The New Anti-Corruption Strategy of the NACP: How a State Institution Has Turned into a Tool for Declarative Control and Imitation of Change
The National Agency for the Prevention of Corruption (NACP) announced the start of preparation of a new project of the Anti-Corruption Strategy and the next State Anti-Corruption Program. According to official explanations, the document should be a response to “existing problems in the industry” and be based on the results of special studies. However, this is far from the first strategy, program, and not the first attempt to “improve anti-corruption policy.” In recent years, dozens of similar documents were created, numerous “action plans” were approved, and reforms were presented, but not a single top corruptor was put behind bars, and key institutions turned into reporting service centers. Will the new program become a real tool for cleaning up the state or will it remain another declarative document without consequences? A question to which there is no convincing answer yet.
The anti-corruption strategy of the NAZK of the new cycle
The head of the NAKC, Viktor Pavluschyk, said that the National Agency for the Prevention of Corruption has started the preparation of a new Anti-Corruption Strategy and State Program, which should become tools for systemic policy renewal in the field of anti-corruption. He noted that now the key task of the agency is not only the implementation of the current program, but also the full-fledged formation of a new anti-corruption policy. It is about a conceptual renewal of approaches that must meet both the internal demands of society and the obligations of Ukraine within the framework of the European integration process.
According to Pavluschyk, the agency is conducting a series of studies that should reveal critical problems in the current corruption prevention system. We are talking about both statistical data processing and analytical evaluation of the work of key institutions, procedures, channels of access to information, lobbying practices and public reporting. This is a complex work, the result of which should be the project of a new anti-corruption strategy, which will be realistic and effective.
Separately, the head of the NAZK emphasizes that when preparing a new document, heredity is an important principle. Continuation of the course formed in the previous Anti-corruption program is considered as preserving the integrity and logic of the reforms that began before the full-scale war. However, mechanical copying of previous experience is not considered an option. The agency intends to take into account not only the positive developments, but also to analyze the shortcomings — institutional, procedural, reputational — that prevented the effective implementation of the integrity policy in practice.
He emphasizes that the update of the anti-corruption strategy will take place as a response to structural changes in public administration. In particular, it is about the need to redefine control priorities, review accountability models, assess the effectiveness of existing registers, and regulate honest lobbying practices. The head of the agency insists: the strategy cannot be detached from reality, it must take into account the positive and negative experience of anti-corruption activities in the state.
The statement of the head of the NAKC appeared at a time when new political challenges force the country to rethink the means of control, accountability and transparency of the activities of state bodies. At the same time, the need to revise the anti-corruption policy arose as a response to the accumulated contradictions of the previous period: distrust of institutions, discussions about the effectiveness of NABU and SAP, tension around external control, scandals with dishonest declarations. In this context, the development of a new course of the NAKC becomes an attempt to regain self-confidence and demonstrate that “systemic work is being carried out” in the process of fighting corruption.
Between imitation of politics and blurred promises
When the head of the National Agency for the Prevention of Corruption declares that the development of a new Anti-Corruption Strategy and State Program is currently underway in Ukraine, this does not appear to be news, but a formulation designed to hide a strategic vacuum. The words about “policy formation” in 2025 sound like an indirect but undeniable recognition that such a policy has not yet been formed, or has existed exclusively on paper, in project statements and presentation slides. In a country where corruption is systemic, where dozens of high-profile episodes of impunity have accumulated over the years of war, the lack of an effective anti-corruption strategy is a failure, not a reason for new announcements.
Pavluschyk emphasizes that NAZK is currently conducting research that will form the basis of the future strategy. But the very fact that the agency is only studying the problem, and not naming it, suggests that it either does not have the full picture of the situation, or is deliberately avoiding responsibility for its delineation. If NAKC cannot specifically name the “most urgent problems” in the field in which it works, then why does this body exist at all? If the research is only supposed to answer the question of what exactly does not work in the anti-corruption system, then this means that all previous activities of the agency are imitations of activities. More than five years of launching the e-declaration system, several hundreds of thousands of declarations, thousands of inspections, and at the same time not a single clearly formed problem and response to it.
It is also indicative of how the head of the NAKC bypasses the analysis of the implementation of the current anti-corruption program. There is no mention of its specific results, nor of its performance evaluation. There is no analysis and parsing of errors – only abstracts of the phrase about the heredity of approaches. But the heredity of what exactly? Which tool has a real impact on reducing the level of corruption? What kind of practice led to specific consequences for specific individuals? Pavluschyk did not give any answer. And thereby confirmed that the continuation of past approaches will be as inert as it was.
It should be noted that NAKC is a body with a clearly defined function: verification of declarations, monitoring of the way of life of officials, preparation of the regulatory framework. At the same time, the agency is not a law enforcement agency, does not have the right to conduct operational actions, pre-trial investigations and does not prosecute. It is an analytical and preventive institution, but even within the limits of these powers, the agency did not manage to develop permanent rules that should acquire the force of a national norm. In addition, the clarifications provided by the NAZK on one or another occasion are not a source of law and do not have legal force in courts. That is why judges who review the agency’s protocols ask legitimate questions: what exactly did the person violate – the interpretation of the NACP? What method was used to obtain evidence? What was the verification algorithm? However, this is no longer a question of NAZK itself, but of its legal status determined by the state.
In addition, at the legislative level, it is not defined according to which principle the declarations of officials are checked. Now it is decided by NAZK. And therein lies the inherent risk of selectivity. Everything that is not regulated by law can become a tool of backroom pressure. Will the deputy from the pro-government majority be checked? Will the head of the OVA be affected? Who and when will become the object of control – no one knows. Because it is determined by NAZK, which is perhaps the weakest link in the entire anti-corruption chain.
More than 21,000 special inspections carried out by NAZK in 2024 are impressive at first glance. However, if as a result only 480 people were not assigned to positions, and more than 4 thousand requests remained in the process of processing, this means that the system is loaded to the limit, but it is not working at efficiency. The reasons for this are quite clear – mass rotations, relocation of institutions from temporarily occupied territories, personnel shortage in the public sector. However, a decision that would allow reducing the number of checks when moving within one body has not yet been adopted. And NAKC only now, in the middle of 2025, announces its intention to “work in this direction”. This is what delayed reaction to obvious things looks like.
The issue of political dependence of the agency is even more pressing. NAZK should be an independent body, but it is subordinate to the Verkhovna Rada of Ukraine and accountable to the Cabinet of Ministers of Ukraine. At the same time, among its values, the agency pathetically defines: “We are impartial and apolitical. We cannot be influenced and there is no point in putting pressure on us.” By the way, his other values sound no less pathetic, including: “Proactiveness and innovation are part of our daily work”, “Based on our own experience and the best global practices, we find new solutions adapted to Ukrainian realities, and therefore more effective for our society”, “We achieve extraordinary results and are a standard in matters of corruption prevention not only in Ukraine, but also in the world”. That is, solid slogans that have already become a trend in the modern policy of state bodies.
However, if personnel appointments, the sequence of inspections and the choice of control objects depend on the political cycle or the request from the executive power, what kind of anti-corruption policy can we talk about? This is not a policy, but a functional mask. Pavluszyk does not give any signal as to how the institution strives for true independence. On the contrary, his statement demonstrates a comfortable habit of living in “preparation” mode.
Another factor that raises questions is the lack of a frank report to society. If the effectiveness of NAKC is really high, why do journalists reveal declaration scandals, and not the agency? Why, in the case of luxury, in the declarations of judges, prosecutors, and deputies, exactly public initiatives are included, and not the state structure, which should be the real center of detection? As we can see, the best tool for detecting corruption remains not the NAKC and other numerous anti-corruption bodies, but society — those who have the motivation to conduct analytical work.
So, Pavluschyk’s statements about the new strategy of the NACP sound isolated from real experience. They are rhetorically correct, but institutionally empty. If in the fifteenth year of reforms and the ninth year after the launch of e-declaration in the country there is no formed, full-fledged, coordinated and effective anti-corruption policy, this is already a sentence, not a prospect. The statement of intention to develop another strategy only emphasizes that we are standing still, confused in explanations, reports, presentations, concepts, endless meetings and constant empty promises. Everything that today is called the anti-corruption fight in Ukraine increasingly resembles a protracted process of complacency: documents are adopted, programs are written, strategies are updated, but in the meantime there is no systematic result.
So it turns out that the rhetoric includes “strategy”, “reforms”, “formulation of anti-corruption policy”, “new cycle”, and as a result, there is not a single top corruptor behind bars, not a single real precedent that would have reputational and political consequences, as well as a lesson for everyone. High-profile criminal proceedings are opened not based on the results of inspections by the NAKC, but in spite of its silence. The entire fight against corruption, which should be a state course, today relies on either external pressure or internal public pressure. In this process, the NASK is only a part, it does not imitate more than the rest of the organs, before that, it has almost no pressure levers.
As long as the state system declares an anti-corruption policy, corrupt officials only increase their adaptability and become even more impunity with the tacit consent of those who should prevent it. In Ukraine, an effective anti-corruption system has not yet been created, despite the high-profile names, it is in a state of chronic blackout. And while the country can talk about the fight against corruption for years without a single loud verdict, all this remains not politics, but only decoration and empty slogans.
