The Ministry of Social Policy, in collaboration with the Ukrainian National Lobbyists Association, has identified a corruption risk involving the unlawful influence of lobbyists on ministry employees
Based on the results of a corruption risk assessment, the Ministry of Social Policy, Family, and Unity of Ukraine has included a new corruption risk in its Anti-Corruption Program for 2026–2028: the possibility of illegal influence by lobbyists on ministry employees. The initiative to identify this risk was carried out with the direct participation of the Ukrainian National Lobbyists Association (UNLA).
This was made possible by the establishment, pursuant to Order No. 90 of the Ministry of Social Policy dated March 11, 2026, of a working group to assess corruption risks within the ministry. Yana Tsymbalenko, a representative of the National Association of Lobbyists of Ukraine—a Ph.D. in Public Administration and an associate professor—was included in the working group’s membership, as approved by this order, with her consent.
On March 27, 2026, the Ukrainian National Lobbyists Association submitted a report to the Ministry of Social Policy regarding the identification of the risk of behind-the-scenes influence on decision-making and the need to implement a regulated lobbying mechanism. The ministry’s Corruption Prevention and Detection Division reviewed the information provided as part of the working group’s activities and, based on the results of this analysis, confirmed the validity of the proposal.
As a result, the risk “Possibility of unlawful influence by lobbying entities on employees of the Ministry of Social Policy” has been added to the Ministry’s register of corruption risks, with the following rationale: “Due to the absence of an internal document governing the interaction of ministry staff with lobbyists, there is a possibility of unlawful influence (in particular through deception, bribery, threats, or coercion).”
This risk is listed in item 5 of the risk register (Appendix 3) to the Anti-Corruption Program of the Ministry of Social Policy, Family, and Unity of Ukraine for 2026–2028, approved by Order No. 248 of the Ministry of Social Policy. According to the order, the results of the identification of corruption risks, the likelihood of their occurrence, and their consequences, as well as mitigation measures and implementation stages, are specified in the risk register, which is an integral part of the program.
The sources of risk have been identified as the lack of adequate internal controls and potential misconduct by certain officials. Measures to mitigate these risks include the development of an internal document outlining the mechanisms for interaction between Ministry of Social Policy employees and lobbyists, as well as the conduct of training sessions for staff on anti-corruption legislation, conflicts of interest, integrity, and ethics.
Consequently, following discussions with the Ukrainian National Lobbyists Association, the Ministry of Social Policy, Family, and Unity of Ukraine officially recognized for the first time—as part of its departmental anti-corruption program—the risk of unlawful influence by lobbyists on ministry staff and committedto develop an internal regulatory mechanism for such interactions. This decision reflects a general trend toward the introduction of transparent and regulated lobbying procedures in the activities of Ukraine’s government agencies.
