NACP’s Anti-Corruption Strategy Needs Open and Transparent Coordination with the Public – UNLA
The process of forming the NACP Anti-Corruption Strategy for 2026-2030 should be carried out in compliance with the principles of openness, transparency and accountability, but these requirements have not been properly met so far. This was stated by Yana Tsymbalenko, the Anti-Corruption Commissioner of the Ukrainian National Lobbyists Association, a member of the UNLA Board of Trustees, in a commentary to Interfax-Ukraine.
According to her, the analysis of the available information shows significant violations during the public discussion of subsection 1.5 of the draft Anti-Corruption Strategy, in particular, the lack of full public consultations.
“Formation of the Anti-Corruption Strategy is a process that directly affects the rules of ethical behavior of officials, prevention of conflicts of interest and standards of transparency of the state. At the same time, we see no evidence of a high-quality and inclusive discussion of the relevant provisions, which calls into question the legitimacy of the entire process,” said Tsymbalenko.
She emphasized that after the publication of the draft strategy, the NACP did not provide any reports on the results of the discussion, did not publish a register of proposals received, and did not present updated versions of the document, taking into account possible public comments.
The expert drew special attention to the formal nature of the event, which, according to the published “Schedule of Public Discussions,” allegedly took place on October 24, 2025. According to her, there are no official announcements of the event, information about invited stakeholders, lists of participants or experts, or information about the preparation of materials for discussion.
“It is particularly significant that lobbying issues were not actually discussed, despite the fact that they are explicitly mentioned in the relevant subsection of the strategy. The presentation was made exclusively by the NACP representatives, without involvement of independent experts, professional communities or representatives of civil society,” emphasized Tsymbalenko.
In her opinion, the event was more of an internal presentation of the NACP’s position than a full-fledged public consultation, as required by the principles of transparent rulemaking. At the same time, the topic of lobbying regulation was not included in the content of the presentations at all, and none of the speakers was declared an expert in this area.
Tsymbalenko also drew attention to the NACP’s ignoring the proposals of professional associations. In particular, the Ukrainian National Lobbyists Association has repeatedly initiated cooperation with the agency to develop the lobbying institution, but has not received any response.
“In democratic practices, lobbying is seen as a tool for preventing political corruption, which allows to bring influence on government decisions out of the shadows and make it transparent and accountable. A formal approach to this topic creates a risk of devaluing its anti-corruption potential,” she summarized.
