€420 million at stake: why Ukraine's anti-corruption strategy keeps disappearing from parliament's voting schedule – and what it means for Ukraine's future reconstruction

Two versions of the Ukrainian parliament's plenary agenda. One includes the Anti-Corruption Strategy for 2026–2030. The other does not.

This is how Ukrainian Member of Parliament Yaroslav Zhelezniak described the bill's second disappearance from parliament's voting schedule. The reason: a lack of votes.

The bill in question, No. 15230-d, was registered on July 27, 2026. Despite nearly two years of work involving the National Agency on Corruption Prevention (NACP), government institutions, Ukrainian and international experts, it has yet to pass even its first reading.

The NACP has publicly urged lawmakers to support the bill, as Ukraine has already missed the September 30, 2026 deadline agreed with the EU for adopting the Strategy.

At stake is €420 million in European financial assistance. But the stakes are much higher: the rules under which Ukraine will manage hundreds of billions of dollars in future reconstruction spending.

€420 Million: Why the Vote Matters

Adopting the Anti-Corruption Strategy is not merely a matter of domestic policy. It is one of Ukraine's international commitments on its path toward EU membership.

The commitment is included in the Rule of Law Roadmap, the interim benchmarks of Ukraine's EU accession process, and the Ukraine Plan under the Ukraine Facility – the EU's financial support mechanism that links disbursements to the implementation of agreed reforms.

The fulfillment of the relevant milestone is linked to a €420 million payment.

This is not an automatic reward for a parliamentary vote. To receive the funding, Ukraine must fulfill the agreed conditions, and the European Commission must verify their implementation.

Under the revised timetable, parliament was expected to adopt the Strategy by the end of the third quarter of 2026, while the Cabinet of Ministers must approve the State Anti-Corruption Program by the end of the year.

The first deadline has already been missed. Without an adopted Strategy, the next stage — approving the program for its implementation – cannot be properly completed.

And the problem is not that parliament lacks a ready document.

After reviewing three alternative bills, the Verkhovna Rada's Anti-Corruption Policy Committee, together with the NACP, prepared a revised version. The committee recommended that parliament adopt it in the first reading.

After extensive consultations, expert reviews, and negotiations, the decision once again comes down to political will.

$588 Billion for Reconstruction. Who Will Be Accountable for How It Is Spent?

According to the latest Rapid Damage and Needs Assessment (RDNA5), prepared by the Ukrainian government, the World Bank, the European Commission, and the United Nations, Ukraine's recovery and reconstruction needs amount to nearly $588 billion over the next decade.

That is almost three times Ukraine's annual GDP.

Clearly, not all these resources will flow through the state budget. Private investors, international financial institutions, and donors are also expected to contribute.

But regardless of where the money comes from, Ukraine must answer some fundamental questions: Who determines reconstruction priorities? What rules govern the allocation of funding? And how can the public verify that the money is being used effectively?

This is precisely why Ukraine's recovery from the consequences of Russian aggression has, for the first time, been identified as a separate priority area in the draft Anti-Corruption Strategy.

In preparing this section, the NACP and experts from the Risk Scoring Center analyzed the regulatory framework, state audit findings, judicial practice, open data, and the mechanisms used to implement reconstruction projects.

The result was the identification of five systemic problems, now included in the draft Anti-Corruption Strategy. Addressing them will help determine how transparently Ukraine can manage its future investments.

First: Reconstruction Without a Unified Strategic Framework

Ukraine is rebuilding housing, roads, hospitals, and energy facilities, yet it still lacks a single approved national recovery strategy that would establish long-term objectives and align reconstruction priorities.

Without such a strategy, even essential projects may compete for limited resources without a sufficiently clear rationale for how funding is allocated. This creates risks of fragmented spending, imbalances between sectors, and an accumulation of unfinished projects.

The absence of strategic planning documents was highlighted in the Accounting Chamber of Ukraine's Decision No. 55-2 of December 10, 2024. The audit identified the absence of approved documents, including a unified nationwide recovery plan and a recovery and development plan for Ukraine's regions.

The draft Ukraine Recovery Plan prepared by the National Recovery Council has still not been approved.

Second: Decisions Based on Incomplete or Unreliable Data

How can authorities determine which road should be repaired first without comprehensive data on road conditions and traffic volumes?

How can housing programs be planned without reliable assessments of the needs of internally displaced persons?

And how can construction costs be verified without reliable information on the prices of building materials and labor?

These are not merely technical shortcomings in databases. They create conditions for poor management decisions that, at the scale of Ukraine's reconstruction, could cost billions.

The problem persists. Funding for road projects is often allocated without adequately considering the actual condition of the roads.

A State Audit Service report dated October 26, 2023, No. 000600-22/33 documented the absence of electronic road asset records in most regional infrastructure restoration services.

The Accounting Chamber's Decision No. 39-2 of August 27, 2024 identified inflated cost estimates for water pipeline projects and errors in assessing the number of people affected, including ineffective management of UAH 449.2 million in Kherson Oblast.

Similarly, an analytical study of social housing under the Ukraine Facility revealed a significant discrepancy between the planned construction cost of UAH 56,000 per square meter and the officially approved indicative housing construction cost of UAH 23,841 per square meter, established by the same ministry.

Third: Experimental Procedures That Weaken Oversight

Wartime reconstruction requires swift decisions. But speed cannot justify opaque funding allocations or weaker oversight of contractors.

Ukraine's Accounting Chamber has already identified problems in the use of resources from the Fund for the Elimination of the Consequences of Armed Aggression, particularly in the implementation of experimental reconstruction projects.

In its Decision No. 32-3 of July 3, 2024, the Accounting Chamber found that decisions to launch several experimental projects worth UAH 30.7 billion – 49.6% of the Fund's total resources – had been made in violation of legal requirements, through insufficiently transparent and inadequately justified procedures.

The key question is not whether simplified procedures should be allowed.

It is which requirements for justifying project needs, procurement, financing, and reporting must remain mandatory even during wartime.

Fourth: Opaque Prioritization of Public Investments

Ukraine has already introduced a new public investment management system, including sectoral project portfolios, project evaluation, prioritization procedures, and the formation of a Unified Project Portfolio.

However, the existing procedures still require improvement.

For example, when selecting projects for public investment programs, the program initiator determines the selection criteria and also establishes the commission responsible for applying them.

At the same time, the general regulatory framework does not sufficiently specify deadlines for approving and publishing selection criteria, rules for changing them during a selection process, or safeguards to ensure the independence of project evaluation.

This creates a risk that criteria could be tailored to favor particular projects.

Fifth: The Inability to Fully Trace the Flow of funds

The Budget Code envisages one system. In practice, another is being used. And the government is already planning a third digital architecture.

Article 33-1 of Ukraine's Budget Code provides that the Unified Public Investment Project Portfolio must be formed using the Unified Information System for Public Investment Project Management (UISPIPM).

Until this system is established, the relevant digital processes are handled through DREAM.

In July 2026, the government adopted Resolution No. 945 regulating the operation of DREAM, but designated it as only one component of the Unified Digital Ecosystem for Public Investment Management.

Meanwhile, the Concept approved by Government Order No. 547-r envisages the Ministry of Finance establishing the UISPIPM by the end of 2028.

We therefore have three interconnected concepts: DREAM, the UISPIPM, and the Unified Digital Ecosystem. But is it clear where the complete history of each project will be accessible, and who will be responsible for the accuracy of the data?

Today, DREAM contains information about projects, Prozorro holds procurement data, and budgetary and Treasury systems record financing and payments.

Yet these datasets cannot always be automatically linked.

Where will a citizen, journalist, or auditor be able to open a single project record and see everything: who initiated it, which criteria were used to select it, how much funding was allocated, who won the contract, how much was actually paid, what was built, and what violations auditors identified?

Ukraine does not need another digital platform with a new name. It needs a single, transparent, and verifiable record of every public investment – from the initial decision to the final payment and audit.

The Anti-Corruption Strategy is intended to turn these identified problems into official priorities of state policy.

The next step should be the adoption of the State Anti-Corruption Program, which will establish specific measures, responsible institutions, implementation deadlines, and performance indicators.

In other words, the Anti-Corruption Strategy defines what the state commits to changing, while the program establishes who will deliver those changes, how, and by when.

Over the next five years, the state is expected to address problems identified across 16 areas — from reconstruction, defense, justice, and energy to public procurement, construction, healthcare, and education.

That is why delaying the adoption of the Anti-Corruption Strategy is not simply another disruption to the parliamentary schedule.

It creates risks for future European financing, the fulfillment of Ukraine's EU integration commitments, and the introduction of rules governing the use of reconstruction resources.

The EU expects Ukraine to implement the reforms it has committed to. Ukrainian society expects clear and fair rules for how public money is spent.

Yet the Verkhovna Rada has still been unable to secure even a first-reading vote on a document that should form the foundation for these changes – and whose adoption is linked to receiving €420 million from the EU.

This is happening while the government is suspending expenditures on construction, reconstruction, and major repairs, urging local communities to limit non-essential spending, and the prime minister acknowledges that restoring funding depends on international assistance and the adoption of the necessary legislation.