Since 2014, Ukraine has built an extensive anti-corruption and reform infrastructure funded by international donors and implemented through state institutions, NGOs, think tanks, consultants and technical assistance programmes.
Public claims circulating in 2026 allege that approximately €80–120 million was spent over a five-year period on judicial reform programmes, with individual expert fees allegedly reaching €500–1,500 per working day and, according to some publications, expert and consultancy costs representing as much as 60–70% of certain project budgets. I have not found a consolidated independent audit establishing that €120 million was misappropriated, or confirming that 60–70% of all judicial reform funding was spent in this way.
A second widely circulated allegation claims that Ukrainian anti-corruption and civil society organisations “stole” approximately UAH 796.6 million in international assistance in 2025. Examination of the underlying figures shows something rather different: many of the amounts reproduced in those publications correspond almost exactly to the organisations’ publicly reported annual revenues for 2025, rather than to established losses or amounts identified as stolen.
Among the figures publicly reported for 2025 are approximately UAH 120.25 million for the Centre for Economic Strategy, UAH 88.37 million for Transparency International Ukraine, UAH 82.7 million for ZMINA, UAH 61.17 million for the Institute of Mass Information, UAH 53.35 million for DEJURE Foundation and UAH 51.50 million for the Anti-Corruption Action Centre.
For comparison, the combined figure of approximately UAH 796.6 million is equivalent to roughly 1.57 times the entire 2025 annual budget of the High Anti-Corruption Court of Ukraine, which was approximately UAH 507.6 million.
The legal question, therefore, is not whether these publicly reported revenues can simply be labelled “theft” — they cannot. The more serious question is whether a professional reform and anti-corruption sector operating for more than a decade and exercising considerable influence over legislation, public policy and public appointments is subject to transparency, conflicts-of-interest and effectiveness standards comparable to those it demands from the state and private business.
For many years, I have watched the professional activities of Ukraine’s anti-corruption community.
During that time, the fight against corruption has developed into something much larger than a government policy. It has become an entire professional industry: NGOs, think tanks, international programmes, experts, monitoring initiatives, training sessions, conferences, rankings, research projects and advocacy campaigns.
And all of this costs a considerable amount of money.
On several occasions, I even found the time to attend some of these forums myself. They tended to look remarkably similar: endless reports of success, attractive presentations, panels discussing the “next stage of reform”, the correct English terminology and, occasionally, somewhat less correct English pronunciation.
Years passed.
Eventually, I improved my own English, learned how to make presentations myself and perhaps became slightly less vulnerable to the magic of PowerPoint.
But one very simple professional question remained.
As a lawyer, I would like to know:
What was the actual result, and how much did that result cost?
Today, that question has become particularly relevant.
A statement that “corruption has increased” is currently frequently attributed to NABU Director Semen Kryvonos. I have not found that exact wording in a sufficiently reliable primary source and therefore would not attribute that quotation directly to him.
However, the Head of the Specialised Anti-Corruption Prosecutor’s Office, Oleksandr Klymenko, recently expressed the problem in even more direct terms:
“Corruption in Ukraine is not decreasing… and if we are talking about top-level corruption, it is actually increasing.”
NABU Director Semen Kryvonos has also spoken about the transformation of corruption and the emergence of influential beneficiaries behind major companies supplying defence products.
So after more than ten years of anti-corruption reform, asking about its economic effectiveness can hardly be dismissed as a marginal or anti-reform position.
Where Did the Claim About “UAH 797 Million Stolen by Activists” Come From?
I became interested in a figure that has recently circulated widely: the allegation that Ukrainian civil society and anti-corruption organisations “stole” approximately UAH 796.565 million of international assistance in 2025.
So I decided to check it.
And this is where the story becomes considerably more interesting.
The publication from which this allegation spread widely does not refer to a court judgment.
It does not refer to a State Audit Service report.
It does not refer to proceedings or findings by NABU, the State Bureau of Investigation or a prosecutor.
Nor does it refer to an independent forensic audit establishing losses of UAH 797 million.
Instead, the publication relies on a social media post. More importantly, the article itself subsequently describes the figures as a list of organisations “indicating their income.”
That matters.
Because the numbers start matching publicly available financial information almost exactly.
The Centre for Economic Strategy reported approximately UAH 120.247 million in income for 2025.
Transparency International Ukraine — approximately UAH 88.373 million.
The Institute of Mass Information — approximately UAH 61.174 million.
DEJURE Foundation — approximately UAH 53.352 million.
The Anti-Corruption Action Centre — approximately UAH 51.499 million.
Publicly available information for ZMINA indicates approximately UAH 82.7 million in 2025 revenue, while the circulated list gave a figure of approximately UAH 82.4 million.
In other words, at least five of the most frequently quoted figures in the alleged “UAH 797 million theft” story correspond almost exactly to the organisations’ annual reported revenues.
And the annual revenue of an NGO is not “stolen money”.
Nor is it the personal income of its employees.
From a legal perspective, the distance between saying:
“An organisation received UAH 120 million in funding”
and saying:
“An organisation stole UAH 120 million”
is approximately the distance between a bank transfer and a criminal conviction.
To establish misappropriation, one would need to identify the particular funds involved, the legal basis on which they were received, the unlawful means by which they were appropriated, the persons responsible, the amount of loss, intent and the relevant causal connection.
An annual financial statement establishes none of these elements.
But it does establish something else.
The financial scale of this sector is substantial.
The approximately UAH 796.6 million referred to in that publication — if correctly described as aggregate organisational revenue rather than “stolen money” — is equivalent to approximately 1.57 annual budgets of Ukraine’s High Anti-Corruption Court, whose 2025 state budget allocation was approximately UAH 507.6 million.
And that is a comparison worth discussing.
Not as a criminal allegation.
As an economic one.
What About the €120 Million Spent on Judicial Reform?
Another figure currently circulating is that approximately €80–120 million was spent over roughly five years on reforming Ukraine’s judicial system through programmes financed by the EU, USAID, the Council of Europe and other donors.
The same publications claim that consultants were sometimes paid between €500 and €1,500 per working day, while consultancy and expert costs allegedly accounted for as much as 60–70% of the budgets of certain projects.
I found publications containing those claims.
What I have not found is a consolidated publicly available independent audit which would allow me to establish conclusively that exactly €120 million was spent during a defined five-year period, much less that 60–70% of all such funds were paid as expert fees.
And I certainly found no evidence that would permit €120 million to be described legally as “stolen”.
Accordingly, for me the €120 million figure is a reason to request consolidated reporting and detailed disclosure — not a basis for presenting misappropriation as an established fact.
The distinction is fundamental.
It is also misleading to suggest that because much of the money did not enter the bank accounts of Ukrainian ministries or other public authorities, it was therefore automatically uncontrolled.
International technical assistance does not necessarily have to pass through the accounts of a Ukrainian ministry.
Ukraine has a specific legal framework governing the registration, coordination and monitoring of international technical assistance projects.
The more important question is whether that system allows a taxpayer in London, Berlin or Washington — as well as a Ukrainian citizen — to see a comprehensible chain:
donor → implementing organisation → subcontractor → expert → specific deliverable → measurable result.
That is where, in my view, the real problem begins.
A Beautifully Audited PDF Is Not the Same as Proof of Effectiveness
For the sake of fairness, another point must be made.
It would be incorrect to claim that all these organisations conceal their financial information.
Transparency International Ukraine, for example, publishes annual reports and audit information. The Anti-Corruption Action Centre also publishes information concerning donors, financial reporting and audits.
So saying that “there is no reporting whatsoever” would be inaccurate.
But a financial audit and an assessment of the effectiveness of a public reform are entirely different things.
As a lawyer, I want answers to a different set of questions.
If a project cost, for example, €5 million, what exactly did Ukraine receive for that money?
How many pieces of legislation were drafted?
How many were adopted?
Which recommendations were implemented?
Which measurable indicator was supposed to change?
What was that indicator before the project started?
What was it when the project ended?
And who assessed the outcome — the same organisation that received and spent the grant, or a genuinely independent evaluator?
Because a report stating that:
“38 roundtables were organised, 14 policy papers were produced and 750 stakeholders were engaged”
is evidence of activity.
It is not necessarily evidence of a result.
And What About Tax?
Initially I wanted to phrase the issue more simply: NGOs receive grants and do not pay taxes.
After checking the legal position, I removed that sentence.
It would have been inaccurate.
A non-profit organisation, provided that it complies with statutory requirements, enjoys a specific corporate income tax regime. Its income must be used for its statutory purposes.
But that does not mean its employees operate in some form of tax-free extraterritorial jurisdiction.
Salaries are subject to personal income tax and the military levy, while the employer must also comply with applicable social security contribution obligations.
Non-profit organisations are also required to file reports concerning the use of their income and financial statements.
So the correct questions are different:
What proportion of grant funding is ultimately spent on salaries, individual entrepreneurs and external consultants?
What are the actual consultancy rates?
Who approves them?
Were competitive procurement procedures used?
Are consultant contracts, timesheets and deliverables available for scrutiny by the donor and, where appropriate, by the Ukrainian public?
Those are legitimate questions.
Why Are They Not All in the NACP Transparency Register?
Another issue initially looked very straightforward.
If civil society organisations professionally influence legislation, government policy, appointments and regulatory decisions, why do we not see all of them in the NACP Transparency Register?
The Register has been operational since 1 September 2025.
But Ukrainian lobbying law is more nuanced than that.
The National Agency on Corruption Prevention itself explains that activities by NGOs and non-profit organisations intended to influence public policy without a commercial interest are not, solely for that reason, considered lobbying requiring registration as a lobbying entity.
A commercial interest is one of the relevant elements in determining whether activity constitutes lobbying under the statutory framework.
Therefore, the absence of an NGO from the Transparency Register does not itself prove any violation.
But it creates a much more interesting legal question.
What happens where an ostensibly public-interest campaign is financed by a person, foundation or business that has a specific commercial interest in the adoption — or non-adoption — of a particular law, regulation or government decision?
Where does advocacy end and lobbying begin?
And who is responsible for examining that boundary?
Because I Have Seen Another Side of “Civil Society Activism”
In my own professional practice, I encountered a situation in which individuals presenting themselves as anti-corruption activists offered one side in a corporate conflict the possibility of organising a protest outside a competitor’s business and arranging a media campaign portraying its owner as “corrupt”.
The commercial objective was much less ideological: to stop the competitor’s production for at least one season.
I deliberately do not identify the individuals or businesses concerned here.
Without examining contracts, correspondence, payments and other evidence, an episode such as this should not be transformed into a public allegation that a specific individual committed a criminal offence.
But as a lawyer, experiences like this make me ask different questions.
Who commissioned the “investigation”?
Who paid for it?
Did the person financing it have a commercial interest?
Was that interest disclosed to the audience?
Are we dealing with civil society activity, journalism, public affairs, lobbying — or simply a commercial information service?
On another occasion, an American businessman suggested that I look carefully at a different case.
Following a highly publicised campaign against a Ukrainian manufacturer, the company’s operations were effectively disrupted, while some of its customers very quickly switched to Chinese and American products.
I am not alleging that an intentional causal relationship existed between those events.
But this is precisely why functioning systems have disclosure and conflict-of-interest rules.
The public should be able to understand not only who is speaking, but also who finances the speaker and whether someone derives an economic benefit from the outcome of the campaign.
And Finally — Military Service Exemptions
In 2024, there was also public controversy surrounding the reservation from mobilisation of employees of organisations implementing international technical assistance projects.
According to information released in response to government inquiries at the time, 523 employees of donor institutions and international technical assistance project implementers had been reserved from mobilisation.
Publicly circulated lists included, among others, Transparency International Ukraine and the Centre for Economic Strategy.
It is sometimes stated simplistically that these activists were “reserved by the Ministry of Justice”.
That is not an entirely accurate description of the legal mechanism.
The process was linked to the Secretariat of the Cabinet of Ministers and decisions of the Ministry of Economy under the version of the reservation rules applicable at that time.
Those rules have subsequently changed, meaning that a 2024 list cannot simply be treated as evidence of a person’s current status in 2026.
Nor does lawful reservation from mobilisation prove any wrongdoing.
But the public is entitled to ask about the criteria.
If a manufacturing company produces goods, pays taxes, employs workers and struggles to obtain reservation status for a limited number of essential specialists, while personnel working on a grant-funded programme receive reservation because their project has been deemed important to the state, then the public should receive a clear explanation of what precisely makes that particular project critical and what measurable benefit it provides to Ukraine.
What I Would Like to See Instead of Another Presentation
Most of these questions could be answered without criminal proceedings and without political campaigns.
For every substantial internationally funded reform project, seven categories of information should be publicly available:
- the donor, total funding and project period;
- principal implementing organisations and sub-grantees;
- administrative expenditure, payroll and external expert rates;
- the specific deliverables for which funds were paid;
- initial KPIs and actual results upon completion;
- potential commercial or other conflicts of interest affecting beneficiaries or project participants;
- an independent assessment of effectiveness — preferably not performed by the same organisation that received the funding.
Then we would not have to debate whether €1,500 per day is excessive for an international expert.
If €30,000 worth of that expert’s work saves the Ukrainian state €30 million, they may have been one of the cheapest consultants Ukraine has ever hired.
But if, after five years, the project leaves behind 40 presentations, 17 roundtables, three roadmaps, another application for donor funding and a conclusion that “the reform must continue”, the question becomes rather different.
Corruption Versus Anti-Corruption
I have no legal basis for stating that Ukrainian civil society organisations “stole UAH 797 million”.
The public information I reviewed does not establish that.
Nor have I found sufficient documentary evidence to describe the alleged €120 million spent on judicial reform programmes over approximately five years as proven misappropriation.
But examining these figures raised another, perhaps more important, question.
Over more than ten years, Ukraine has developed a professional sector that earns its living from reforming the state, evaluating the state, criticising the state, influencing public decisions and participating in the development of public policy.
Much of that activity is funded through structures where it remains surprisingly difficult for an ordinary citizen to reconstruct the complete route from donor money to a specific measurable result.
That does not mean corruption.
But the status of “anti-corruption activist” cannot serve as an exemption from the same transparency standards that these organisations have spent ten years demanding from government and private business.
Perhaps our central mistake is the habit of dividing society into “corrupt officials”, who must be monitored indefinitely, and “activists”, whose integrity is presumed merely from the title of their organisation.
Law does not work that way.
Oversight is required wherever there is money, power or influence.
Especially where all three are concentrated in the same place.
I am therefore not prepared to conclude that the fight against corruption has itself become corruption.
But I would formulate the question differently:
Has anti-corruption in Ukraine developed into a separate, professional and very well-funded market of influence which itself requires substantially greater transparency?
And if the answer is “no”, the easiest way to demonstrate that is not another presentation.
It is the documents.
Oleksandr Chernykh, lobbyist , attorney in law
