One of the crucial anticorruption bodies in Ukraine is the National Agency on Corruption Prevention (NACP), which has been working for over ten years. Every year, the state spends almost UAH 600 mln on the activity of the NACP, and the average salary of the agency employees is about UAH 100 thousand a month. Yet, despite such expenses, frankly speaking, the results of the NACP work aren’t impressive.
NGL.media analysed about three thousand cases, transferred to the court following the work results of the NACP in 2020-2025. It turned out that the courts just dismiss most of these cases.
The NACP practically doesn’t reveal any top corruption cases on its own, it just reacts to the messages from the NABU or investigative journalists. For instance, in the well-known case of Tetiana Krupa, at first, the NACP found violations for the amount of UAH 356 thousand, and only when the NABU stepped in, it turned out that the violations amounted to tens of millions.
On their own, the NACP employees inspect only about one thousand out of over 630 thousand declarations in one year, but the criterion of their selection is unknown. In general, only one out of ten NACP employees carries out these inspections, which is obviously not enough, the rest give anticorruption lectures in schools, organize exhibitions, etc.
So how can one evaluate the actual effectiveness of the NACP? This is something nobody can tell for sure, because there is no independent audit. And it looks like no such audit will be conducted in the nearest future.
The NACP does prevent, but not completely
The National Agency on Corruption Prevention deals with a broad range of issues. This isn’t just maintaining the register of declarations and their analysis, but also the participation in legislative changes, education, awareness campaigns and many more directions, described in detail on the website of the NACP. Even a glance at the plans of the NACP work shows that most resources are spent on the analysis of draft laws and awareness raising functions: preparing educational anticorruption programs, conducting trainings for state officials, etc.
It is hard to evaluate the effectiveness of these events, so NGL.media focused on the indices that can be analysed using open data. First of all, it concerns the inspections of state officials’ declarations.
Pursuant to the law, the NACP is authorized to draw up records on administrative offences and to collect the materials, revealing the features of a criminal offence, and transfer them to the law enforcement bodies.
The administrative records are drawn up and transferred to the court, if:
- inaccurate data are found in the declarations for the total amount from 150 to 750 subsistence rates from UAH 499,200 to UAH 2,496,000 in 2026. If the offence exceeds 500 subsistence rates, it falls under criminal responsibility;
- the declaration wasn’t submitted on time but it concerns only top officials, in other cases, the National police deals with it;
- there are violations regarding holding more than one office, gifts, conflicts of interests, etc.
After the inquiry, NGL.media received from the NACP the numbers of all the cases, transferred to the court in 2020-2025. To understand the performance of the NACP work, we analysed almost 3,000 such cases It should be noted that the distribution of cases in terms of years was extremely uneven: for instance, in 2022, 266 cases were transferred to the court, and in 2023 – only 76. It is explained by the fact that after the beginning of the full-scale war, the obligation to submit a declaration was suspended, and the authorities of the NACP to inspect declarations were temporarily limited. These authorities were restored at the end of 2023, half of which are records on untimely submission of the reports by the political parties. One quarter is related to mistakes, made while submitting declarations, and almost 10% of the cases are related to conflicts of interests.
Minimal performance
The analysis by NGL.media shows that 52% of all the records, drawn up by the NACP, are just dismissed by courts, and in cases regarding the conflict of interests, this index reaches 90%. The defendants in 5% more cases are found guilty but exempted from liability.
Mainly, the courts dismiss these cases due to three reasons: failure to meet the time limits for bringing charges pursuant to the law, penalties must be imposed within three months since the day of discovery, but not later than one year since the day of committing the offence, lack of evidence or the minor nature of the offence.
It is noteworthy that starting with 2024, the number of cases, won by the NACP in court, increased up to about 60% 62% in 2024 and 58.4% in 2025. However, the statistics improved mainly due to cases ofuntimely reporting of political parties. The law, restoring the obligation of the parties to submit quarterly reports, came into force at the end of 2023. So, the NACP started inspecting actively whether the parties were submitting these reports, and if they didn’t, the NACP drew up administrative records. These cases are easier to prove than, say, conflicts of interests, so the courts find defendants guilty more often.
Last year, the share of cases on party reports was about 80% of all the cases, won by the NACP in court. The same year, there was some improvement regarding the cases of conflict of interests, although the Public Integrity Council at the NACP a collegiate body, established pursuant to the law “On Corruption Prevention” to ensure transparency and public control over the activity of the NACP still believes it to be a low index of effectiveness.
“A small share of records, pursuant to which the defendants are found guilty, may demonstrate the problems with the quality of preparing administrative materials or the problems in judicial practice, caused by disagreement with the normative and legal regulations. These statistics demonstrate current problems with revealing offences in the legislative sphere related to prevention and regulation of conflicts of interests,” said the report of the Public Integrity Council at the NACP for last year.
It should be noted that last year, the NACP in cooperation with the experts of the Centre of Policy and Legal Reform studied the judicial practice of hearing the records on corruption-related offences in 2014-2024. The results were presented in detail in the report of almost 170 pages, but the essence of this matter can be approximately described as follows: in ten years, the problem of dismissed cases and minimal punishment for crimes of corruption hasn’t changed much.
Top corruption goes unnoticed
As for more serious corruption-related offences, which amount to criminal responsibility, in the ideal variant, it is the NACP that should be the first to discover persons, involved in such cases, as “Midas” for instance In November 2025, the NABU announced its discovery of the criminal organization, whose main direction of work was “systematic obtaining unlawful gains from the contractors of Enerhoatom in the amount of 10% to 15% from the contract cost”. That’s when the bureau gave notices of suspicion to seven persons: Tymur Mindich, the co-founder of the Kvartal-95 studio, Ihor Myroniuk, former advisor to the minister of energy, Dmytro Basov, the executive director on security issues of Enerhoatom, and four employees of the so called “back-office of money legalization”. Later, the NABU declared that the money could be laundered via the construction of Dynasty cooperative society. In May, Andrii Yermak, the former head of the President’s Office, was given an official suspicion within this case, and to transfer the information to the NABU, but this is not what happens in reality.
Every year, about 630 thousand Ukrainian state officials submit their declarations, but it is physically impossible to check each one of them. Previously, the NACP employees conducted inspections based on the level of the officials’ positions. Since the beginning of the full-scale war, the inspections were suspended, and they were restored only at the end of 2023. That’s when the approach to inspections changed too. Now, all the declarations undergo automated inspection: they are automatically compared against state registers and databases, and if any inconsistencies are revealed, the declarants receive a notice about it so that they could take these mistakes into account while submitting the next declaration.
At the same time, some declarations are selected for specific deeper inspection, which is conducted by the NACP employees directly. The detailed algorithm for selecting such declarations is kept secret, it is only known that the system of logical and arithmetic control is in place. Only about one thousand declarations get to undergo a deeper inspection.
The automated processes were created as an auxiliary mechanism for thorough analysis of declarations, but in practice, they work insufficiently. A dishonest declarant may include only some basic data in the declaration, which matches state registers 100% – and the system won’t work, because there is nothing to compare it to. Off-shores, cash, children’s study abroad – all these go unnoticed by automatic control.
“The increase in process automation should have compensated for the lack of human resources. And it does increase the quantitative indices of inspections, but in terms of quality, they don’t yield the result that would meet the public demand,” Natalia Sichevliuk, the legal advisor to Transparency International Ukraine, explains to NGL.media.
The evident example of the abovementioned is a recent case of Herman Halushchenko, the former minister of energy, detained by the NABU on suspicion of laundering about USD 12 mln via offshore companies. Yet, his declarations used to pass the automated inspection successfully. In the opinion of Natalia Sichevliuk, if someone in the NACP personally inspected Halushchenko’s declarations, the features of illegal enrichment could have been revealed much sooner.
However, automation isn’t the only problem. Even if the declaration gets to be inspected manually, it doesn’t guarantee that the NACP will reveal the actual scale of the offence. A vivid example of that is the case of Tetiana Krupa, suspected of illegal enrichment for the amount of UAH 160 mln. Her declaration for 2023 was inspected manually, and as a result, the NACP found inaccurate data for the amount of UAH 356.4 thousand, which falls only under administrative responsibility. Yet, after she was detained, when millions of dollars in cash were found in her office and home, the NACP re-inspected the same declaration and declared the offences for the amount of UAH 18.4 mln which now falls under criminal responsibility.
“Generally, it is the same statistics from year to year: many offences regarding inaccurate data are discovered, but the unsubstantiated assets and features of illegal enrichment are much fewer. And this is exactly what forms the main demand both from the public, and the international partners. Because, no matter how much we want them to combat corruption on all the levels, everybody still understands that the corruption at the highest level still does most harm during the war,” Natalia Sichevliuk from the Transparency International Ukraine says.
This point of view is confirmed by the NACP reports as well. For instance, last year, following the results of lifestyle monitoring, the agency came to the conclusion about probable illegal enrichment of 94 state officials as compared to 505 declarations with features of inaccurate declaring.
In the words of Anastasia Radina, the head of the parliamentary committee on issues of anticorruption policy, the question about prioritizing state officials for inspection by the NACP was raised in the Verkhovna Rada many times, yet it yielded no results.
“There is no goal of inspecting 600 thousand declarations a year. There is a goal to elaborate such a risk-oriented approach, which would enable extracting from the [general] pool those declarations that deserve attention first and foremost. And which also makes declarants feel that their declarations aren’t submitted in void. Has it been implemented? In my opinion, it hasn’t,” Radina says.
In her words, while conducting complete inspections and monitoring the lifestyle, the NACP is mainly oriented towards the law enforcement system.
“Even last year, they told us at the NACP that first of all, they are focused on the inquiries from the law enforcement bodies. That is, our central body of the executive power, whose function is to conduct the lifestyle monitoring and thus define who or what law enforcement bodies should pay attention to, starts working only when they paid attention to it on their own,” Anastasia Radina believes.
Appealing the results of the NACP work
If one is to look at figures only, the NACP indeed works: last year, violations were found in every other inspected declaration – inaccurate data for UAH 3.8 bln, features of illegal enrichment for UAH 460 mln In 2025, the NACP conducted a total of 970 complete inspections of declarations, and violations were found in 505 of these. The lifestyle monitoring of 247 declarants was also conducted.. Yet, real sentences are quite rare. Besides, some results of inspections are successfully appealed by declarants in court.
NGL.media counted that in 2020-2025, they submitted 104 appeals, 88 of which (85%) were granted.
Last November, the Kyiv district administrative court abolished the results of the inspection of the declaration, submitted by Valentyna Aranchii, the first vice-rector of the Poltava State Agrarian University. The NACP employees found inaccurate data for the amount of UAH 1.7 mln. However, the court ruled that they had failed to meet the deadlines for conducting the inspection and had exceeded their authority. This case is currently under appeal.
Hundreds of budget millions
Last year, the NACP received UAH 1.36 bln from the state budget, UAH 768 mln of which were transferred to finance political parties The state finances the statutory activity of the parties, which have got at least 5% of the votes in the most recent elections held on the proportional basis. As for the agency itself, it spent UAH 593 mln on its own activity last year.
Where did this money go? Almost all of it went for salaries, and the rest – mostly for equipment, municipal and other services.
Last year, the NACP paid UAH 505 mln to its employees, which is 84% of the entire amount; 413 people worked in the agency, so the average salary of a NACP employee was about UAH 1.2 mln a year.
However, Viktor Pavlushchyk, the head of the NACP, declared over UAH 4 mln of his salary last year. More than three million were received by his deputies – Serhii Huliak and Dmytro Kalmykov. Yulia Kulikova, the head of the department for conducting complete inspections, stated UAH 2.2 mln of her salary per year in her declaration.
At the same time, only about 10% of the agency employees actually inspect declarations and monitor lifestyle, which were the goals for establishing the NACP in the first place, as per Kateryna Butko, the head of the Public Integrity Council at the NACP.
“The agency has an awareness-raising department which deals with school programmes about corruption, for instance. There is a department, dealing with anticorruption expertise – the analysis of corruption risks in draft laws. Plus, there is certainly a large group of people working on the anticorruption strategy, whistleblowers, lobbying,” Butko explains.
Shortage of human resources is a constant response of the agency management to the criticism of their performance, as per Anastasia Radina. She believes that actually the problem lies in the distribution of resources.
“We said that the agency should increase the staff numbers in the departments, dealing with declaration inspections or lifestyle monitoring. And we are told: It won’t happen, because we are short of people. Yet, at the same time, these people are found to give a lecture at school on the harms of corruption,” Anastasia Radina explains in a conversation with NGL.media. “One may not necessarily agree with me, I am sceptical about the possibility of the central body of the executive power to carry out awareness-raising work. Obtaining results in this field requires much more resources than one-time lectures of the topics “Don’t take bribes!”, “Be vigilant”, and other socialist slogans.
Help from international donors
The NACP is also financed by governments of other countries – the EU, the USA, the UK, Canada, and Switzerland. In six years, the agency received over UAH 100 mln from foreign donors, including almost UAH 30 mln from the EU.
For instance, the EU paid for sociological surveys for the NACP, the elaboration of anticorruption strategy, trainings on risk assessment, trips to Romania, and software. Also, the EU gave financial aid for the elaboration of the lifestyle monitoring concept. And immediately after the Russian invasion in 2022, it even supplied the NACP with armour vests and ballistic helmets.
According to the documents on the international technical aid to the NACP, which are at the disposal of NGL.media, the Europeans paid for the leadership training for Viktor Pavlushchyk, the head of the NACP, and the English language courses for the employees, they also financed the awareness-raising activity of the NACP – the elaboration of an integrity strategy for educational institutions. Within the framework of this aid, the NACP employees conducted trainings at schools and gave them the textbooks of “Anticorruption course for the 9th grade”.
Prior to early 2025, the NACP was actively supported by the USAID as well. For instance, the American money was used to create the whistleblower portal, where one could anonymously report the facts of corruption and even receive 10% from the amount of the losses, incurred by the state.
This portal was launched in September 2023. At present, the NACP reported only two payments to whistleblowers One of the payments was received by Yevhen Shevchenko, who in 2020 reported the attempt to bribe the heads of the SAP and the NABU, although in both cases, the whistleblowers informed the NABU, not the NACP.
It is easy to get into the NACP without any checks
Open competitions were established for people willing to join the NACP team, starting from 2020. All the candidates passed testing and meetings with the members of the Public Integrity Council at the NACP. Prior to the appointment, they also passed special checks, including the inspection of their declarations and integrity.
There are checks for employees after their appointment as well. It is done by the department of NACP internal control where seven people are employed. Last year, this department conducted six complete inspections of employees’ declarations and 92 checks of information about candidates.
Similar to other state structures, the procedure for employment at the NACP was changed by the full-scale invasion – since May 2022, all the appointments are made without any competitive procedure. Both meetings, and special checks were suspended.
“There is a human resources department of the NACP which processes the CVs. From time to time, they report to the public integrity council to say who they hired, how many people applied, etc. But there are no meetings or competitions,” Kateryna Butko, the head of the Public Integrity Council at the NACP, explained.
While analysing the declarations of the active NACP employees, in some of them the NGL.media analysts obviously found some information, which raises doubts regarding integrity.
For instance, in 2023, Hanna Dihtiarenko, the specialist of the integrity formation department, bought a Toyota Camry of 2007 for mere UAH 45 thousand. This is extremely cheap, since such cars cost 6-8 times more, as a rule. Dihtiarenko refused to talk to NGL.media.
Last spring, Natalia Pohorilo, another agency employee, received a gift of an apartment in Kyiv with an area of 60 sq.m., and valued it as UAH 200 thousand. At the same time, the actual cost of apartments in her house starts from USD 50 thousand. “This is a gift from my own brother,” Natalia Pohorilo explained. “When he was drawing up the gift agreement, he specified this price.” Yet, she refused to explain the origin of her brother’s money for this gift.
There is an employee, Sofia Tsyktich, the daughter of Vitalii Tsyktich, the daughter of “Maidan judge”, in the department of policy formation in the sphere of corruption prevention of the NACP Vitalii Tsyktich, the judge of the Shevchenkivskyi district court, made several rulings against the participants of the Revolution of Dignity, depriving them of driving licences. Also, he allowed car searches of the protest participants. She was employed in the NACP in 2024, while continuing her studies in the Taras Shevchenko National University of Kyiv. Only one year later, Sofia became the owner of the Kyiv apartment with an area of 90 sq.m. via privatization. This is an apartment that was received by her father as company housing three years before that.
It should be noted that the scheme with privatization of company housing is widespread among judges – they hide their real estate by registering it in the names of their relatives (for instance, Vitalii Tsyktich used an apartment, registered in the name of his mother, a pensioner, for years). State officials receive company housing, because they allegedly don’t have their own living space, and several years later they privatize it. At the same time, in case of judges, with their salary they can easily afford a purchase of their own housing instead of taking real estate, which may be needed by other, less well-to-do officials, for themselves.
Finally, that’s what Vitalii Tsyktich did – last year he bought an apartment in the Kyiv RC Nyvky-Park for almost UAH 4 mln, and two Mercedes cars, for which he paid almost UAH 2 mln more.
A convenient anticorruption body
Last July, the Verkhovna Rada adopted a law that limited the independence of the NABU and the SAP in combating corruption considerably. Public activists, some people’s deputies, and international partners spoke against this decision that provoked protests, involving thousands of people. Finally, this decision was abolished.
At the same time, the NACP, a body that forms the anticorruption policy, didn’t comment on these events at all. The first public statement of Viktor Pavlushchyk, the head of the agency, appeared only three months later.
“In my opinion, the main thing which the NACP should have done at the time was to give public comments on this story, to say that it is not normal. Because it is the NACP that is responsible for the anticorruption policy in the country in general. And it should have reminded that the independence of the NABU and the SAP is a part of our international obligations, and the anticorruption strategy, etc,” Kateryna Butko, the head of the Public Integrity Council at the NACP, believes.
In the words of Anastasia Radina, the NACP could have stopped the voting process in the Verkhovna Rada, since it has a right to stop hearing any draft law for about ten days to carry out the examination. Yet, the NACP didn’t take advantage of this possibility at the time.
A similar logic of work – saying nothing – was manifested in another case. In February 2025, the NACP started a complete inspection of the declaration of Andrii Yermak, the then head of the President’s Office. Yet, breaking the established procedure, the agency didn’t publish any information about the start or results of the inspection prior to Yermak’s dismissal. The reason, stated for it, was a letter “from a state body with the requirement to restrict the access to information about the inspection due to the application of safety measures to the declarant”.
According to Anastasia Radina’s information, the letter was sent by the Security Service of Ukraine. “This letter should not have served as any legal basis for the NACP whatsoever. It isn’t envisaged by the procedure of inspecting a declaration that other bodies may demand that the NACP should close some information for inspection in any way,” the head of the parliamentary committee on anticorruption policy issues explains.
Radina believes that the only explanation for the NACP behaviour could be only “ensuring the comfort” of Andrii Yermak. “For a very respectable person not to be distracted from state-level issues by bad journalists and their questions about inspecting the declaration. I don’t see any other explanation. Absolutely all the state officials undergo their declaration inspection wonderfully, being highlighted in this online NACP register. Nobody has died due to this reason, nobody started doing their official duties any worse,” the deputy notes.
It is noteworthy that the questions about the independence of the NACP were also raised in the autumn of 2025, after the publication of so called “Mindich’s tapes”. According to the NABU records, in May 2025, Dmytro Basov, the head of security department of Enerhoatom, may have allegedly given a bribe of USD 20 thousand to the NACP. At that time, Viktor Pavlushchyk, the head of the agency, announced an internal investigation, which, after all, didn’t see the involvement of any NACP employees in the “Midas” case.
“Didn’t reach the threshold of ineffectiveness”
According to the law “On Corruption Prevention”, the agency has to undergo an independent audit once every two years. However, in almost 10 years of the NACP existence, it was conducted only once – for 2020-2021.
At the end of 2019, the agency was headed by Oleksandr Novikov, a former prosecutor. He was supposed to completely reboot the NACP after the management of Natalia Korchak and Oleksandr Manhul. In their times, the agency practically didn’t check the officials’ property, and the employees allegedly received orders from the President’s Administration on whose declarations shouldn’t be inspected. Journalists discovered that Korchak herself owned undeclared property.
The audit results of the first two years of Oleksandr Novikov’s work were published only in July 2023. Kateryna Butko, the head of the Public Integrity Council at the NACP, says that this audit should have demonstrated work effectiveness, first of all related to the agency management. Yet, considering that it was being prepared for a year and a half, the results didn’t impact much.
“After a new head, elected in a transparent competition, has been working for the first two years, his work is to be checked by auditors. They specify what should be improved for the head to have a chance to do it while still in office. And here, we have received the report at the time when this person is about to leave his office, and the NACP head, say, is lukewarm to this matter,” Butko explains.
The independent auditors evaluated Oleksandr Novikov’s work rather positively: in 2020-2021, under his leadership the agency completed 72% of the indices, defined for the audit. Yet, in their conclusion they failed to define whether the agency is working effectively.
“During the evaluated period, the NACP activity mainly didn’t reach the threshold of ineffectiveness. However, following the evaluation of the NACP’s meeting the criteria and the general opinion of the commission about the NACP activity during the mentioned period, the commission refrained from making a conclusion about the effectiveness of the NACP,” says the report.
In Kateryna Butko’s opinion, one of the problems lies in the very criteria, approved by the government. They are too numerous to be able to clearly answer the question whether the NACP does a good or bad job.
“The very idea of the audit should be somewhat reassessed. They had an 80-page-long list of criteria from the Cabinet of Ministers for the auditors to follow. But to get effective results, the auditors should define the indices on their own and focus on, say, 10 key indices. They shouldn’t, forgive me, evaluate how clean toilets are,” Butko explains.
Why haven’t there been any further audits? The Ministry of Justice hasn’t implemented the criteria by which auditors are to check the agency. At the same time, as pointed out by the Transparency International Ukraine, the Ministry of Justice consulted with the NACP about the indices, practically allowing the agency to impact the way it will be evaluated.
Will there be a new audit?
At present, the most recent independent evaluation of the NACP work is the report of the European Commission for 2025. In particular, it highlights the non-transparency of automated inspection of declarations. The rules, by which a declaration is selected for inspection, are not public, so it is impossible to evaluate how effective and independent from any side impact the algorithm is. Also, the European Commission emphasized that there should be a new audit, and the sooner, the better.
In November 2025, a draft law that is to unblock and generally change the procedure of the NACP audit was registered in the Verkhovna Rada. Firstly, the government will have to set up an evaluation commission. Secondly, the criteria of evaluating the NACP will be defined by the very commission, not the government via the Ministry of Justice.
“The appropriate approach to solving this matter would be like this: the auditors, recommended to the Cabinet of Ministers by international partners, should be given a possibility to define the audit criteria on their own. The NABU and the ARMA have undergone this audit during the full-scale invasion,” Anastasia Radina says.
In her opinion, the reports, composed by the NACP itself, cannot be considered an objective assessment. “The very goal of auditing is for external independent players to say, ‘So, is the report true or not?’ For some reason, we make children, for instance, pass an independent evaluation, we don’t just accept the grades given by their tutors and teachers of specific subjects,” Radina explains.
In their response to NGL.media’s inquiry, the NACP stated that they “fully support the conducting of the external independent audit”.
“I can’t name the ‘success story’ of the NACP, single out one of the agency’s functions and, within it, single out a specific case which was a success. At the same time, unfortunately, I can single out many separate cases which make us raise a question on how effective they work,” Anastasia Radina states.
Authors Maria Horban and Kateryna Rodak, editor Oleh Onysko, infographics Maksym Piho, translation Nelya Plakhota, cover Viktoria Demchuk
