The development hell of the anti-corruption strategy: two years of development, 400 expected results, and one procedural trap

Pavlo Velykorechanin, Deputy Head of ARMA (2023-2025)

In the film industry, there is a term called "development hell." This is when a movie is written, rewritten, cast, rewritten again, has its director changed, is recast, and so on for years. The movie seemingly exists on paper, stars are already attached, and there is a multi-million dollar budget—but it never actually hits the screen.

This is roughly the state of the Anti-Corruption Strategy for 2026–2030 today. And this, you must admit, is quite unexpected for a document that was officially in preparation for almost two years.

Let's break down how we got here, step by step.

Two Years of Collective Work

First, about the scale. The draft Strategy, which forms the basis of all three current draft laws, has been prepared by the National Agency on Corruption Prevention (NACP) since 2024. According to official NACP figures, this work involved 26 public discussions with 790 experts, 26 separate analytical studies, identified over 140 problems in 16 priority areas, and formulated more than 400 expected strategic results. Transparency International Ukraine, the Anti-Corruption Action Centre (AntAC), the Institute of Legislative Ideas, and dozens of industry experts participated in the development.

This is not some "scrap of paper from the NACP." It is a five-year framework document upon which crucial reforms depend—ranging from judicial governance to defense procurement, from customs to whistleblower protection. In short, the main idea of this document is to close the "blind spots" the anti-corruption system has lived with for the past five years and synchronize it with the EU integration agenda.

On April 2, 2026, the NACP officially handed the draft over to the Cabinet of Ministers. And from that moment, development hell began.

Three Draft Laws Instead of One

For a month, Yulia Svyrydenko's government kept the document shelved the document, making its own amendments. This wouldn't have been an issue if the amendments had been technical. However, they turned out to be substantive, and not in the direction of strengthening the document.

Seeing where the process was heading, the Verkhovna Rada Committee on Anti-Corruption Policy made an unconventional decision: Committee Chair Anastasiya Radina proactively registered the NACP's baseline text as a separate legislative draft. Thus, on May 13, Draft Law No. 15230 appeared in the Rada.

Five days later, the government submitted its own version under number 15230-1. Another week later, on May 25, the "European Solidarity" party entered the game with its alternative draft law, No. 15230-2.

A compromise working draft, indexed as No. 15230-d, is already prepared in the profile committee. But until it is adopted, we are in a situation where three different proposals, each with political undertones, are sitting on the same "skeleton."

What the Government Crossed Out

If we compare the baseline NACP text with what the government submitted, the picture is as follows: the government removed the exact provisions that European partners most loudly demanded in the December 2025 communiqué by Taras Kachka and Marta Kos.

There are three specific points:

• First: The problem of political influence on the appointment and dismissal of the Prosecutor General vanished from the government's version. In other words, the government simply decided that we don't have such a problem for the next five years.
• Second: The competitive selection of the Head of the State Bureau of Investigation (SBI) with a decisive vote for international experts was crossed out.
• Third: The right of the Head of the Specialized Anti-Corruption Prosecutor's Office (SAPO) to enter information into the Unified Register of Investigative Decisions (ERDR) regarding MPs without the Prosecutor General's approval was removed.

In short, with one stroke of the pen, the tools that make anti-corruption bodies politically independent of the executive branch were removed from the text. This is not a technical-legal improvement. This is a substantive decision.

What "European Solidarity" Wants

The position of "European Solidarity" ("ES") on the Strategy deserves a separate analysis, as it is not limited to a cliché "we are against the government" stance. The trigger for their separate draft version was the "Mindich tapes"—audio recordings that brought the issue of political control over the State Bureau of Investigation (SBI) to a head. This is why the primary focus of their draft law is on the SBI.

In essence, "ES" demands a complete "reboot" of this agency. Their draft introduces several new mechanisms:

• Periodic external independent audits (following a negative conclusion of which the leadership is suspended).
• A clear focus on official misconduct and torture (the SBI's primary mission).
• SOCTA analysis according to European standards.
• The hearing of the SBI Director's report by the Verkhovna Rada within 30 days after the law enters into force (ambitious, to say the least).

In addition to the SBI, "ES" proposes to legally strengthen the role of the Public Integrity Council, detail the rotation of court chairs, and reform the National School of Judges. Here, they are standing on the side of civil society rather than the system.

However, there are two "buts" that prevent their version from being considered ideal:

1. "ES" proposes to equalize the rights of international experts in selection panels with those of Ukrainian members, effectively stripping them of their decisive vote. This directly contradicts point 23.2.1 of the interim key indicators under Cluster 1 "Fundamentals of the EU Accession Process."
2. Regarding the Prosecutor General's appointment procedure, "ES" appeals to vague "best European practices" without proposing a concrete competitive mechanism, which is present in the MP-sponsored draft No. 15230.

In other words, substantively, "ES's" position is a demand for maximum accountability of law enforcement agencies to parliament, while simultaneously limiting the direct influence of international experts.

What Will Happen to the Government's Draft Law

Here begins the legal, but critically important part. Part 3 of Article 105 of the Rules of Procedure of the Verkhovna Rada states directly: if the government that submitted a draft law resigns before the document is adopted in the first reading, it is automatically considered withdrawn. No manual procedures, no voting—it simply vanishes from consideration in the electronic system.

We know this precedent well. In July 2025, upon the resignation of Denys Shmyhal's government, as many as 353 government draft laws were withdrawn this way. Svyrydenko's government later re-registered only 59 of them—less than seventeen percent. Everything else simply fell away.

The government's No. 15230-1 currently holds the status of "being processed in committee" and has not been adopted in the first reading. Thus, from the moment of the vote on the government's resignation, it legally "evaporates." The MP-sponsored No. 15230 and No. 15230-2 live on independently and continue to move forward.

Problem One: The Deadline Has Already Been Missed

According to the Ukraine Facility plan, the Strategy, along with the State Anti-Corruption Program, was supposed to be adopted by the end of June 2026. It was not. A European Commission spokesperson confirmed that the funding associated with the fourth and fifth tranches is currently "suspended." Thus, Ukraine risks losing part of its European aid due to stalled anti-corruption reforms, rather than receiving additional funds for their implementation.

The Kachka-Kos communiqué, adopted in Lviv in December 2025, contained ten points to restore trust after the July 2025 episode involving the temporary weakening of the NABU and SAPO. Ukraine committed itself to fulfilling them within 12 months. According to the "Membership Check" coalition, as of June 2026, only 15 percent of the plan has been implemented. There is progress, but it is painfully slow.

Problem Two: ARMA is Missing from the Strategy

For some reason, this is rarely discussed, but it represents a major conceptual gap. Neither the NACP's baseline text nor any of the three draft laws contain a section on the National Agency for Recovery and Management of Assets (ARMA). Only in the committee's compromise version No. 15230-d does problem 1.10.4 emerge regarding the "improper management of assets transferred to ARMA."

This looks strange, to say the least. The ARMA reform, adopted under Law No. 4503-IX in 2025, was one of the few truly systemic institutional reforms in recent years. Yet, its implementing regulations remains largely unimplemented as of 2026, despite the fact that key asset management mechanisms were supposed to become operational starting in February. Ignoring this history in a five-year Strategy means embedding a "blind spot" right from the start.

The situation we find ourselves in paradoxically presents an opportunity. Losing the government's No. 15230-1 due to the cabinet's resignation is not a disaster. It is an opportunity to do things right.

• First: Do not wait for a draft law proposal from the new government. The committee can and must take No. 15230 (the NACP text without government omissions) as a basis right now. This document does not depend on the composition of the Cabinet of Ministers. All that is needed is the political will of the Rada.
• Second: "Stitch" together the best elements of the three texts. Take the EU integration provisions from No. 15230 (the Prosecutor General selection competition, the decisive vote of international experts in selection panels). Add strong details from No. 15230-2 concerning the reboot of the SBI, the role of the Public Integrity Council, and the rotation of court chairs. And carefully discard a few controversial ideas, such as the attempt to strip international experts of their decisive vote.
• Third: Bring ARMA back into the text. This is not a matter of agency ambition, but a matter of the strategy's integrity. Without tools for asset tracking, tracing, and management, an Anti-Corruption Strategy for five years ahead looks like a plan to renovate an apartment without installing plumbing.
• Fourth: Tie the entire Strategy to measurable indicators. Every expected result must have a source of verification, a responsible executor, and a hard deadline. The example of Latvia, which the OECD ranks as having one of the highest-quality anti-corruption plans in the world, proves that without this, the document turns into a mere declaration.

The development hell of the Anti-Corruption Strategy has not lasted for just two weeks or two months. It has been ongoing since the moment the document went to the Cabinet of Ministers and was not adopted when it was supposed to be. What is at stake here is not political, but functional: for the next five years, Ukraine will either get a working tool to fight corruption or a declaration that binds no one to anything.

Parliament has an opportunity to show that the institutional independence of the anti-corruption system is not a gift from any specific government. It is the country's choice. And this choice is being made right now, in the relevant committee, among three texts. We all know the stakes.