant share of a public servant’s salary is a “bonus” that largely depends on the opinion of their supervisor; second, those who have worked in public service for a long time have a much higher salary than newcomers (even if the latter are more skilled) because of tenure add-ons. Therefore the public service is a very closed and rigid system. Moreover, the idea that public servants should have decent salaries is rather unpopular in Ukrainian society. So whenever the country is facing difficulties, such as in early 2015 or during COVID, the government limits the salaries of public servants, which encourages people who can earn more in the private sector to exit public service. 

Attempts to reform the public service have had limited success so far. At the end of 2015, Parliament substantially amended the law on public service. The law divided public servants into three categories (A, B, and C), introduced open competitions for public service positions, specified which positions were political and which were not, and clarified some processes. The law also introduced the position of state secretaries (chiefs of staff) within ministries. This idea is not new — even president Kuchma tried to introduce state secretaries in 2001 in order to create some institutional memory. Unlike ministers, state secretaries would not be obliged to leave their offices if a Cabinet is replaced and thus could continue to implement reforms launched by the previous government. This idea did not work because each minister wants to bring their own people into ministries and implement policies in line with their vision. Currently, state secretaries are responsible for support functions within ministries, such as staffing, legal matters, procurement, etc.

In 2016, in line with the new law, the Cabinet of Ministers created a commission on hiring for the highest level of public service. In 2016-2018, the commission organized over 200 competitions for Level A positions and appointed 150 officials selected via competitions. The introduction of transparent competition for public service positions and the launch of an online portal for government vacancies were notable accomplishments of the reform. In 2018, KPIs for public servants and the European credit-transfer system for their training were introduced. 

A major attempt to overcome deficiencies in Ukraine’s public sector was the creation of directorates within ministries. Directorates should have become the “seeds” of proper policy-making within ministries. Initially financed by the EU and created from scratch, they attracted highly skilled and motivated people who also received higher salaries. Eventually, the directorates should have been integrated into ministries. However, this idea worked only when ministers were interested in the reform. For example, the Ministry of Health effectively used its directorates to implement healthcare reform. 

By 2018, 58 directorates were created with more than 500 experts joining the government. At the end of 2019, the government mandated that all ministries should create directorates. Despite that, today, out of 19 ministries, only 11 have a total of 48 directorates (thus, different ministries implemented this idea to a different extent). However, we don’t know how much the policy-making approaches of directorates differ from those used by “traditional” departments.

Reforms in 2019-2024

After his election with a stunning majority of 73% in April 2019, president Zelenskyy dismissed the previous Parliament and announced new elections. His popularity allowed him to obtain a Parliamentary majority for the first time since Ukraine restored its independence in 1991. Thus, in the autumn of 2019, the pace of reforms intensified as Parliament quickly adopted laws, including many reforms that were stuck in the previous Parliament.

One of the first laws adopted by the new Parliament was the law on the “reload” of government (i.e. the new law on public service). This law substantially simplified the procedures for hiring and firing public servants and introduced an opportunity for ministries to hire contractual employees for certain projects (in 2020, contracts specifying measurable tasks and deadlines were introduced). At the same time, the new law transferred the power to set salaries of public servants to the Cabinet of Ministers, whereas they were previously defined by law. This allowed for more flexibility but increased anxiety among public servants.

The canceling of competitions for public service positions first because of COVID, and then because of the full-scale war, was a step back in reforming the public service. On the other hand, some advances were made with the salary system in 2024: the Cabinet of Ministers approved a catalog of government positions and a new system of salaries based on grades and positions. The recently adopted laws on administrative procedure and the hierarchy of legislative acts should also improve the functioning of Ukrainian bureaucracy. During 2025-2026, the government and Parliament should legislatively define that a bonus cannot exceed 30% of an employee’s total salary and re-launch competitions for public service positions, the government HR portal, and the cadre management system.

In 2024, Parliament passed two laws “for the future” — they will come into effect after the martial law is lifted. One of them regulates the procedure for public consultations — it requires all government agencies to organize public consultations about regulations which they plan to adopt in order to take into account the opinion of stakeholders on these regulations. Unfortunately, the law does not apply to Members of Parliament. The second law introduces English as the language of international communication in Ukraine. Heads of government agencies, as well as border guards, dispatchers, and call center employees will be required to speak English. To facilitate this, English lessons will be introduced in kindergartens (today, children start learning English in the first grade).

In the anti-corruption sphere there were both positive and negative developments. The new law that increased punishment for illegal enrichment adopted in 2019 received positive feedback from Reform Index experts. However, the Constitutional Court de facto canceled both this norm and e-declarations in 2020. After protests by citizens and the international community, Parliament restored these norms. It also strengthened criminal responsibility for lying in declarations and increased the number of public servants who should file them. At the start of the full-scale invasion, the registry of e-declarations was closed, and in 2023 it was opened again upon the insistence of Ukrainian civil society and international partners. However, a more balanced approach should have been applied here to protect civil servants whose relatives remain in the occupied territories.

In 2023, the NACP introduced a procedure for monitoring the lifestyle of officials in order to determine whether their expenditures match the revenues indicated in their declarations. Assets acquired before entering the public service will also be monitored. Transparency International highlights a few drawbacks in the procedure for lifestyle monitoring. The most important is that the non-random assignment of NACP employees to monitor officials entails a corruption risk. Also, the automatic declaration checks may not be a suitable instrument for revealing dubious revenues of officials.

Although the new government enabled the functioning of the High Anti-Corruption Court (HACC) in September 2019, it sabotaged other anti-corruption institutions. For example, the elected head of the SAPO was not appointed for two years, and the EU had to include his appointment into the list of conditions for opening membership negotiations with Ukraine in 2022. In May 2024, a whistleblower reported that some of the NABU staff were warning top officials about corruption investigations related to them. In September 2024 NABU deputy head who allegedly was involved in leaks was fired but the investigation is ongoing. Hopefully, NABU will be able to fire compromised staff and restore its reputation as the most effective anti-corruption agency.

A major attempt to ease pressure on businesses was made in 2021, when the corrupt tax police were replaced by the Economic Security Bureau of Ukraine (ESBU). The idea (which had circulated within the government since 2013) was to create an analytical agency that would investigate the finances of enterprises to uncover tax evasion instead of employing more aggressive tax police methods. However, since a former tax police officer was appointed the Bureau head, nothing really changed for businesses. After a number of scandals, and upon the insistence of Ukraine’s international partners and civil society, Parliament adopted a law on the ESBU “reload” that envisages its audit, replacement of its head (people appointed by international organizations will have a decisive say in selection of a new head), and attestation of ESBU employees, including an integrity check. If the law is implemented properly, this “reload” should make the ESBU operate as initially envisaged.

As we mentioned earlier, a few anti-corruption agencies have been “reloaded” since 2019. The “reload” of the Special Anti-Corruption Prosecution was perhaps the most successful. The SAPO became independent from the still unreformed Prosecutor General’s Office; it is now a separate legal entity and thus has more freedom in determining its staff numbers, allocating its budget, etc. The SAPO head received access to top state secrets. As a TI expert notes, these changes are mostly positive, but Parliament still needs to remove the opportunity to close cases against top officials because of the deadline for investigation expired (benchmark 44 in the IMF program) as well as to provide the SAPO head with the powers to open cases against MPs and request extradition without the consent of the Prosecutor General.

In 2024, within implementation of the Ukraine Facility plan, Parliament allowed to soften punishment for corrupt activities if convicts expose their accomplices and reimburse the damages. Theoretically, this will reduce incentives to engage in corrupt schemes. Additionally, Parliament introduced the OECD (Organisation for Economic Co-operation and Development) recommendations for combating bribery of foreign public officials. NABU will enforce this legislation.

Another condition on Ukraine’s path to the EU was the introduction of transparent lobbying rules (note that discussions on passing a lobbying law have been ongoing in Ukraine for about 20 years). Finally, Parliament passed such a law, but Reform Index experts rated it negatively because it does not address the issue of shadow lobbying and at the same time complicates advocacy for civil society organizations that do it openly.

In line with Zelenskyy’s electoral campaign promises, the immunity of MPs was reduced (although few people actually understand what Parliamentary immunity means and how it works, this topic has been quite popular with the public and thus was used by many politicians to gain electoral votes). The new law on MP immunity and the change in the procedure for holding MPs accountable actually made them more dependent on the decisions of the Prosecutor General, who is controlled by the president. This shifted the balance of power towards the president and thus received a negative grade (-2) from Reform Index experts. The responsibility of MPs for non-personal voting was increased (although without much impact on the behaviour of MPs). Another law aims to prevent MPs from “spamming” draft laws with amendments (when MPs did not want to adopt some important draft law, they would submit thousands of amendments to it. In this case, the law allows a third of MPs to introduce a special procedure for draft law adoption limiting the number of amendments that can be submitted by a faction or an individual MP).

In 2022, pro-Russian political parties were finally banned. The one that was in Parliament (Opposition Platform for Life) dissolved its faction and formed two new factions that during 2022 — the first half of 2024 mostly voted together with the president’s “Servant of People” faction. This considerably increased their effectiveness rank. Later, their support for reforms declined.

Since 2019, the government has considerably intensified digitalization. In 2020, it launched the Diia service — a mobile app and web portal that allows citizens to obtain a number of government services online. Although there are concerns about data security in Diia, over 20 million people use the platform today. In April 2021, e-passports were equalized with paper passports. 

At the end of 2021, Parliament adopted a law on public electronic registries. This law enabled the unification of the basic information needed for the identification of a person. Thus, different government agencies will be able to obtain this information from the same source, which will simplify the provision of administrative services and lower the risk of errors. In 2023, the government introduced the platform of registries. The platform will allow government agencies to create different registries and to exchange data between them. This should further increase the efficiency of administrative service provision.

In 2022, a few regulations were adopted to increase the security of online government resources (the law on cloud services, the law and Cabinet of Ministers decree on the protection of public electronic resources, and the law on counteracting cyber threats). 

In October 2022, Parliament adopted a new law on official statistics. It makes the statistical agency more independent, introduces a merit-based selection of its head, and adopts the UN standards for data collection and distribution. Most likely, this law will be implemented only after martial law is lifted.

What next?

The IMF program and Ukraine Facility plan mostly include the development of already deployed reforms or implementation of reforms that had to be introduced some time ago. For example, the NABU should finally start independent wiretapping, and the government should abstain from trying to capture anti-corruption institutions or influence them. The government also plans to continue digitalization. As Ukraine plans to join the EU, a key next step will be the adoption of EU regulations on data protection.

The main milestones of civil service reform in the IMF program and the Ukraine Facility Plan are changes to the compensation system, the restoration of competitive recruitment for civil service positions and of an electronic personnel management system. However, absence of competitions and non-transparent salaries are not the only problems of the civil service. For example, the regulatory impact analysis of legislation, introduced back in 2004, is often implemented only formally or not implemented at all (especially for draft laws submitted by MPs). 

The trust in the government remains low, while the perceived corruption is high (this perception is of course influenced by corruption scandals), making civil service appear unattractive, particularly to young people. In other words, the advantages of working in the civil service (e.g. involvement in reforms and job stability) currently do not outweigh the associated inconveniences, such as public declaration of all the family assets, the status of a politically exposed person etc. Renewal of competitions and changing the pay system will improve the situation, but a fundamental shift in the civil service culture and understanding of its societal role is needed.