Anti-Corruption Strategy: Government Version Focuses on Digitalization and Institutional Resilience but Overlooks Political Risks

The Anti-Corruption Strategy until 2030 is intended not only to serve as a guideline for state anti-corruption policy but also as a tool for fulfilling Ukraine's international commitments to the EU within the Ukraine Facility program. To this end, the government submitted an alternative draft law No. 15230-1 to the parliament.

The goal of the government strategy is a significant reduction in corruption levels through a combination of institutional development and sectoral reforms in 16 priority areas. However, the status of "alternative" and certain exceptions in the document's text cast doubt on the readiness to eliminate political risks within the criminal justice system.

The draft law is an alternative to the main draft Law of Ukraine "On the Principles of State Anti-Corruption Policy for 2026–2030." At the same time, most of its provisions are identical in content to those contained in draft No. 15230. Therefore, the vast majority of comments and proposals expressed by the Main Directorate in its conclusion on draft law No. 15230 are also relevant for the government version.

16 Priorities and Focus on Digitalization

Draft law No. 15230-1 proposes to approve a framework Anti-Corruption Strategy until 2030, covering key areas of public administration. The document defines two main directions of state policy: the development of a general corruption prevention system and the minimization of corruption risks in the most vulnerable sectors.

Among the priority areas, the Strategy identifies the judicial system and law enforcement agencies, the defense sector and infrastructure restoration, energy, customs and tax sectors, as well as land and agricultural relations.

A separate emphasis is placed on the digitalization of state processes. It is planned to expand the use of automated systems to reduce the influence of the human factor, particularly in customs clearance, construction, and management of state property.

Risk of Political Influence on the Prosecutor General

One of the key differences of the government draft law No. 15230-1 from the main document is the absence of provisions recognizing political influence on the office of the Prosecutor General as one of the corruption risks. At the same time, this issue has been repeatedly raised by Ukraine's international partners.

In particular, the European Commission's 2025 report emphasized the need to ensure the independence of the Prosecutor General's office and to improve legislative mechanisms that would prevent political influence on the activities of prosecution bodies.

The absence of this issue in the Anti-Corruption Strategy for 2026–2030 means that the state does not identify political influence on the prosecution leadership as one of the systemic risks and, accordingly, does not provide specific measures to minimize it.

Blind Spot of the SBI: Exclusion from Strategic Monitoring

In subsection 2.2 of the Strategy ("Prosecutor's Office, Law and Order, and Counteraction to Criminal Offenses"), the government draft omits any mention of the SBI in the context of corruption practices and lack of transparency.

Problem 2.2.6 is formulated so that risks of non-transparent appointment and promotion concern exclusively the National Police of Ukraine. The SBI is thus excluded from the description of corruption threats.

The Strategy does not mention risks of spreading "informal practices" within the Bureau, which effectively supports the current state of management in the body at the strategic level.

The European Commission recommended that Ukraine introduce transparent and merit-based procedures for selecting leadership positions not only in the National Police but also in the SBI (including territorial departments). The government version ignores these recommendations.

Institutional Resilience of NABU, SAP, and NAPC

The draft law also provides for a number of changes aimed at strengthening the institutional capacity of key anti-corruption bodies.

For the National Agency on Corruption Prevention (NAPC), one of the priorities is strengthening independence and financial stability. The document foresees legislative regulation of the agency's financial support, revision of internal control units' work, improvement of the independent external audit mechanism, and expansion of public access to statistical data through publication in open data format.

Regarding the National Anti-Corruption Bureau of Ukraine (NABU), the strategy envisages expanding institutional autonomy and technical capabilities of the bureau. In particular, it proposes reviewing the list of positions under NABU's jurisdiction, ensuring autonomous interception of electronic communications, expanding access to state registries and forensic examinations, as well as strengthening personnel potential and territorial units.

For the Specialized Anti-Corruption Prosecutor's Office (SACPO), the document provides for further strengthening of procedural independence. Specifically, it proposes expanding the powers of the SACPO head, granting the right to independently resolve certain procedural issues, including international cooperation and extension of pre-trial investigation terms. Additionally, similar powers are planned to be granted to the acting head of SACPO, as well as improving the mechanism for conducting independent external audits of the prosecutor's office activities.

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