Ukraine

Country score (EU Average*)

63(72) Political Financing
92(57) Financial Disclosure
71(49) Conflict of Interest
80(59) Freedom of Information
72(63) Public Procurement
78(66) Anti Money Laundering
87(71) Asset Recovery

Country Facts

Income	Lower middle
GNI per capita (2011 PPP $)	8060.00
Population, total	44831159.00
Urban population (% of total)	69.70
Internet users (per 100 people)	52.50
Life expectancy at birth (years)	71.30
Mean years of schooling (years)	11.3
Global Competitiveness Index	3.9

Sources: World Bank, UNDP, WEF.

Political Financing

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Bans and limits on private income						78
Public funding						25
Regulations on spending						50
Reporting, oversight and sanctions						100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Bans and limits on private income
Is there a ban on donations from foreign interests to political parties?	Yes. Foreign states, foreign legal entities, entities with at least 10% non-resident ownership or voting rights, foreign-controlled entities, and non-citizens/stateless persons are barred from supporting political parties. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(5), (7))
Is there a ban on donations from foreign interests to candidates?	Yes. Presidential and parliamentary candidate funds cannot receive contributions from persons barred from supporting parties; local candidate funds expressly ban foreigners and stateless persons. (Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(1); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(5), (7))
Is there a ban on corporate donations to political parties?	No. There is no blanket ban on all corporate donations to parties; only specified legal entities are prohibited, such as state or municipal entities, partly state-owned entities, foreign-linked entities, and government contractors. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(2)-(5), (9))
Is there a ban on corporate donations to candidates?	No. Corporate donations are not banned for all candidates across all elections: presidential and parliamentary funds follow party-donor eligibility, while local-election candidate funds ban legal entities. (Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(3); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1))
Is there a ban on donations from corporations with government contracts to political parties?	Yes. Legal entities with public procurement contracts above the statutory threshold are barred from contributing to parties during the contract and for one year after it ends. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(9))
Is there a ban on donations from corporations of partial government ownership to political parties?	Yes. Legal entities with at least 10% state or local-government ownership or voting rights may not support parties. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(3))
Is there a ban on donations from corporations with government contracts to candidates?	Yes. Presidential and parliamentary candidate funds may not receive contributions from persons barred from supporting parties, which includes legal entities with qualifying public procurement contracts; local candidate funds ban legal entities altogether. (Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(3); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(9))
Is there a ban on donations from corporations of partial government ownership to candidates?	Yes. Presidential and parliamentary candidate funds may not receive contributions from persons barred from supporting parties, which includes partly state-owned legal entities; local candidate funds ban legal entities altogether. (Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(3); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(3))
Is there a ban on donations from Trade Unions to political parties?	No. The party-finance law does not expressly prohibit trade unions from contributing as such. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1))
Is there a ban on donations from Trade Unions to candidates?	No. There is no explicit trade-union ban for all candidates; local-election candidate funds ban legal entities generally, but presidential and parliamentary rules rely on party-donor prohibitions that do not expressly name trade unions. (Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(3); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1))
Is there a ban on anonymous donations to political parties?	Yes. Anonymous persons or persons using a pseudonym may not make contributions to parties. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(7))
Is there a ban on anonymous donations to candidates?	Yes. Presidential and parliamentary candidate funds can receive contributions only from persons eligible to support parties, excluding anonymous donors; local candidate funds expressly ban anonymous donors. (Electoral Code of Ukraine, Arts. 96(3), 152(3)-(4), 215(3)(2), 215(4); Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(7))
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)?	Yes. Contributions from public authorities, local self-government bodies, and state or municipal enterprises, institutions, and organizations are prohibited; candidate funds likewise cannot receive from prohibited party donors or, in local elections, from legal entities. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(1)-(3); Electoral Code of Ukraine, Arts. 96(3), 152(3), 215(3)(3))
Is there a ban on any other form of donation?	Yes. Beyond foreign, anonymous and state-resource restrictions, the law contains additional explicit donor prohibitions and eligibility restrictions. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(1)(4), (6), (8), (10))
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)?	Yes. Annual donations to a political party are capped for both citizens and legal entities. (Law of Ukraine "On Political Parties in Ukraine", Art. 15(3)-(4))
Is there a limit on the amount a donor can contribute to a political party in relation to an election?	Yes. For election-related party funds, donor contributions are capped: parliamentary election funds use the maximum annual party-donation ceiling, and local-election party funds cap each natural person’s contribution to one fund. (Electoral Code of Ukraine, Arts. 152(2), 215(2))
Is there a limit on the amount a donor can contribute to a candidate?	Yes. Donor contributions to candidate election funds are capped for presidential, parliamentary, and local elections. (Electoral Code of Ukraine, Arts. 96(2), 152(2), 215(2))
Public funding
Eligibility criteria for direct public funding to political parties: Share of votes in previous election	Yes. A party qualifies for state funding of its statutory activities if its nationwide party list received at least 5% of valid votes in the last regular or early parliamentary election. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-3(1))
Eligibility criteria for direct public funding to political parties: Representation in elected body	No. The law does not make representation in an elected body the criterion; it uses a vote-share threshold in the last parliamentary election. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-3(1))
Eligibility criteria for direct public funding to political parties: Participation in election	No. Mere participation in an election is not sufficient. The party list must receive at least 5% of valid votes in the last parliamentary election. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-3(1))
Eligibility criteria for direct public funding to political parties: Number of candidates	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election	No. The law does not use a share of seats as the eligibility rule for state funding of statutory activities; it uses a vote-share threshold. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-3(1))
Eligibility criteria for direct public funding to political parties: Share of votes in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party	No. Registration is a general condition for party legal existence, but the funding entitlement rule is expressly tied to the vote-share threshold in the last parliamentary election. (Law of Ukraine "On Political Parties in Ukraine", Arts. 11, 17-3(1))
Eligibility criteria for direct public funding to political parties: Share of seats in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other	Yes. To receive the budget funds, the party must open a separate bank account in national currency and submit the bank certificate for that account. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-3(2)-(3))
Allocation calculations for direct public funding to political parties: Proportional to votes received	Yes. The main component of annual state funding is distributed proportionally to the number of valid votes cast for eligible party lists in the nationwide constituency. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1)(2))
Allocation calculations for direct public funding to political parties: Equal	Yes. A separate tranche equal to 10% of the annual amount is distributed equally among eligible parties that satisfy the statutory gender-balance condition among elected MPs. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1)(1))
Allocation calculations for direct public funding to political parties: Proportional to seats received	No. The allocation rule is based on votes, not on seats won. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1)(2))
Allocation calculations for direct public funding to political parties: Flat rate by votes received	No. The law does not set a flat-rate amount per vote; it provides proportional allocation by votes. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1)(2))
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed	No. Reimbursement of campaign expenses exists as a separate form of state funding for parliamentary-election agitation, but it is not the allocation formula for direct public funding of parties’ statutory activities. (Law of Ukraine "On Political Parties in Ukraine", Arts. 17-1(2), 17-4, 17-5)
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other	No. The law provides only an equal gender-related tranche and a proportional-by-votes tranche; no other allocation method is expressly established. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1))
Earmarking provisions for direct public funding to political parties: Campaign spending	Yes. Direct public funding includes reimbursement of a political party’s election-campaign expenses in parliamentary elections. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-1(2); Art. 17-4)
Earmarking provisions for direct public funding to political parties: Ongoing party activities	Yes. The law expressly finances parties’ statutory activities that are not connected with participation in elections. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-1(1))
Earmarking provisions for direct public funding to political parties: Intra-party institution	No. The law finances statutory activities generally, including staff costs of statutory bodies, but it does not earmark a separate share for intra-party institutions as such. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-1(1))
Earmarking provisions for direct public funding to political parties: Other	No. No other specific earmarking category for direct public funding is expressly established beyond statutory activity and campaign-expense reimbursement. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-1(1)-(2))
Allocation criteria for free or subsidized access to media for political parties: Equal	No. Equal-treatment rules concern paid media access, not an allocation rule for free or subsidized media access for political parties. (Electoral Code of Ukraine, Art. 54(1)-(4))
Allocation criteria for free or subsidized access to media for political parties: Number of candidates	No. No binding provision allocates free or subsidized media access to parties according to the number of candidates. (Electoral Code of Ukraine, Art. 54(1)-(4))
Allocation criteria for free or subsidized access to media for political parties: Share of seats	No. No binding provision allocates free or subsidized media access to parties according to their share of seats. (Electoral Code of Ukraine, Art. 54(1)-(4))
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election	No. No binding provision allocates free or subsidized media access to parties according to their vote share in the preceding election. (Electoral Code of Ukraine, Art. 54(1)-(4))
Allocation criteria for free or subsidized access to media for political parties: Other	No. No other allocation criterion for free or subsidized media access to political parties is expressly established. (Electoral Code of Ukraine, Art. 54(1)-(4))
Are there provisions for free or subsidized access to media for candidates?	Yes. A binding rule provides state-funded broadcast debates for candidates in the second round of presidential elections. (Electoral Code of Ukraine, Art. 108(1)-(5))
Provisions for any other form of indirect public funding: Premises for campaign meetings	No. Candidates and parties may rent premises for campaign events from any owner, but the law does not provide free or subsidized premises. (Electoral Code of Ukraine, Art. 51(7)-(9))
Provisions for any other form of indirect public funding: Space for campaign materials	Yes. Public authorities must allocate places and equip stands or notice boards in public places for campaign materials. (Electoral Code of Ukraine, Art. 53(3))
Provisions for any other form of indirect public funding: Tax relief	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised transport	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost	No. Absent from legal framework
Provisions for any other form of indirect public funding: Other	No. No other indirect public-funding category is expressly established in the legal provisions identified for this section beyond campaign-material display space. (Electoral Code of Ukraine, Art. 53(3))
Is the provision of direct public funding to political parties related to gender equality among candidates?	Yes. Ten percent of annual public funding is distributed equally among eligible parties whose elected MPs meet the gender-balance threshold. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1))
Are there provisions for other financial advantages to encourage gender equality in political parties?	No. The law ties part of direct public funding to gender balance, but no separate other financial advantage for gender equality in political parties was identified. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-5(1))
Regulations on spending
Is there a ban on vote buying?	Yes. Vote buying is criminalized as offering, promising, giving, soliciting or receiving undue advantage for actions related to the direct exercise of electoral rights. (Criminal Code of Ukraine, Art. 160)
Are there bans on state resources being used in favour or against a political party or candidate?	Yes. Public authorities and officials are barred from participating in campaigning in working time, and campaigning for or against parties or candidates is prohibited at events organized by public bodies and on public premises. (Election Code of Ukraine, Art. 12(5)(2)-(4), Art. 57(1)(2), para. 2, Art. 57(15)-(16); Law of Ukraine "On Political Parties in Ukraine", Art. 4(2))
Are there limits on the amount a political party can spend?	No. The code regulates use of party election-fund money, but no explicit overall spending ceiling for a political party was identified. (Election Code of Ukraine, Arts. 150(1), 152(1)-(2), (9))
Are there limits on the amount a candidate can spend?	No. Spending caps were identified for presidential candidates and for candidates’ own funds in parliamentary elections, but not for all candidates as a general rule. (Election Code of Ukraine, Art. 96(1), para. 3; Art. 152(1))
Reporting, oversight and sanctions
Do political parties have to report regularly on their finances?	Yes. Political parties must submit a quarterly report on assets, income, expenditures and financial liabilities to the NACP. (Law of Ukraine "On Political Parties in Ukraine", Art. 17)
Do political parties have to report on their finances in relation to election campaigns?	Yes. Party election-fund managers must submit interim and final financial reports in parliamentary and local elections. (Election Code of Ukraine, Art. 153(2)-(5), Art. 214(4)-(5))
Do candidates have to report on their campaign finances?	Yes. Candidates’ election-fund managers must submit interim and final campaign-finance reports in presidential, parliamentary and local elections. (Election Code of Ukraine, Art. 97(2)-(5), Art. 153(6), Art. 214(6))
Is information in reports from political parties and/or candidates to be made public?	Yes. Party reports are placed in the open state register, and election-fund reports are published online after receipt. (Law of Ukraine "On Political Parties in Ukraine", Art. 17; Election Code of Ukraine, Art. 153(5), Art. 214(10))
Must reports from political parties and/or candidates reveal the identity of donors?	Yes. The law requires campaign-finance reports to state the contributor’s name, and party reports’ contribution information is publicly accessible subject only to limited redactions of tax number, address and date of birth. (Election Code of Ukraine, Art. 214(7), (10); Law of Ukraine "On Political Parties in Ukraine", Art. 17(11)(2), (15)-(16))
Institutions receiving financial reports from political parties and/or candidates
Institutions receiving financial reports from political parties and/or candidates: Electoral Management Board	Yes. Election-finance reports are submitted to the Central Election Commission or territorial election commissions, depending on the election. (Election Code of Ukraine, Art. 97(2), Art. 153(2), (5)-(6), Art. 214(4)-(6))
Institutions receiving financial reports from political parties and/or candidates: Auditing agency	No. The Accounting Chamber audits use of public funds for parties’ statutory activities, but the law does not designate an auditing agency as the recipient of parties’ or candidates’ financial reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-9, Art. 18)
Institutions receiving financial reports from political parties and/or candidates: Ministry	No. The law does not designate a ministry as the recipient of parties’ or candidates’ financial reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 17; Election Code of Ukraine, Arts. 97, 153, 214)
Institutions receiving financial reports from political parties and/or candidates: Special institution	Yes. Political parties’ regular reports are submitted to the National Agency on Corruption Prevention, and certain national-election finance reports are also filed with it. (Law of Ukraine "On Political Parties in Ukraine", Art. 17; Election Code of Ukraine, Art. 97(2), Art. 153(2), (5))
Institutions receiving financial reports from political parties and/or candidates: Court	No. The law does not designate a court as the body that receives parties’ or candidates’ financial reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 17; Election Code of Ukraine, Arts. 97, 153, 214)
Institutions receiving financial reports from political parties and/or candidates: Other	No. Apart from election commissions and the NACP, no other institution category is clearly designated in the law as the recipient of parties’ or candidates’ financial reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 17; Election Code of Ukraine, Arts. 97(2), 153(2), 214(4)-(6))
Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court	No. Courts adjudicate cases brought by other bodies, such as claims on misuse of public funding and cases on party prohibition, but no rule makes a court the institution that examines reports or investigates violations. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-9(2), Art. 21(1))
Institution responsible for examining financial reports and/or investigating violations: Ministry	No. The registration authority supervises compliance with the Constitution, laws and party statutes, but financial-report examination and political-finance compliance control are assigned elsewhere. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(1), (4))
Institution responsible for examining financial reports and/or investigating violations: Auditing agency	Yes. The Accounting Chamber is expressly tasked with controlling the lawful and targeted use of state-budget funds allocated for parties’ statutory activities. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-9(1), Art. 18(1)(3))
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body	Yes. The CEC and other election commissions oversee timely submission, proper form and accuracy of interim and final election-fund reports within the electoral process. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(2))
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose	Yes. NACP is expressly responsible for enforcing political-finance restrictions and for checking the timeliness, completeness, form and accuracy of party and election-fund reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(4))
Institution responsible for examining financial reports and/or investigating violations: Other	No. Article 18 names the competent control bodies; no additional body outside the listed categories was identified for report examination or investigation. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1))
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court	Yes. Courts have a formal role because they hear administrative-offence cases under Articles 212-15 and 212-21 and decide claims on misuse of public funding or party prohibition. (Code of Ukraine on Administrative Offenses, Art. 221; Law of Ukraine "On Political Parties in Ukraine", Art. 17-9(2), Art. 21(1), Art. 24)
Institutions with a formal role in political finance oversight: Ministry	Yes. The state registration authority formally supervises party compliance with the Constitution, laws and party statutes and may seek prohibition or cancellation of registration in court. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(1), Art. 21(1), Art. 24)
Institutions with a formal role in political finance oversight: Auditing agency	Yes. The Accounting Chamber has a formal oversight role over the lawful and targeted use of public funds allocated to political parties. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-9(1), Art. 18(1)(3))
Institutions with a formal role in political finance oversight: EMB	Yes. Election commissions have a formal oversight role over election-fund reporting by monitoring submission deadlines, format and accuracy. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(2))
Institutions with a formal role in political finance oversight: Institution for this purpose	Yes. NACP has a formal oversight role over party funding restrictions, public-funding use and the checking of party and election-fund reports. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1)(4), Art. 17-7, Art. 17-8)
Institutions with a formal role in political finance oversight: Other	No. No other institution with a distinct formal political-finance oversight role was clearly identified beyond the categories listed in the law. (Law of Ukraine "On Political Parties in Ukraine", Art. 18(1))
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines	Yes. Administrative and criminal fines are expressly provided for political-finance breaches, including unlawful contributions and reporting violations. (Code of Ukraine on Administrative Offenses, Art. 212-15, Art. 212-21; Criminal Code of Ukraine, Art. 159-1)
Sanctions for political finance infractions: Loss of public funding	Yes. State funding for a party’s statutory activities may be suspended or terminated for specified reporting and compliance breaches. (Law of Ukraine "On Political Parties in Ukraine", Art. 17-7, Art. 17-8)
Sanctions for political finance infractions: Penal/Criminal	Yes. Criminal liability applies for unlawful financing of a political party or election campaigning and for bribery of voters or election-commission members. (Criminal Code of Ukraine, Art. 159-1, Art. 160)
Sanctions for political finance infractions: Forfeiture	Yes. Unlawful contributions or campaign support are subject to confiscation, and criminal-law measures for legal entities include forfeiture of property in relevant cases. (Code of Ukraine on Administrative Offenses, Art. 212-15; Criminal Code of Ukraine, Art. 96-6, Art. 96-8)
Sanctions for political finance infractions: Deregistration of party	No. Cancellation of party registration is tied to registration defects or failure to nominate candidates for ten years, not to political-finance infractions. (Law of Ukraine "On Political Parties in Ukraine", Art. 24)
Sanctions for political finance infractions: Loss of elected office	No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party	No. The party law provides warnings and prohibition, but not suspension of a political party as a sanction. (Law of Ukraine "On Political Parties in Ukraine", Art. 19, Art. 20, Art. 21)
Sanctions for political finance infractions: Loss of nomination of candidate	No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights	No. The Criminal Code allows deprivation of the right to hold certain positions or engage in certain activities, not a general loss of political rights. (Criminal Code of Ukraine, Art. 159-1)
Sanctions for political finance infractions: Other	Yes. The party law also provides warnings and orders to eliminate violations as distinct measures apart from fines, criminal penalties and funding loss. (Law of Ukraine "On Political Parties in Ukraine", Art. 19, Art. 20)

Legislation

*Last update: 2017

Financial Disclosure

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Disclosure items						59
Filing frequency						100
Sanctions						100
Monitoring and Oversight						100
Public access to declarations						100
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State						92
Ministers						92
Members of Parliament						92
Civil servants						92

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Disclosure items
Spouses and children included in disclosure	Yes . The declaration must include not only the official’s assets but also those of family members, defined broadly to include spouse and dependent children. This significantly expands transparency beyond the individual officeholder. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income and Assets
Real estate	Yes. All immovable property (owned or used), including land, houses, apartments, must be declared regardless of location (domestic or abroad). (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Movable assets	Yes. Valuable movable property (e.g., vehicles, jewelry, artworks) must be declared when exceeding legally defined thresholds, ensuring proportionality. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cash	Yes. Cash holdings must be declared when exceeding a statutory threshold, addressing risks of undeclared liquidity. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Loans and Debts	Yes. Financial liabilities, including loans, credits, and other obligations, must be disclosed, allowing assessment of financial exposure and risks. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income from outside employment/assets	Yes. All sources of income must be declared, including passive income (dividends, rent, interest), ensuring full visibility of financial flows. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Incompatibilities
Gifts received as a public official	Yes. Gifts are strictly regulated; only permissible within limits and must be declared when exceeding thresholds. This aims to prevent undue influence. (Art 23, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Private firm ownership and/or stock holdings	Yes. Corporate rights, shares, and beneficial ownership in private companies must be declared, enabling scrutiny of potential economic influence. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ownership of state-owned enterprises (SOEs)	Yes. Participation in any legal entity, including state-owned enterprises, must be declared if it constitutes a corporate right or financial interest. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Holding government contracts	No. The law does not explicitly require disclosure of “government contracts” as such, but any income or financial interest arising from such contracts must be declared. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Board member, advisor, or company officer of private firm	Yes. Positions held in companies or organizations must be declared, which allows identification of institutional links and potential conflicts. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Post-employment	Yes. Cooling-off rules prohibit certain activities after leaving office (e.g., working for entities previously regulated), reducing revolving-door risks. 2024: Yes (Art 26, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Simultaneously holding policy-making position and policy-executing position	Yes. The law imposes incompatibility rules preventing accumulation of conflicting public roles. (Art 25, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Participating in official decision-making processes that affect private interests	Yes. Officials must avoid and disclose conflicts of interest and abstain from decision-making where private interests are involved. (Art 28, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Concurrent employment of family members in public sector	No. The law regulates nepotism and direct subordination, but does not create a standalone disclosure obligation in the asset declaration. (Art 27, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing frequency
Filing required upon taking office	Yes. Initial declaration must be submitted upon entering office, establishing a baseline of assets. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required upon leaving office	Yes. A final declaration ensures monitoring of asset evolution during tenure. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required annually	Yes. Annual declarations are mandatory, ensuring continuous monitoring over time. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Significant changes in assets must be reported within a short timeframe, improving real-time transparency. (Art 52, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative penalties (fines) apply for delays in submission. (Art. 172-6, Code of Administrative Offenses.)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Failure to submit a declaration may lead to criminal liability. (Art. 366-3, Criminal Code.)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Intentional submission of false information is criminally punishable. (Art. 366-2, Criminal Code.)
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations are submitted electronically to the Unified State Register of Declarations, administered by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Enforcement body explicitly identified	Yes. The NACP is responsible for oversight, while law enforcement bodies handle criminal violations. (Art 11 and 12, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying submission	Yes. The NACP checks whether declarations are submitted on time and in proper form. (Art 48, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying accuracy	Yes. The NACP conducts full verification, including cross-checking with registries and financial dataT. (Art 50, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Public access to declarations
Public availability	Yes. Declarations are publicly accessible online, which is a key transparency feature of the Ukrainian system. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Timing of information release specified	Yes. Declarations are published shortly after submission in the public register. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Location(s) of access specified	Yes. Access is provided via the official online register of declarations managed by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cost of access specified	Yes. Access is explicitly free of charge, ensuring open public scrutiny. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ministers
Disclosure items
Spouses and children included in disclosure	Yes . The declaration must include not only the official’s assets but also those of family members, defined broadly to include spouse and dependent children. This significantly expands transparency beyond the individual officeholder. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income and Assets
Real estate	Yes. All immovable property (owned or used), including land, houses, apartments, must be declared regardless of location (domestic or abroad). (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Movable assets	Yes. Valuable movable property (e.g., vehicles, jewelry, artworks) must be declared when exceeding legally defined thresholds, ensuring proportionality. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cash	Yes. Cash holdings must be declared when exceeding a statutory threshold, addressing risks of undeclared liquidity. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Loans and Debts	Yes. Financial liabilities, including loans, credits, and other obligations, must be disclosed, allowing assessment of financial exposure and risks. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income from outside employment/assets	Yes. All sources of income must be declared, including passive income (dividends, rent, interest), ensuring full visibility of financial flows. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Incompatibilities
Gifts received as a public official	Yes. Gifts are strictly regulated; only permissible within limits and must be declared when exceeding thresholds. This aims to prevent undue influence. (Art 23, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Private firm ownership and/or stock holdings	Yes. Corporate rights, shares, and beneficial ownership in private companies must be declared, enabling scrutiny of potential economic influence. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ownership of state-owned enterprises (SOEs)	Yes. Participation in any legal entity, including state-owned enterprises, must be declared if it constitutes a corporate right or financial interest. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Holding government contracts	No. The law does not explicitly require disclosure of “government contracts” as such, but any income or financial interest arising from such contracts must be declared. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Board member, advisor, or company officer of private firm	Yes. Positions held in companies or organizations must be declared, which allows identification of institutional links and potential conflicts. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Post-employment	Yes. Cooling-off rules prohibit certain activities after leaving office (e.g., working for entities previously regulated), reducing revolving-door risks. 2024: Yes (Art 26, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Simultaneously holding policy-making position and policy-executing position	Yes. The law imposes incompatibility rules preventing accumulation of conflicting public roles. (Art 25, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Participating in official decision-making processes that affect private interests	Yes. Officials must avoid and disclose conflicts of interest and abstain from decision-making where private interests are involved. (Art 28, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Concurrent employment of family members in public sector	No. The law regulates nepotism and direct subordination, but does not create a standalone disclosure obligation in the asset declaration. (Art 27, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing frequency
Filing required upon taking office	Yes. Initial declaration must be submitted upon entering office, establishing a baseline of assets. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required upon leaving office	Yes. A final declaration ensures monitoring of asset evolution during tenure. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required annually	Yes. Annual declarations are mandatory, ensuring continuous monitoring over time. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Significant changes in assets must be reported within a short timeframe, improving real-time transparency. (Art 52, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative penalties (fines) apply for delays in submission. (Art. 172-6, Code of Administrative Offenses.)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Failure to submit a declaration may lead to criminal liability. (Art. 366-3, Criminal Code.)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Intentional submission of false information is criminally punishable. (Art. 366-2, Criminal Code.)
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations are submitted electronically to the Unified State Register of Declarations, administered by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Enforcement body explicitly identified	Yes. The NACP is responsible for oversight, while law enforcement bodies handle criminal violations. (Art 11 and 12, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying submission	Yes. The NACP checks whether declarations are submitted on time and in proper form. (Art 48, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying accuracy	Yes. The NACP conducts full verification, including cross-checking with registries and financial dataT. (Art 50, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Public access to declarations
Public availability	Yes. Declarations are publicly accessible online, which is a key transparency feature of the Ukrainian system. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Timing of information release specified	Yes. Declarations are published shortly after submission in the public register. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Location(s) of access specified	Yes. Access is provided via the official online register of declarations managed by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cost of access specified	Yes. Access is explicitly free of charge, ensuring open public scrutiny. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Members of Parliament
Disclosure items
Spouses and children included in disclosure	Yes . The declaration must include not only the official’s assets but also those of family members, defined broadly to include spouse and dependent children. This significantly expands transparency beyond the individual officeholder. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income and Assets
Real estate	Yes. All immovable property (owned or used), including land, houses, apartments, must be declared regardless of location (domestic or abroad). (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Movable assets	Yes. Valuable movable property (e.g., vehicles, jewelry, artworks) must be declared when exceeding legally defined thresholds, ensuring proportionality. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cash	Yes. Cash holdings must be declared when exceeding a statutory threshold, addressing risks of undeclared liquidity. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Loans and Debts	Yes. Financial liabilities, including loans, credits, and other obligations, must be disclosed, allowing assessment of financial exposure and risks. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income from outside employment/assets	Yes. All sources of income must be declared, including passive income (dividends, rent, interest), ensuring full visibility of financial flows. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Incompatibilities
Gifts received as a public official	Yes. Gifts are strictly regulated; only permissible within limits and must be declared when exceeding thresholds. This aims to prevent undue influence. (Art 23, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Private firm ownership and/or stock holdings	Yes. Corporate rights, shares, and beneficial ownership in private companies must be declared, enabling scrutiny of potential economic influence. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ownership of state-owned enterprises (SOEs)	Yes. Participation in any legal entity, including state-owned enterprises, must be declared if it constitutes a corporate right or financial interest. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Holding government contracts	No. The law does not explicitly require disclosure of “government contracts” as such, but any income or financial interest arising from such contracts must be declared. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Board member, advisor, or company officer of private firm	Yes. Positions held in companies or organizations must be declared, which allows identification of institutional links and potential conflicts. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Post-employment	Yes. Cooling-off rules prohibit certain activities after leaving office (e.g., working for entities previously regulated), reducing revolving-door risks. 2024: Yes (Art 26, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Simultaneously holding policy-making position and policy-executing position	Yes. The law imposes incompatibility rules preventing accumulation of conflicting public roles. (Art 25, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Participating in official decision-making processes that affect private interests	Yes. Officials must avoid and disclose conflicts of interest and abstain from decision-making where private interests are involved. (Art 28, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Concurrent employment of family members in public sector	No. The law regulates nepotism and direct subordination, but does not create a standalone disclosure obligation in the asset declaration. (Art 27, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing frequency
Filing required upon taking office	Yes. Initial declaration must be submitted upon entering office, establishing a baseline of assets. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required upon leaving office	Yes. A final declaration ensures monitoring of asset evolution during tenure. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required annually	Yes. Annual declarations are mandatory, ensuring continuous monitoring over time. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Significant changes in assets must be reported within a short timeframe, improving real-time transparency. (Art 52, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative penalties (fines) apply for delays in submission. (Art. 172-6, Code of Administrative Offenses.)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Failure to submit a declaration may lead to criminal liability. (Art. 366-3, Criminal Code.)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Intentional submission of false information is criminally punishable. (Art. 366-2, Criminal Code.)
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations are submitted electronically to the Unified State Register of Declarations, administered by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Enforcement body explicitly identified	Yes. The NACP is responsible for oversight, while law enforcement bodies handle criminal violations. (Art 11 and 12, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying submission	Yes. The NACP checks whether declarations are submitted on time and in proper form. (Art 48, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying accuracy	Yes. The NACP conducts full verification, including cross-checking with registries and financial dataT. (Art 50, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Public access to declarations
Public availability	Yes. Declarations are publicly accessible online, which is a key transparency feature of the Ukrainian system. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Timing of information release specified	Yes. Declarations are published shortly after submission in the public register. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Location(s) of access specified	Yes. Access is provided via the official online register of declarations managed by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cost of access specified	Yes. Access is explicitly free of charge, ensuring open public scrutiny. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Civil servants
Disclosure items
Spouses and children included in disclosure	Yes . The declaration must include not only the official’s assets but also those of family members, defined broadly to include spouse and dependent children. This significantly expands transparency beyond the individual officeholder. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income and Assets
Real estate	Yes. All immovable property (owned or used), including land, houses, apartments, must be declared regardless of location (domestic or abroad). (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Movable assets	Yes. Valuable movable property (e.g., vehicles, jewelry, artworks) must be declared when exceeding legally defined thresholds, ensuring proportionality. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cash	Yes. Cash holdings must be declared when exceeding a statutory threshold, addressing risks of undeclared liquidity. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Loans and Debts	Yes. Financial liabilities, including loans, credits, and other obligations, must be disclosed, allowing assessment of financial exposure and risks. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Income from outside employment/assets	Yes. All sources of income must be declared, including passive income (dividends, rent, interest), ensuring full visibility of financial flows. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Incompatibilities
Gifts received as a public official	Yes. Gifts are strictly regulated; only permissible within limits and must be declared when exceeding thresholds. This aims to prevent undue influence. (Art 23, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Private firm ownership and/or stock holdings	Yes. Corporate rights, shares, and beneficial ownership in private companies must be declared, enabling scrutiny of potential economic influence. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ownership of state-owned enterprises (SOEs)	Yes. Participation in any legal entity, including state-owned enterprises, must be declared if it constitutes a corporate right or financial interest. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Holding government contracts	No. The law does not explicitly require disclosure of “government contracts” as such, but any income or financial interest arising from such contracts must be declared. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Board member, advisor, or company officer of private firm	Yes. Positions held in companies or organizations must be declared, which allows identification of institutional links and potential conflicts. (Art 46, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Post-employment	Yes. Cooling-off rules prohibit certain activities after leaving office (e.g., working for entities previously regulated), reducing revolving-door risks. 2024: Yes (Art 26, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Simultaneously holding policy-making position and policy-executing position	Yes. The law imposes incompatibility rules preventing accumulation of conflicting public roles. (Art 25, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Participating in official decision-making processes that affect private interests	Yes. Officials must avoid and disclose conflicts of interest and abstain from decision-making where private interests are involved. (Art 28, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Concurrent employment of family members in public sector	No. The law regulates nepotism and direct subordination, but does not create a standalone disclosure obligation in the asset declaration. (Art 27, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing frequency
Filing required upon taking office	Yes. Initial declaration must be submitted upon entering office, establishing a baseline of assets. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required upon leaving office	Yes. A final declaration ensures monitoring of asset evolution during tenure. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Filing required annually	Yes. Annual declarations are mandatory, ensuring continuous monitoring over time. (Art 45, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Significant changes in assets must be reported within a short timeframe, improving real-time transparency. (Art 52, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	Yes. Administrative penalties (fines) apply for delays in submission. (Art. 172-6, Code of Administrative Offenses.)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	Yes. Failure to submit a declaration may lead to criminal liability. (Art. 366-3, Criminal Code.)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	Yes. Intentional submission of false information is criminally punishable. (Art. 366-2, Criminal Code.)
Monitoring and Oversight
Depository body explicitly identified	Yes. Declarations are submitted electronically to the Unified State Register of Declarations, administered by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Enforcement body explicitly identified	Yes. The NACP is responsible for oversight, while law enforcement bodies handle criminal violations. (Art 11 and 12, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying submission	Yes. The NACP checks whether declarations are submitted on time and in proper form. (Art 48, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Some agency assigned responsibility for verifying accuracy	Yes. The NACP conducts full verification, including cross-checking with registries and financial dataT. (Art 50, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Public access to declarations
Public availability	Yes. Declarations are publicly accessible online, which is a key transparency feature of the Ukrainian system. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Timing of information release specified	Yes. Declarations are published shortly after submission in the public register. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Location(s) of access specified	Yes. Access is provided via the official online register of declarations managed by the NACP. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))
Cost of access specified	Yes. Access is explicitly free of charge, ensuring open public scrutiny. (Art 47, Law of Ukraine “On Prevention of Corruption” No. 1700-VII (2014, as amended))

Legislation

*Last update: 2017

Conflict of Interest

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Restrictions						55
Sanctions						58
Monitoring and Oversight						100
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State						61
Ministers						76
Members of Parliament						76
Civil servants						72

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	Yes. The President is expressly covered by the anti-corruption law and is subject to the general duties on preventing and resolving conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 3(1)(a), 28)
Accepting gifts	Yes. The President may not demand, request, or receive gifts in connection with public functions, except hospitality gifts within the statutory limits. (Law of Ukraine On Prevention of Corruption, Arts. 23, 24)
Private firm ownership and/or stock holdings	No. There is no blanket ban on owning a private firm or holding shares. The law instead requires declaration of equity rights and beneficial ownership, and bans certain outside paid activities and company-body roles. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5), 46(1)(5-1))
Ownership of state-owned enterprises (SOEs)	No. There is no general ban on owning shares in state-owned enterprises. The legal framework bans membership in management or supervisory bodies of profit-making enterprises, not shareholding as such. (Constitution of Ukraine, Art. 103; Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5))
Holding government contracts	No. No ban on all government contracts for the President while in office. The framework instead contains conflict-of-interest duties and declaration requirements. (Law of Ukraine On Prevention of Corruption, Arts. 28, 46(1)(10))
Board member, advisor, or company officer of private firm	Yes. The Constitution bars the President from holding office in state authorities or associations of citizens, from other paid or entrepreneurial activity, and from membership of an administrative body or supervisory board of a profit-making enterprise. (Constitution of Ukraine, Art. 103; Law of Ukraine On Prevention of Corruption, Art. 25)
Post-employment	Yes. A one-year post-employment restriction applies. A former President may not take certain private-sector jobs or business dealings connected with entities he supervised or decided on while in office. (Law of Ukraine On Prevention of Corruption, Art. 26)
Simultaneously holding policy-making position and policy-executing position	Yes. The Constitution makes the office of President incompatible with another representative mandate, office in government authorities or associations of citizens, other paid or entrepreneurial activity, and membership of an administrative body or supervisory board of a profit-making enterprise. (Constitution of Ukraine, Art. 103)
Participating in official decision-making processes that affect private interests	No. The anti-corruption law contains general conflict-of-interest duties, but it separately says that the rules for resolving conflicts of interest in the activity of the President are to be determined by laws governing the status of that office. No presidential recusal rule was in force in 2024. (Law of Ukraine On Prevention of Corruption, Arts. 28, 35-1)
Assisting family or friends in obtaining employment in public sector	No. The law prohibits direct subordination of close persons, but no rule forbids the President from helping family or friends obtain public-sector employment. (Law of Ukraine On Prevention of Corruption, Art. 27)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Fines are expressly provided for violations of anti-corruption restrictions, including outside-activity, gifts, and conflict-of-interest rules. (Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. No administrative or disciplinary sanction specifically applicable to the President under this framework short of criminal liability or constitutional impeachment. The law's general disciplinary language does not translate into an ordinary presidential disciplinary regime. (Law of Ukraine On Prevention of Corruption, Art. 65-1; Constitution of Ukraine, Art. 111)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. No criminal offence consisting simply of breaching these presidential conflict-of-interest restrictions as such. The framework provides general liability clauses and administrative offences only (Law of Ukraine On Prevention of Corruption, Art. 65-1; Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The National Agency on Corruption Prevention monitors compliance with anti-corruption legislation and the prevention and settlement of conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 4, 11)
Enforcement body specified (sanctions, hearings)	Yes. The National Agency on Corruption Prevention can issue mandatory precepts, draw up administrative-offence protocols, request documents, and refer matters for legal liability. (Law of Ukraine On Prevention of Corruption, Arts. 11, 12, 13)
Ministers
Restrictions
General restriction on conflict of interest	Yes. Ministers are expressly covered by the anti-corruption law and are subject to the general duties on preventing and resolving conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 3(1)(a), 28)
Accepting gifts	Yes. Ministers may not demand, request, or receive gifts in connection with public functions, except hospitality gifts within the statutory limits. (Law of Ukraine On Prevention of Corruption, Arts. 23, 24)
Private firm ownership and/or stock holdings	No. There is no blanket ban on owning a private firm or holding shares. The law instead requires declaration of equity rights and beneficial ownership, and bans certain outside paid activities and company-body roles. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5), 46(1)(5-1))
Ownership of state-owned enterprises (SOEs)	No. There is no general ban on owning shares in state-owned enterprises. The legal framework bans membership in management or supervisory bodies of profit-making enterprises, not shareholding as such. (Constitution of Ukraine, Art. 120; Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5))
Holding government contracts	No. No ban on all government contracts for ministers while in office. The framework instead contains conflict-of-interest duties and declaration requirements. (Law of Ukraine On Prevention of Corruption, Arts. 28, 46(1)(10))
Board member, advisor, or company officer of private firm	Yes. The Constitution bars ministers from combining office with other work except teaching, research, and creative activities outside working hours, and from being members of an administrative body or supervisory board of a profit-making enterprise (Constitution of Ukraine, Art. 120; Law of Ukraine On Prevention of Corruption, Art. 25)
Post-employment	Yes. A one-year post-employment restriction applies. Former ministers may not take certain private-sector jobs or business dealings connected with entities they supervised or decided on while in office. (Law of Ukraine On Prevention of Corruption, Art. 26)
Simultaneously holding policy-making position and policy-executing position	Yes. Members of the Cabinet of Ministers of Ukraine may not combine their office with other work except teaching, research, and creative activities outside working hours, and may not be members of an administrative body or supervisory board of a profit-making enterprise. (Constitution of Ukraine, Art. 120)
Participating in official decision-making processes that affect private interests	Yes. Ministers are subject to the general conflict-of-interest duties and must not act or decide in conditions of a real conflict of interest; they must report and settle such conflicts under the law. (Law of Ukraine On Prevention of Corruption, Arts. 28, 29)
Assisting family or friends in obtaining employment in public sector	No. The law prohibits direct subordination of close persons, but no rule that generally forbids ministers from helping family or friends obtain public-sector employment. (Law of Ukraine On Prevention of Corruption, Art. 27)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Fines are expressly provided for violations of anti-corruption restrictions, including outside-activity, gifts, and conflict-of-interest rules. (Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Administrative or disciplinary follow-up is available under the anti-corruption framework. The law provides for bringing persons to disciplinary liability and for mandatory precepts and other enforcement measures by the National Agency on Corruption Prevention. (Law of Ukraine On Prevention of Corruption, Arts. 12, 65-1)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. No criminal offence consisting simply of breaching these ministerial conflict-of-interest restrictions as such. The framework provides general liability clauses and administrative offences (Law of Ukraine On Prevention of Corruption, Art. 65-1; Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The National Agency on Corruption Prevention monitors compliance with anti-corruption legislation and the prevention and settlement of conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 4, 11)
Enforcement body specified (sanctions, hearings)	Yes. The National Agency on Corruption Prevention can issue mandatory precepts, draw up administrative-offence protocols, request documents, and refer matters for legal liability. (Law of Ukraine On Prevention of Corruption, Arts. 11, 12, 13)
Members of Parliament
Restrictions
General restriction on conflict of interest	Yes. Members of Parliament are expressly covered by the anti-corruption law and are subject to the general duties on preventing and resolving conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 3(1)(a), 28)
Accepting gifts	Yes. Members of Parliament may not demand, request, or receive gifts in connection with public functions, except hospitality gifts within the statutory limits. (Law of Ukraine On Prevention of Corruption, Arts. 23, 24)
Private firm ownership and/or stock holdings	No. There is no blanket ban on owning a private firm or holding shares. The law instead requires declaration of equity rights and beneficial ownership, and bans certain outside paid activities and company-body roles. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5), 46(1)(5-1))
Ownership of state-owned enterprises (SOEs)	No. There is no general ban on owning shares in state-owned enterprises. The legal framework bans membership in management or supervisory bodies of profit-making enterprises, not shareholding as such. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5))
Holding government contracts	No. No ban on all government contracts for Members of Parliament while in office. The framework instead contains conflict-of-interest duties and declaration requirements. (Law of Ukraine On Prevention of Corruption, Arts. 28, 46(1)(10))
Board member, advisor, or company officer of private firm	Yes. The Constitution and anti-corruption law restrict other paid work and membership in the management or supervisory bodies of profit-making enterprises (Constitution of Ukraine, Art. 78; Law of Ukraine On Prevention of Corruption, Art. 25)
Post-employment	Yes. A one-year post-employment restriction applies. Former Members of Parliament may not take certain private-sector jobs or business dealings connected with entities they supervised or decided on while in office. (Law of Ukraine On Prevention of Corruption, Art. 26)
Simultaneously holding policy-making position and policy-executing position	Yes. The Constitution provides that a People's Deputy of Ukraine may not have another representative mandate or be in the civil service, and further incompatibility requirements are set by law. (Constitution of Ukraine, Art. 78)
Participating in official decision-making processes that affect private interests	Yes. Members of Parliament are subject to the general conflict-of-interest duties and must not act or decide in conditions of a real conflict of interest; they must report and settle such conflicts under the law. (Law of Ukraine On Prevention of Corruption, Arts. 28, 29)
Assisting family or friends in obtaining employment in public sector	No. The law prohibits direct subordination of close persons, but no stand-alone rule that forbids Members of Parliament from helping family or friends obtain public-sector employment. (Law of Ukraine On Prevention of Corruption, Art. 27)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Fines are expressly provided for violations of anti-corruption restrictions, including outside-activity, gifts, and conflict-of-interest rules. (Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Administrative or disciplinary follow-up is available under the anti-corruption framework. The law provides for bringing persons to disciplinary liability and for mandatory precepts and other enforcement measures by the National Agency on Corruption Prevention. (Law of Ukraine On Prevention of Corruption, Arts. 12, 65-1)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. No criminal offence consisting simply of breaching these parliamentary conflict-of-interest restrictions as such. The framework provides general liability clauses and administrative offences (Law of Ukraine On Prevention of Corruption, Art. 65-1; Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The National Agency on Corruption Prevention monitors compliance with anti-corruption legislation and the prevention and settlement of conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 4, 11)
Enforcement body specified (sanctions, hearings)	Yes. The National Agency on Corruption Prevention can issue mandatory precepts, draw up administrative-offence protocols, request documents, and refer matters for legal liability. (Law of Ukraine On Prevention of Corruption, Arts. 11, 12, 13)
Civil servants
Restrictions
General restriction on conflict of interest	Yes. Civil servants are covered by the anti-corruption law and are subject to the general duties on preventing and resolving conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 3(1)(v), 28)
Accepting gifts	Yes. Civil servants may not demand, request, or receive gifts in connection with public functions, except hospitality gifts within the statutory limits. (Law of Ukraine On Prevention of Corruption, Arts. 23, 24)
Private firm ownership and/or stock holdings	No. There is no blanket ban on owning a private firm or holding shares. The law instead requires declaration of equity rights and beneficial ownership, and bans certain outside paid activities and company-body roles. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5), 46(1)(5-1))
Ownership of state-owned enterprises (SOEs)	No. There is no general ban on owning shares in state-owned enterprises. The legal framework bans membership in management or supervisory bodies of profit-making enterprises, not shareholding as such. (Law of Ukraine On Prevention of Corruption, Arts. 25, 46(1)(5))
Holding government contracts	No. No ban on all government contracts for civil servants while in office. The framework instead contains conflict-of-interest duties and declaration requirements. (Law of Ukraine On Prevention of Corruption, Arts. 28, 46(1)(10))
Board member, advisor, or company officer of private firm	Yes. Civil servants are barred from other paid or entrepreneurial activity except teaching, scientific, or creative work and certain listed practice, and from membership in management or supervisory bodies of profit-making enterprises (Law of Ukraine On Prevention of Corruption, Art. 25)
Post-employment	Yes. A one-year post-employment restriction applies. Former civil servants may not take certain private-sector jobs or business dealings connected with entities they supervised or decided on while in office. (Law of Ukraine On Prevention of Corruption, Art. 26)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework
Participating in official decision-making processes that affect private interests	Yes. Civil servants are subject to the general conflict-of-interest duties and must not act or decide in conditions of a real conflict of interest; they must report and settle such conflicts under the law. (Law of Ukraine On Prevention of Corruption, Arts. 28, 29)
Assisting family or friends in obtaining employment in public sector	No. The law prohibits direct subordination of close persons, but no rule forbids civil servants from helping family or friends obtain public-sector employment. (Law of Ukraine On Prevention of Corruption, Art. 27)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	Yes. Fines are expressly provided for violations of anti-corruption restrictions, including outside-activity, gifts, and conflict-of-interest rules. (Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	Yes. Administrative and disciplinary sanctions are available. Civil servants may be brought to disciplinary liability for breach of official discipline, and anti-corruption law also provides for disciplinary liability for violating its requirements. (Law of Ukraine On Prevention of Corruption, Art. 65-1; Law of Ukraine On Civil Service, Arts. 61, 64-66, 77)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. No criminal offence consisting simply of breaching these civil-service conflict-of-interest restrictions as such. The framework provides general liability clauses and administrative offences (Law of Ukraine On Prevention of Corruption, Art. 65-1; Code of Ukraine on Administrative Offences, Arts. 172-4, 172-5, 172-7)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The National Agency on Corruption Prevention monitors compliance with anti-corruption legislation and the prevention and settlement of conflicts of interest. (Law of Ukraine On Prevention of Corruption, Arts. 4, 11)
Enforcement body specified (sanctions, hearings)	Yes. The National Agency on Corruption Prevention can issue mandatory precepts, draw up administrative-offence protocols, request documents, and refer matters for legal liability; disciplinary sanctions against civil servants are imposed through the civil-service disciplinary system. (Law of Ukraine On Prevention of Corruption, Arts. 11, 12, 13; Law of Ukraine On Civil Service, Arts. 68, 69, 77)

Legislation

*Last update: 2017

Freedom of Information

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Scope and Coverage						100
Information access and release						100
Exceptions and Overrides						100
Sanctions for non-compliance						33
Monitoring and Oversight						67

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope and Coverage
Scope of disclosure
Existence of legal right to access	Yes. 1. Every person shall have the right to address an information provider with an information request, regardless of whether the document in question is related to that person, without specifying the reason for request. (Article 19, Law on Access to Public Information, adopted in 2011)
"Information" or "Documents" is defined	Yes. 1) information possessed by government agencies and other public information providers identified by this Law (hereinafter referred to as information, information providers, etc.); 2) information of public interest (importance), i.e. information that indicates threats to state sovereignty and territorial integrity of Ukraine; enables citizens to make informed political choices; guarantees awareness of events and facts affecting one’s life; ensures realization of constitutional rights, freedoms and duties; helps prevent violations of human rights, deception of the public, hazardous environmental and other consequences of actions of commercial entities, or absence thereof, etc. (Article 1, Law on Access to Public Information, adopted in 2011)
Proactive disclosure is specified	Yes. 2. Information identified by Section 1 of this article shall be subject to obligatory publication on the providers’ official websites immediately following its emergence, and within 5 calendar days following its emergence if published otherwise. (Article 14.2., Law on Access to Public Information, adopted in 2011)
Coverage of public and private sectors
Executive branch	Yes. 1. For the purpose of this Law, information providers shall be understood as: 1) government agencies; 2) legal entities financed by national or local budgets, concerning information on the use of budget finds; 3) legal entities with powers delegated by the government or local selfgovernment institutions according to the law or contract to provide educational, recreational, social, or other government services, concerning information on their performance; 4) commercial entities that have dominant positions in the market, special or exclusive rights, or are natural monopolies, concerning information on supply conditions and prices of goods and services. (Article 12, Law on Access to Public Information, adopted in 2011)
Legislative branch	Yes. 1. For the purpose of this Law, information providers shall be understood as: 1) government agencies; 2) legal entities financed by national or local budgets, concerning information on the use of budget finds; 3) legal entities with powers delegated by the government or local selfgovernment institutions according to the law or contract to provide educational, recreational, social, or other government services, concerning information on their performance; 4) commercial entities that have dominant positions in the market, special or exclusive rights, or are natural monopolies, concerning information on supply conditions and prices of goods and services. (Article 12, Law on Access to Public Information, adopted in 2011)
Judicial branch	Yes. 1. For the purpose of this Law, information providers shall be understood as: 1) government agencies; 2) legal entities financed by national or local budgets, concerning information on the use of budget finds; 3) legal entities with powers delegated by the government or local selfgovernment institutions according to the law or contract to provide educational, recreational, social, or other government services, concerning information on their performance; 4) commercial entities that have dominant positions in the market, special or exclusive rights, or are natural monopolies, concerning information on supply conditions and prices of goods and services. (Article 12, Law on Access to Public Information, adopted in 2011)
Other public bodies	Yes. 1. For the purpose of this Law, information providers shall be understood as: 1) government agencies; 2) legal entities financed by national or local budgets, concerning information on the use of budget finds; 3) legal entities with powers delegated by the government or local selfgovernment institutions according to the law or contract to provide educational, recreational, social, or other government services, concerning information on their performance; 4) commercial entities that have dominant positions in the market, special or exclusive rights, or are natural monopolies, concerning information on supply conditions and prices of goods and services. (Article 12, Law on Access to Public Information, adopted in 2011)
Private sector	Yes. 1. For the purpose of this Law, information providers shall be understood as: 1) government agencies; 2) legal entities financed by national or local budgets, concerning information on the use of budget finds; 3) legal entities with powers delegated by the government or local selfgovernment institutions according to the law or contract to provide educational, recreational, social, or other government services, concerning information on their performance; 4) commercial entities that have dominant positions in the market, special or exclusive rights, or are natural monopolies, concerning information on supply conditions and prices of goods and services. (Article 12, Law on Access to Public Information, adopted in 2011)
Access to specific documents (subject to reactive and/or proactive disclosure)
Draft legal instruments	Yes. 3. Draft laws and regulations submitted to respective providers for consideration shall be published no later than within 30 calendar days before consideration. (Article 14.3 Law on Access to Public Information, adopted in 2011)
Enacted legal instruments	Yes. 1. Information providers shall be obliged to disclose information concerning: 1) organizational structure, mission, functions, authority, main tasks, working areas, and financial resources (structure and amount of budget funds, procedures and mechanisms for their spending, etc.); 2) regulatory principles of activities, regulatory acts and individual legal acts adopted by the provider, and draft resolutions; 3) services provided by those institutions, conditions for their provision, forms and sample documents, instructions for completion thereof; 4) procedures for completion and submission of information requests, and procedures to appeal decisions of the information providers’, their actions or lack thereof; 5) general information about the registration system and types of information possessed by providers; 6) mechanisms or procedures for the society to present its interests or influence in some other way policy development or powers exercised by information providers; 7) plans and meeting agendas; 7 8) locations where requestors can obtain the required forms; 9) general rules and working regulations of the institution; 10) reports, particularly on addressing information requests, etc (Article 14.1 Law on Access to Public Information, adopted in 2011)
Annual budgets	Yes. 1. Information providers shall be obliged to disclose information concerning: 1) organizational structure, mission, functions, authority, main tasks, working areas, and financial resources (structure and amount of budget funds, procedures and mechanisms for their spending, etc.); 2) regulatory principles of activities, regulatory acts and individual legal acts adopted by the provider, and draft resolutions; 3) services provided by those institutions, conditions for their provision, forms and sample documents, instructions for completion thereof; 4) procedures for completion and submission of information requests, and procedures to appeal decisions of the information providers’, their actions or lack thereof; 5) general information about the registration system and types of information possessed by providers; 6) mechanisms or procedures for the society to present its interests or influence in some other way policy development or powers exercised by information providers; 7) plans and meeting agendas; 7 8) locations where requestors can obtain the required forms; 9) general rules and working regulations of the institution; 10) reports, particularly on addressing information requests, etc (Article 14.1 Law on Access to Public Information, adopted in 2011)
Annual chart of accounts (actual expenditures)	Yes. 1. Information providers shall be obliged to disclose information concerning: 1) organizational structure, mission, functions, authority, main tasks, working areas, and financial resources (structure and amount of budget funds, procedures and mechanisms for their spending, etc.); 2) regulatory principles of activities, regulatory acts and individual legal acts adopted by the provider, and draft resolutions; 3) services provided by those institutions, conditions for their provision, forms and sample documents, instructions for completion thereof; 4) procedures for completion and submission of information requests, and procedures to appeal decisions of the information providers’, their actions or lack thereof; 5) general information about the registration system and types of information possessed by providers; 6) mechanisms or procedures for the society to present its interests or influence in some other way policy development or powers exercised by information providers; 7) plans and meeting agendas; 7 8) locations where requestors can obtain the required forms; 9) general rules and working regulations of the institution; 10) reports, particularly on addressing information requests, etc (Article 14.1 Law on Access to Public Information, adopted in 2011)
Annual reports of public entities and programs	Yes. 1. Information providers shall be obliged to disclose information concerning: 1) organizational structure, mission, functions, authority, main tasks, working areas, and financial resources (structure and amount of budget funds, procedures and mechanisms for their spending, etc.); 2) regulatory principles of activities, regulatory acts and individual legal acts adopted by the provider, and draft resolutions; 3) services provided by those institutions, conditions for their provision, forms and sample documents, instructions for completion thereof; 4) procedures for completion and submission of information requests, and procedures to appeal decisions of the information providers’, their actions or lack thereof; 5) general information about the registration system and types of information possessed by providers; 6) mechanisms or procedures for the society to present its interests or influence in some other way policy development or powers exercised by information providers; 7) plans and meeting agendas; 7 8) locations where requestors can obtain the required forms; 9) general rules and working regulations of the institution; 10) reports, particularly on addressing information requests, etc (Article 14.1 Law on Access to Public Information, adopted in 2011)
Information access and release
Procedural access
Universal access (agencies, citizens and non-citizens)	Yes. 1. Every person shall have the right to address an information provider with an information request, regardless of whether the document in question is related to that person, without specifying the reason for request. (Article 19.1, Law on Access to Public Information, adopted in 2011)
Type of request is specified (written, electronic, oral)	Yes. 2. Information requests may be individual or collective. They may be submitted orally, in writing, by mail, fax, phone, e-mail, or by other means at the requestor’s discretion. 3. Oral information requests shall be submitted to get access to operational information or information required in order to prevent unlawful actions or emergencies. 4. Written requests may be submitted at will. (Article 19.2, 19.3, 19.4, Law on Access to Public Information, adopted in 2011)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.)	Yes. 6. If a person is unable to submit a written request for valid reasons (i.e. incapacitation, disability, etc.), it shall be completed by an official dealing with information requests and bear the official’s name and contact phone number. A copy of the request shall be provided to the requestor. (Article 19.6, Law on Access to Public Information, adopted in 2011)
Cost of access is specified (free, request fees, photocopying costs, other administrative costs)	Yes. 1. Requested information shall be provided free of charge. 2. Should the information request require producing copies of documents amounting to more than 50 pages the requestor shall be obliged to reimburse the cost of copying and printing. 3. The cost shall be determined by the respective provider based on fair market value of copying and printing within the limits established by the Cabinet of Ministers of Ukraine. (Article 22, Law on Access to Public Information, adopted in 2011)
Deadlines for release of information
20-day response deadline	Yes. 1. Information providers shall address the request as soon as possible but no later than within 5 business days following receipt of request. 2. If the information request concerns information required for protection of person’s life or freedom, or it is related to the environmental situation, quality of food and household products, accidents, disasters, natural hazards and other emergencies, both real and potential, that threaten people’s security, response shall be given immediately but no later than within 48 hours following receipt of request. 3. Demands for immediate addressing of the request shall be motivated. 4. If the request is for a large volume of information or requires processing of a large amount of data, information providers may extend the term for addressing the request to 20 business days specifying the reason for such extension. Information provider shall immediately notify the requestor as well as the Human Rights Commissioner in writing but no later than within 5 business days. (Article 21 Law on Access to Public Information, adopted in 2011)
Agency granted right to extend response time	Yes. 1. Information providers shall address the request as soon as possible but no later than within 5 business days following receipt of request. 2. If the information request concerns information required for protection of person’s life or freedom, or it is related to the environmental situation, quality of food and household products, accidents, disasters, natural hazards and other emergencies, both real and potential, that threaten people’s security, response shall be given immediately but no later than within 48 hours following receipt of request. 3. Demands for immediate addressing of the request shall be motivated. 4. If the request is for a large volume of information or requires processing of a large amount of data, information providers may extend the term for addressing the request to 20 business days specifying the reason for such extension. Information provider shall immediately notify the requestor as well as the Human Rights Commissioner in writing but no later than within 5 business days. (Article 21 Law on Access to Public Information, adopted in 2011)
Maximum total response time of no more than 40 days	Yes. 1. Information providers shall address the request as soon as possible but no later than within 5 business days following receipt of request. 2. If the information request concerns information required for protection of person’s life or freedom, or it is related to the environmental situation, quality of food and household products, accidents, disasters, natural hazards and other emergencies, both real and potential, that threaten people’s security, response shall be given immediately but no later than within 48 hours following receipt of request. 3. Demands for immediate addressing of the request shall be motivated. 4. If the request is for a large volume of information or requires processing of a large amount of data, information providers may extend the term for addressing the request to 20 business days specifying the reason for such extension. Information provider shall immediately notify the requestor as well as the Human Rights Commissioner in writing but no later than within 5 business days. (Article 21 Law on Access to Public Information, adopted in 2011)
Exceptions and Overrides
Exemptions to disclosure
Existence of secrecy/states secrets law	Yes. Law of Ukraine “On State Secrets” (Закон України «Про державну таємницю») Law No. 3855‑XII of 21 January 1994, amended 2025 (Law of Ukraine “On State Secrets” (Закон України «Про державну таємницю») Law No. 3855‑XII of 21 January 1994, amended 2025)
Existence of personal privacy/data law	Yes. LAW OF UKRAINE On Personal Data Protection no. 2297-VI (LAW OF UKRAINE On Personal Data Protection no. 2297-VI)
Specific exemptions to disclosure	Yes. 1. Restricted information shall include: 1) secret information; 2) confidential information. 2. Secret information shall be understood as legally restricted information the disclosure of which may harm persons, society, and the state. 3. Confidential information shall be understood as restricted information possessed, used and managed by natural persons and legal entities, except government agencies, that may be disclosed at their discretion in keeping with procedures and subject to conditions established by them. Commercial secrets, personal information, or any other confidential information except information of public interest shall be qualified as confidential information. (Article 7 Law on Access to Public Information, adopted in 2011)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.
Appeals
Appeals allowed within public entities	Yes. 1. Information providers’ decisions, actions, or lack thereof may be appealed with the head of the providing entity or a higher authority, if applicable, the Human Rights Commissioner, or a court. (Article 25.1 Law on Access to Public Information, adopted in 2011)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	Yes. 1. Information providers’ decisions, actions, or lack thereof may be appealed with the head of the providing entity or a higher authority, if applicable, the Human Rights Commissioner, or a court. (Article 25.1 Law on Access to Public Information, adopted in 2011)
Judicial appeals mechanism	Yes. 1. Information providers’ decisions, actions, or lack thereof may be appealed with the head of the providing entity or a higher authority, if applicable, the Human Rights Commissioner, or a court. (Article 25.1 Law on Access to Public Information, adopted in 2011)
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	Yes. 1. Persons found to have violated this Law shall bear responsibility as stipulated by the law. 2. Responsibility for violation of the acts related to information access shall be borne by persons found to have committed the following transgressions: 1) unlawful denial of information; 2) providing false information; 3) untimely provided information; 4) deliberate concealment of information; 5) ungrounded refusal to disclose information; 6) ungrounded classification of certain types of information as having restricted data; 7) other violations of the right to access to information and legal interests of natural persons and legal entities. 3. Persons who consider their rights and lawful interests to have been violated by information providers have the right to compensation for material and moral damage in accordance with procedures established by civil law (Article 29 Law on Access to Public Information, adopted in 2011)
Fines are specified for violations of disclosure requirements	No. Absent from legal framework (Absent from legal framework)
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework (Absent from legal framework)
Monitoring and Oversight
Information officers must be appointed in public agencies	Yes. 1. Providers shall be under the obligation to: 5) establish special departments or assign officials to provide access to information to those who request it; (Article 13.1 5) Law on Access to Public Information, adopted in 2011)
Public body that is responsible for applying sanctions	No. Absent from legal framework (Absent from legal framework)
Public body that is responsible for public outreach (raising public awareness)	Yes. In addition to the powers provided by the Law of Ukraine On the Verkhovna Rada Human Rights Commissioner, the Commissioner shall: 1) take part in development and implementation of the national policy to provide access to information; 2) conduct public awareness efforts in mass media, and carry out educational activities related to access to information; 3) take necessary measures to promote access to information; 4) organize trainings for civil servants on securing access to information; 5) carry out academic and expert research of access to information issues; 6) monitor and collate the results of efforts to provide access to information; 7) inspect information providers in the process of addressing information requests and disclosure of information, either following complaints or on his/her own initiative; 8) examine citizens’ complaints about violations of their rights and lawful interests by information providers; 9) maintain and compile records of cases where the right to access to information has been violated, and make proposals for their elimination; 10) cooperate with international organizations and respective foreign institutions on compliance with the international standards for securing access to information. (Article 17.1 Law on Access to Public Information, adopted in 2011)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	No. Absent from legal framework (Absent from legal framework)
Ombudsman involvement in implementation is specified by law	Yes. In addition to the powers provided by the Law of Ukraine On the Verkhovna Rada Human Rights Commissioner, the Commissioner shall: 1) take part in development and implementation of the national policy to provide access to information; 2) conduct public awareness efforts in mass media, and carry out educational activities related to access to information; 3) take necessary measures to promote access to information; 4) organize trainings for civil servants on securing access to information; 5) carry out academic and expert research of access to information issues; 6) monitor and collate the results of efforts to provide access to information; 7) inspect information providers in the process of addressing information requests and disclosure of information, either following complaints or on his/her own initiative; 8) examine citizens’ complaints about violations of their rights and lawful interests by information providers; 9) maintain and compile records of cases where the right to access to information has been violated, and make proposals for their elimination; 10) cooperate with international organizations and respective foreign institutions on compliance with the international standards for securing access to information. (Article 17.1 Law on Access to Public Information, adopted in 2011)
Reporting of data and/or implementation is required	Yes. 2. Information providers shall submit to the Human Rights Commissioner an annual report on their compliance with information requests. The report shall specify the following: 1) the number of information requests received and the number of requests met; 2) the number of rejected requests, with references to the provisions on the basis of which information access was denied; 3) the number of complaints about denying access to information; 4) amount of fees collected for providing requested information; 5) information on compliance with the obligation to publish information; 6) other information at the request of the Human Rights Commissioner unless provision of such information is prohibited by law. (Article 13.2 Law on Access to Public Information, adopted in 2011)

Legislation

*Last update: 2017

Public Procurement

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Scope						98
Information availability						99
Evaluation						81
Open competition						47
Institutional arrangements						36

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS)	UAH 100,000. Below UAH 100,000 (martial law) / UAH 200,000 (peacetime): simplified procedure with reporting or direct contracting; above UAH 100,000: full Prozorro competitive procedure required; draft under Draft Law No. 11520: EUR 2,000–EUR 10,000: request for quotations on Prozorro Market; above EUR 10,000: competitive open tender. (Law No. 922-VIII; CMU Res. No. 1178/2022; Draft Law No. 11520)
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	UAH 1,500,000. The works competitive procurement threshold has remained at UAH 1,500,000 since the 2019 reform; during martial law, CMU Resolution No. 1178/2022 additionally permits direct contracting for critical infrastructure works above UAH 1,500,000 (as extended to 1 March Dec. 2024 by draft CMU decision ); draft under Draft Law No. 11520: EUR 37,500 (~UAH 1,500,000) as the works competitive tender threshold (no structural change to works threshold). (Law No. 922-VIII, Art. 3; CMU Res. No. 1178/2022; draft CMU decision)
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	UAH 100,000. Standard services follow the same thresholds as goods; the Draft Law No. 11520 proposes separate thresholds for specific/social services aligned with EU Directive 2014/24/EU (light-touch regime above EUR 750,000). (Law No. 922-VIII; CMU Res. No. 1178/2022; Draft Law No. 11520)
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	UAH 100,000. All public sector contracting authorities (central, regional, local) apply Law No. 922-VIII; above the thresholds: mandatory Prozorro competitive procedures; below: simplified/direct procedures with varying levels of reporting. (Law No. 922-VIII, Art. 3; CMU Res. No. 1178/2022)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	UAH 100,000. Law No. 922-VIII covers both classical sector and utilities contracting authorities under the same threshold and procedure structure; the Draft Law No. 11520 proposes separate utilities procedures aligned with Directive 2014/25/EU as part of full EU acquis alignment; currently no separate utilities regime. (Law No. 922-VIII; Draft Law No. 11520)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	UAH 200,000. During martial law, defence procurement follows separate special rules; for the purposes of this workbook, the operative lower threshold for goods/services in 2024 is coded at UAH 200,000 and works at UAH 1,500,000, replacing the earlier forward-looking placeholder. (CMU Res. No. 1275/2022 (as applicable in Dec. 2024); Law No. 922-VIII, Art. 3(6))
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	UAH 100,000. Below threshold: simplified or direct procedure; above: full Prozorro competitive procedure; international publication threshold: EUR 140,000 (draft). (Law No. 922-VIII; CMU Res. No. 1178/2022; Draft Law No. 11520)
What are the minimum application thresholds for the procurement type? (Product type WORKS)	UAH 1,500,000. Works threshold unchanged at UAH 1,500,000; (Law No. 922-VIII, Art. 3; CMU Resolution No. 1178/2022)
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	UAH 100,000. Standard services follow goods thresholds; social/specific services to follow a separate higher threshold of EUR 750,000 under Draft Law No. 11520 aligned with EU Directive 2014/24/EU. (Law No. 922-VIII; Draft Law No. 11520)
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. All procurement documentation must be published on Prozorro from the date of notice publication; access is free and unrestricted; the OCDS data standard makes all documents machine-readable and accessible via API; clarifications and amendments are also published through Prozorro. (Law No. 922-VIII; Prozorro system)
Are any of these documents published online at a central place?	Yes. Prozorro: https://prozorro.gov.ua (mandatory central hub; OCDS data); Prozorro Market (e-catalogue system): https://market.prozorro.gov.ua; OCDS Open Data bulk download: https://data.open-contracting.org/en/publication/154; DOZORRO monitoring: https://dozorro.org; Bi-Prozorro analytics: https://bi.prozorro.org; Ministry of Economy (regulatory body): https://me.gov.ua; AMCU (review body): https://amcu.gov.ua (Law No. 922-VIII; Prozorro system; AMCU)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system)	Yes. All contracting authorities must maintain complete procurement files through Prozorro; contract implementation monitoring is tracked through Prozorro; the State Audit Service (SASU) is the primary ex-post monitoring body with access to all Prozorro data; in 2024, SASU's post-hoc focus (81.8% of monitoring initiated after contract conclusion) limits preventive impact; Draft Law No. 11520 requires SASU to explain identified violations to contracting entities, confirm corrections and publish enforcement information. (Law No. 922-VIII; SASU; Draft Law No. 11520; TI Ukraine reports (2024))
Are contracts awarded within a framework agreement published (ie mini contracts)?	Yes. Framework agreement call-off orders are published through Prozorro in OCDS format; the OCDS architecture ensures that all call-off contracts are traceable and downloadable in bulk; the Draft Law No. 11520 introduces updated framework agreement procurement procedures; joint procurement is also a new mechanism draft in Draft Law No. 11520. (Law No. 922-VIII; Prozorro OCDS; Draft Law No. 11520)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	Yes. Law No. 922-VIII requires tenderers to declare subcontractors; subcontractor information is published through Prozorro as part of contract documentation in OCDS format; the open data architecture makes subcontractor data accessible for civil society monitoring (DOZORRO). (Law No. 922-VIII; Prozorro OCDS)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column.	0%. All known subcontractors must be declared regardless of the proportion subcontracted; no percentage threshold. (Law No. 922-VIII)
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. Technical specifications may not refer to a specific manufacturer, origin, process, trademark, patent, type, or place of production in a way that favours or eliminates operators; "or equivalent" must be included. (Law No. 922-VIII)
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No. No explicit SME preference; equal treatment applies; lot division facilitates SME access; the wartime direct contracting model has in practice reduced competitive access, including for SMEs. (Law No. 922-VIII)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	Yes. Ukraine has a localisation list of goods that must be domestically produced (relevant for goods tenders) as a condition for certain procurement categories; the Prozorro localisation list for Dec. 2024 is currently active; the EU-Ukraine Mutual Access Agreement (April 2023) provides mutual access to each other's public procurement markets but maintains Ukraine's right to apply localisation for specific goods to support domestic industrial capacity during recovery; under the WTO GPA (acceded 2016), non-discrimination applies for GPA-covered procedures. (Law No. 922-VIII; EU-Ukraine Mutual Access Agreement April 2023; Prozorro current localisation list)
Is there a specific set of rules for green/sustainable procurement?	Yes. Law No. 922-VIII permits but does not mandate green procurement criteria; the EU accession criteria explicitly require Ukraine to adopt and implement a National GPP Action Plan as a condition for closing the procurement negotiation chapter; the Ministry of Economy has been developing GPP policy; the Draft Law No. 11520 will incorporate sustainability criteria aligned with EU Directive 2014/24/EU. (Law No. 922-VIII; EU accession criteria; Draft Law No. 11520; TI Ukraine)
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. Law No. 922-VIII establishes mandatory and discretionary exclusion grounds broadly aligned with EU Directive 2014/24/EU Art. 57: criminal conviction for corruption, fraud, terrorist financing; bankruptcy/insolvency; non-payment of taxes; false declarations; three-year debarment; the Draft Law No. 11520 strengthens exclusion mechanisms and aligns them more precisely with EU Directive 2014/24/EU; DOZORRO monitors exclusion ground compliance through Prozorro OCDS data. (Law No. 922-VIII, Art. 17; Draft Law No. 11520; DOZORRO)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	No. For abnormally low tenders, Law No. 922-VIII requires the contracting authority to request clarification before exclusion; exclusion is not automatic; aligned with EU Directive 2014/24/EU Art. 69. (Law No. 922-VIII)
Is scoring criteria published?	Yes. Award criteria and their weights must be published in procurement documents; the mandatory award criterion is MEAT (most economically advantageous tender), determined by price, quality, technical specifications and other non-price factors; scoring criteria are transparent through Prozorro OCDS publication; in practice, price dominates given the wartime urgency and increased use of direct contracting; the Draft Law No. 11520 reinforces MEAT and introduces life-cycle costing. (Law No. 922-VIII; Draft Law No. 11520)
Are decisions always made by a committee?	Yes. Law No. 922-VIII requires contracting authorities to establish a Tender Committee (tenderny komitet) or appoint a Procurement Authorised Person (for simplified procedures); the tender committee evaluates tenders and issues written, reasoned decisions published through Prozorro; the 2019 reform introduced the alternative of a single authorised person for simplified procedures. (Law No. 922-VIII, Art. 11)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. Law No. 922-VIII includes explicit conflict-of-interest provisions for tender committee members; members must declare conflicts of interest; DOZORRO monitors for conflict-of-interest patterns through Prozorro OCDS data (e.g., detecting repeated awards to the same supplier by the same contracting authority); the Draft Law No. 11520 strengthens conflict-of-interest rules. (Law No. 922-VIII, Art. 11; Draft Law No. 11520; DOZORRO)
Is some part of evaluation committee mandatorily independent of contracting authority?	No. No legal requirement for tender committee members to be independent of the contracting authority; members are generally officials of the contracting authority; the single authorised person option further reduces external oversight for simplified procedures. (Law No. 922-VIII, Art. 11)
Are scoring results publicly available?	Yes. All evaluation decisions and their reasoning are published through Prozorro in OCDS format; DOZORRO provides civil society monitoring and red-flag analytics on all published evaluation decisions; all tenderers are notified of decisions through Prozorro; the OCDS data architecture allows bulk analysis of all award decisions; Bi-Prozorro provides real-time market analytics; this is arguably the world's most transparent procurement award publication system. (Law No. 922-VIII; Prozorro OCDS; DOZORRO; Bi-Prozorro)
Does the law specify under which conditions the tender can be cancelled?	Yes. Law No. 922-VIII specifies conditions for cancellation; contracting authorities must publish cancellation notices with reasons through Prozorro; cancellation data is included in the Prozorro OCDS open data. (Law No. 922-VIII)
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. Prozorro: https://prozorro.gov.ua (mandatory, all procedures above threshold); Prozorro Market (e-catalogue): https://market.prozorro.gov.ua; accredited private commercial platforms connected to the Prozorro central database (OpenMarket, Newtend, E-tender.biz, Prozorro.sale, etc.); Ministry of Economy website: https://me.gov.ua. (Law No. 922-VIII; Prozorro system)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. Prozorro: https://prozorro.gov.ua; restricted (closed) procedures are published on Prozorro; the wartime direct contracting procedures for defence/critical infrastructure are published on Prozorro (with some security redactions). (Law No. 922-VIII; CMU Res. No. 1178/2022; Prozorro system)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. Negotiated and direct procedures must be published on Prozorro; defence and critical infrastructure direct contracts published subject to security redaction; AMCU complaint system operates through Prozorro for all published procedures; (Law No. 922-VIII; CMU Res. No. 1178/2022; Prozorro system)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	2. The 2019 reform of Law No. 922-VIII and subsequent wartime rules permit contracting authorities to complete a tender and award a contract even where only 1 bid was received, provided the single bid meets all qualification and price requirements; this was introduced as a wartime innovation and the Draft Law No. 11520 enshrines single-bidder auction contracts in law; previously a minimum of 2 bids was required. (Law No. 922-VIII; Draft Law No. 11520)
What is the minimum number of bidders for negotiated procedures?	1. During martial law (CMU Res. No. 1178/2022), direct contracting (negotiated without competition) is permitted for defence, critical infrastructure and other categories without a minimum bidder requirement; in normal competitive procedures: at least 1 valid bid required (since wartime reform). (Law No. 922-VIII; CMU Res. No. 1178/2022)
What is the minimum number of bidders for competitive dialogue procedures?	N/A. Law No. 922-VIII does not include a competitive dialogue procedure; the Draft Law No. 11520 and EU accession criteria require Ukraine to introduce competitive dialogue, competitive negotiation and innovation partnership aligned with EU Directive 2014/24/EU. (Law No. 922-VIII; Draft Law No. 11520; TI Ukraine)
Bidding period length
What are the minimum number of days for open procedures?	30. Law No. 922-VIII sets minimum 30 calendar days from Prozorro notice publication to bid submission deadline for full above-threshold open tenders; government has flexibility under martial law rules to adjust specific time limits; TI Ukraine reports (2024) reports the government extended certain minimum deadlines. (Law No. 922-VIII; CMU Res. No. 1178/2022; TI Ukraine reports (2024))
What are the minimum number of days for restricted procedures?	7. For simplified procedures (below UAH 200,000 / UAH 100,000 during martial law): minimum 7 calendar days from Prozorro notice to deadline. (Law No. 922-VIII; CMU Res. No. 1178/2022)
What are the minimum number of days for competitive negotiated procedures?	During martial law, direct contracting for defence and critical infrastructure has no minimum publication/notice period; contracts are concluded directly and reported on Prozorro after conclusion. (CMU Res. No. 1178/2022; draft CMU decision)
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. Law No. 922-VIII (Art. 3) does not apply to: (1) classified/state secret procurement; (2) nuclear materials procurement; (3) acquisition of cultural property; (4) certain purchases from a single provider under special conditions; (5) international organisation-governed procurement; during martial law (CMU Res. No. 1178/2022), additional exceptions apply: direct contracting for defence goods, weapons and equipment; direct contracting for critical infrastructure repair and protection; procurement for rapid response to enemy action; these wartime exceptions are the most significant practical departure from the regular framework. (Law No. 922-VIII, Art. 3; CMU Res. No. 1178/2022)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. Law No. 922-VIII applies to: (a) state bodies and state institutions; (b) local self-government bodies; (c) legal persons receiving public funds or guaranteed loans; (d) public enterprises, state-owned enterprises and communal enterprises; (e) utilities contracting authorities; (f) any legal person where more than 50% of capital is publicly owned; the law's broad scope is one of the largest contracting authority scopes in the region. (Law No. 922-VIII, Art. 2)
Does the law specify the main procedure types or procurement methods permitted?	Yes. The current law has only open procedure, simplified procedure and direct contracting; the wartime direct contracting has dominated since 2022; the Draft Law No. 11520 significantly expands procedure types to align with EU Directive 2014/24/EU: introducing competitive dialogue, innovation partnership, joint procurement, DPS and reserved contracts as new instruments. (Law No. 922-VIII; CMU Res. No. 1178/2022; Draft Law No. 11520)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. The Antimonopoly Committee of Ukraine (AMCU) (https://amcu.gov.ua) is the independent first-instance review body for public procurement complaints; the AMCU was designated as the procurement appeals body by the 2019 reform (Law No. 114-IX); it replaced the former Tender Chamber; complaints are submitted electronically through Prozorro (in OCDS-documented form); the AMCU must decide within 7 working days (extendable to 12 working days for complex cases); the AMCU establishes a commission to review each complaint; the PPP Law (Draft Law No. 7508, not part of the Dec. 2024 baseline) also designates the AMCU as the review body for PPP tender complaints; AMCU decisions may be challenged before the Administrative Courts; the OECD Peer Review of Competition Law and Policy: Ukraine reviews AMCU's role and capacity. (Law No. 922-VIII, Art. 18; CMU Res. No. 1178/2022; CMU Resolution No. 292/2020 (complaint fees); AMCU; draft PPP Law No. 7508 (not part of Dec. 2024 baseline))
Is there a procurement regulatory body dedicated to public procurement?	Yes. The Ministry of Economy of Ukraine (https://me.gov.ua) is the central regulatory body for public procurement; it issues regulatory guidance, standard documents and methodology, develops amendments to Law No. 922-VIII and leads Draft Law No. 11520; the State Audit Service (SASU) is the primary ex-post monitoring body, conducting monitoring through Prozorro; the Prozorro system is technically managed in partnership between government and civil society (hybrid model); TI Ukraine's DOZORRO platform provides civil society monitoring. (Law No. 922-VIII; Ministry of Economy; SASU)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)?	No. Law No. 922-VIII does not establish a regulated profession of procurement adviser; tender committee membership requires relevant expertise but no mandatory certification; the EU accession criteria include the requirement to strengthen institutional capacity of contracting authorities; the Draft Law No. 11520 includes provisions on improving contracting authority capacity. (Law No. 922-VIII; Draft Law No. 11520; TI Ukraine)
Is disclosure of final, beneficial owners required for placing a bid?	No. Law No. 922-VIII does not currently require beneficial ownership disclosure as a precondition for bidding; Ukraine has a State Register of Beneficial Owners (managed by the Ministry of Justice); the Draft Law No. 11520 is expected to introduce beneficial ownership transparency requirements linked to Prozorro; this is also part of the EU accession anti-corruption reform package. (Law No. 922-VIII; Draft Law No. 11520)
Complaints
Is there a fee for arbitration procedure?	Yes. A complaint fee is payable to the AMCU for filing a procurement complaint, introduced by CMU Resolution No. 292 of 22 April 2020; the fee is set on a graduated scale based on the estimated value of the procurement; fees are refundable if the complaint is upheld; the fee structure was intended to filter out frivolous complaints; fees are paid electronically through the Prozorro system; the 2024 TI Ukraine report on state of procurement notes the AMCU handled complaints within the legal deadlines in 2023. (Law No. 922-VIII, Art. 18; CMU Resolution No. 292/2020; TI Ukraine 2024)
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. When a complaint is registered by the AMCU through Prozorro, the contracting authority may not sign the contract until the AMCU issues its decision; the suspension is automatic from the date of AMCU acceptance of the complaint; the AMCU posts the decision within 1 working day (operative part) and within 3 working days (full decision) after adoption; the automatic suspension is implemented through the Prozorro system (the system blocks contract signing during the complaint examination period). (Law No. 922-VIII, Art. 18; CMU Res. No. 292/2020)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	7. The AMCU must decide on a complaint within 7 working days of acceptance; for complex cases requiring additional information, the deadline may be extended by the AMCU to 12 working days; within 1 working day after the decision, the operative part must be published in Prozorro; within 3 working days, the full decision must be published; the automatic Prozorro publication of decisions is one of the system's key transparency innovations. (Law No. 922-VIII, Art. 18; CMU Res. No. 292/2020)
Is there a requirement to publicly release arbitration court decisions ?	Yes. AMCU decisions are automatically published in the Prozorro electronic system immediately after their upload, as well as sent to the complainant and contracting authority; this makes Ukraine's review decision publication arguably the most automated and transparent in the region; all AMCU procurement decisions are also published on the AMCU website; DOZORRO monitors complaint and decision patterns through Prozorro OCDS data; (Law No. 922-VIII, Art. 18; Prozorro system; AMCU website)

Legislation

Cabinet of Ministers Resolution No. 1178 of 12 October 2022 on the peculiarities of public procurement under martial law (Ukrainian)	pdf
Cabinet of Ministers Resolution No. 1275 of 11 November 2022 on defence procurement during martial law (Ukrainian)	pdf
Cabinet of Ministers Resolution No. 292/2020 on the establishment of the authorised body in public procurement (Ukrainian)	pdf
Law of Ukraine No. 922-VIII on Public Procurement (Ukrainian)	pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Risk-based approach						100
Sanctions for natural persons						100
Sanctions for legal persons						75
Pecuniary sanctions for obliged entities						80
Beneficial ownership of legal persons and legal arrangements						67
Supervision of obliged entities						100
Financial Intelligence Units (FIUs)						67
Mutual legal assistance (MLA) and International Cooperation						100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Risk-based approach
Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it.	Yes. Article 28. National Risk Assessment 1. The specially authorised body, other state bodies carrying out activities in the field of prevention and counteraction, with the involvement of other entities (if necessary) shall participate in the national risk assessment. 2. The national risk assessment shall be carried out systematically, but at least once every three years. The specially authorised body shall be responsible for conducting the national risk assessment. (Article 28, Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years.	Yes. Article 28. National Risk Assessment 1. The specially authorised body, other state bodies carrying out activities in the field of prevention and counteraction, with the involvement of other entities (if necessary) shall participate in the national risk assessment. 2. The national risk assessment shall be carried out systematically, but at least once every three years. The specially authorised body shall be responsible for conducting the national risk assessment. (Article 28, Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks.	Yes. Article 28. National Risk Assessment 1. The specially authorised body, other state bodies carrying out activities in the field of prevention and counteraction, with the involvement of other entities (if necessary) shall participate in the national risk assessment. 2. The national risk assessment shall be carried out systematically, but at least once every three years. The specially authorised body shall be responsible for conducting the national risk assessment. (Article 28, Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Sanctions for natural persons
The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;	Yes. A person who: 1) acquired or used assets (proceeds) in respect of which the actual circumstances indicate that they have been received, whether directly or indirectly, in full or in part, by committing a predicative act, or who used to own them, except for a person who committed a predicative act, 2) converted or transferred such assets (proceeds) to conceal or veil their criminal origin, 3) helped another person engaged in the legalization (laundering) to avoid liability, or 4) hide or veiled a true nature of such assets (proceeds), sources of their origin, location, disposal of them, movement thereof or rights thereto, – committed a crime of the gravity degree 3. (Article 6.3.21, Criminal Code of Ukraine)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;	Yes. A person who: 1) acquired or used assets (proceeds) in respect of which the actual circumstances indicate that they have been received, whether directly or indirectly, in full or in part, by committing a predicative act, or who used to own them, except for a person who committed a predicative act, 2) converted or transferred such assets (proceeds) to conceal or veil their criminal origin, 3) helped another person engaged in the legalization (laundering) to avoid liability, or 4) hide or veiled a true nature of such assets (proceeds), sources of their origin, location, disposal of them, movement thereof or rights thereto, – committed a crime of the gravity degree 3. (Article 6.3.21, Criminal Code of Ukraine)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.	Yes. A person who: 1) acquired or used assets (proceeds) in respect of which the actual circumstances indicate that they have been received, whether directly or indirectly, in full or in part, by committing a predicative act, or who used to own them, except for a person who committed a predicative act, 2) converted or transferred such assets (proceeds) to conceal or veil their criminal origin, 3) helped another person engaged in the legalization (laundering) to avoid liability, or 4) hide or veiled a true nature of such assets (proceeds), sources of their origin, location, disposal of them, movement thereof or rights thereto, – committed a crime of the gravity degree 3. (Article 6.3.21, Criminal Code of Ukraine)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence.	Yes. Article 2.6.1. Definition and types of an inchoate crime 1. A crime shall be deemed inchoate if it does not have all attributes of an object or a physical element of a completed crime set out in part 1 and part 2 of Article 2.1.3 of this Code. 2. A preparatory crime and criminal attempt shall be the types of an inchoate crime. 3. The elements of an inchoate crime shall be established based on the attributes of the elements of a relevant completed crime and attributes set out in Articles 2.6.2 and 2.6.3 of this Code. 4. Criminal sanctions shall be imposed on the subject of the crime who has committed a preparatory crime or criminal attempt but has not completed the crime due to the reasons they could not control. 5. The following shall not constitute a criminal offense: 1) preparation to commit a minor offense; 2) attempted minor offense; 3) preparation to commit a crime of the gravity degrees 1–4 (other than preparatory crimes punishable by law in accordance with an international treaty); /// Article 2.6.3. Criminal attempt 1. Criminal attempt shall mean an action or omission committed by a subject with direct intent who partially committed a physical element of a completed crime. 2. A criminal attempt shall be deemed: 1) completed if an actor completed all the actions that were considered by them necessary to complete the commission of the crime; 2) incomplete if an actor has not completed all the actions that were considered by them necessary to complete the commission of the crime. 5. The gravity degree of a criminal attempt to commit a crime of the gravity degrees 3–8 shall be reduced: 1) by one degree in the case of a completed attempt; and 2) by two degrees in the case of an incomplete attempt. /// Article 2.7.1. The definition of complicity in a criminal offense 1. Complicity in a criminal offense shall mean the joint commission of a criminal offense by two or more subjects of the crime by conspiracy among them reached verbally, in writing, or by way of actions implied by conduct before such criminal offense is completed. 2. The elements of a criminal offense committed with complicity shall be established based on the elements of a criminal offense committed by the actor and taking into account the attributes set out in parts 2–5 of Article 2.7.2 of this Code. (Article 2.6.1, 2.6.3 and 2.7.1., Criminal Code of Ukraine)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years.	Yes. Article 3.2.5. Penalties for a crime 1. The following penalties shall be imposed for crimes depending on the degree of their gravity: 1) a crime of the gravity degree 1 – a fine ranging from 100 to 500 calculation units or imprisonment for a term from three months to two years; 2) a crime of the gravity degree 2 – a fine ranging from 500 to 1000 calculation units or imprisonment for a term from two to three years; 3) a crime of the gravity degree 3 – a fine ranging from 1000 to 2000 calculation units or imprisonment for a term from three to four years; (Article 3.2.5, Criminal Code of Ukraine)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences	Yes. A person who: 1) acquired or used assets (proceeds) in respect of which the actual circumstances indicate that they have been received, whether directly or indirectly, in full or in part, by committing a predicative act, or who used to own them, except for a person who committed a predicative act, 2) converted or transferred such assets (proceeds) to conceal or veil their criminal origin, 3) helped another person engaged in the legalization (laundering) to avoid liability, or 4) hide or veiled a true nature of such assets (proceeds), sources of their origin, location, disposal of them, movement thereof or rights thereto, – committed a crime of the gravity degree 3. (Article 6.3.21, Criminal Code of Ukraine)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator;	Yes. A person who: 1) acquired or used assets (proceeds) in respect of which the actual circumstances indicate that they have been received, whether directly or indirectly, in full or in part, by committing a predicative act, or who used to own them, except for a person who committed a predicative act, 2) converted or transferred such assets (proceeds) to conceal or veil their criminal origin, 3) helped another person engaged in the legalization (laundering) to avoid liability, or 4) hide or veiled a true nature of such assets (proceeds), sources of their origin, location, disposal of them, movement thereof or rights thereto, – committed a crime of the gravity degree 3. (Article 6.3.21, Criminal Code of Ukraine)
Sanctions for legal persons
Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person.	Yes. 1. If there are grounds provided for in part 1 of Article 3.11.2 hereof, the court may apply criminal remedies to legal entities, including foreign legal entities under the private law /// 1. There may be the following grounds for the application of criminal remedies to a legal entity: 1) committing any intentional crime of the gravity degrees 3–9 under this Code on behalf and for the benefit of a legal entity or its associate by an authorized person of such legal entity; 2) committing either of the following crimes by a person subordinated to (controlled by) an authorized person of the legal entity due to poor control by the latter: against humanity – Articles 4.4.6, 4.5.4–4.5.9 (committed against a child), 4.11.4; against public health – Articles 5.1.4–5.1.8, 5.1.11, 5.2.4–5.2.9, 5.2.11–5.2.12, 5.3.4–5.3.12; against economy – Articles 6.1.4, 6.1.5, 6.1.6, 6.2.3, 6.3.5–6.3.11, 6.3.15–6.3.21, 6.5.4– 6.5.6; against society – Articles 7.1.4–7.1.9, 7.2.4–7.2.10, 7.6.4–7.6.7 (committed against a child), 7.7.4–7.7.8, 7.9.4–7.9.7; against justice – Articles 8.1.4–8.1.7, 8.2.3–8.2.17, 8.3.3, 8.3.4, 8.3.7; against the state – Articles 9.3.7 і 9.3.8, 9.5.4–9.5.9; against sovereignty – Articles 11.5.10. 2. An authorized person of a legal entity is a subject of a crime who, according to the law, constituent documents of a legal entity, special authority, contract, or court decision: 1) holds an executive office, represents the legal entity or makes decisions on its behalf, acting individually or as part of the collective body of the legal entity; 2) exercises control within such legal entity; or 3) is an ultimate beneficial owner (controller) of that legal entity. 3. A crime shall be deemed committed for the benefit of a legal entity if this crime: 1) has created conditions for the legal entity to obtain unjust benefit or resulted in obtaining such benefit; 2) has created conditions for realizing intangible interest of the legal entity or resulted in its realization; or 3) has been aimed at evading legal liability by such legal entity. (Article 3.11.1 and 3.11.2, Criminal Code of Ukraine)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority.	No. Absent from legal framework (Absent from legal framework)
Legal persons held liable are punishable by criminal or non-criminal fines.	Yes. Article 3.11.3. Type of criminal remedies applicable to legal entities 1. The following criminal remedies may be imposed on a legal entity: 1) a fine, or 2) limitation of support from public funds; 3) restriction of certain activities; 4) confiscation of property or seizure of things; 5) liquidation. 2. The court may also decide to disclose information on criminal remedies applied to a legal entity in the following cases: 1) application of measures provided for in paragraphs 3–5 of part 1 of this Article; 2) committing a crime under Article 9.3.8 of this Code. (Article 3.11.3, Criminal Code of Ukraine)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence.	Yes. Article 3.11.3. Type of criminal remedies applicable to legal entities 1. The following criminal remedies may be imposed on a legal entity: 1) a fine, or 2) limitation of support from public funds; 3) restriction of certain activities; 4) confiscation of property or seizure of things; 5) liquidation. 2. The court may also decide to disclose information on criminal remedies applied to a legal entity in the following cases: 1) application of measures provided for in paragraphs 3–5 of part 1 of this Article; 2) committing a crime under Article 9.3.8 of this Code. (Article 3.11.3, Criminal Code of Ukraine)
Pecuniary sanctions for obliged entities
In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach.	Yes. Violation of the requirements for conducting due diligence, requirements for identifying whether clients and other persons specified by law are politically exposed persons, their family members, or persons associated with politically exposed persons; failure to submit, untimely submission, violation of the procedure for submission, or submission to the central executive body implementing state policy in the field of preventing and countering the legalization (laundering) of proceeds from crime, financing of terrorism, and financing of the proliferation of weapons of mass destruction, of unreliable information in cases provided for by law; violation of the requirements for creating (maintaining) and storing documents (including electronic ones), records, data, and information; violation of the requirements for accompanying transfers with information about the initiator and recipient of the transfer; violation of the requirements for refusing to establish (maintain) business relations (conducting a financial transaction); violation of the procedure for suspending a financial (financial) transaction (operation), as well as the procedure for freezing or unfreezing assets related to terrorism and its financing, proliferation of weapons of mass destruction and its financing; violation of the requirements for identifying and registering financial transactions subject to financial monitoring, - entail the imposition of a fine on officials of primary financial monitoring entities, liquidators or an authorized person of the Deposit Guarantee Fund of individuals from three hundred to two thousand tax-free minimum incomes of citizens. Failure to provide, untimely submission or submission of unreliable information related to the analysis of financial transactions that have become the object of financial monitoring, certificates and copies of documents (including those containing information with restricted access) at the request of the central executive body implementing state policy in the field of prevention and counteraction to the legalization (laundering) of proceeds from crime, financing of terrorism and financing of the proliferation of weapons of mass destruction, - entail the imposition of a fine on officials of enterprises, institutions, organizations, citizens - business entities that are not subjects of primary financial monitoring, from one hundred to two hundred tax-free minimum incomes of citizens./// Failure to submit or untimely submission to the state registrar of information on the ultimate beneficial owner of a legal entity or on its absence, or documents to confirm information on the ultimate beneficial owner of a legal entity, as provided for by the Law of Ukraine "On State Registration of Legal Entities, Individual Entrepreneurs and Public Organizations", the Law of Ukraine "On Prevention and Counteraction to the Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction" - entail the imposition of a fine on the head of a legal entity or a person authorized to act on behalf of a legal entity (executive body) in the amount of one thousand to three thousand tax-free minimum incomes of citizens. (Article 166^9 and 166^11, Code of Ukraine on Administrative Offences)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention).	Yes. Violation of the requirements for conducting due diligence, requirements for identifying whether clients and other persons specified by law are politically exposed persons, their family members, or persons associated with politically exposed persons; failure to submit, untimely submission, violation of the procedure for submission, or submission to the central executive body implementing state policy in the field of preventing and countering the legalization (laundering) of proceeds from crime, financing of terrorism, and financing of the proliferation of weapons of mass destruction, of unreliable information in cases provided for by law; violation of the requirements for creating (maintaining) and storing documents (including electronic ones), records, data, and information; violation of the requirements for accompanying transfers with information about the initiator and recipient of the transfer; violation of the requirements for refusing to establish (maintain) business relations (conducting a financial transaction); violation of the procedure for suspending a financial (financial) transaction (operation), as well as the procedure for freezing or unfreezing assets related to terrorism and its financing, proliferation of weapons of mass destruction and its financing; violation of the requirements for identifying and registering financial transactions subject to financial monitoring, - entail the imposition of a fine on officials of primary financial monitoring entities, liquidators or an authorized person of the Deposit Guarantee Fund of individuals from three hundred to two thousand tax-free minimum incomes of citizens. Failure to provide, untimely submission or submission of unreliable information related to the analysis of financial transactions that have become the object of financial monitoring, certificates and copies of documents (including those containing information with restricted access) at the request of the central executive body implementing state policy in the field of prevention and counteraction to the legalization (laundering) of proceeds from crime, financing of terrorism and financing of the proliferation of weapons of mass destruction, - entail the imposition of a fine on officials of enterprises, institutions, organizations, citizens - business entities that are not subjects of primary financial monitoring, from one hundred to two hundred tax-free minimum incomes of citizens./// Failure to submit or untimely submission to the state registrar of information on the ultimate beneficial owner of a legal entity or on its absence, or documents to confirm information on the ultimate beneficial owner of a legal entity, as provided for by the Law of Ukraine "On State Registration of Legal Entities, Individual Entrepreneurs and Public Organizations", the Law of Ukraine "On Prevention and Counteraction to the Legalization (Laundering) of Proceeds from Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction" - entail the imposition of a fine on the head of a legal entity or a person authorized to act on behalf of a legal entity (executive body) in the amount of one thousand to three thousand tax-free minimum incomes of citizens. (Article 166^9 and 166^11, Code of Ukraine on Administrative Offences)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed.	Yes. 4. The measures of influence stipulated in part three of this Article shall be applied to the reporting entitiesby the state financial monitoring entities, which pursuant to this Law perform the functions of state regulation and supervision over the reporting entities, in the manner prescribed by the appropriate state financial monitoring entity taking into account the requirements stipulated in this Law. (Article 32.4., Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures.	No. Absent from legal framework (Absent from legal framework)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments.	Yes. 10. The decision (resolution) of the state financial monitoring entity (its authorised official) on application to the reporting entity of the measures of influence provided by this Article, shall come into force from the working day following the day of approval of such decision (resolution). Information on the application of measures of influence to the reporting entity (indicating the name of the reporting entity, information on applied measures of influence, including the amount of fine, and general information on violations of the law), appeals against these measures of influence and the relevant court decision, which has entered into force, shall be published on the official website of the appropriate state financial monitoring entity in the manner prescribed by it and shall remain available for review for at least five years from the date of publication. (Article 32.10., Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Beneficial ownership of legal persons and legal arrangements
Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered.	Yes. 2. The United State Register shall contain the following information on a legal entity, except for state bodies and local governments as legal entities: 9) information on the ultimate beneficial owner of a legal entity, including the ultimate beneficial owner of a founder, if the founder is a legal entity (except for political parties, structural units of political parties, trade unions, their associations, trade union organisations provided for in the charter of trade unions and their associations, creative unions, local branches of creative unions, employers’ organisations, their associations, bar associations, chambers of commerce and industry, condominium associations, religious organisations, state bodies, local governments, their associations, state and municipal enterprises, institutions, organisations): surname, name, patronymic (if any), date of birth, country of citizenship, series and number of passport of a citizen of Ukraine or passport document of a foreigner, place of residence, rtaxpayer identification number (if any), as well as full name and identification code (for resident) of the legal entity’s founder wherein this person is the ultimate beneficial owner, nature and extent (level, scope, portion) of beneficial ownership (benefit, interest, impact). If a legal entity has no ultimate beneficial owner of the legal entity, including no ultimate beneficial owner of its founder, if the founder is a legal entity, the justified reason for their absence shall be recorded; (Article 9.2 9) Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation.	No. Absent from legal framework (Absent from legal framework)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number	No. Absent from legal framework (Absent from legal framework)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date.	No. Absent from legal framework (Absent from legal framework)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them.	No. Absent from legal framework (Absent from legal framework)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register.	No. Absent from legal framework (Absent from legal framework)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date.	Yes. 1. Control in the field of state registration shall be exercised by the Ministry of Justice of Ukraine, including by monitoring the registration actions in the United State Register in order to detect violations of the procedure for state registration by state registrars, authorised persons of state registration entities, as well as to detect facts of failure to submit or untimely submission to the state registrar of the information on the ultimate beneficial owner of a legal entity as provided by this Law. (Article 34^1.1, Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration.	No. Absent from legal framework (Absent from legal framework)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership.	No. Absent from legal framework (Absent from legal framework)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States.	Yes. 7. State bodies, including courts, National Police authorities, prosecution offices, agencies of the Security Service of Ukraine, as well as local governments and their officials, shall receive information from the United State Register free of charge in order to exercise their powers determined by law exclusively in electronic form through the portal of electronic services in the manner determined by the Ministry of Justice of Ukraine in Procedure for providing information from the United State Register, except as provided by this Law. (Article 11.7., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing;	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure;	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed.	Yes. 1. The information contained in the United State Register shall be open and publicly accessible (except for the taxpayer identification numbers and passport data) and in the cases provided for in this Law, a fee shall be charged for its provision. (Article 11.1., Law of Ukraine No. 755-IV “On State Registration of Legal Entities, Individual Entrepreneurs and Public Organisations”)
Supervision of obliged entities
Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113.	Yes. 3. The state financial monitoring entities are the National Bank of Ukraine, the central executive body that ensures the formation and implementation of state policy in the field of prevention and counteraction to legalisation (laundering) of criminal proceeds, terrorist financing and financing of proliferation of weapons of mass destruction, Ministry of Justice of Ukraine, National Commission on Securities and Stock Market, Ministry of Digital Transformation of Ukraine and specially authorised body. (Article 6.3., Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Financial Intelligence Units (FIUs)
Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing.	Yes. 3. The state financial monitoring entities are the National Bank of Ukraine, the central executive body that ensures the formation and implementation of state policy in the field of prevention and counteraction to legalisation (laundering) of criminal proceeds, terrorist financing and financing of proliferation of weapons of mass destruction, Ministry of Justice of Ukraine, National Commission on Securities and Stock Market, Ministry of Digital Transformation of Ukraine and specially authorised body. (Article 6.3., Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing.	Yes. state financial monitoring of a specially authorised body - set of measures on collection, processing and analysis of information about financial transactions submitted to the specially authorised body by the primary and state financial monitoring entities and other public agencies, appropriate bodies of foreign states, other information that may be related to suspicion of legalisation (laundering) of criminal proceeds, terrorist financing and/or financing of proliferation of weapons of mass destruction and/or other illegal financial transactions, as well as measures on verification of such information according to the legislation of Ukraine and other measures aimed at meeting the legislation in the field of prevention and counteraction (Article 1.1. 16), Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing.	No. Absent from legal framework
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference.	No. Absent from legal framework
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information.	Yes. 2. The reporting entity shall: 13) submit, at the request of the specially authorised body within its powers, information on tracking (monitoring) of financial transactions of a client whose transactions have become the object of financial monitoring, in the manner prescribed by the central executive body that ensures the formation and implementation of public policy in the field of prevention and counteraction to legalisation (laundering) of criminal proceeds, terrorist financing and financing of proliferation of weapons of mass destruction, in coordination with the relevant state financial monitoring entities, which according to this Law perform the functions of state regulation and supervision of primary financial monitoring, and the Individual Deposit Guarantee Fund; (Article 8.2. 13) Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction.	Yes. 2. The specially authorised body may decide to further suspend financial transactions carried out according to part one of this Article, for a period of up to seven working days, which must be immediately notified to the reporting entity and law enforcement agencies authorised to make decisions according to the Criminal Procedure Code of Ukraine. 3. In case of suspicion, the specially authorised body may decide to suspend expenditure financial transactions for up to seven working days, which must be immediately notified to the reporting entity and law enforcement agencies authorised to make decisions according to the Criminal Procedure Code of Ukraine. In this case, the reporting entity shall on the day of receipt, but not later than 11 hours of the next working day after receipt of the decision, notify the specially authorised body of the balance on the client's account, financial transactions (funds) and in case of suspension of financial transactions on transit accounts of the reporting entity — on the balance of funds on such accounts within the credited amounts (Article 23.2 and 23.3. Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Mutual legal assistance (MLA) and International Cooperation
Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU.	Yes. Section VII of AML Law extensively regulates the procedures for international cooperation (Articles 30-31 of Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange.	Yes. Section VII of AML Law extensively regulates the procedures for international cooperation (Articles 30-31 of Law of Ukraine On Prevention and Counteraction to Legalisation (Laundering) of Criminal Proceeds, Terrorist Financing and Financing of Proliferation of Weapons of Mass Destruction)

Legislation

*Last update: 2017

Asset Recovery

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Asset Offices						100
Confiscation						89
International cooperation						75

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Asset Offices
Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters.	Yes. Ukraine has a dedicated Asset Recovery and Management Agency (ARMA), established in 2016, responsible for identifying, tracing, managing and selling assets derived from corruption and other crimes, (Law of Ukraine “On the National Agency of Ukraine for Detection, Investigation and Management of Assets Derived from Corruption and Other Crimes” (ARMA Law).)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order.	Yes. ARMA has the statutory mandate to manage assets arrested in criminal proceedings, including by transferring them to private managers and selling them via electronic auctions, (ARMA Law; secondary legislation on ARMA reform and regulation of authorised officers and management/disposal of assets, including use of the Prozorro.Sale)
Confiscation
Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures)	Yes. The CPC provides for “arrest of property” (seizure) to preserve material evidence, secure a civil claim, ensure possible confiscation or special confiscation, and preserve property subject to confiscation, covering movable and immovable property, funds, (Criminal Procedure Code of Ukraine, Article 170 (grounds and purpose of seizure of property) and Article 98 (definition of material evidence).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation)	Yes. The CCU provides for confiscation of property as a punishment (Article 59) and, in addition, special confiscation (Article 96˛) of proceeds and instrumentalities of crime, applied by court decision; the Constitutional Court (Criminal Code of Ukraine, Article 59 (forfeiture of property as punishment) and Articles 96¹–96² (special confiscation).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value)	Yes. Special confiscation applies to any money, valuables and other property obtained as a result of a criminal offence, including income from such property and property into which it has been wholly or partly converted, enabling value‑based (CCU, Article 96²(1)–(2) (special confiscation of proceeds, converted property and income derived from proceeds).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation)	Yes. Special confiscation can be applied to property transferred to another natural or legal person if this person knew or should have known that the property meets the criteria for special confiscation; (CCU, Article 96²(1)–(2) (special confiscation of property transferred to third parties who knew or should have known about its criminal origin).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation)	Yes. Special confiscation is available for a wide range of offences punishable by imprisonment or fine above certain thresholds and is aimed at proceeds, converted property and income; together with specific provisions on illicit enrichment, (CCU, Article 96ą (grounds for special confiscation) and Article 96˛ (scope of property subject to special confiscation), in conjunction with offences such as illicit enrichment under the Special Part.)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation)	Yes. Amendments to Article 96˛ make special confiscation applicable even if the perpetrator is exempt or discharged from criminal liability, including where proceedings are closed because of the death of the suspect or accused or other grounds preventing conviction, (CCU, Article 96˛(3) (special confiscation applicable when the perpetrator is exempt from criminal liability or proceedings are closed due to death or similar reasons).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation)	Yes. Special confiscation is ordered by a court decision that recognises the property as obtained as a result of an intentional criminal offence, used to induce or finance a criminal offence, or as reward for such offence, even where the person is not convicted, thus functioning as a criminal‑law based non‑conviction (CCU, Article 96²(1)–(3) (definition and application of special confiscation independent of conviction in specified circumstances).)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth)	Yes. Special confiscation is widely applicable to serious offences and targets proceeds and assets of criminal organisations; combined with provisions on illicit enrichment and ARMA’s tracing and management powers, it allows confiscation of assets where their lawful origin is rebutted and they are linked to criminal activities, (CCU, Articles 96¹–96² (special confiscation for serious offences); ARMA Law; provisions on illicit enrichment in the Special Part of the CCU.)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027)	No. Ukraine has a strong institutional and legal framework for asset recovery (including ARMA and special confiscation) and reports regularly on reforms and practice, but there is no explicit statutory national asset recovery strategy with a five‑year update obligation as of 31.12.2024. (No explicit national asset recovery strategy provision identified in the CCU, CPC or ARMA Law.)
International cooperation
To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters.	Yes. ARMA is responsible for tracing and identifying assets derived from corruption and other crimes, including in cross‑border cases, and Ukraine’s legal framework enables arrest (seizure) (ARMA Law (mandate to detect, investigate and manage criminal assets); CPC, Article 170 and related provisions on seizure of property,)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information	Yes. ARMA participates in international cooperation, exchanges information with foreign authorities and asset recovery offices, and is part of global discussions on asset recovery, including within UNODC (ARMA Law and Ukraine’s statements on asset recovery cooperation under UNCAC.)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders.	No. Ukrainian legislation on mutual legal assistance and confiscation does not provide a specific statutory framework for cost‑sharing (No explicit cost‑sharing clause identified in the CCU, CPC, ARMA Law or MLA)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions	Yes. Ukraine is actively engaged in returning illicit assets and may share confiscated assets with foreign states under UNCAC (International asset‑recovery practice reported in “Ukraine’s Experience in Asset Recovery” and Ukraine’s statements under UNCAC.)

Legislation

*Last update: 2017

Ukraine

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