Transparency International Ukraine Unveils Shadow Report with 141 Key Recommendations to Advance Ukraine’s EU Integration in 2025–2026

Shadow Report Presentation by Transparency International Ukraine

According to Рубрика — Суспільство: On October 19, Transparency International Ukraine, together with a coalition of civil society organizations, released their third Shadow Report addressing Chapters 23 and 24 of the European Commission’s 2025 progress report on Ukraine. Covering the period from September 2025 to August 2026, the report offers 141 specific recommendations aimed at accelerating Ukraine’s path toward European Union membership. It highlights four critical obstacles currently hindering progress:

• The institutional capacity of anti-corruption agencies;
• Criminal justice;
• Financial oversight;
• Management of criminal assets.

Investigations by the National Anti-Corruption Bureau of Ukraine (NABU) and the Specialized Anti-Corruption Prosecutor's Office (SAPO) reveal attempts by senior officials to influence selection committees. Meanwhile, the SAPO audit has yet to commence, and an external evaluation of the National Agency on Corruption Prevention (NACP) has been stalled for over four years. NABU’s jurisdiction does not extend to the leadership of the Presidential Office, the State Bureau of Investigations, or the Economic Security Bureau. Additionally, the Lozovyi amendments remain in place, and legislation aimed at curbing abuses of procedural rights has not been adopted.

The report also notes that two-thirds of the High Anti-Corruption Court’s (HACC) verdicts result from plea agreements, while the NACP rarely detects cases of illicit enrichment. Furthermore, the NACP fails to publish its logical and arithmetic control rules, and the system for managing seized and confiscated assets requires improvements in record-keeping and enforcement mechanisms. Pressure on NABU and SAPO persisted throughout the reporting period, including raids, arrests of detectives, surveillance of their leaders, and activities by Temporary Investigative Commissions.

Report Development and Recommendations

Experts from Transparency International Ukraine conducted 17 interviews with representatives across various sectors, submitted 12 information requests to state bodies to clarify statistics, and analyzed 73 actions from the Roadmap on the rule of law, anti-corruption, and anti-money laundering efforts. The report was developed with contributions from several expert organizations, such as the Laboratory of Legislative Initiatives, ZMINA Human Rights Center, Advocate of the Future, Europe Without Barriers, the Ukrainian Bar Association, the Opora Civil Network, and the Center for Democracy and Rule of Law, with informational support from European Truth.

Chapters 23 and 24 form part of Cluster 1, "Foundations of the EU Accession Process," which is both the first to open and the last to close in Ukraine’s EU negotiations. This Shadow Report marks a crucial step in outlining priorities for enhancing anti-corruption policies and improving the criminal justice system in Ukraine.

This document serves as a vital tool for assessing Ukraine’s advancement in combating corruption and upholding the rule of law. The recommendations contained within provide a foundation for reforms necessary to propel Ukraine closer to European integration.

As Ukraine continues to navigate its path towards EU integration, the recent findings from the EU Commission's recommendations underscore the urgent need for reforms in anti-corruption agencies and asset declaration processes. These developments are crucial for addressing the systemic challenges highlighted in the Shadow Report and ensuring a more robust framework for Ukraine's governance and accountability.