The NACP will be able to re-inspect government bodies: what has changed
This is set out in NACP Order No. 177/26 of 25 June 2026, registered by the Ministry of Justice on 14 July under No. 1040/46434.
Previously, during its inspections, the NACP mainly assessed how work to prevent corruption was organised within a government body or other institution. In particular, it examined the preparation and implementation of anti-corruption programmes, the functioning of channels for reporting breaches, and the protection of whistleblowers.
The new order broadens the scope of oversight. The NACP will now also assess whether an institution has complied with the instructions and written recommendations issued following the results of a previous inspection.
Consequently, the completion of an inspection and the receipt of recommendations will no longer mark the end of the oversight process. The Agency will be able to revisit the matter and check whether the identified shortcomings have been rectified.
When an unscheduled inspection may take place
Failure to provide information on compliance with an order or written recommendations in response to a request from the NACP will constitute a separate ground for an unscheduled inspection.
The head of the institution will be required to inform the Agency of the measures taken and to provide documents confirming compliance with the established requirements.
At the same time, the mere fact of receiving recommendations does not automatically trigger a new inspection. An unscheduled inspection on new grounds is possible if the institution fails to provide the NACP with the requested information regarding the status of their implementation.
The order does not introduce a separate new fine. Based on the results of the inspection, the NACP will exercise the powers provided for in the Law ‘On the Prevention of Corruption’.
What may be required of managers
The NACP will be able to issue written recommendations not only directly to the institution where the audit was carried out, but also to legal entities subordinate to it.
This means that a central authority or local government body will not be able to limit itself to making changes solely within its own organisation if the problems identified also concern subordinate enterprises or institutions.
Managers will be required to organise the implementation of the recommendations and report on the results, supported by documentary evidence. The NACP, for its part, will be able to assess not only the existence of internal regulations and anti-corruption programmes, but also the practical results of their implementation.
Who the NACP may inspect
Under the Law ‘On the Prevention of Corruption’, such inspections may cover state bodies, local government bodies, legal entities governed by public law and certain legal entities specified by legislation.
During its inspections, the NACP checks the preparation and implementation of anti-corruption programmes, the work of authorised departments, channels for reporting possible corruption, compliance with whistleblower protection guarantees and other internal mechanisms.
If violations are identified, the Agency may issue an order to rectify them, demand that an internal investigation be conducted, or bring the guilty party to justice. Where there are sufficient grounds, the NACP may also refer the case to other authorised bodies or take the matter to court.
Which institutions are included in the plan for 2026
The NACP’s official plan for 2026 lists ten institutions where scheduled audits of anti-corruption work are to begin.
An audit of the Ministry of Youth and Sport was scheduled for March, the Dnipro City Council for April, the State Service of Ukraine for Transport Safety for May, and the State Customs Service for June.
The plan provides for an audit of the Odesa City Council in July. In August, an audit is due to begin at the State Employment Service, and in September at the private joint-stock company ‘National Energy Company “Ukrenergo”’.
An audit of the National Agency for Asset Tracing and Management is scheduled for October, of the State Property Fund for November, and of the State Labour Service of Ukraine for December.
The inclusion of an organisation in the plan does not imply the presence of corruption or any established violations within it. The plan merely specifies the organisations to be audited and the months in which the scheduled audits are to begin.
The results of the audits will be made public
Information on the results of the audits and the decisions taken by the NACP is to be published on the Agency’s official website. It is also planned to publish this information in open data format.
This will allow the public to monitor not only the violations identified, but also the response of the institutions’ management to the NACP’s orders and recommendations.
The order states that the changes come into force on the day of its official publication.
Follow us on Telegram.
