Igor Popov, Director, United Ukraine think tank
All management theories recommend conducting periodic assessments of performance, both internal and external, in order to improve efficiency, and then using these assessments to make management decisions on planning, priorities, workflows and motivation. Business corporations hire reputable consulting and audit firms for this purpose. Government bodies sometimes also engage private consultants or establish special assessment commissions. In our public discourse, the experience of Kakha Bendukidze’s reforms is usually seen as positive, while the Department of Government Efficiency (DOGE) under Elon Musk is viewed mainly as a negative example.
The introduction of external assessment for law enforcement agencies has become a separate challenge for Ukraine. The law on the National Anti-Corruption Bureau of Ukraine (NABU) established mandatory annual assessments. Such an assessment was meant to serve as one of the safeguards balancing the strengthened institutional independence of the new anti-corruption body. If the assessment was negative, the NABU Director could be dismissed from office, and this was probably one of the reasons why the assessment process was sabotaged. The creation of the assessment commission was blocked for many years, and as a result the first external assessment was carried out only in 2025. The commission assessed NABU’s work only for the period from March 2023 to November 2024, but its report provided important conclusions and 26 recommendations for improving NABU’s work. For example, it identified the problem of detectives being overloaded with minor cases, which prevents resources from being concentrated on investigations of high-level corruption. A number of recommendations concerned improvements to the work of the Internal Control Department. Recommendations on giving NABU autonomous capabilities to intercept communications and ensuring access to timely and impartial expertise were included in the draft State Anti-Corruption Strategy and became indicators in Ukraine’s EU-integration plans.
The next annual assessment of NABU’s activities is to be conducted in 2026, although the relevant assessment commission has not yet been formed. The new commission will examine the status of implementation of the recommendations from the previous assessment. It may also conduct an in-depth analysis of the duration of pre-trial investigations and develop recommendations to strengthen the principle of the inevitability of punishment in high-level corruption cases. The main KPIs for assessing investigations could include convictions and the recovery of losses inflicted on the state by corrupt officials.
The rule on external assessment of the Specialized Anti-Corruption Prosecutor’s Office (SAPO) is contained in Article 8-1 of the Law “On the Prosecutor’s Office.” Such an assessment must be conducted every two years, but no more than twice during the term of office of the SAPO head. The commission consists of three members and is appointed by the Prosecutor General on the basis of proposals from international and foreign organizations. So far, SAPO has not undergone such an assessment, but it is already possible to identify a number of issues that could be included in the terms of reference for the relevant commission. A discussion is already under way about who should authorize investigative actions involving members of parliament. Proposals to revise the relationship between the SAPO head and the Prosecutor General have also attracted public attention. There are proposals both to strengthen oversight and to weaken it. The commission should examine the practice of court proceedings in such cases, including the effectiveness of plea agreements between defendants and investigators. A significant share of agreements and judgments are classified, which has drawn criticism from experts and relevant professional associations. The authorized commission should review all details of such agreements and provide recommendations on the use of this instrument in future cases.
In June 2026, the Accounting Chamber published a report based on the audit of the State Bureau of Investigation (SBI). This report assessed the results of the SBI reform carried out in 2020-2021 and confirmed the institutional capacity of the SBI to perform the tasks assigned to it. The report also provided recommendations for further improving the Bureau’s efficiency. In addition to financial control, the Accounting Chamber’s mandate includes the authority to assess the activity and effectiveness of state bodies, which is what was done in this case. The report is public and is available on the Accounting Chamber’s resources.
It is noteworthy that a number of the Accounting Chamber’s recommendations for the SBI correlate with the recommendations of the NABU assessment commission. Here, too, considerable attention is paid to strengthening internal control mechanisms, including proposals to enhance the institutional independence of the relevant units. The report also proposes including the Research Institute of Forensic Examinations of the State Bureau of Investigation in the list of entities authorized to conduct forensic expert activities. This confirms the importance of access to professional and timely expert examinations.
The report recommends establishing a clear procedure for appointing and dismissing the First Deputy and Deputy Directors of the SBI. This should become one of the tasks for the next package of legislative amendments. Another part of these amendments should eliminate contradictions and inconsistencies between the current Law on the SBI and the Criminal Procedure Code of Ukraine regarding investigative jurisdiction.
The joint statement by Enlargement Commissioner Marta Kos and Ukraine’s Deputy Prime Minister for European and Euro-Atlantic Integration Taras Kachka, adopted in December 2025, also contains recommendations on continuing the reform of the SBI. Representatives of the Ukrainian government and the EU state the need for an independent comprehensive review of the SBI’s institutional structure, integrity safeguards and oversight functions in order to assess the necessity and feasibility of further reforms in line with the best European practices. Accordingly, the audit conducted by the Accounting Chamber is part of the implementation of the European integration roadmap. On the basis of the SBI assessment report, the Verkhovna Rada should prepare specific proposals aimed at strengthening the institutional structure and integrity safeguards.
Let us be frank: in Ukraine, the term “reboot” is often exploited for political purposes and reduced to personnel purges and political influence over independent bodies. A draft law on a “reboot” can sometimes fit on a single page and simply create a mechanism for appointing a candidate from a specific political group to a leadership position in an independent body. On the other hand, organizational audits are a global practice for carrying out systemic reforms, and their results should lead to institutional changes, not political reshuffles.
Ukrainian society is interested in the effective work of law enforcement agencies, and therefore it will support clear and transparent recommendations based on a systematic analysis of problems and challenges. Discussions on the specifics of investigations, staffing and financial support, and nuances of the codes should be separated from emotional political debates, which are increasingly used as cover for specific lobbying. In these discussions, it is important to rely on best practices applied in EU member states, practices that have been tested over years of work and thousands of cases.
Igor Popov, Director, United Ukraine think tank
