Two Ukrainian non-governmental organizations — "Legal State" and "Stop Parasite" — have published a study analyzing an October 27 statement signed by a number of NGOs urging the Verkhovna Rada to adopt bill No. 15230-d on the Anti-Corruption Strategy for 2026–2030 without changes. The authors of the check compared the signatories with state registries and, according to their data, identified overlaps in leadership, founding, and grant funding among some of the organizations. The material was published with a reference to RBC-Ukraine.
What Exactly the Researchers Checked
According to the authors, the signatories argued in the statement that adopting the document is a condition for Ukraine to receive about 420 million euros under the Ukraine Facility program. A check of the registries showed that 58 signatures correspond to 52 registered non-profit legal entities. Some organizations in the list overlap, and several share common leaders or founders, which, according to the researchers, narrows the actual number of independent entities behind the appeal.
Incomes and Concentration of Funds
According to the study, 41 organizations from the list declared a total income of about 791 million UAH for 2025. At the same time, 568 million UAH — approximately 72% of the total amount — belongs to ten organizations. Among the leaders in income, the authors name DiXi Group (100.8 million UAH), Transparency International Ukraine (88.4 million UAH), the Center for Economic Strategy (67.6 million UAH), DEJURE (53.4 million UAH), and the Anti-Corruption Action Center (51.5 million UAH). Such concentration, in the researchers' opinion, indicates that a significant portion of the declared "public" resource is concentrated in a small number of large structures.
Overlaps in Leadership and Grants
Comparing data on founders, leaders, and participation in grant projects, the authors calculated that the identified ties cover 23 signatories. In addition, it was established that representatives of five organizations from the list participated in the work of expert teams that developed the Anti-Corruption Strategy itself, which they are now publicly calling to adopt. An analysis of funding sources for 2015–2026 showed that some of the signatories received financial support from international donors.
Question Regarding the Public Council at the NAPC
The researchers paid special attention to the Public Council under the National Agency on Corruption Prevention, which also signed the statement. According to the provided data, the current composition of the council has been operating since June 2020, while the legislation provides for a two-year term of office; at the time of the study's preparation, ten out of fifteen members remained on the council. The authors point to this as an additional argument in favor of reviewing the legitimacy of some signatories.
Context: NAPC Position on the Corruption Ranking
Earlier, the NAPC reported that following the past year, Ukraine improved its performance in the Corruption Perceptions Index by one point and ranked 104th out of 182 countries worldwide. Against this backdrop, the published study adds to the discussion on the adoption of the Anti-Corruption Strategy regarding the transparency and independence of the public structures themselves that are initiating the call to parliament.
