Ukraine’s Mirror of Progress on the Path to the EU: ALI Presents the Shadow Report

On 23 October 2025, in Kyiv, a coalition of civil society organisations led by the Agency for Legislative Initiatives (ALI) presented the Shadow Report to the European Commission’s 2024 Report on Ukraine. The report covers Chapters 23, ‘Judiciary and Fundamental Rights’ and 24, ‘Justice, Freedom and Security’ — chapters that the European Union considers fundamental to Ukraine’s integration process. The presentation became a platform for open dialogue between government, experts and European partners — about Ukraine’s progress towards EU integration and the challenges that still lie ahead.

The main goal of the Shadow Report is not criticism but to propose a roadmap for strengthening the state on its path to the EU. This was underlined by Svitlana Matviienko, Executive Director of the Agency for Legislative Initiatives: 

“The Shadow Report is not an 'oppositional' document — it is our shared assessment with state institutions, a kind of mirror reflecting Ukraine’s progress towards EU membership. And on this path, civil society remains a reliable partner in advancing reforms.”
Svitlana Matviienko
Executive Director of the Agency for Legislative Initiatives

The document contains more than 500 specific recommendations covering the rule of law, judicial independence, reform of law enforcement agencies, human rights protection and the fight against corruption and organised crime. The practical value of this analytical work was emphasised by Oksana Tsymbrivska, Head of the EU Project Pravo-Justice:

“The Shadow Report not only highlights achievements and challenges — it offers over 500 concrete recommendations this year. I want to thank all coalition members led by the Agency for Legislative Initiatives and the experts involved for producing such a comprehensive document. I am confident it will be practically useful for the state as it continues reforms on the path to the EU.”
Oksana Tsymbrivska
Head of the EU Project Pravo-Justice

The event took place on the eve of the release of the new EU Enlargement Report, in which the European Union will assess Ukraine’s reform progress. As Katarína Mathernová, EU Ambassador to Ukraine, noted, the accession process should be measured not by speed, but by resilience:

“EU accession is not a sprint — it is a marathon, long and, at times, monotonous. We are now at the stage when the negotiation cluster should already be open, because Ukraine is ready, even if we (the EU) are not quite there yet. But we will get there, because I am convinced that Ukraine’s future is inseparable from Europe’s future.”
Katarína Mathernová
EU Ambassador to Ukraine

Taras Kachka, Deputy Prime Minister for European and Euro-Atlantic Integration, stressed in his remarks that cooperation between government, civil society and international partners is the key to reform effectiveness:

“What lies ahead is a routine but crucial phase — less about headlines and more about tangible results.”
Taras Kachka
Deputy Prime Minister for European and Euro-Atlantic Integration

The importance of mutual support between government and civil society was also highlighted by Iryna Mudra, Deputy Head of the Office of the President:

“The preparation of this report by independent experts demonstrates genuine cooperation between government and civil society — and the growing maturity of both. It reflects the civic responsibility of our society and the willingness of the authorities to engage in constructive dialogue.”
Iryna Mudra
Deputy Head of the Office of the President

She added that despite challenges, the President and his team have acted within their powers and at the necessary pace: ‘Over the past year, everything within the President’s powers has moved forward without delay’.

Experts, meanwhile, pointed out that progress in the justice sector remains uneven. Karyna Aslanyan, Head of the ‘Rule of Law’ Area at the Agency for Legislative Initiatives, noted: 

“We have seen real progress — the appointment of new judges, significant advances in competitions and recruitment and efforts to address staff shortages. But every step forward seems to come with a step back — we still face disruptions in the work of judicial governance bodies and the Constitutional Court. The Shadow Report enables us to discuss these challenges openly yet constructively, so that next year we can talk more about progress than setbacks.”
Karyna Aslanyan
Head of the ‘Rule of Law’ Area at the Agency for Legislative Initiatives

Yevhen Krapyvin, Head of the ‘Law and Order’ Area at the Agency for Legislative Initiatives, emphasised the need to ensure the full independence of the prosecution service — a key to fostering a European justice culture:

“The prosecution service is still sometimes described as a law enforcement body, although it is not. The EU accession process — particularly the framework used by the European Commission in its enlargement reports — places the prosecution service within the rule of law and the broader system of justice institutions. This helps to foster a European understanding of the prosecution service as part of the justice system. Establishing genuine prosecutorial independence — both procedural and institutional — remains a key task for the reform ahead.”
Yevhen Krapyvin
Head of the ‘Law and Order’ Area at the Agency for Legislative Initiatives

The Shadow Report is the result of joint work by the Agency for Legislative Initiatives, Transparency International Ukraine, the Human Rights Centre ZMINA, Tomorrow’s Lawyer, Europe Without Barriers, European Pravda and the Ukrainian Bar Association. Its aim is to provide a comprehensive, independent assessment of Ukraine’s implementation of the European Commission’s recommendations, identify reform gaps and outline priorities for the next phase of the country’s movement towards EU membership.

The Shadow Report was prepared by a coalition of civil society organisations led by the Agency for Legislative Initiatives, under a grant provided by the EU Project Pravo-Justice, implemented by Expertise France. The content is the sole responsibility of the authors and does not necessarily reflect the views of the European Union.

Shadow Report on Chapter 23 'Judiciary and Fundamental Rights' and Chapter 24 'Justice, Freedom and Security' of the European Commission’s Report on Ukraine’s Progress under the 2024 EU Enlargement Package:

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