The NACP’s anti-corruption strategy for 2026-2030 needs more open discussion and transparent coordination with the public, according to Yana Tsymbalenko, anti-corruption commissioner of the National Association of Lobbyists of Ukraine and member of the Board of Trustees.
“The formation of the Anti-Corruption Strategy for 2026-2030 is a process that should be as open as possible, as it concerns the rules that determine the ethical behavior of officials, the prevention of conflicts of interest, and the standards of transparency of the state. However, analysis of the available information shows us that the public discussion of section 1.5 of the Anti-Corruption Strategy took place with numerous violations of the principles of openness and accountability,” she told Interfax-Ukraine.
Cymbalenko noted that despite the publication of the text of the strategy prepared by the NACP, “there is no evidence of full and high-quality consultations, which calls into question the legitimacy of the entire process.”
“In particular, there are no reports on the results of the discussion, no register of proposals from the public has been submitted, and updated versions of the document based on possible comments have not been published. The absence of any records or recordings of the discussion contradicts the general standards of transparency that the state declares,” she said.
The expert recalled that the “Schedule of Public Discussions” is publicly available, according to which the meeting allegedly took place on October 24, 2025. However, according to her, there were no official announcements of this event, the circle of invited stakeholders was not determined, the lists of participants or experts were not published, and it is not known who exactly prepared the materials for discussion.
“It is particularly telling that, despite the name of the division, lobbying issues were not discussed at all. This raises additional doubts about the quality and completeness of the consultations, as well as the compliance of the process with the requirements of the legislation on the formation of state anti-corruption policy,” she said, noting that the presentation of key developments was entrusted exclusively to representatives of the NACP without the involvement of independent experts, representatives of professional communities, or the public.
“The presentation focused mainly on technical aspects, while the key part concerning the regulation of lobbying in the program is completely absent. None of the speakers were presented as experts on lobbying, and the relevant topics were not included in the content of the presentations. This means that one of the most sensitive and controversial topics of the future Anti-Corruption Strategy was not even brought up for public discussion,” she said.
According to Tsymbalenko, “the event (presentation of the strategy – IF-U) looked more like a short internal presentation of the NACP’s position than a full-fledged consultation as required by the principles of transparent rule-making.”
“The NACP’s disregard for proposals from professional associations specializing in lobbying is also unacceptable. In particular, the National Association of Lobbyists of Ukraine (NALU) has repeatedly approached the NACP with a proposal to work together on establishing a lobbying institution in the country. The lack of any response from the NACP not only demonstrates disregard for the interests of the professional community, but also poses a serious reputational risk for an agency that declares openness, accountability, and integrity,” said Tsymbalenko.
“In modern democratic practices, lobbying is seen as a tool for preventing political corruption. It allows influence on government decisions to be brought out of the shadows and ensures its transparency and accountability. Combining this topic with unrelated blocks creates the risk of its simplified interpretation or a formal approach to important issues, which may devalue the potential of lobbying as a mechanism for the state’s anti-corruption capacity,” she said.
