Article 9.1.
Public Procurement

Article provisions:
Each State Party shall, in accordance with the fundamental principles of its legal system, take the necessary steps to establish appropriate systems of procurement, based on transparency, competition and objective criteria in decision-making, that are effective, inter alia, in preventing corruption. Such systems, which may take into account appropriate threshold values in their application, shall address, inter alia:

a) The public distribution of information relating to procurement procedures and contracts, including information on invitations to tender and relevant or pertinent information on the award of contracts, allowing potential tenderers sufficient time to prepare and submit their tenders;

b) The establishment, in advance, of conditions for participation, including selection and award criteria and tendering rules, and their publication;

c) The use of objective and predetermined criteria for public procurement decisions, in order to facilitate the subsequent verification of the correct application of the rules or procedures;

d) An effective system of domestic review, including an effective system of appeal, to ensure legal recourse and remedies in the event that the rules or procedures established pursuant to this paragraph are not followed;

e) Where appropriate, measures to regulate matters regarding personnel responsible for procurement, such as declaration of interest in part.
State evaluation
Public evaluation
National legislation of Ukraine is consistent with part one of Article 9 of the UNCAC. Enforcement of the law is also at a high level. Public procurements are open and transparent, and information about their conduct is known in advance and is available to all comers. Active application of the Prozorro system, continuous improvement of public procurement procedures, and the effective appeal system to a specialized body (AMCU) allow us to conclude that public procurement is effective in practice. That is why there are permanent attempts to withdraw certain goods/works/services from the public procurement procedures to reduce the transparency of the use of budgetary funds. Unfortunately, from time to time, such attempts are successful. A significant challenge is also the need to create an effective mechanism to monitor the conduct of public procurement and the actual implementation of already made procurements. At present, the ability of the supervisory body (SASU) should be improved because the main control is carried out by the efforts of the public.

In short:

State of implementation

Legal framework

1.1. Legal Requirements for Public Procurement

In 2015, the basic law on public procurement was adopted, i.e., the Public Procurement Law of Ukraine (hereinafter referred to as “the PPL”). It determines the legal and economic basis for the procurement of goods, works, and services to meet the needs of the state and local communities.

Information on announced procurements enters the central Prozorro database and is simultaneously published on electronic platforms. Procuring entity tender documentation is placed on these platforms. According to the PPL, the tender documentation sets out the conditions for the tender. Suppliers submit their bids based on the tender documents. Their evaluation takes place through the use of an electronic auction. Before the start of the auction, all information on the prices of tender offers is published.

In Ukraine, it is allowed to participate in the procurement procedure for almost anyone who is a private individual (sole entrepreneur) or legal entity. No restrictions are imposed on the participation of private individuals. Instead, only “parent” legal entities can be participants in public procurement as a legal entity, “subsidiaries” are prohibited from such participation.. It increases competition among bidders.

The winner of the procurement is the bidder who best meets the requirements of the tender documentation and the established criteria:

  1. price; or
  2. cost of the life cycle (the cost of servicing the subject of procurement); or
  3. price along with non-price criteria: terms of payment, term of performance, warranty service, technology transfer, and others.

The PPL determines several ways to obtain public procurement information:

  • annual procurement plans published by public authorities on their websites and containing all necessary information on future orders.
  • electronic procurement system, in which a procuring entity publishes information about the procurement through the above-mentioned authorized electronic platforms.

All procurement is divided into several types depending on their cost and complexity. This is necessary to ensure the effectiveness of the procurement system.
The PPL, in particular, defines the following types of the procurement:

1) Procurement without the use of the electronic procurement system. A procuring entity independently selects a supplier and enters into a contract with her or him. This procedure applies to purchases in the sum of up to 1,500 euros. Based on the results, a procuring entity publishes her or his report within three working days from the date when the contract is concluded.

2) Simplified procurement. It is a separate type of procurement conducted with the use of an electronic platform and carried out in a specific way (within a shorter time). It is applied where the cost of goods, works, and services are as follows:

  • For “Regular procuring entities” (public authorities, local self-government bodies, etc.) – from EUR 1500 to EUR 6250 for goods and services; and up to EUR 47 000 for works;
  • For “Procuring entities in specific sectors of the economy” (heat energy, or natural gas suppliers, etc. with a share of the state ownership not less than 50%) – from EUR 1500 to EUR 31000 for goods and services; and up to EUR 156000 for works.

3) Procurement through an electronic catalog Prozorro market. It is an alternative to simplified procurement. A procuring entity can independently choose among the offers made by suppliers in the electronic catalog and buy the necessary goods (cost up to EUR 1500), or form a request for the price of offers (from EUR 1500 to EUR 6000) when there are several participants and then the winner will be selected by the system. This type of procurement is not used to order works and services.
These three types belong to the below-threshold procurement.

4) General procurement procedures (or above-threshold procurement). It is a type of procurement with the use of an electronic system. It is applied where the cost of the goods, works, and services are as follows:

  • For “Regular procuring entities” – from EUR 6250 for goods and services; from EUR 47000 for works.
  • For “Procuring entities in specific sectors of the economy” – from EUR 31000 for goods and services; from EUR 156000 for works.

When using this type of procurement, a procuring entity independently chooses one of the four procurement procedures (open tender; competitive dialogue; negotiated procurement procedure (only by exception); limited participation tender).

When a cost for goods, and services is higher than EUR 133000, and EUR 5.1 mln for services, the procurement notice must be published in English.

The PPL establishes an exhaustive list of cases where suppliers are not allowed to participate in procurement procedures. These are not allowed to public procurement:

individuals who have not indicated information on their ultimate beneficial owners in the relevant register;
individuals who, during the last three years, have been prosecuted for violations in the form of anti-competitive concerted actions.

There is a tendency to exclude certain goods, services, and works from the PPL scope (the assessment of which we provide below). To give an example, in March 2020, the law was adopted (with amendments dated July 2021), stipulating that for the period of quarantine, the PPL does not apply to “COVID-procurement”, i.e., procurement of certain medical supplies in connection with the COVID-19 pandemic. The list of such goods is approved by the Cabinet of Ministers of Ukraine. And in June 2021, the PPL no longer regulated the procurement of the works on the construction of the Big Ring Road (around the city of Kyiv), as well as procurement, is done within the preparation for Constitution Day and Independence Day celebrated on August 24, 2021.

In 2020, the separate Defense Procurement Law of Ukraine was adopted, regulating procurement to meet the needs of the security and defense sector.

1.2. Oversight in Procurement

The PPL establishes a fairly large list of possible procurement oversight mechanisms (for example, monitoring, revisions, inspections, audits, etc.). Such control is carried out by some subjects:

  1. The State Treasury Service of Ukraine (STSU).
  2. The Accounting Chamber (AC).
  3. Antimonopoly Committee of Ukraine (AMCU).
  4. State Audit Service of Ukraine (SASU).
  5. Civil Society Organizations.
  6. National Police, and Prosecutors’ Offices.

Each of them exercises its powers within its functions and on certain aspects of public procurement.
The PPL also stipulates rules of procedure for appealing procurement procedures. The responsible body, i.e., the Antimonopoly Committee of Ukraine (the AMCU), is an independent regulator with a special status and additional guarantees for its independence.

The AMCU forms a commission to consider complaints about violations of public procurement legislation. The complaint is to be submitted in the form of an electronic document through the electronic procurement system. The consideration term is set to be 10 working days starting from the date when the consideration commences. The commission’s decision can be appealed to the court.
Implementation in practice
2.1. Prozorro System

Public procurement operates through the electronic Prozorro system. It was created within the cooperation of Transparency International Ukraine, private electronic platforms, Quintagroup IT-company, and the Ministry of Economy of Ukraine. In 2016, Quintagroup Co. handed the Prozorro system over to the “Prozorro” state-owned enterprise.

From April 1, 2016, it became mandatory for central authorities and monopolists, and from August 1, 2016, – for other public procuring entities (in the original Ukrainian language it is called “zamovnyk”). Prozorro is a platform that currently unites more than 35000 state and municipal authorities and enterprises (procuring entities who purchase goods, works, and services) and about 250000 commercial companies (i.e., suppliers, in original Ukrainian language it is called “postachalnyk”). In 2019, the TI Ukraine survey showed that 54% of public procurement participants are mostly satisfied with the Prozorro system.

Registration for public procurement is carried out through private authorized Prozorro websites, being part of the Prozorro system, through which procuring entities and suppliers handle procurement within the system. All actions of procurement participants are carried out through their personal accounts on the electronic platform. There are 13 inter-competing private authorized procurement websites, with their usage rules being available in open free online access. Procuring entities apply to procurement websites free of charge, but suppliers are to pay a charge that varies depending on the total purchase price. The purchase announcement is fully visible to everyone, making hiding any information impossible. In addition, the interested can get acquainted with the entire history of any procuring entity and ask any questions therein.

Such a system proves to eliminate the monopoly role of the state and corruption-related risks.
According to civil society experts, the existence of such a system (state-owned enterprise together with private websites) allows, on the one hand, to develop and strengthen competition, and on the other, to prevent websites from manipulating and behaving in a non-competitive manner. Anyone, being compliant with requirements, can become a website for procurement. In case of poor work of one website for procurement, procuring entities can change it into another one.

In 2020, 3.74 million procurement procedures were conducted, with 37.9 thousand procuring entities, including 246, 29 thousand participants.

Of these, more than 3.48 million procurement procedures were below-threshold procurement (i.e., without the use of an electronic system), with a total value of more than EUR 6 billion. Above-threshold procurement (i.e., with the electronic system being applied) was used in about 259,000 cases, with their total value calculated over EUR 31 billion.

In 2021 (as of September 30, 2021), there were conducted 3.64 million procurement procedures, with 33170 thousand procuring entities, and 224600 thousand participants.

Of these, more than 3.40 million procurement procedures were below-threshold procurement (i.e., without the use of an electronic system), with a total value of more than EUR 4.4 billion. Above-threshold procurement (i.e., using an electronic system) was used in about 240,000 cases, with their total value being over EUR 26 billion.

According to Prozorro data, in 2020, the application of the electronic system saved more than EUR 1,8 billion, and in 2021 (as of the 30th of September) – more than EUR 1 billion.

The data given above show that 93% of procurement cases were below-threshold, and only 7% happened to be above-threshold ones. At the same time, the total value of above-threshold procurement was 5 times higher (EUR 31 billion compared with EUR 6 billion) than the total value of below-threshold procurement. The use of electronic systems in conducting high-valued procurement is proved to be reasonable. In terms of below-threshold procurement, the introduction of simplified procurement in 2020 ensured transparency and accountability of procurement, created oversight opportunities. During the year when simplified procurement was applied, almost EUR 100 thousand was saved.

At the same time, there are risks in conducting simplified procurement. Procuring entities most often complained about the PPL inaccuracies, the duration of simplified procurement, and misunderstanding of the requirements for the simplified procurement duration terms, moreover participants argued the problems related to the impossibility of appealing simplified procurement to the AMCU, as well as collusions, and discrimination.

According to Prozorro, the use of the electronic system has saved more than EUR 1.8 billion in 2020, and more than EUR 1 billion in 2021 (as of September 30).

E-catalog Prozorro market, a new, special type of procurement, was launched just in 2020 but has already demonstrated its effectiveness. On the one hand, the Prozorro market eliminates many corruption risks and other bad practices that occur in below-threshold procurement, and on the other hand, significantly reduces time spent on procurement, and simplifies procurement procedures. E-catalog is constantly evolving, new products are being added all the time. After a warning, unscrupulous suppliers may be excluded from the system. According to experts, the Prozorro market is easy to use, and its introduction has a positive effect on simplified procurement.

2.2. Procurement plans

Annual procurement plans are to be published on the websites of state bodies of various levels, from central to local, as well as on the “” site (i.e., the portal, which contains a large array of open data of state bodies), where anyone can find information about the funds of any operator, she or he is interested in.

Information on annual procurement plans is also included in the central Prozorro database . Information is simultaneously being published on the portal and displayed on Prozorro sites . Access to all information is free and open.

All procurement information may be additionally published by a procuring entity in other media, or on its website.

According to interviewed experts, Ukraine is thought to be one of the exemplary countries in terms of disclosure of procurement plans and the scope of information obligatory to be provided by public procurement participants. No attempts are testified to have been found to hide, or not disclose, information on the procurement plan.

2.3. Tender winner selection criteria

Existing criteria for selecting procurement winners are applied in different ways. Price criterion is applied in all cases, but the life cycle criterion and non-price criteria are used not so often by procuring entities.
From the beginning of 2017 to December 2020, procuring entities applied non-price criteria in 0.7% of procurement cases (where it was applicable), in particular, 12,996 cases in total. The researchers found that the larger the value of announced procurement was, the more likely non-price criteria were applied. For example, in the range of up to EUR16000, there were was 6 cases among 1000 procurement cases where non-price criteria were applied. In contrast, this number increased to 115 among 1000 cases of procurement was the value of more than EUR 3 million.

The difficulty of applying non-price criteria lies in the different approaches to the interpretation of the PPL’s norm. On one hand, the AMCU concludes that the list of criteria is exhaustive, but on the contrary other hands, the Ministry of Economy argues that the non-price criteria are inexhaustible. This practice does not contribute to their wide application.

Recently, in April 2021, the life cycle criterion was introduced into the Prozorro system. That is why there is no widespread practice of applying this criterion yet. Given this, it is too early to assess its effectiveness. However, the opinions of experts are divided, some experts point out the possibility of abuse of this criterion to select the desired winner, but others do not agree with this concern.

2.4. Peculiarities of conducting public procurement

Public procurement in Ukraine has peculiarities that improve the quality of their conduct and assist participants in performing all necessary procedures.

  1. Before admitting a bidder to the procurement, all procuring entities verify information about the ultimate beneficial owner in the state register. If the information in this register does not match the information submitted into the documents, a procuring entity rejects the bid. However, out-of-date and incomplete data in the state register is known to cause problems. In this context, in terms of the formed practice of rejecting bids on this ground, the AMCU does not always consider rejecting tender bids on the ground of lack of information about the ultimate beneficial owner to be justified. If there is no information about founders of bidding legal entities, rejection of the tender bid is considered to be lawful and the AMCU upholds procuring entities. However, if there is no information about the founders of bidding individuals, rejection of the bids is considered unlawful, and a bidder is allowed to bid in a tender.
  2. There is a so-called “black list” of entities prohibited to participate in procurement, with the list being integrated into the Prozorro system. Procuring entities can also verify this information using a document published on the AMCU website containing the entities black-listed on the ground of anti-competitive, concerted actions committed by them during the last 3 years. The AMCU constantly and consistently updates the data, and inaccuracies are possible only in cases of participant’s court appeal against decisions on inclusion into the document. The idea to hold the list as an official register seems reasonable, as it will ensure ease in its use, transparency, sustainability in its operation, and accountability for data accuracy and timely updating.
  3. The list of bidders is not published until the submission of bids and amendments. It prevents bidders from possible collusion and strengthens procurement competitiveness and transparency.As it was said above, in Ukraine, there is a separate law for procurement in defense. It was adopted to address all peculiarities of procurement which is crucial under current conditions.

In particular, the Defense Procurement Law contains, according to the experts’ view, many positive novels, inter alia:

  • introduction of three-year defense procurement planning, thus allowing procuring entities and bidders to work out long-term plans and to allocate budgets qualitatively;
  • restriction of secrecy to reasonable limits, thus protecting unique Ukrainian developments from foreign spying, and at the same time preventing from abusing the “secret” label when procuring competitive goods;
  • formation of an open register of suppliers, thus weakening political influence and preventing fictitious companies from bidding, etc.

Despite the rather high quality of the law and positive assessment of the expert community, the law has not been implemented. As of January 2021, the relevant by-laws were not in place to launch the necessary mechanisms, in particular, about 30 by-laws have not been developed yet. The situation is getting worse by making information closed and secret, thus not allowing the public to exercise effective oversight over the use of funds.

2.5. Procurement conduction by public bodies

Tender committees were engaged in procurement conducted by public bodies. They consisted of several (approximately 5-10) employees of the body, who often did not even have anything to do with procurement issues.

As a result, the tender committees were not efficient enough and had some shortcomings, in particular:

  • were personnel- and time-consuming;
  • consisted of persons without sufficient level of professionalism to decide on procurement;
  • provided for “collective responsibility”, meaning no accountability of individual officials.

For such shortcomings to be addressed, the institute of authorized persons has been established. An authorized person is enshrined to be a definite public official responsible for the organization and conduction of procurement. Studies have shown that the introduction of such an institution has reduced the time of organization of below-threshold procurement (by 2 hours), above-threshold (by 5 hours), and reduced the share of unsuccessful procedures (from 30% to 20%).

As of September 2021, the transition period was underway, meaning the simultaneous existence of tender committees together with authorized persons. However, from January 1, 2022, the Authorized Person will conduct all procurement. A transition period was introduced, inter alia, to enable them to certify their qualifications. Thus, each Authorized Person is obliged to pass a test on the web portal by January 1, 2022, to certify her or his level of knowledge in the field of public procurement.

According to experts, personal responsibility for procurement is seen as the main advantage of the institution of an authorized person. The body will have an individual responsible for the entire procurement process, using not engaged in other paid work. Talking of the risks of this new institution, experts have concerns about wages, and the massive workload on the authorized person, since plenty of procurements are conducted annually.

New simplifying procurement instruments are constantly being found. In 2021, the public introduced procurement policies, i.e., an algorithm of actions within public procurement, which aims at minimizing the risks of unsuccessful procurement. The first such document was adopted in the Vinnytsia region. Such an instrument is assessed quite positively, but due to further rent lack of practice of its widespread application, it needs time to prove its success.

2.6. Execution of public procurement contracts

Execution of public procurement contracts, specifically, factual supply of goods, providing services, or performing work, is recognized to be one of the problems in the field of public procurement. Procuring entities by themselves control complete the execution of procurement contracts. There is no special body to control execution. Partial information on the execution of the contract can be checked by SACU within its audit. It is quite difficult to obtain information on the execution of procurement contracts. The experts convince that procuring entities do not provide such information referring to its secrecy, therefore, it is necessary to make requests.

Given that, there is a need to improve the procedures to monitor the execution of public procurement contracts. Experts suggest making the following steps:

  • Provide the public upon request with documents confirming the execution of public procurement contract (e.g., the act of acceptance);
  • Improve the system so that procuring entity uploads the necessary documents on the execution of public procurement contract into the system;
  • Keep separate records of information on the execution of public procurement contracts;
  • Publish an act confirming the experience of supplying analog goods/works/services.

In this context, an example of “Ukrposhta” JSC is interesting. Having problems with the proper execution of contracts, it was decided to invite competitors of the supplier, who also competed in the tender, but did not win, to accept the goods. In this way, “Ukrposhta” JSC succeeded in radically changing the quality of goods supplied. And for this procuring company, it was a completely free procedure.

2.7. Exceptions from the Law

Most procurements are made in the electronic system under the rules of procedure prescribed by the PPL. However, there are cases of exclusion of certain categories of goods, works, or services from the scope of the PPL.

A great number of draft laws aiming at making certain categories exceptions from the PPL are registered every year. More often than not, the draft amendments proposing exceptions are not well-grounded, consequently, most of them were not adopted by the Parliament. However, there were cases when certain amendments were supported.

Thus, on June 3, 2021, the PPL was amended, and “works on construction (including construction work-related services) of the Big Ring Road around the city of Kyiv (Kyiv region)” were excluded from the Law scope. The amendments were adopted despite the negative assessment of public agencies (NACP, AMCU, SASU) and the public. The value of such works reaches EUR 2.6 billion, and procurement is made without the use of Prozorro. It significantly affects the transparency of the use of state budget funds.

Due to the COVID-19 pandemic, the amendments also revoked so-called COVID procurement from the scope of the Law. It was a necessary step to shorten the time spent on procuring especially important goods. However, these goods are being returned under the scope of the PPL very slowly and gradually. As of October 20, 2021, more than 190,000 COVID procurement contracts worth more than EUR 1.2 billion were concluded.

At the same time, some experts reckon that it is necessary to speed up these processes and make regular procurement carried out according to standard rules without any exceptions, because they, among other things, contribute to corruption.

Another exception made it possible to procure the staff needed for celebrating Independence Day and Constitution Day by applying negotiated procurement procedures, without any competitive bidding. According to the Ministry of Finance of Ukraine estimations, the celebration cost over EUR 150 million, with not related to the celebration large-scale infrastructure projects added to the cost. Such law application abuses the use of budget funds.

2.8. Public procurement control

As mentioned above, control in the field of public procurement is exercised by 6 subjects. But despite this, experts assure that the control system does not work well enough or does not work at all.
Foremost, it is based on the ratio between the number of procurement and the number of inspections carried out. In particular, each year about 3 million procurement cases are conducted, and the control system scrutinizes only a couple of thousand procurement cases. Undoubtedly, it negatively affects ensuring the inevitability of punishing violators.

Secondly, the control system has a conceptual shortcoming, as it is purely a financial audit, but does not provide checking if procurement is effective and well-grounded. The experts express their concern that there are cases when million-cost procurement is carried out for obscure purposes.

Each subject of control has its powers and functions; accordingly, each controls certain aspects of public procurement. In particular, as follows.

The State Audit Service conducts monitoring, inspections, and audits of procurement. During 2020, the State Audit Office and its interregional territorial bodies monitored 9700 procurement procedures (that is 0.25% of the total number of procurement cases conducted in 2020) with a total value of about EUR 5.5 billion (that is 15% of the total value of procurement conducted in 2020), resulted in detection of violations of the law, committed by procuring entities in 8700 procurement cases (that is almost 90% of procurement cases audited), with a total value of about EUR 4.6 billion.

In most cases (5400 procurement cases), violations committed by procuring entities affected the results of procurement, and such violations were mostly rooted in wrongful decisions made in consideration of tender bids, the conclusion of procurement contr, acts and making amendments to them, the use of negotiated procurement procedures.

The monitoring results can be appealed by procuring entities. Considering the appeals, first instance courts uphold procuring entities’ claims (71%) two times more often than auditors’ ones (29%). Appeal courts also most frequently rule against auditors, in particular, in 74% of cases compared with 26% of court decisions against procuring entities. In terms of the Supreme Court, 78% of cases are against and 22% are in favor of procuring entities. One of the most typical reasons why courts stand for procuring entities is that auditors do not satisfy the courts by their explanation of ns how a procuring entity is seen to eliminate the violation.

One of the most common reasons why courts uphold the procuring entity’s side is an auditor’s inspection concluding act lacking specification of a definite way a procuring entity has to follow to respond to violations. The absence of these instructions in the conclusion of the State Audit Service may indicate the uncertainty of such a conclusion. Giving instructions will prevent similar violations in the future.
According to the results of control measures, in 2019, the State Audit Service brought to administrative responsibility only 120 officials of procuring entities. In 2020, this number reached 426, in January-July 2021, there were 302 people punished. The experts reckon that the mechanism for dispensing justice needs improving, as it is proved by the above-given figures to operate not efficiently (given the ratio between the number of violations and the number of officials factually brought to justice). Such non-efficiency is thought to have a connection with certain procedural drawbacks (incorrect filing of procedural documents, the possibility to evade responsibility by not providing information about the violator’s identity, the expired statute of limitations, etc.), and the workload of the State Audit Service.

Experts convince that simplifying the mechanism for imposing fines, and strengthening the risk-oriented approach to detect wrongful procurement at the monitoring stage, are the ways to address this situation.
The State Treasury Service of Ukraine (STSU) makes payments under contracts concluded as a result of procurement, and monitors compliance with budget legislation in the field of procurement. According to the STSU, in January-December 2020, its bodies issued 227 warnings about an improper implementation of budget legislation totaling EUR 7.5 million. The vast majority of warnings concerned the lack of procurement documents.

STSU systems are integrated with the e-procurement system. The information on payment transactions made under the procurement contract is transferred in an automated mode.

The Accounting Chamber may conduct post-audit of public procurement (objects of control). Having an annual work plan, the Accounting Chamber, within its public financial control measures, may audit the procurement made by an object of control during the auditing period.

Moreover, the Accounting Chamber analyzed the report of the Ministry of Economy on the functioning of the public procurement system. According to the analysis results, the stated sum of savings in the sum of EUR 1.5 billion is contradictory. The auditors believe that this figure and conclusions provided by the report of the Ministry of Economy are insufficient for a comprehensive assessment of the functioning of the public procurement system in 2020. This information is also insufficient to assess the effectiveness and transparency of such procurement, the state of the competitive environment, the prevention of corruption, and the development of fair competition.

Experts’ views on these figures are contracting. Some experts are confident in these figures and conclusions, given that the mechanism for calculation of budget savings is complex and therefore some figures may be overestimated. But other experts presume that public procurement is a market mechanism, and the value of end-to-end procurement often reflects the real state of affairs in the market.
Public control of public procurement is carried out through the DOZORRO platform, which unites dozens of public organizations. This platform provides an opportunity to discuss each tender with potential and existing bidders, to find out their expert opinion on the correctness of the wording in the tender documentation, to obtain professional expertise, etc. It is a convenient tool for monitoring management because it is easy and accessible to keep track records of procedures controlled and violations detected.
Moreover, the DOZORRO expert team created the BI public analytics module, which is a free analytical tool that contains data on all procurement made through the Prozorro system since 2015. The information is delivered in the form of user-friendly spreadsheets, analytical graphs, and diagrams. The tool is fully integrated with the Prozorro system; therefore, the data is automatically updated daily. The open data format allows conducting necessary analysis.
In 2020, the DOZORRO sent more than 9000 letters to procuring entities, regulators, or law enforcement agencies.
Based on the results of the procurement analysis, the DOZORRO community submitted some allegations of crimes and other violations in the field of public procurement:

7 criminal proceedings were opened; 72 contracts were terminated;
members of tender committees or authorized persons were brought to justice in 46 cases;
250 procurements were canceled;
changes were made to the tender documentation in 390 procurements;

according to the results of appeals to the AMCU, cases of collusion were confirmed in 36 procurements .
The interviewed experts are assured that the information available to the public is complete. If desired, it is possible to obtain all necessary information about a tender bid. In addition, some experts observe that the amount of this information is growing and growing, the available fields are expanding, thus improving the quality of procurement in general, and enhancing civil society control. For example, this applies to a field such as “price per unit”. Adding this field will allow monitoring of price offers, prevention of abuse in procurement, and much proper control in the field of public procurement.

2.9. Complaints about public procurement

Complaints about public procurement can be submitted to the AMCU or court. These instruments are used in different ways.

According to various estimates, the percentage of appeals against procurement to the AMCU is about 8% of those who have the right to do so. In the period from 01.01.2020 to 31.12.2020, the Antimonopoly Committee of Ukraine received 12675 complaints, of which 11,463 complaints (90%) were taken for consideration. Based on the results of the review of complaints, 11353 decisions were made, in particular,
3808 refusals to satisfy the complaint (33,5%);
6834 complaints were satisfied in full or partially (60,2%);
711 decisions on termination of complaints (6,3%).

On the one hand, it shows trust in the current appeal mechanism and its sufficiently active use by procuring entities. On the other hand, the percentage of appeals is quite high and, consequently, the AMCU considers thousands of complaints annually.

Due to recent amendments made in terms of procurement appeal (approach to charge fee from a complaint depending on the cost and subject of the procurement, with payment made only online for filing a complaint, the possibility of appealing the procuring entity’s decision to cancel procurement, the impossibility of withdrawing the complaint, etc.), the share of satisfied complaints increased from 43% to 65%. After April 19, 2020, the share of non-satisfied complaints dropped from ≈37% to ≈28%, and the share of rejected complaints decreased almost six times, and the time during which complainants waited for the decision of the AMCU Board shortened from an average of 20 to 17 calendar days in September 2020. The novel additional safeguards reduced the number of unscrupulous complainants, thus deterring complaints from being submitted solely to delay the procurement process.

Experts also argue that the novels in the legislation, according to which the amount of the complaint is returned in case of winning, was also positively perceived by the subjects, and consequently increased the number of appeals. Nevertheless, the complainants paid more funds to the State Budget in 2020 than it was foreseen.

At the same time, to improve the quality of the appeal process, it is also recommended to further digitalize complaints. Another way to improve this process is to standardize the tender documents, therefore, it will be in short notice clear which points are being challenged and what the complainants are most appealing to.

At the same time, the negative aspect of appeals to the AMCU, namely the inconsistency of the practice of decisions, is obvious, is confirmed by all the interviewed civil society experts, as well as by published research findings. This practice hampers the desire to appeal, because the fee of a complaint increased, and it is possible to obtain a decision not in their favor in similar cases.

The way out of this situation, experts see a generalization of the practice of the AMCU, which, on the one hand, would allow them to act early within their decisions, and on the other hand, would allow appellants to predict the outcome of their complaints in the future.

Also, complainants need to adapt to changes in terms of providing evidence to substantiate the legality of appealing the requirements of the tender documents. So far, there is no practice of what and when evidence is admitted as appropriate and is accepted for consideration. In practice, it leads to the complaints return.

Appeals to court, according to the civil society expert community, are not highly effective. Bidders rarely go to court to defend their procurement rights. The reasons for this are the low speed of consideration of complaints (several months or longer), the inability to enforce certain court decisions in practice (especially those that offer to “reset” the procurement from a definite point, which is complicated (and sometimes impossible) to realize within current Prozorro system). In addition, similar to appeal to the AMCU, there is no consistent practice of court decisions.

One of the problems in judicial practice is to determine the jurisdiction of cases to appeal the decisions of the AMCU on complaints about violations of public procurement legislation by the District Administrative Court of Kyiv to consider this category of cases. This court is said to be connected with a large number of top-level corruption scandals. To the problem of corruption is added the extraordinary overload of the DACK, specifically almost a thousand cases per judge. These reasons negate the desire of businesses to appeal the decision of the AMCU.




The whole process of public procurement is conducted in an electronic system.
Private inter-competing authorized sites are in place.
Accessibility to information on the conduction of public procurement is ensured.
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National legislation of Ukraine is consistent with the political funding standards enshrined by part 3 of Article 7 of the UN Convention against corruption. Well-grounded limitations on financing political parties and election campaigns, as well as state funding of political parties and their reporting, are set by the laws. At the same time, law requirements are not always fulfilled in a compliant manner. On the one hand, the transparency, openness, and accessibility of party reports can be highly appreciated, which allows the public to exercise effective control over party finances. However, on the other hand, due to unjustified legislative changes related to the COVID-19 pandemic, political parties have been able not to submit their reports for over a year. This has deprived the public and the state of control over the financing of political parties and the use of state budget funds. Funding requirements for political parties and election campaigns can be easily circumvented through a number of schemes. Their widespread use is due to the ineffective institution of prosecution for violations of the law.

2In short:

2State of implementation

Legal framework

The Law on Political Parties of 2001 is the main law governing the financing of political parties. In particular, it defines the main ways of financing political parties, restrictions of funding, and sets requirements for reporting and control. In turn, the detailed regulation of election campaigns is stipulated by the Electoral Code of 2019.

1.1. Requirements for Funding of Political Parties

In the sense of the law, a political party is a non-profit organization, i.e., it can spend money only on the exercise of its statutory activities. Two possible sources of income for political parties are voluntary contributions to support the party and state funding.

The Law on Political Parties clearly defines the term “contribution towards a political party” and sets out an exhaustive list of restrictions on its receipt. In particular, the contributions are prohibited to be paid by the following entities:

  • state authority, and state-owned enterprise;
  • legal entity, the ultimate beneficiary of which is a high-ranking official (with certain exceptions);
  • foreign country citizen, legal entity, or state;
  • citizen of Ukraine younger than 18 years;
  • legal entity providing state authorities with services/goods/works in the sum of more than EUR 3700.

It is forbidden to make anonymous contributions, to donate more than EUR 75000 by an individual, and EUR 150000 by a legal entity during the year, etc. Contributions paid by several legal entities owned by one beneficiary owner are considered to be as one contribution. Contributions in the form of works/goods/services are allowed.

Regular reporting and annual audits (internal ones for all; external ones for those receiving state funding) are provided to ensure compliance with these restrictions as well as party transparency.

A party report is submitted to the NACP each quarter, and it contains information on:

  • money available on all accounts, securities, real estate, vehicles, etc.;
  • contributions made in any form, as well as other money received by a party;
  • payments and expenses;
  • financial liabilities.

Reports of political parties are publicly accessible and, since recently, are published in a special register, i.e., POLITDATA. The reports are audited by the NACP. Administrative and criminal liability is provided for violation of the established rules.

1.2. Election campaign funding

The Electoral Code establishes 3 types of elections, namely, presidential elections, parliamentary elections, and local elections. For each type of election, there are separate rules for campaign financing. More detailed information on the peculiarities of such financing is given in the table below.

During the election of the President of Ukraine, the election fund of a presidential candidate is used, which is formed from the candidate's own funds, party funds and voluntary contributions. The size of the fund may not exceed 16.8 million euros. Unused funds are returned to the political party or the state budget. Interim and final reports for the period before and after the elections are submitted, and reports are published on the websites of the CEC, NAPC and political party.

During the election of people's deputies, the election fund of a candidate or party is used, which is formed from party funds, candidates' funds (not more than 7,500 euros) and voluntary contributions (only in cash). The size of the party's fund may not exceed 16.8 million euros, the candidate - 750 thousand euros. Unused funds are returned to the political party or the state budget. Interim and final reports for the period before and after the elections are submitted, and reports are published on the websites of the CEC, NAPC and political party.

During local elections, the election fund of a candidate or organization is used, which is formed from the funds of the party organization, candidates (not more than 1,800 euros) and voluntary contributions (only in cash). The size of the fund is virtually unlimited. Unused funds are returned to the political party or the state budget. Interim and final reports for the period before and after the elections are submitted, and reports are published on the websites of TECs, local councils, CEC offices or otherwise.

The law allows the use of election funds exclusively to finance election campaigning. All payments outwent from the election fund are made exclusively in non-cash form. In addition, there are time limits on the use of funds, particularly, for the election of the President and MPs it is the last Friday before an election day, and for local elections, it is the next Wednesday coming after an election day.
Voluntary contributions to election funds are subject to the same restrictions as contributions towards a political party. These restrictions are different only for local elections, specifically, the maximum sum of a contribution cannot exceed EUR 1,800; it is forbidden for legal entities, anonymous people, and foreigners to pay contributions.

1.3. State financing of political parties

State financing of political parties has been provided in Ukraine since 2016. According to the law on political parties, state financing is provided for two purposes:

  1. Statutory activities of a political party, but with the activities being not related to participation in elections (quarterly ingoings);
  2. Reimbursement of pre-election campaign expenses (one-time payment).The general fund from which the parties are financed is formed according to the following formula: EUR 1.8 multiplied by the total number of voters in previous elections. A political party is entitled to state financing if it receives more than 5% of the votes of all voters, therefore, if it is represented in the Parliament.

The amount of funding for each political party is determined by two criteria:

  • 10% of the total fund is divided equally between parties that adhere to the gender quota;
  • 100% of the total fund is distributed among the parties in proportion to the number of votes voted for them.

If a political party does not use public funds by the end of the year, money is returned to the state budget.
If a political party enters the Parliament, it is entitled to reimbursement of expenses related to the financing of its election campaign (but not more than the maximum size of the election fund of a political party).

The NACP exercises state control over the use of funds by political parties. In case of violations, the NACP has the right to stop state financing in perpetuity or to suspend it for a certain time.

Suspension of funding is possible in the case of:

  • Failure of a political party to submit a report by the deadline;
  • Submission of a report with a gross violation of the requirements or indicating inaccurate information (if it differs from reliable information in the amount of more than approximately 3700 euros).
  • If the shortcomings in the report are eliminated, the NAPC will resume state funding from the next quarter.

Suspension of public funding applies in the case of:

  • Application of criminal and legal measures to a political party;
  • Prohibitions on the activities of a political party, cancellation of its registration;
  • Repeated during the year: failure to report to the NAPC; submission of a report with a gross violation of the requirements or indicating inaccurate information; intentional receipt by a political party of a contribution received from a person who was not entitled to make such a contribution, or receipt of a contribution exceeding the maximum amount;
  • Establishment by the court of the fact that the funds of state funding for statutory activities were spent for other purposes or for participation in elections, etc.
Implementation in practice

2.1. Reporting of Political Parties

Quarterly reports by political parties are a key tool for checking political finances. Until recently, each political party submitted its reports to the NACP in two forms, namely, in electronic (PDF and XLS) form and paper. The NACP, in turn, published these reports on its website (in PDF and XLS formats). Despite their openness and accessibility, this reporting format had several shortcomings.

  1. The reports published on the site were enormously massive and often of poor quality. The experts reckon that their processing took a lot of resources and time because before the direct analysis the reports had to be unified, cleaned, and digitized.
  2. Paper reports, in turn, were very huge and required a significant amount of paper. For example, to print a report of one fairly large political party it was necessary to consume 70-80 packs of A4 sheets of paper. Transporting such a report to the NACP required several cars or one truck.

In May 2021, the situation radically changed when the NACP completely commenced the electronic system for reporting by political parties, i.e., POLITDATA. Its launch significantly increased transparency in political funding. From one side, civil society is able to check the report in a shorter time and more efficiently due to the fact that information is accessible and unified, and on another side, political parties save their resources and time when submitting their reports. Unlike the usual placement of copies of reports on the NACP website, POLITDATA provides for automatic processing of such information. In particular, in addition to displaying reports in XLS format, POLITDATA provides information in the form of statistical and practical data with a search engine to find the required report. All data in POLITDATA is placed in the open data format, particularly in API (machine-readable format), which greatly simplifies working political party reports out by the public. By 2021, political party reports are submitted exclusively in the electronic form to POLITDATA. For this purpose, political parties and their branches are registered in the system. As of September 2021, 112 political parties (out of more than 600) have been registered with POLITDATA, and 31 reports have been submitted.

Despite increasing transparency in political financing, political parties have the right (on days when this paper was being written) not to submit such reports. In April 2020, a law, that postponed the submission of reports by parties until the end of the quarantine imposed by the COVID-19 pandemic, entered into force. Taking such measures looks more like the “whim” of political parties than an urgent need since the quarantine hardly poses any obstacle to submitting such reports. As of September 2021, there was still a quarantine period, consequently, political parties did not submit their reports for more than a year. Because of this, the public has not known for a year what money was spent for the local elections held in October 2020, and how political parties spent state funds. Upon completion of the quarantine, political parties are obliged to submit all previously non-submitted reports almost simultaneously. Experts are of the opinion that it can also cause negative consequences. First, after the resumption of reporting, the NACP will obtain a large number of reports at one time, which will not allow them to be processed qualitatively due to the short deadlines for inspections. Second, those political parties that reported during the quarantine period can be in a worse position than others because their reports can attract more attention from the NACP and the public.

2.2. Election Campaigns Reports

The reports on election campaign funds are published on the websites of NACP, CEC, TEC, etc. in pdf and xls formats. Despite the commencement of the electronic system, the submitted reports will not be placed on POLITDATA. Such an approach raises the same shortcomings as those in terms of quarter reports happening before, specifically, their processing will take a long time and resources. It is unlikely to result in effective state and public scrutiny of election campaigns finance.

The levels of openness and accessibility of the reports on local election campaign funds are low. There are no problems with this in the national elections (president and parliament), and the CEC and NACP publish election campaigns reports in a timely and complete manner; however, the situation is worse in local elections. As the Table shows, ____ election campaign fund reports are published on the official websites of TECs (not usually available), or local councils, or otherwise, during local elections. However, in practice, these provisions of the law are not followed. The public monitored the publication of reports by political parties and candidates in 15 major Ukrainian cities during the recent local elections. The results found that local branches of political parties did not publish 55% of their final financial reports. In turn, mayoral candidates published only 44% of all reports. The quality of inspections of reports is also poor. The results of the selective analysis carried out by the public revealed that a significant part of TECs did not check any report, although, in situations where the checks were conducted, they were of declarative nature. Experts are of the view that this problem arises because TECs are much busier counting votes and processing election results, consequently, not having enough capacity to properly audit financial statements.

2.3. Financing of Political Parties

Despite the openness of financial statements of political parties and the ability to control every incoming to the party’s budget, it cannot be said that, in Ukraine, political parties are fully transparent. It is almost impossible to understand who finances political parties and how big financing is.

Legislative requirements for party financing can be easily circumvented with the help of developed schemes, the most popular of which are described below.

1) Use of fictitious donors.
This scheme is as follows: a person who is interested in financing political party hands the cash over to another person (he or she is called “pidstavna osoba”). This person, in turn, transfers, identifying his or her name, the money to the party’s bank account and receives a reward for such a transaction. Given that the maximum sum of a voluntary contribution paid by an individual is EUR 75000, it is not necessary to involve many fictitious donors to transfer big money.
In 2020, one political party used such a scheme. In the 2nd quarter of 2020, it declared zero receipts, an office with an area of 14.8 m2, located in Kyiv, one laptop, a table, and two chairs. But in the 3rd quarter that year, the party received almost EUR 1 million as voluntary contributions. The public found out that that money was contributed towards that political party mainly by students and unemployed people.
According to experts, besides fictitious “poor” donors (whose insolvency can be easily proven), there are also schemes with fictitious “rich” donors. That means that political parties are looking for people who can easily explain the legality of their earnings and use them to fund political parties. For example, one party received funds directly from the top management of large Ukrainian companies owned by an oligarch.

2) Use of fictitious legal entities and civil society organizations.
This scheme is similar to the previous one, but legal entities are used instead of individuals. For example, in 2019, one of the largest political parties in Ukraine received approximately EUR 90,000 from two companies that were registered by one person a month before the transfer. Approximately the same scheme was used by the ruling party. Experts note that there are cases when the amount of donation paid by a legal entity is equal to (or even less) its total annual revenue.
Due to the financing of political parties by legal entities, it is possible to evade the restrictions imposed on financing made by foreign citizens. For example, a foreign citizen can invest in a legal entity registered in Ukraine, and the latter, in turn, can legally finance the party.

2.4. Financing of Election Campaigns

There are also many ways for political parties to hide their ingoings and outgoings during election campaigns. To give you some of the most spread of them:

1) Use of public organizations with the same name as a political party.
To implement this method, there must be a civil society organization registered with the same name as a political party. Then the civil society organization finances political advertising pays salaries to employees, advertisers, and headquarters members of a political party, and so on. The political party does not report on these expenses, as they were, de jure, carried out by a separate legal entity. For example, such a scheme was actively used during the local elections in 2020 and the parliamentary elections in 2019.

2) Concealment of expenses on advertising on social networks.
The popularity of political advertising on social networks is growing rapidly. According to civil society estimates, in the first half of 2020, politicians spent on advertising on Facebook about USD 850000, and USD 1.2 million for the same period in 2021. Despite such high expenses, political parties mostly did not report on it. As a result, a huge amount of money spent on election campaigns remains in the shadows.
Experts note that in practice there are several shortcomings in reporting the cost of advertising on social networks, and among them are:

  • Lack of a convenient way to pay for advertising from the election campaign fund account. It happens due to the inability of legal entities to pay for advertising on Facebook, and due to the lack of official representation of the company in Ukraine;
  • lack of a separate category of expenditures (columns) in the forms of final and interim reports approved by the CEC. Experts believe that the form of reports should be further detailed, as at the moment the “other expenses” column covers a significant number of possible transactions that need to be allocated separately.

Shadow cash used by political parties during election campaigns is widespread. A large amount of money is spent on the salaries of political party observers and members of polling stations, and is paid “in envelopes”. One of the interviewed experts estimates that about half a million people are needed to organize the election campaign. Accordingly, one can only imagine the scale of this practice.

2.5. Responsibility for violation of requirements of the law

Widespread use of the described schemes is possible for several reasons, but the main one, in our opinion, is the evasion of bringing to liability, and petty sanctions for violations of the law. In addition to the general problems being experienced in bringing to administrative liability that we described in Section ___, the cases regarding violations of the requirements for financing a political party and election campaigns have certain features.

Efficiency in bringing to administrative responsibility for violation of rules of financing political party (election campaigns) and reporting (hereinafter “cases”) is extremely poor. Courts close most of the cases, impeding bringing to justice. According to information provided by the NACP, in 2020, courts closed 299 cases, that is 88% of all the cases heard in courts. Among them, 198 cases (66%) were closed on the ground of with the expiry of procedural deadlines, 81 cases (27%) - the absence of the constituent elements of the offense, and 8 cases (2,7%) - due to minor insignificance. The tendency of closing cases goes up, particularly, in 2018, courts closed 77% of cases, but, in 2019, 82% of cases. Factually, administrative liability is enforced in 12% of cases, even it happens, the sanctions impede prevention because, in 2020, the average sum of fine imposed by court resolution was EUR 144.

Among the main shortcomings appearing in the consideration of this category of cases by courts (except for the general shortcomings that are inherent in all administrative cases), the experts point out:

  • Lack of a clearly defined subject of the commission of an administrative offense, who is responsible for submitting the report of the political party, and the place of commission of such an offense, which affects the jurisdiction of such cases;
  • Insufficient period (24 hours) fixed to draw up a report, starting from the moment when the person who committed an offense was identified;
  • Absence of a deadline during which the NACP representatives are obliged to send the report to the court after the report is drawn up;
  • Ambiguity of court practice regarding the return of case materials in case of violation of jurisdiction, etc.

The efficiency of bringing to criminal liability is even poorer. In particular, in 2020, the NACP sent 22 notifications to the police about the detection of the facts of a criminal offense, as a result of which 11 proceedings were opened, but those cases did not reach the court. And for the whole time of existence of the article of the Criminal Code (since 2006), there was only 1 court case ruled guilty sentence.

2.6. State Financing of Political Parties

State financing of political parties is one of the main sources of income for political forces. The amount of state financing is increasing each year, and it is rather huge. As of July 2021, only 5 parties were applying for the state funding. In 2021, the total state budget allocated for political parties financing was approximately EUR 21.9 million. For comparison, in 2020, this figure was approximately EUR 8.8 million. As of July 2021, since the beginning of the year, the NACP transferred approximately EUR 16.2 million to political parties.
These funds are distributed in proportion to the votes received by voters in the recent parliamentary elections. For example, since the beginning of the year, the ruling party of the President, which has had a significant majority in the Parliament, has already received about EUR 7.5 million. To compare, during the same period, the least represented political party in the Parliament received about EUR 1.5 million.

The oversight mechanism is efficient, but not perfect. On one side, the NACP rather properly and thoroughly scrutinize the reports of political parties, and on grounded reasons suspends state financing. But on the other side, the currently applicable mechanism of suspension of state funding does not fully guarantee political parties against whimmy decisions of the NAPC. The issue of suspending public funding in 2020 was quite acute. Then, the NAPC suspended state funding for three parliamentary parties, namely, the ruling political party and two opposition ones. Two political forces submitted clarifying reports to correct the shortcomings identified by the NACP. As a result of the verification of clarifying reports, state financing was resumed. The third political force appealed the NACP’s decision to court. The final decision has not yet been ruled, but the party no longer receives money from the state budget. The grounds to suspend financing of those political parties were numerous violations of the Law on Political Parties.

The NAPC claims that:

  • one of the parties paid more than EUR 15000 for media monitoring services. For these funds, the contractor provided a report, which is an exact copy of publicly available information previously posted on the official website of one of the public organizations;
  • the reports of another party indicated that it transferred more than EUR 62000 for the organization and provision of forums based on documents that did not exist at that time;
  • Another party transferred money to five companies for printing products under contracts worth more than EUR 437 000. According to state authorities, the heads of local organizations who, according to the documents, received these products were abroad at that time. At the same time, the bank accounts of these companies, to which the funds were to be transferred, were opened later than the date of the conclusion of contracts.

The arguments of the NAPC were quite convincing and indicated a good level of inspection. However, political parties believed that the NAPC had exceeded its authority in assessing the services provided to parties. As a result of these events, representatives of all political forces in Parliament submitted a bill, which in fact provided for the deprivation of the NAPC of the power to control political finances. Due to public pressure, consideration of the bill had to be suspended. Instead, another bill is being considered in the Parliament, that envisages additional guarantees against NAPC’s arbitrary decisions, but entitles the oversight body to exercise control of political financing.




The introduction of the electronic system for submitting political party reports (POLITDATA) has significantly increased the transparency and accessibility of information on political party financing.
State funding of political parties is provided at a proper level.
NAPC’s control over party finances is efficient and of proper quality.
For more than 19 months, without justified reasons given, political parties have the right not to submit their reports.
Reports of local election campaigns funds are practically not published and are not checked by oversight bodies.
Legislative requirements and restrictions on the financing of political parties and election campaigns can be easily circumvented. There are a number of widely-used ways to do this.
Shortcomings of the mechanism for bringing to responsibility allow offenders to evade responsibility.
Administrative and criminal liability for violating reporting and funding requirements for political parties is extremely ineffective.
The mechanism of suspension of state funding does not fully guarantee political parties against whimmy decisions of the NAPC
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