Reformation of Ukraine is a cornerstone of the European integration process and one of the key factors that defines the speed of Ukraine’s accession towards the European Union. Considering this, leading think tanks and civil society organizations that have expertise in European integration, anti-corruption reforms and the rule of law decided to carry out independent monitoring of Ukraine’s implementation of reforms related to its European integration commitments (a full list of organisations is provided below).

The goal of this expert monitoring is to to support Ukraine’s successful progress towards European Union membership through an independent assessment of the implementation of key reforms. Timely and efficient fulfilling of these commitments will demonstrate Ukraine’s ability to implement systemic changes. An independent positive assessment will help to dispel existing concerns among EU politicians, experts and citizens more convincingly, proving that Ukraine is implementing the necessary reforms on its path to the European Union, particularly in the areas of the rule of law and the fight against corruption. At the same time, we are convinced that European integration reforms are needed first and foremost by the Ukrainian people themselves.

At the current stage, the expert coalition based its research on the 10 key reform priorities set out in the Joint Statement between Marta Kos, European Commissioner for Enlargement, and Taras Kachka, Deputy Prime Minister for European and Euro-Atlantic Integration of Ukraine, on 11 December 2025 (further referred to as the “Kachka–Kos plan”). More about methodology below.

At the same time, the expert coalition leaves the possibility of expanding the monitoring via other topics and benchmarks, in case they become critical for the European integration process of Ukraine, as well as declares its intention to continue monitoring other documents setting out reforms in this area – once Ukraine has implemented the “Kachka–Kos plan” or even before the completion of its implementation.

The first assessment aimed at capturing a baseline for implementation of reform, in particular before the start of “Kachka-Kos plan” realization. The following monitoring will allow to track the dynamic of the reforms. Follow-up assessments are set to be published approximately once in two months.

This initiative is based on the former experience of independent monitoring of European integration reforms. In June 2022 Ukraine received the candidate country status, together with 7 recommendations from the European Commission, which were necessary for further progress towards membership. As a response, New Europe Center, together with the coalition of leading think tanks and civil society organizations initiated “Candidate Check” – independent expert monitoring of recommendations’ implementation. The initiative proved itself as a useful tool for public oversight of the fulfilment of European integration commitments. The current monitoring exercise continues this tradition: the key organisations involved in ‘Candidate Check’ are also participating in the new ‘Membership Check’ assessment phase.

EXTENDED EXPERT ASSESSMENT

Overall assessment – 9 out 100

 

1. Adopt comprehensive amendments to the Criminal Procedure Code and other legislation to ensure fast and high-quality justice.

Assessment – 2 out of 20

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM^[1] 23.6 – Institutional capacity

Enhanced independence, mandate effectiveness and operational capacity of the specialised anti-corruption institutions (for both the prevention and repression of corruption), including by extending the jurisdiction of the National Anti-Corruption Bureau of Ukraine (NABU) to cover all high-risk public positions and by granting the Specialised Anti-Corruption Prosecutor’s Office (SAPO) the necessary powers to start criminal proceedings against Members of Parliament without prior approval of the Prosecutor General.

IBM 23.6.1 Enhance the independence, mandate effectiveness and operational capacity of the specialised anti-corruption institutions.

IBM 23.6.2 Extend the jurisdiction of the National Anti-Corruption Bureau of Ukraine (NABU) to cover all high-risk public positions.

IBM 23.6.3 Grant the Specialised Anti-Corruption Prosecutor’s Office (SAPO) the necessary powers to start criminal proceedings against Members of the Verkhovna Rada without prior approval of the Prosecutor General.

IBM 23.8 – Track record against corruption

Made tangible progress towards a solid track record of investigations, prosecutions and convictions in corruption cases, in particular final convictions at high level and increased the number and overall value of seized, frozen and confiscated assets, including by removing from legislation the provision on automatic closure of criminal cases due to expiry of pre-trial investigation time limits and by reviewing existing time limits.

IBM 23.8.3 Remove from the legislation the provision on automatic closure of criminal cases due to expiry of pre-trial investigation time limits after the notification of suspicion and review existing time limits.

Expert indicator: Adoption of a draft law introducing amendments to the Criminal Procedure Code.

What has been done?

The draft law for implementing the benchmark has neither been made available for public discussion nor registered.

By letter No. 326/14.1-21/25 dated 20 November 2025, the Ministry of Justice informed the National Agency on Corruption Prevention (NACP) that, pursuant to an instruction from the Prime Minister of Ukraine, it had developed a draft law “On Amendments to the Criminal Code of Ukraine and the Criminal Procedure Code of Ukraine to strengthen the institutional capacity of the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialised Anti-Corruption Prosecutor’s Office (SAPO), and to remove procedural obstacles to the effective pre-trial investigation of criminal offences.”

The provisions of the draft law are aimed, in particular, at expanding the scope of subjects under NABU’s jurisdiction by introducing relevant amendments to Article 216 of the Criminal Procedure Code of Ukraine, as well as at legislatively establishing the powers of the Deputy Prosecutor General — Head of the Specialised Anti-Corruption Prosecutor’s Office (SAPO) to form joint investigative teams, send extradition requests in NABU cases, and take over criminal proceedings in compliance with the requirements of Ukraine’s international treaties, the provisions of current legislation, and the principle of SAPO’s independence in procedural decision-making (amendments to Articles 571, 574, and 575 of the Criminal Procedure Code of Ukraine).

At the same time, the draft law is not publicly available, and some of the key amendments outlined in the benchmarks are not addressed at all.

In parallel, NABU developed its own draft law to introduce the necessary amendments to strengthen its capacity, in particular, excluding the automatic closure of criminal proceedings upon the expiry of pre-trial investigation time limits after notification of suspicion, expanding NABU’s jurisdiction, resolving disputes over investigative jurisdiction, etc. This draft law was submitted to the Deputy Prime Minister for European and Euro-Atlantic Integration, Taras Kachka.

Responsible for analysis: Anti-Corruption Action Center (AntAC), Anti-Corruption Center MEZHA and Transparency International Ukraine.

 

2. Ensure that NABU has effective access to impartial, timely and high-quality forensic examinations.

Assessment – 0.5 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.6 – Institutional capacity

Enhanced the independence, mandate effectiveness and operational capacity of the specialised anti-corruption institutions (for both the prevention and repression of corruption), including by extending the jurisdiction of the National Anti-Corruption Bureau of Ukraine (NABU) to cover all high-risk public positions and by granting the Specialised Anti-Corruption Prosecutor’s Office (SAPO) the necessary powers to start criminal proceedings against Members of Parliament without prior approval of the Prosecutor General.

Expert indicator: Adoption of a draft law introducing amendments to the Law of Ukraine “On Forensic Examination,” as well as secondary legislation, with the aim of establishing a new independent expert institution with a competitive selection of its head, defining safeguards for the head’s independence from politically motivated dismissal, and ensuring the competitive selection of forensic experts.

What has been done?

In 2024, under the Resolution of the Cabinet of Ministers of Ukraine No. 798-р dated September 8, 2023, “On the Establishment of the Research Centre for Independent Forensic Examinations,” the Research Centre for Independent Forensic Examinations (hereinafter — the Centre) was established as part of Ukraine’s commitments to the IMF to ensure NABU’s access to independent and competent forensic experts. Such a Centre was intended to enable NABU to exercise its investigative powers effectively. In the process of establishing the Centre, safeguards for its independence were to be introduced, including a supervisory board composed primarily of representatives from international organisations, the appointment of the Centre’s head by the supervisory board, and so on.

At the same time, NABU emphasises the need for the institutional independence of such an expert body, specifically its establishment directly under the Cabinet of Ministers, without subordination to any specific ministry, as well as the introduction of an independent, competitive selection process for the head of the institution. This requires amendments to the Law of Ukraine “On Forensic Examination.”

In December 2025, a joint meeting was held between NABU, the Ministry of Justice, the Specialised Anti-Corruption Prosecutor’s Office (SAPO), and other state authorities, during which the Ministry of Justice announced the launch of the procedure to establish the Centre’s supervisory board to ensure its independence.

NABU’s position is that the Centre can serve only as a technical base, while the expert institution should be established separately from the Ministry of Justice and provided with the necessary safeguards of independence. Progress in implementation remains limited.

Responsible for analysis: Anti-Corruption Action Center (AntAC), Anti-Corruption Center MEZHA and Transparency International Ukraine.

 

3. Conduct a comprehensive review of the selection and dismissal procedure of the Prosecutor General.

Assessment – 0 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.2 – Independence, Accountability and Integrity

Further enhanced structural independence, integrity and accountability sustained at all levels of the judiciary, notably through improving merit-based selection processes; […] rendering the selection and dismissal procedure for the Prosecutor General and high-level prosecutors more transparent and merit-based.

IBM 23.2.1 Improved merit-based selection processes.

IBM 23.2.3 Enhanced structural independence, integrity and accountability of the Prosecution Service

Expert indicator: Adoption of a draft law introducing amendments to the Law of Ukraine “On the Prosecutor’s Office” and other legislation, providing for greater transparency and objectivity in the procedure for selecting the Prosecutor General, including the significant involvement of independent experts nominated by international partners, as well as in the procedure for dismissal.

What has been done?

No progress has been made.

Responsible for analysis: Anti-Corruption Action Center (AntAC) and Anti-Corruption Center MEZHA.

 

4. Resume the selection process for appointments and transfers of managerial positions and other prosecutorial positions in the Prosecutor General’s Office, regional and district prosecutor’s offices.

Assessment – 0.5 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.2 – Independence, Accountability and Integrity

Further enhanced structural independence, integrity and accountability sustained at all levels of the judiciary, notably through improving merit-based selection processes […].

Expert indicator: Adoption of a draft law introducing amendments to the Law of Ukraine “On the Prosecutor’s Office,” repealing provisions that allow for the appointment and transfer of prosecutors to regional prosecutor’s offices and the Prosecutor General’s Office without a competitive selection procedure, as well as provisions granting the Prosecutor General’s Office the right of access to any materials of pre-trial investigations.

What has been done?

According to Letter No. 31276/38-6-26/11.3.2 of the Ministry of Justice of Ukraine dated March 6, 2026, the Office of the Prosecutor General has developed a draft law amending the Law of Ukraine “On the Prosecutor’s Office” regarding evaluation of prosecutors’ performance and the selection of prosecutors for managerial (administrative) positions. The draft law is currently being finalised; however, it has not yet been made available for public discussion and remains the only draft law addressing the issue.

At the same time, the draft law does not repeal paragraph 5-4 of the Transitional Provisions of the Law of Ukraine “On the Prosecutor’s Office,” under which non-competitive appointments to the position of prosecutor have been possible since July 2025. The results of MEZHA’s analysis of this draft law are available at the link. Therefore, there has been no progress in implementation.

Responsible for analysis: Anti-Corruption Action Center (AntAC) and Anti-Corruption Center MEZHA.

 

5. Reform the State Bureau of Investigation (SBI).

Assessment – 1 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 24.3 – Reform of the State Bureau of Investigation

Made tangible progress in the comprehensive reform of the State Bureau of Investigation, with the meaningful involvement of independent experts nominated by international partners.

Expert indicator: Adoption of a draft law introducing amendments to the Law of Ukraine “On the State Bureau of Investigation,” providing for competitive selection for senior positions with the significant involvement of independent experts nominated by international partners, as well as the re-attestation of staff.

What has been done?

On August 6, 2025, a number of Members of Parliament, including Anastasia Radina, Yaroslav Zhelezniak, and others, registered draft law No. 13602 on amendments to certain legislative acts of Ukraine regarding the improvement of the functioning of the State Bureau of Investigation. The draft law was submitted to the relevant committee; however, no progress has been made in its consideration.

At the same time, on January 3, 2026, the President of Ukraine publicly announced the preparation of a presidential draft law on reforming the State Bureau of Investigation, which was to be registered by the end of January 2026. In response to a request for public information from MEZHA on January 27, 2026, the Office of the President reported that it had no information on the status of this draft law’s development. According to MEZHA’s sources in the Office of the President, the presidential draft law was prepared by Oleh Tatarov, Deputy Head of the Office of the President; however, it did not contain any substantive changes and did not comply with international obligations, raising concerns among international partners. At present, this draft law has not yet been registered, and its text remains unpublished.

Responsible for analysis: Anti-Corruption Action Center (AntAC) and Anti-Corruption Center MEZHA.

 

6. Appoint without delays internationally vetted judges to the Constitutional Court and members of the High Council of Justice.

Assessment – 1 out of 5

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.4 – Efficiency of the Judiciary

Enhanced the efficiency and performance of courts and prosecution offices, including by improving the legislation on the Constitutional Court’s procedure, ensuring the quorum of the Constitutional Court and the timely appointment of internationally vetted candidates,

Expert indicators:

Regarding the selection/appointment of Constitutional Court judges

Interim indicators:

1. Election by the end of June 2026 of 2 Constitutional Court judges under the quota of the Verkhovna Rada of Ukraine (approximately in April–May 2026, the Advisory Group of Experts (AGE) is expected to complete the assessment of candidates and submit the lists to the Verkhovna Rada Committee on Legal Policy).
2. Announcement by April 2026 of a competition for 1 vacant position of a Constitutional Court judge under the quota of the President of Ukraine, or appointment of a candidate recommended by the AGE and the selection commission in the first half of 2025.
3. If a new competition is held – appointment of 1 Constitutional Court judge under the quota of the President of Ukraine no later than the end of September 2026.
4. Submission by mid-September 2026 of 2 candidates for the position of Constitutional Court judge under the quota of the Congress of Judges of Ukraine.

Target indicator (maximum score: 2.5 points): as of 31 December 2026:

1. a) all vacant positions in the Constitutional Court are filled;
2. b) the selection process for Constitutional Court judges for positions that will become vacant in November 2026 and March 2027 has been launched in a timely manner (no later than 90 days before the expiry of the term of office of the respective Constitutional Court judge; 1 – under the quota of the Congress of Judges of Ukraine (vacant from 21 November 2026, competition announced in August 2026); 1 – under the quota of the President of Ukraine (vacant from 2 March 2027, competition announced in December 2026)).

What has been done?

Regarding the Constitutional Court:

Under the quota of the Verkhovna Rada of Ukraine, a competition is ongoing for 2 vacant positions of Constitutional Court judges. The Advisory Group of Experts (AGE) is expected to submit the list of candidates to the relevant parliamentary committee in late April – early May 2026. Under the quota of the President of Ukraine, 1 vacant position remains unfilled: the candidate recommended by the AGE and the selection commission has not been appointed since the first half of 2025, and no new competition for the position has been announced. Under the quota of the Congress of Judges of Ukraine, 2 positions remain vacant. Due to an insufficient number of candidates meeting the established requirements, a new competition has been launched.

Regarding High Council of Justice:

On 10 March 2026, the Congress of Judges of Ukraine elected two members of the High Council of Justice, reducing the number of vacant posts to two (19 out of 21 members have been appointed/elected). Two posts for members of the High Council of Justice allocated to the Ukraine Advocates’ Association have remained vacant since January 2022. No competition has been announced for these positions. In August 2026, the terms of office of three members of the High Council of Justice will expire (two under the quota of the Verkhovna Rada, and one under the quota of the Congress of Representatives of Higher Education Law Schools and Scientific Institutions). In February 2026, competitions were announced to fill the relevant positions.

Responsible for analysis: DEJURE Foundation, Centre of Policy and Legal Reform (CPLR) (in regards to the issue of the High Council of Justice).

 

7. Extend the involvement of international experts in the selection commission for the High Qualification Commission of Judges (HQCJ).

Assessment – 1 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.2 – Independence, Accountability and Integrity

Further enhanced structural independence, integrity and accountability sustained at all levels of the judiciary, notably through improving merit-based selection processes; revising the integrity vetting procedures for the Supreme Court and other high court judges and the selection procedures for the Supreme Court and extending the selection commission for the members of the High Qualification Commission of Judges of Ukraine (HQCJ) without delay, with the meaningful involvement of independent experts nominated by international partners;

Expert indicators:

Interim indicators:

1. Adoption and entry into force of draft law No. 13382 or another draft law providing for the restoration of the participation of international experts in the selection commission for members of the High Qualification Commission of Judges of Ukraine;
2. A request by the Head of the High Council of Justice, or a person acting in that capacity, to the appointing entities to submit candidates for the selection commission;
3. Submission by the appointing bodies of the selection commission (the Council of Judges of Ukraine, and international and/or foreign organisations that provide Ukraine with international technical assistance in the field of judicial reform and/or anti-corruption under international or intergovernmental agreements) of a sufficient number of candidates to form a duly authorised composition of the commission;
4. Formation of a duly authorised composition of the selection commission for members of the HQCJ, including international experts with a decisive voting role.

Target indicator (maximum score: 10 points): as of 31 December 2026: a duly authorized composition of the selection commission for members of the HQCJ has been formed, including international experts with a decisive voting role.

What has been done?

Draft law No. 13382 has been registered in the Verkhovna Rada of Ukraine, providing for the restoration of the participation of international experts in the selection commission for members of the High Qualification Commission of Judges of Ukraine. As of the time of assessment, there has been no further consideration of this draft law since June 2025. There are also no alternative draft laws on the parliamentary agenda that take into account the current aspects of the functioning of the selection commission, in particular the risk of forming its composition without the participation of international experts prior to the entry into force of the relevant law.

Responsible for analysis: DEJURE Foundation, Centre of Policy and Legal Reform (CPLR), Transparency International Ukraine (TI), Anti-Corruption Action Center (AntAC).

 

8. Adopt the draft law on declarations of integrity of judges. For the Supreme Court, this includes the temporary involvement of internationally nominated independent experts.

Assessment – 2 out of 10

What should be done? Interim benchmarks, success indicators.

In line with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.2 – Independence, Accountability and Integrity

Revising the integrity vetting procedures for the Supreme Court and other high court judges and the selection procedures for the Supreme Court and extending the selection commission for the members of the High Qualification Commission of Judges of Ukraine (HQCJ) without delay, with the meaningful involvement of independent experts nominated by international partners;

IBM 23.2.2 – Revised integrity vetting procedures for the Supreme Court and other high court judges

Expert indicators:

1. Adoption of the mentioned draft law no later than June 2026.

Entry into force of the law on improving the procedure for verifying judges’ integrity declarations, which provides for:

1. a) clarification of the content of integrity declarations and the grounds for initiating verification;
2. b) extension of the period covered by the verification;
3. c) specification of the verification procedure and timelines;
4. d) determination of the rights and obligations of natural and legal persons involved in the verification process;
5. e) determination of the legal consequences of the verification;
6. f) verification of the integrity declarations of judges of the Supreme Court and higher specialised courts (in line with the recommendations of the European Commission set out in the 2025 Enlargement Report), with the involvement of independent experts delegated by international partners, holding a decisive voting role.
7. Adoption by the HQCJ of internal regulatory acts to implement the requirements of the Law.
8. The HQCJ launches the verification of integrity declarations of judges of the Supreme Court and higher specialized courts.

Maximum score (10 points): as of 31 December 2026:

The law on improving the procedure for verifying integrity declarations has entered into force, and the HQCJ has launched the verification of integrity declarations of judges of the Supreme Court and higher specialised courts under the updated procedure.

What has been done?

In June 2025, the Verkhovna Rada of Ukraine adopted draft law No. 13165-2 in the first reading, aimed at improving the procedure for verifying integrity declarations. However, the draft law does not take into account the recommendations of the European Commission, in particular regarding the verification of integrity declarations of Supreme Court judges with the involvement of independent experts delegated by international partners. As of the time of assessment, no other legislative initiatives on this issue are available. The draft law has not been prepared for the second reading, and there is no information on whether the amendments submitted for the second reading have been taken into account. The adoption of the relevant draft law was envisaged as an obligation of Ukraine under the Ukraine Facility for the second quarter of 2025. As of the time of assessment, this obligation has not been fulfilled.

Responsible for analysis: DEJURE Foundation, Centre of Policy and Legal Reform (CPLR).

 

9. Adopt the Anti-Corruption Strategy and the State Anti-Corruption Program by Q2 2026.

Assessment – 0.5 out of 5

What should be done? Interim benchmarks, success indicators.

In accordance with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.5 – Legislative Alignment

Advanced, sustained and continuously implement the anti-corruption legal and strategic frameworks, including significant gradual alignment with the EU acquis and implementation of relevant GRECO, OECD and OSCE/ODIHR recommendations, with effective coordination, budgeting, monitoring and evaluation.

IBM 23.9 – Mainstreaming of anti-corruption in relevant sectors

Improved the mainstreaming of anti-corruption through risk assessments and integrity measures in the sectors most vulnerable to corruption.

Expert indicators:

1. Adoption of the Anti-Corruption Strategy (ACS) and the State Anti-Corruption Programme (SAP) within the established timelines and their compliance with Ukraine’s EU integration commitments, in particular with regard to: ensuring transparent competitive selection procedures for senior positions in the National Police of Ukraine (NPU), the State Bureau of Investigation (SBI) and the Office of the Prosecutor General, with the participation of international experts; strengthening the institutional capacity of the NABU and the SAPO.
2. Development of the ACS and SAP based on a public analysis of the state of corruption and the results of implementation of previous strategic documents, with the involvement of civil society representatives and proper communication on how their proposals are taken into account. Systematic engagement by the NACP of the public and external experts in fulfilling European Union commitments in the field of anti-corruption mainstreaming, as well as ensuring the coordinating and methodological role of the NACP in this area.
3. Amendments to legislation to grant the NACP the authority to apply enforcement measures to heads of public authorities, institutions, enterprises and organisations in cases of unjustified failure to implement SAP measures.

What has been done?

On 7 January 2026, the NACP submitted the draft Anti-Corruption Strategy for 2026–2030 to ministries for approval. During January 2026, ministries provided their responses: the majority supported the draft; however, certain central executive authorities submitted comments and proposals. Under these circumstances, the approval process still entails significant risks that a number of key anti-corruption and law enforcement reforms may not be duly taken into account.

The NACP involved groups of external experts in the preparation of the ACS for 2026–2030, which is generally a positive practice. However, this also reflected the absence of a unified approach to drafting the sections of the ACS, in particular with regard to the formulation of expected strategic results.

As of the time of assessment, draft sections of the SAP have not been published.

Responsible for analysis: Anti-Corruption Center MEZHA and Transparency International Ukraine (TI).

 

10. Develop and strengthen internal control systems against high level corruption.

Assessment – 0.5 out of 10

What should be done? Interim benchmarks, success indicators.

In accordance with the interim benchmarks, Ukraine is expected to achieve the following results:

IBM 23.7 – Corruption preventionї

Strengthened the efficiency of the corruption prevention framework by making further progress in the development and enforcement of legal and policy frameworks relating to asset declarations, whistleblower protection, conflict of interest, lobbying, financing of political parties/electoral campaigns, including effective, proportionate and sufficiently dissuasive sanctions in case of violations

Expert indicators:

1. Introduction of systematic internal control audit assessments in the public sector by the State Audit Service of Ukraine (SASU), specifically:
2. a) the development and application of a methodology for assessing internal control;
   b) the inclusion of internal control issues as mandatory elements of audit procedures;
   c) the provision of training for SASU staff on internal control assessment.
3. Development and approval of a national action plan to bring internal control and internal audit systems into line with international standards and best practice.
4. Integration of corruption risk management into the overall risk management system within public authorities, in particular:
5. a) the existence of anti-corruption programmes approved by the National Agency for the Prevention of Corruption (NAPC), based on
   b) a systematic analysis of corruption risks;
   c) integration of NACP tools (in particular mechanisms for resolving conflicts of interest and protecting whistleblowers) into internal control and risk management practices;
   d) ensuring the institutional capacity of authorised persons for corruption prevention to implement anti-corruption programmes.

What has been done?

As part of its monitoring activities, the State Audit Service has included questions regarding the state of internal controls at the facilities it inspects. A whistleblower portal is also in operation, although it requires significant further development.

Responsible for analysis: Anti-Corruption Center MEZHA and Transparency International Ukraine (TI).

 

Methodology of expert monitoring of “Kachka-Kos plan” implementation

Assessment approach

Expert evaluation is based on the complex analysis of the actual progress in reforms implementation. Assessment takes into account:

• matching of taken decisions to the goals of “Kachka-Kos plan”;
• institutional and practical changes that emerge as a result of reforms implementation;
• in case the interim benchmarks set by the Council of the EU for Chapters 23 and 24 provide a more detailed explanation of the substance of the reform, compliance with these benchmarks is also taken into account.

Interim steps (for example, preparation of draft laws, drafts of strategic documents or concepts) will be taken into evaluation only in case that experts have the access to the respective documents and can assess their contents. The exception is the initial stage of the work, for which no more than 10% are awarded for each goal.

Expert evaluation is independent and may not coincide with the evaluation of the European Union institutions. Coalition leaves the right to form its own vision of progress, a success indicator for reforms, based on expert analysis.

The “scaling” of reforms

Every point of “Kachka-Kos plan” received a separate weight, considering the scale of reforms, the amount of needed legislative and institutional changes, as well as the importance for European integration of Ukraine.

The maximum overall evaluation of the plan is 100.

The differentiation of scale is as follows:

• 20 – reform regarding adopting comprehensive amendments to the Criminal Procedure Code and other legislation to ensure fast and high-quality justice. Increased value of this reform stems from its complex nature, as it has the biggest number of elements, involves a substantial number of legislative changes and its proper implementation will have a significant impact on the effectiveness of the anti-corruption system and the functioning of the criminal justice system.
• 5 – two reforms that have a narrow and precise amount of work:
  • to appoint without delays internationally vetted judges to the Constitutional Court and members of the High Council of Justice;
  • to Adopt the Anti-Corruption Strategy and the State Anti-Corruption Program.
• 10 – other reforms that are set in the “Kachka-Kos plan”.

Such an approach will show the difference in scale, difficulty and systematic influence of various reforms in terms of European integration of Ukraine.

In case of negative tendencies or reform backtracking, experts have the possibility to review evaluation in the next parts of monitoring.

Evaluation scale of reforms progress

Assessment of every reform is made with the help of a scale that demonstrates the level of actual reform implementation.

Percentage from maximum mark for every goal	Description of the conditions under which points are awarded
0%	No progress has been made, or it is still at the stage of discussing initial implementation ideas; there is a reversal of reform in this area
Up to 10%	There are detailed proposals or a well-thought-out vision for reform, government bodies or senior officials make political statements about their intention to carry out the reform
Up to 20%	The draft documents implementing the changes were officially presented (published); in particular, the bills were tabled in Parliament
Up to 50%	Officially registered draft decisions go through preparatory stages prior to adoption (such as the first reading in Parliament, consideration of amendments for the second reading, review by the European Commission, etc.). If these stages do not improve the quality of the draft and no political commitments are made to rectify the issues, points are not awarded in full.
Up to 100%	The reform has been implemented in the form and to the extent set out in the “Kachka-Kos Plan”. In the event of incomplete implementation, or if experts consider that the chosen approach does not deliver the necessary practical changes, points will not be awarded in full.

*For the assessment of goal 66 «Appoint without delays internationally vetted judges to the Constitutional Court and members of the High Council of Justice» a special methodology was set up.

For this goal 5 points are allocated, that being divided between members’ appointment of HCJ and CCU judges.

Points allocation:

• 2,5 – for filling in vacant positions in HCJ;
• 2,5 –for filling in vacant positions in CCU.

Constitutional Court of Ukraine assessment:

Assessment for the first and second quarters of 2026

As of the time of the assessment (first quarter of 2026), there are 5 vacant posts at the Constitutional Court of Ukraine.

The assessment for the first and second quarters of 2026 is carried out in proportion to the number of filled posts:

• 5 points are awarded for each filled vacancy;
• if all 5 posts are filled, a maximum of 2.5 points is awarded.

Assessment in the third and fourth quarters of 2026

In the third and fourth quarters of 2026, the assessment is carried out taking into account not only the filling of existing vacant posts, but also the timely announcement of competitions for the posts of judges of the Constitutional Court of Ukraine, for which the deadline for announcing the competition falls in 2026.

The maximum score in the third and fourth quarters of 2026 is 2.5 points, of which:

• up to 2 points — for filling existing vacant posts;
• up to 0.5 points — for the timely announcement of competitions for the posts of judges of the Constitutional Court of Ukraine, for which the deadline for announcement falls in 2026.

High Council of Justice assessment:

As of the time of the assessment:

• 2 vacant positions remain unfilled (under the quota allocated by the Ukraine Advocate’s Association);
• 2 vacant positions have been filled.

In August 2026, 3 positions of members of the High Council of Justice will become vacant. That is, a total of 5 vacant positions of members of the High Council of Justice are to be filled in 2026 (excluding the vacant positions filled by the Congress of Judges in March 2026).

For filling 2 vacant positions, 1 point is awarded.

Additionally:

• 1 point is reserved for assessing the filling of vacant posts under the advocates’ quota;
• 0,5 point is reduced due to significant delays on the part of the relevant appointing authority (under the advocates’ quota).

Expert coalition

Expert coalition consists of leading think tanks and civil society organizations that specialises in European integration, as well as relevant reforms (particularly in the areas of the rule of law and the fight against corruption):

• Anti-corruption Center MEZHA
• European Pravda
• National Interest Advocacy Network «ANTS»
• DEJURE Foundation
• New Europe Center
• Centre of Policy and Legal Reform
• Anti-Corruption Action Center
• Transparency International Ukraine

Experts that have participated in the research:

• Martyna Bohuslavets, Olena Kupina (Anti-Corruption Center MEZHA)
• Sergiy Sydorenko (European Pravda)
• Hanna Hopko, Kateryna Musiienko (National Interest Advocacy Network «ANTS»)
• Mykhailo Zhernakov, Kateryna Hasymova, Olha Kovalska (DEJURE Foundation)
• Sergiy Solodkyy, Leo Litra, Anton Alimov, Dmytro Babushko (New Europe Center)
• Viktoriia Melnyk, Roman Smaliuk (Centre of Policy and Legal Reform)
• Daria Kaleniuk, Tetyana Shevchuk, Kateryna Pityk (Anti-Corruption Action Center)
• Andrii Borovyk, Kateryna Ryzhenko (Transparency International Ukraine)

^[1] Interim benchmark