Brussels shifts from praise to “concerns about impartiality” as €50 billion in EU assistance hangs in the balance on anti-corruption benchmarks.
Tetiana Krupa headed a regional disability commission in western Ukraine. She declared a 26-square-meter house worth $76 and two hectares of land at $118. Her family's 64 properties raised no alarms at Ukraine's National Agency on Corruption Prevention (NACP), which reviewed her declaration and found nothing wrong. Then investigators found $6 million in cash at her home.
The European Commission’s 2025 enlargement report, published on 4 November, revealed a dramatic reversal in Brussels’ assessment of Ukraine’s National Agency on Corruption Prevention (NACP).
The agency went from receiving praise as an institution that “achieved good results and demonstrated its independence” in 2024 to facing “concerns about its impartiality and the effectiveness of some of its operations” just one year later.
Two agencies, two outcomes
The EU’s €50 billion Ukraine Facility—the largest financial support package in European history during wartime—works through quarterly payments tied to governance benchmarks. Anti-corruption performance is among them. When Ukraine tried to gut NABU’s independence in July, thousands took to the streets in cities across Ukraine—the first major anti-government protests since Russia’s full-scale invasion. The EU froze $5.5 billion until street protests forced Zelenskyy to reverse course.
Ukraine’s declaration system exists precisely to catch officials living beyond their means.
Every public official must disclose assets annually in an open registry—one of the most advanced transparency tools in the world, with 9 million published documents accessible to anyone. NACP verifies these declarations against 20 state databases, from land registries to vehicle records. When the system works, suspicious wealth gets flagged before it becomes a scandal.
On 28 November, NABU raided the apartment of Zelenskyy’s chief of staff, Andriy Yermak, forcing his resignation within hours—demonstrating that Ukraine’s investigative agency can reach the president’s inner circle. NACP—the agency that should have caught problems earlier through declaration review—appears to have let obvious red flags sail through.
The declaration that should have raised alarms
The case of Tetiana Krupa illustrates what the EU means by “effectiveness concerns.”
Krupa headed the Medical-Social Expertise Commission in Khmelnytskyi Oblast—an official position requiring asset declaration. When authorities raided her home in October 2024, they found nearly $6 million in cash. But her declaration had already passed NACP’s manual review without triggering any investigation.
A glance at that declaration reveals why experts find this inexplicable: Krupa’s family declared 64 properties. Among them were eight land plots, each measuring two hectares and valued at a total of 10,000 UAH ($237)—roughly 5,000 UAH ($118) per hectare. A 125-square-meter apartment purchased in 2018 was declared at 108,000 UAH ($2,557) for the entire property. The smallest house, 26 square meters, was listed at 3,200 UAH ($76).
NACP Deputy Head Dmytro Kalmykov told European Pravda that the agency lacks the authority to question documented transaction values. “If there’s a contract saying one hectare costs 5,000 UAH, NACP cannot challenge that document during a full verification,” he said.
Ukrainian anti-corruption law requires NACP to verify the validity of declared asset valuations during complete audits. Transparency International Ukraine examined 200 published NACP verification reports and found problems in 199 of them—including 40% where asset valuation checks were purely formal.
What the EU now demands
The 2025 enlargement report lists several requirements specifically targeting NACP:
- Expand the categories of officials required to file declarations
- Simplify and improve declaration verification procedures
- Strengthen NACP’s capacity to identify unjustified assets
- Immediately implement key recommendations from the 2023 independent evaluation
- Conduct the next independent evaluation without delay using a credible methodology
The demand for an audit carries particular weight. Ukrainian law requires the NACP to undergo an external, independent evaluation every two years. The agency has completed only one such audit—a process that started in 2021 and dragged into 2023. Three years have passed without another.
The audit standoff
NACP claims it wants the audit. “We would very much like this audit to start from 1 January,” Kalmykov told European Pravda.
Trending Now
But the agency refuses to accept new evaluation criteria.
“An audit for past years can only be conducted using the criteria that were in effect at that time,” Kalmykov insisted. “Anything else would directly contradict the Constitution.”
Transparency International Ukraine’s Kateryna Ryzhenko disputes this, noting the previous methodology was so flawed that confirming poor performance was “almost unrealistic.” She says the delay lies entirely with Ukraine: the government must develop an adequate methodology, and international partners’ proposals have sat untouched through three justice ministers.
The standoff matters because only a negative audit can remove NACP’s leadership without their consent.
The “twenty to NACP” question
The agency’s credibility faces another challenge from Ukraine’s ongoing $100 million corruption scandal at Energoatom.
In recordings released as part of the “Mindichgate” investigation, a suspect identified as “Tenor” mentions giving “20 to NACP.” Ukrainian News Agency reported that NABU identified “Tenor” as Dmytro Basov, Energoatom’s executive director for physical protection and security. He has been remanded in custody with bail set at 40 million UAH ($950,000).
NACP head Viktor Pavlushchyk told the parliament’s investigative commission that the agency had launched an internal probe, although no employees allegedly involved had been identified. Parliament’s European integration committee has called for an urgent NACP audit.
One area of agreement
Not all EU demands face resistance. NACP, Brussels, and Ukrainian experts agree on one reform: extending declaration requirements to cover presidential, governmental, and parliamentary patronage staff—the advisors and assistants who often wield real decision-making power.
“Given Ukrainian management realities, these people actually influence decisions and sometimes are the ones making them,” Kalmykov acknowledged.
But this change requires parliamentary action. Whether the Verkhovna Rada will act amid the current political crisis remains uncertain—Yermak resigned just hours ago, and Zelenskyy’s approval has collapsed to 25%.
The European Commission spokesperson stated on 28 November that today’s Yermak raid “shows that the anti-corruption bodies in Ukraine are doing their work.” The question is whether the agency designed to catch problems before they become raids can do the same.
