Politically Neutral Civil Service: Human Capital Driving Reform or a Vulnerable Link in Public Administration?

The functioning of the civil service can be broadly divided into two interrelated dimensions:

  • the role of the civil service in society (practical implementation of tasks and functions of the state);
  • civil service management processes (the mechanisms governing the working conditions of civil servants).

The human capital of the civil service, working conditions, and the organisational structure of state authorities directly affect the quality of state functions and determine the role the civil service plays. This means human capital can become one of two options:

  1. a driver of positive change — when civil servants possess the necessary expertise, experience, and ability to implement new policies, digital solutions, and European governance standards, while the organisational structure of state authorities aligns with specific sectoral needs. In such cases, the responsibilities of each authority are clearly defined, vertical and horizontal coordination between them is strong, and continuity is ensured even during justified institutional transformations;
  2. a factor of stagnation — when civil servants face a lack of motivation, political pressure, inadequate remuneration, limited opportunities for professional growth, high staff turnover, or corruption risks. Under these conditions, the organisational structure of public administration is often fragmented and misaligned with current challenges and results in blurred institutional competencies, overlapping responsibilities, or accountability gaps.

The quality of state functions directly depends on how well the civil service is organised and managed, as well as on the level of training, motivation, and support of civil servants. State functions shape the requirements for the civil service — its workforce, structure, professional standards, and management principles. Civil service management should flexibly adapt to evolving state functions to ensure their effective implementation. 

Thus, these dimensions are interdependent and should be considered in public administration reform processes. 

The current composition of the civil service has been shaped by three key factors:

Power transition, organisational and functional shifts (2019)

Following the 2019 presidential and early parliamentary elections, Ukraine experienced a sweeping change in political leadership at all levels. This triggered turbulenceResolution No. 829 of the Cabinet of Ministers of Ukraine dated 2 September 2019 marked the beginning of turbulence in the system of central executive authorities. within the system of central executive authorities (CEAs), altering their coordination mechanism, redistributing competencies, and prompting structural changes in ministerial staff. Amendments to civil service legislation simplifiedLaw of Ukraine No. 117-IX dated 19 September 2019 ‘On Amendments to Some Laws of Ukraine on Restarting Power’ (effective as of 25 September 2019). both hiring and dismissal procedures. It became possible to sign contracts for civil service positions (categories ‘B’ and ‘C’) without a competitive selection process. Additionally, a mechanism was introduced for the politically unmotivated dismissal of senior officials, while competitive selection procedures for these roles were dismantled. Such sweeping changes intensifiedStatistical data on the quantitative composition of civil servants for 2019 is not available on the NAUCS website, but the relative data for the first quarter of 2020 show staff turnover due to the reorganisation of agencies, with 29,428 vacant positions at the end of the first quarter of 2020 (73 in category ‘A’, 7,460 in category ‘B’, and 21,895 in category ‘C’), the number of dismissals was 11,826 (14 in category ‘A’, 3,011 in category ‘B’, and 8,801 in category ‘C’), the number of appointments was 9,181 (20 in category ‘A’, 2,165 in category ‘B’, 6,996 in category ‘C’). Interdepartmental migrations in the first quarter of 2020 covered 5,421 persons appointed to positions by transfer (8 — category ‘A’, 1,243 — category ‘B’, 4,170 — category ‘C’). staff turnover.

The new political leadership created legal grounds to recruit a new, loyal team. At the same time, the simplified competition procedures revealed a shortage of qualified civil service candidates willing and able to undergo the previously required stages of the civil service selection process.

The COVID-19 pandemic (2020–2021)

In response to the COVID-19 pandemic, the government introduced quarantine measures, and Law No. 117-IX suspended civil service competitionAccording to paragraph 8 of Section II ‘Final Provisions’ of the Law of Ukraine dated 13 April 2020 No. 553-IX ‘On Amendments to the Law of Ukraine “On the State Budget of Ukraine for 2020”’, it is established that temporarily, for the duration of the quarantine and for 30 days from the date of its cancellation, the provisions of the Law of Ukraine ‘On Civil Service’ and the Law of Ukraine ‘On Central Executive Authorities’ regarding the conduct of competitions for civil service positions and appointments to civil service positions based on the results of the competition shall be suspended.. An alternative hiring mechanism was introduced for exceptional cases related to fulfilling public functions during quarantine, involving interviews with authorised officials, including remote formats such as videoconferences. Contracts were limited to two months after the end of quarantine, leading to mass appointments of individuals without civil service experience8,281 people with no work experience were appointed to civil service positions, with the highest number in the first quarter before the quarantine was cancelled — 2,441..

In February 2021, Law No. 1285-IX reinstatedAccording to the Law of Ukraine dated 23 February 2021 No. 1285-IX ‘On Amending Certain Laws of Ukraine to Resume Competitions for Public Service Positions and Other Public Service Issues’ (which came into force on 6 March 2021), it has been established that: 1) competitions for positions held by individuals with whom contracts for civil service have been concluded for the duration of the quarantine period shall be announced within six months from the date of entry into force of this Law in accordance with the order in which contracts for civil service for the relevant positions were concluded; 2) contracts for civil service during the quarantine period shall remain in force until the appointment of a candidate to a civil service position based on the results of a competition, but for no longer than nine months from the date this Law comes into force. competitive hiring starting in August that year, with the possibility of extending existing contracts signed during quarantine for up to nine months after the law took effect. The government instructed ministries to limit contract extensions and relaunch competitions. This partially restored merit-based hiring (at least legitimising prior non-competitive appointments), though some exceptions remained, particularly regarding contract extensions and, consequently, the tenure of civil servants hired without competition. 

Overall, the simplification of competition procedures following the power transition and the suspension of competitions during quarantine enabled the influx of new people loyal to the political leadership and a rapid staffing of newly created ministries without competitive hurdles.

Full-scale Russian aggression against Ukraine (since 2022)

The introduction of martial law in Ukraine profoundly impacted civil service operations. Law No. 2259-IX established special provisions for the operation of state authorities, including appointments to positions without competitive selection. The war has also imposed severe financial constraints on central and local executive authoritiesIn accordance with resolutions of the Cabinet of Ministers of Ukraine No. 245 dated 10 March 2022 and No. 401 dated 1 April 2022, expenditures and lending from the general fund of the state budget allocated to central and local executive authorities have been reduced., further destabilising the civil service system.

The first months of the war were marked by a massive outflow of personnelIn 2022, 30,440 people resigned from civil service, in 2023 — 40,193, in 2024 — 37,673, and in the first half of 2025 — 19,049 people. from the civil service. Actual hiring for civil service positions only resumedAccording to data from the Report on the quantitative composition of civil servants, as of 15 May 2022, no appointments to positions had been made, but there had been a staff turnover. Since the beginning of 2022, 5,971 civil servants have resigned, including 901 since 15 April 2022. Staff turnover exceeded appointments to positions in 2022 by 3,674 people. This trend continued in 2023. in June 2022 under budgetary restrictions and without competitive procedures.

Appointments made without competition during martial law, combined with staff shortages due to mobilisation, temporary displacement, including abroad, and subsequent resignations, negatively impacted the quality of the civil service workforce. Many new hires lacked prior experience and needed time to get up to speed and adapt to the differences between the private sector and civil service. However, this measure allowed the government to maintain operations during wartime. 

Ukraine’s professional civil service currently faces a series of systemic problems that undermine its ability to conduct evidence-based policymaking and effectively monitor policy implementation, including:

  • frequent changes in the structure of central executive authorities (reorganisation, liquidation, changes in mandates and coordination mechanisms), which destabilise their operations. These changes lead to staff turnover, reduced productivity, loss of institutional memory, and a decline in work dynamics;
  • erosion of meritocracy in civil service selection due to the suspension of competitive procedures during martial law;
  • lack of a unified methodology for assessing candidates’ suitability for civil service positions under martial law (each institution conducts evaluations at its own discretion);
  • lack of clear legal safeguards protecting civil servants from politically driven dismissals;
  • underdeveloped HR tools for onboarding and adaptation to help new hires (or those returning after long absences) realise their professional and personal potential and integrate effectively into the team;
  • performance evaluations of civil servants are often superficial, failing to provide career growth opportunities and incentivise professional development.

The 2023 SIGMA Monitoring Report highlighted most of these systemic challenges. Throughout 20232024, the European Commission repeatedly emphasised key problems affecting the civil service in Ukraine: the failure to uphold merit-based selection, the underdevelopment of human resource management, and the ineffective regulation of the remuneration of civil servants. In response, the Ukraine Facility Plan for 2024–2027 (under Component I) outlines a priority reform agenda in these areas to serve as the foundation for improving the public administration system in Ukraine.

The Public Administration Reform Roadmap also provides a set of measures aimed at achieving strategic outcomes in the areas of ‘Civil Service and Human Resource Management’ and ‘Accountability’. These aim to build a capable, professional, and motivated civil service, optimise organisational structures, and strengthen accountability.

The Public Administration Reform Strategy for 2022–2025 (hereinafter — the Strategy) sets out three key reform goals, including the establishment of a professional and politically neutral civil service that prioritises the interests of citizens.

Within the areas of ‘Professional Civil Service and Human Resource Management’ and ‘Effective Administration’, the Strategy identifies several tasks aimed at achieving the expected outcomes, specifically:

  1. attracting highly qualified specialists to strengthen the civil service by ensuring fair and transparent selection based on merit, achievements, and equal treatment of candidates;
  2. revising requirements for forming the Senior Civil Service Commission and competitive selection committees in state authorities to improve the quality of civil service selection procedures;
  3. improving the organisation and operations of central executive authorities, including refining coordination mechanisms, optimising organisational structures, clearly defining and distributing functions and responsibilities, eliminating overlap, and introducing accountability for performance results.

State of Play and Progress of Reform

As of 2025, progress in building a professional and politically neutral civil service in Ukraine remains uneven across different areas. According to the European Commission, the most notable achievements have been made in reforming the remuneration system, while human resource management lags behind. The selection process for civil service positions remains the most problematic area. The ongoing full-scale war has significantly impacted these processes, slowing or halting procedures that were underway before 2022. 

In several briefs, the Agency for Legislative Initiatives has outlined the reform progress in various areas and issues unresolved within the Strategy implementation. 

Government and parliamentary legislative proposals (draft laws No. 13478 and No. 13478-1) aim to address some of these issues, including:

  1. introducing new concepts and related procedures into the Law of Ukraine ‘On Civil Service’: adaptationThe process of familiarisation, adaptation and social integration of newly appointed civil servants in a state body to the content and conditions of official activities in the state body and the team, based on the gradual acquisition of new professional knowledge and skills, learning the strategic goals and objectives of the state body, becoming familiar with the team and joining the organisational culture of the state body (adaptation period — from 1 to 4 months). For persons appointed to category ‘B’ civil service positions for the first time, adaptation is mandatory. For others — at the discretion of the head of the civil service., internal competitionThe selection of candidates for civil service positions in a state body from among the civil servants of that body is carried out in order to quickly and effectively fill civil service positions in the state body., newly appointed civil servantAn individual appointed to public service for the first time, or a public servant appointed to another position in public service in one or another state body., candidate and personnel reserveThe candidate reserve includes individuals who, during the competition, are included in the overall ranking of candidates for civil service positions. The personnel reserve is formed from candidates for civil service positions in categories ‘B’ and ‘C’, whom the appointing authority may redesignate as winners of the competition (deferred right).;
  2. clarifying requirements for the formation and membership of the Senior Civil Service Commission, its functions, and safeguards against interference with its activities;
  3. refining requirements for the organisation and conduct of competitions for civil service positions, with an emphasis on achieving gender balanceIn order to ensure gender balance in a civil service authority, affirmative action may be taken to give preference in the selection of the winner of a competition to a candidate of the gender that is underrepresented in that civil service authority within the job category, provided that the candidates who have scored the highest total number of points in the overall ranking have equal professional competence.;
  4. enabling career advancement for civil servants based on their professional competence, performance evaluation results, and diligent fulfilment of their duties by allowing them to occupy higher positions within the same category and institution;
  5. clarifying requirements for performance evaluations: tasks and performance indicators should reflect the employee’s role in achieving institutional goals; a re-evaluation procedure is introduced for poorly rated employees.

These draft laws introduce an algorithm for resuming competitive selectionFor category ‘A’ — from 1 June 2026, the deadline for announcing competitions is 9 months; for category ‘B’ — from 1 July 2026, the deadline for announcing competitions is 12 months; for category ‘C’ — from 1 September 2026, the deadline for announcing competitions is 18 months. for civil service positions held by individuals appointed without competition during martial law. 

If martial law ends or is lifted before 1 June 2026, the process of announcing competitions for civil service positions will begin immediately, with no further delays envisaged. 

The draft laws also set a deadlineFor categories ‘A’ and ‘B’ — 18 months from the date of resumption of competitions; for category ‘C’ — 24 months from the date of resumption of competitions. for how long civil servants appointed without competition may retain their positions.

However, an extension may be granted, provided that the civil servant appointed without competition meets the legally established requirements for the position and continues workingFor category ‘A’ — at least one year at the time of resumption of competitions for this category of positions and at least one positive or excellent rating based on the results of the annual performance appraisal; for categories ‘B’ and ‘C’ — at least 6 months at the time of resumption of competitions for the respective categories of positions. in the respective state authority.

This algorithm aims to protect the civil service from a staffing crisis that could arise once competitive selection resumes, while also retaining experienced professionals (individuals who, although appointed to senior civil service positions or reinstated to the civil service without a competitive procedure, took their positions based on their professional merits). 

Problems in Implementing the Reform

The processes of reforming public administration remain inconsistent, raising several personnel-related issues.

Staff Turnover

Experiments with restructuring the system of central executive authorities are ongoing, highlighting the lack of a coherent strategic vision for the system’s architecture and a clear division of roles and powersThe Cabinet of Ministers adopted a number of decisions on the reorganisation of central executive authorities: it renamed ministries, liquidated several of them and transferred functions, particularly in the areas of social policy, economy, ecology, defence and reintegration.. These processes destabilise the system, dragging it into prolonged legal and organisational procedures linked to the liquidation or reorganisation of legal entities. This negatively affects the human capital of the civil service, contributes to chronic instability, and complicates proper staffing, particularly at middle and senior levels.

Over the years of implementing the Strategy, staff turnover has not decreased to the planned levels and, as of the second quarter of 2025, stood at 12.4%The calculation considers the ratio of the number of dismissed employees to the actual number of civil servants.. Another noteworthy figure is the vacancy rate, which reached 19.6%The calculation considers the ratio of the number of vacancies to the total number of civil servants. by the end of the same period. 

Political Neutrality vs. Political Bias 

The absence of clear legislative protections against politically motivated dismissals remains one of the most vulnerable spots of the civil service. Following the 2019 government reshuffle, based on Law No. 117-IX, state secretaries of ministries and heads of central executive authorities, whose work is coordinated by the government directly or through respective ministers (Category ‘A’ civil service positions), remain at the mercy of political figures, namely the Prime Minister or ministers. 

The state secretary of a ministry is the highest-ranking civil servant within that ministry, accountable and subordinate to the minister. State secretaries are appointed by the government for a five-year term, with the possibility of reappointment. 

Heads of central executive authorities are appointed by the Cabinet of Ministers of Ukraine.

Appointments to these positions are made through competitive selection conducted by the Senior Civil Service Commission (hereinafter — the Commission) in accordance with the Law of Ukraine ‘On Civil Service’. 

However, since 29 September 2019 (the effective date of Law No. 117-IX), the Commission (like any competition commission within a state authority) no longer selects a single winner but instead identifiesPrior to the adoption of Law No. 1285-IX of 23 February 2021, the number of candidates for one position selected by the Commission or the competition commission in a civil service authority was higher — up to five persons. the top candidates for each position (up to three per vacancy), based on their overall ranking. The final decisionPrior to the adoption of Law No. 117-IX, in accordance with the Law of Ukraine ‘On Central Executive Authorities’, it was stipulated that: 1) the State Secretary of the Ministry, whose main tasks include ensuring stability and continuity in the work of the Ministry, is appointed by the Cabinet of Ministers of Ukraine upon the recommendation of the Senior Civil Service Commission for a term of five years with the right of reappointment; 2) the head of the central executive authority, whose activities are supervised and coordinated by the Cabinet of Ministers through the relevant minister, and their deputies are appointed and dismissed by the Government on the recommendation of the Senior Civil Service Commission. on the winner rests with the appointing authority or the head of the civil service. 

Winning a competitive selection for a civil service position is not enough — a candidate should also ‘please’ the appointing authority. This undermines the essence of a competitive selection, even despite the efforts of the National Agency of Ukraine on Civil Service (hereinafter —NAUCS) to ensure transparency by publishing the video recordings of interviews for Category ‘A’ positions on its YouTube channel. This approach creates opportunities for pre-selected candidates, who would not be able to win in a fair competition, to be appointed to top positions.

Moreover, the laws of Ukraine ‘On Civil Service’ and ‘On Central Executive Authorities’ contain discrepancies, particularly in defining the number of candidates the Commission must submit to the appointing authority for selecting the head of a CEA. According to the Law ‘On Central Executive Authorities’, the Commission submits up to five candidates for government consideration. However, recent amendments to the Law ‘On Civil Service’ overlooked this provision.

Additionally, the Law ‘On Central Executive Authorities’ allows dismissals at the request of the Prime Minister or the relevant minister, without requiring any justification. This opens the door to politically motivated dismissals of high-ranking civil servants.

In practice, state secretaries of ministries are often replaced alongside (or even more frequently than) their ministers. For instance, over the past five years, the Ministry of Culture (in all its variations) has had four state secretaries (A. Bidenko, Y. Dul, Y. Leshchuk, O. Kurochenko). None completed the legally mandated five-year term (though the current one still has a chance). Such practice prevents state secretaries from fulfilling one of their core function — ensuring stability and continuity within the ministry. Instead of being a symbol of institutional resilience and a guarantor of state policy continuity, this position increasingly becomes a dependent element of political expediency, undermining the effectiveness of ministerial operations and eroding its strategic function.

As of today, no legislative initiatives have been proposed to revise this flawed mechanism. This likely indicates that the current political leadership finds such a model convenient, as it retains levers of influence over staffing decisions, bypassing competitive selection.

Recommendations

In recent years, Ukraine’s civil service system has faced serious challenges that have significantly impacted staffing policies, appointment and dismissal mechanisms, as well as the stability and professionalisation of the state apparatus.

While some reform successes are evident, creating a truly professional and politically neutral civil service remains a complex task. Achieving this requires coordinated efforts at all levels of public administration and depends on a range of factors — legislative, institutional, personnel-related, and political.

A paradox of civil service reform lies in the fact that civil servants themselves shape policies in this area. They deeply understand existing problems, systematise them, and draft proposals in the form of regulatory legal acts. Yet final decisions rest with political leaders, who change regularly, each bringing their own vision of priorities and directions of the reform. As a result, reform loses consistency, and its strategic orientation shifts, making it difficult to achieve long-term goals such as professionalisation and depoliticisation of the civil service.

Thus, civil servants are simultaneously the most valuable asset and the most vulnerable link in public administration reform. They provide stability, expertise, and institutional memory, but remain dependent on political decisions, which often prevents the full and consistent implementation of the reform.

One of the critical future tasks is to eliminate factors that create excessive dependence of the civil service on political figures. This requires strengthening the institutional autonomy of civil servants, ensuring the stability of their status, improving competitive procedures, and protecting them from politically motivated appointments and dismissals. To achieve this, the following steps are necessary:

Introduce coordinated amendments to the Laws of Ukraine ‘On Civil Service’ and ‘On Central Executive Authorities’, including: 

  • restoring the practice of having the Senior Civil Service Commission and internal competition commissions select the winners for all categories of civil service positions;
  • ensuring that state secretaries fulfil their core function of guaranteeing stability and continuity in the work of ministries, regardless of changes in political leadership. This requires clear legal guarantees protecting them from politically motivated dismissals when a new minister is appointed, thereby strengthening institutional memory and the continuity of policy implementation in their respective areas;
  • providing safeguards against politically motivated dismissals for heads of CEAs.

Introduce a practice of restructuring the CEA system based solely on a functional review of the entire system, identifying all possible alternatives, and providing justification for proposed changes, including financial and staffing resources necessary to implement such transformations. 

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Impact of Civil Servant Dismissals on Public Administration Reform: Judicial Practice

State authorities and local self-government authorities, along with their officials, are obligated to act solely on the grounds of, within the powers of, and in the manner prescribed by the Constitution and laws of Ukraine. 

Under martial law, state authorities continue to exercise the powers granted to them by the Constitution of Ukraine, the Law of Ukraine ‘On the Legal Regime of Martial Law’, and other Ukrainian laws. In other words, their actions must remain within the limits of their powers and comply with the defined functions and procedures. 

The Constitution of Ukraine guarantees the protection of citizens from unlawful dismissal, while the Law of Ukraine ‘On Civil Service’ defines the grounds for termination of civil service, including at the initiative of the civil servant, the appointing authority, or by mutual agreement. Dismissal from a civil service position is also an exceptional form of disciplinary measure applicable only in cases of specific disciplinary offences.

Unjustified dismissals violate the rights of civil servants and, when challenged in court, place an additional burden on the state budget and judicial system. 

Meanwhile, according to the National Agency of Ukraine on Civil Service (hereinafter — NAUCS), cases have been recorded during martial law where appointing authorities have terminated civil service contracts on grounds not stipulated by the Law of Ukraine ‘On Civil Service’.

The following instances of unlawful dismissals have been recorded:

  • due to changes in essential conditions of civil service (without complying with legal requirements, including prior notification of such changes and obtaining a resignation letter, consent to transfer to another proposed position, or agreement to continue service);
  • at the initiative of the appointing authority (under the pretext of staff reductions, changes in structure or staffing schedules, reorganisation of the state authority, or as a disciplinary measure, without observing the legally established procedures and grounds for disciplinary measure);
  • without any reference to the provisions of the Law or the Labour Code of Ukraine regarding the termination of civil service or labour relations.

The SIGMA Monitoring Report notesThe SIGMA Programme conducted a follow-up monitoring assessment (the previous one was carried out in 2018) of Ukraine’s public administration in six sectors defined by the Principles of Public Administration in 2023. The assessment determines the current state of public administration and the improvements required in the framework of Ukraine’s recovery and European integration process. that courts often ‘side with’ dismissed civil servants. However, Ukrainian legislation still fails to provide full protection of the rights of civil servants in cases of dismissal:  

  1. There are no criteria for making individual dismissal decisions in cases of reorganisation.
  2. The law allows dismissal based on a single negative score during annual performance evaluation, which represents a regression compared to 2018.
  3. There are other provisions that create risks for ensuring the right of civil servants to work.

Some unlawfully dismissed civil servants do not pursue legal action to regain their positions.

Reinstating unlawfully dismissed civil servants by court decision constitutes another systemically ignored issue. The law does not define the procedure for state authorities if during court proceedings, the competence or structure of a state authority changes, leading to renaming, restructuring, or eliminating the position, or if other circumstances arise that make immediate enforcement of a court decision and actual reinstatement of an unlawfully dismissed civil servant impossible. As a result, state authorities are forced to comply with the court decision only formally, often reinstating employees outside the official staffing table. This practice undermines the very idea of judicial protection, devalues court rulings, and leaves civil servants in legal limbo.

Enhancing guarantees against unjustified dismissals of civil servants remains one of the key directions of Ukraine’s European integration reforms in public administration. This reform aligns with European standards, particularly the OECD/SIGMA Principles of Public Administrationwhich aim toPrinciple 8e stipulates that civil servants may be dismissed or demoted only on the basis of impartial, legally defined criteria, in accordance with due process and subject to judicial oversight.:

  • protect civil servants from political or arbitrary pressure;
  • ensure stability and professionalism in the public sector;
  • increase trust in the civil service by enhancing transparency and accountability.

Strengthening protections against unjustified dismissals of civil servants is a core objective of the Strategy for Public Administration Reform in Ukraine for 2022–2025 (hereinafter — the Strategy) under the ‘Professional Civil Service and Human Resource Management’ pillar. Its goal is to continue building a professional, ethical, and politically neutral civil service and local self-government service focused on protecting the interests of citizens.

One of the indirect indicators to track progress toward these goals is the reduction of staff turnover across all categories of civil service positions to 10% by 2025. 

State of Play and Progress of Reform

Government initiatives to improve the procedure for terminating civil service include:

  • Draft law No. 6496 (31 December 2021), which proposed updating the procedures for entering, serving, and leaving civil service, optimising the consequences of competitive recruitment for civil service positions, and improving the application of disciplinary measures. The Government withdrew this draft law in 2024.
  • Draft law No. 13478 (15 July 2025), which also aimed to improve the procedure for terminating the civil service. On 17 July 2025, the newly formed Cabinet of Ministers withdrew it following the government’s resignation.

Currently, the alternative draft law No. 13478-1 (16 July 2025), prepared by Members of Parliament, is under consideration. It does not differ from the withdrawn government draft in terms of civil service termination.  One of the improvements proposed by recent legislative initiatives is a change in the approach to using the results of annual performance evaluations as grounds for dismissing civil servants. If a civil servant receives a negative assessment for the first time, a reevaluation can be conducted at least three months later, giving them a proper opportunity to improve and demonstrate progress.

Thus, the outcome of the reevaluation becomes decisive:

  • a positive evaluation means retaining the position;
  • a second negative evaluation may lead to dismissal.

This approach enhances the fairness of evaluations, provides civil servants with a chance to correct their performance, and aims to guarantee the protection of their labour rights. 

Unlike the current regulation, which only allows reevaluationSection ‘Appealing Assessment Outcomes’ of the Procedure for Evaluating Results of the Civil Servants’ Service, approved by Resolution of the Cabinet of Ministers of Ukraine No. 640 dated 23 August 2017 (as amended by Resolution of the Cabinet of Ministers of Ukraine No. 591 dated 10 July 2019). if a civil servant appeals a negative annual assessment, the new approach introduces automatic reevaluation. This avoids unnecessary bureaucratic procedures, such as filing and reviewing complaints or potentially challenging its outcome in court and reduces workplace conflict by ensuring that a civil servant receiving a negative evaluation is not formally forced into a dispute with management. As a result, the risks of conflict escalation and legal disputes are reduced, allowing the civil servant to focus on improving their performance instead of engaging in lengthy appeal procedures.

Additionally, this proposal reinstates the practice of mandatory reevaluation, which was abolished in February 2020. Previously, a reevaluation had to be conducted no earlier than three and no later than five months after a negative assessment was issued. In such cases, within five working days of receiving the negative assessment, new tasks and key performance indicators were set, tailored to the scheduledBy Resolution of the Cabinet of Ministers of Ukraine No. 58 dated 5 February 2020, amendments were made to the Standard Procedure for Evaluating Results of Civil Servants’ Service, in particular, the section ‘Reevaluation’ was excluded. reevaluation date.

Problems in Implementing the Reform

Despite years of implementing the Strategy, staff turnover has not been stabilised. Moreover, an analysis of court cases involving dismissals from civil service reveals systemic issues connected with challenging decisions on dismissal from civil service. 

An analysis of the efficiency of justice administered by the Cassation Administrative Court within the Supreme Court, based on cassation appeals in cases concerning dismissal from civil serviceCivil service — activity in state political positions, in state collegial bodies, professional activity of judges, prosecutors, military service, alternative (non-military) service, other state service, patronage service in state bodies, service in the authorities of the Autonomous Republic of Crimea, local self-government bodies (paragraph 17 of part one of Article 4 of the Code of Administrative Procedure of Ukraine). (excluding cases related to lustration), shows that in 2022, the court reviewed 5,561 appeals (out of a total of 6,916 such cases under consideration); in 2023 — 6,365 appeals (out of 7,286); and in 2024 — 7,035 appeals (out of 8,386). 

There is a clear trend toward an increase in the number of cassation appeals filed with and reviewed by the Supreme Court. This adds pressure to the judicial system and the state budget, as the court sometimes rules in favour of compensation for material and moral damages caused by an official found responsible for unlawful dismissals of a civil servant.

According to the NAUCS statistics, the number of dismissals of civil servants from 2022 through the first quarter of 2025 remains high: 

  1. 30,440 persons (including 5,957 of category ‘B’) in 2022;
  2. 40,193 persons (including 7,985 of category ‘B’) in 2023;      
  3. 37,673 persons (including 6,462 of category ‘B’) in 2024;
  4. 9,216 persons (including 1,541 of category ‘B’) in the first quarter of 2025. 

As of 31 March 2025, cumulative data published on NAUCS’s official website show that over 9,000 civil servants have been dismissed in Ukraine since the beginning of 2025, including more than 1,500 of category ‘B’.

By the end of the first quarter of 2025, the number of vacant civil service positions in Ukraine exceeded 30,000, with more than 8,000 of category ‘B’, which represents 17% of the total staff for this category (over 46,000 positions). 

This significant number of vacancies is partly linked to Russia’s armed aggression against Ukraine, which forced many civil servants to change their place of residence (relocating within the country, moving abroad, being trapped in occupied territories, serving in the Armed Forces of Ukraine, going missing, being captured or killed, etc.). However, staffing issues in the public sector had already existed before the full-scale invasion.

Statistical data on the number of unlawfully dismissed civil servants reinstated in their positions are unavailable. Similarly, no data are provided on the grounds for their dismissal. Data on job vacancies indicate a shortage of skilled professionals in civil service positions, especially in category ‘B’, highlighting the need for human resources. A comprehensive analysis of the available statistical data may point either to an increase in unlawful dismissals or a growing number of court cases where civil servants challenge their dismissals as unlawful. 

An analysis of Supreme Court case lawThe following criteria were used to select legal proceedings: 1) period: from 1 January 2022 to 31 May 2025; 2) category of civil servants: civil servants holding category ‘B’ civil service positions (heads and deputy heads of state authorities whose jurisdiction extends to the territory of the Autonomous Republic of Crimea, one or more regions, the cities of Kyiv and Sevastopol, one or more districts, districts in cities, cities of regional significance; heads of the civil service in the aforementioned state authorities; heads and deputy heads of structural subdivisions of state authorities, regardless of the level of jurisdiction of such state authorities); 3) category of proceedings: administrative proceedings concerning reinstatement at work (in a civil service position) and decisions of the Supreme Court rendered in such proceedings in favour of a dismissed civil servant. The analysis did not consider proceedings concerning dismissal in connection with the vetting of public officials (lustration). confirms a recurring trend in rulings on illegal dismissals of civil servants. A significant portion of these rulings concerns violations of legislation related to changes in the essential conditions of civil service, in particular:

  • failure by the appointing authority or head of the civil service to offer the civil servant another equivalent (in exceptional cases, lower-ranking) position matching their professional training and competencies;
  • a formal attempt by the appointing authority to comply with the Law of Ukraine ‘On Civil Service’, rather than a genuine intention to retain the civil servant.

Another substantial share of Supreme Court rulings concerns dismissals initiated by the appointing authority under the pretext of staff reductions, changes in structure or staffing schedules, or the reorganisation of a state authority.

When the court establishes that a dismissal violated legal procedure, it orders the civil servant to be reinstated in their previous position. However, mechanisms for reinstating civil servants by court order are lacking, and legislative proposals do not address this legal gap.

Although one of the objectives of the Strategy is to strengthen safeguards against the unjust dismissal of civil servants, its implementation plan lacks specific measures directly aimed at tackling this issue. The focus remains on general tools for assessment, selection, and professional development, while legal protections for civil servants remain secondary.

Recommendations

Unlawful dismissals of civil servants undermine public trust in state institutions, risk losing highly qualified personnel (particularly category ‘B’ civil servants) and erode institutional memory, reduce the prestige of civil service and the appeal of the state as a competitive employer, may lead to a decrease in the overall talent pool of the public administration system, and risk demotivating both current civil servants and potential candidates for these positions. The integrity and professionalism of civil servants are essential for delivering quality services to citizens and ensuring effective governance. Further progress in public administration reform concerning unlawful dismissals requires the following measures:

  1. strengthening personal accountability of appointing authorities and heads of civil service for complying with legal requirements when making decisions related to the termination of civil service (at the employer’s initiative);
  2. establishing a legally defined mechanism for reinstating unlawfully dismissed civil servants by court decision. Such a mechanism should outline the employer’s obligations and provide a clear procedure in cases of structural changes within a state authority (e.g., offering an equivalent position with similar functional responsibilities);
  3. conducting awareness-raising campaigns for civil servants about their rights during the dismissal process to prevent and/or challenge unlawful dismissals;
  4. organising training programmes for HR personnel in state authorities on the legal grounds and procedures for terminating civil service;
  5. implementing regular monitoring of case law, particularly Supreme Court decisions, to ensure their consideration in applying civil service legislation and to support its further improvement.  

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Public Consultations as a Tool for Public Participation in Governance

Public participation is an integral part of the democratic policymaking process. Engaging stakeholders in discussions on pressing policy issues, including draft regulatory legal acts, allows them to voice their opinions, provide recommendations or comments, and fosters effective dialogue between state authorities and society. One of the OECD/SIGMA Principles of Public Administration stipulates that policy development should involve active consultations with key external and internal stakeholders, as well as the public.

Currently, the primary legal frameworkVarious legal acts also stipulate consultations in one form or another. For example, the Law of Ukraine ‘On the Principles of the State Regulatory Policy in the Sphere of Economic Activity’ contains the obligation to publish each draft regulatory act in order to receive comments and proposals from individuals, legal entities and their associations. Environmental impact assessment reports, draft professional standards, etc., also require public discussion. regulating consultations conducted by executive authorities is the Procedure for Conducting Public Consultations on the Development and Implementation of State Policy (hereinafter — the Procedure), approved by the Cabinet of Ministers.

Under this Procedure, the executive authority organising consultations should draft an annual tentative plan for their implementation, considering:

  • key objectives outlined in the Programme of Activities of the Cabinet of Ministers of Ukraine;
  • the State Programme for Economic and Social Development of Ukraine;
  • the legislative work plan and other strategic documents;
  • results of previous public consultations.

However, an analysis of tentative plans of ministries reveals a lack of a uniform approach to their formation. For instance, the tentative plan of the Ministry of Defence of Ukraine does not include any draft regulatory legal acts, instead proposing only general issues of state policy for public discussion, such as providing housing for service members or anti-corruption restrictions during military service under martial law. A similar pattern is observed in the tentative plan of the Ministry of Justice of Ukraine.

The Procedure stipulates that public consultations may take three formats: public discussions, electronic consultations (a direct form), and public opinion surveys (an indirect form). Ministries tend to use only one format. For instance, the tentative plan of the Ministry of Digital Transformation of Ukraine includes only electronic public consultations. 

The Procedure also allows for consultations on issues not covered by the tentative plan to be initiated by the public itself, provided that the relevant proposals are submitted to the public council or directly to the executive authority. 

Public discussions are mandatory when a draft regulatory legal act concerns citizens’ vital interests or affects the legal status, funding, or activities of NGOs. 

In the 2023 SIGMA Monitoring Report, public consultations regarding state policy received a low score on the relevant indicatorThe value of this indicator is one point on a five-point scale., largely due to insufficient regulation of the process and the absence of a requirement for mandatory public consultations on all draft laws and regulatory acts approved by the government.

Limiting the range of issues that must be subject to public discussionThe Procedure defines ten categories of draft regulations for which public consultations are mandatory, including issues related to the socio-economic development of the state, the implementation and protection of citizens’ rights and freedoms, the fulfilment of their political, economic, social, cultural and other interests, etc. allows authorities to decide at their own discretion which projects require consultations. This approach turns what should be a tool for public engagement in decision-making into a mere formality by narrowing opportunities for citizens to participate in discussions on issues that may significantly impact society, weakening the effectiveness of consultations, and reducing the transparency of policymaking.

An analysis of explanatory notes to government draft laws shows that ministries that did not hold public consultations neither justify such decisions nor even mention them.

While the Procedure sets a two-week deadline for publishing consultation results, it ties this to the date a relevant decision is made following the discussions, without setting a clear timeframe for when the decision must be made. This creates a risk of delays in both decision-making and report publication.

Some authorities fail to comply with the reporting requirements set out in the Procedure. They either publish reports that omit information on whether public proposals were considered and how they influenced the final decision, or do not publish reports at all. Without transparent reporting on the impact of public consultations on policymaking, this process of engaging citizens in state governance risks becoming a box-ticking exercise.

The Public Administration Reform Strategy for 2022–2025 (hereinafter — the Strategy) provides for a review of procedures and workflows in state authorities, with a particular focus on public consultations on policy development and implementation, as well as monitoring and controlling the execution of administrative decisions. Auditing these processes will help identify systemic negative trends and make these processes more user-friendly for citizens, particularly through the use of modern digital solutions. 

The Strategy sets out tasks aimed at improving the process of public consultations on issues related to the development and implementation of state policy. 

The Strategy Implementation Action Plan includes two components directly related to public consultations:

  • supporting the Draft Law of Ukraine ‘On Public Consultations’ (No. 4254 of 23 October 2020) in the Verkhovna Rada of Ukraine;
  • ensuring the reengineering of the process of public consultations on the development and implementation of state policy.

State of Play and Progress of Reform

In June 2024, the Verkhovna Rada adopted the Law of Ukraine ‘On Public Consultations’ (Law No. 3841-IX), which will take effect 12 months after the termination or cancellation of martial law. 

Law of Ukraine ‘On Public Consultations’

Law No. 3841-IX establishes the principles and procedure for conducting public consultations. Specifically, the consulting authority must publish a consultation document on the online platform for public consultations and/or on its official website, while also informing relevant stakeholders. After the consultations, the body must publish the submitted proposals, analyse them, and prepare and publish a report on the consultation results. The consultation period cannot be shorter than 15 working days, and the final report is published within 30 working days after the end of the consultation. 

Law No. 3841-IX defines an exhaustive list of consultation formats:

  1. electronic consultationsPublication of the consultation paper on the online platform for public consultations and/or on the official website of the authority conducting public consultations.;
  2. targeted consultationsSending consultation paper to stakeholders, conducting surveys and questionnaires.;
  3. public discussionsHolding public events (roundtable meetings, hearings, conferences, focus groups, online and video conferences)..

Public consultations can be held in multiple formats simultaneously; however, according to Law No. 3841-IX, online consultations are mandatory. Public discussions are also obligatory for some authorities in specific cases, such as when a draft act affects constitutional rights, freedoms, and obligations of citizens or impacts the environment, ecological, biological, or genetic safety.

The Law also clearly defines the liability of state authorities that attempt to evade public consultations or violate the procedure. The adoption of the act in violation of the Law may serve as grounds for its cancellation or invalidation by a court. 

Thus, one of the measures outlined in the Action Plan is fully implemented. 

Between its first and second readings in Parliament, Draft Law No. 4254 lost several crucial provisions. Specifically, the adopted Law No. 3841-IX does not mandate public consultations for MPs or parliamentary committees. While MPs may hold public consultations before submitting a draft law to the Verkhovna Rada, and committees may do so after a draft law passes its first reading, the President is not mentioned among the authorities holding public consultations at all. 

UnlikeThe Procedure stipulates that consultations are held on issues related to the socio-economic development of the state, the implementation and protection of citizens’ rights and freedoms, and the fulfilment of their political, economic, social, cultural and other interests, i.e. not necessarily only on legal acts. the current Procedure, Law No. 3841-IX does not allow civil society to initiate consultations. Stakeholders are limited to submitting proposals on the subject of consultations to the relevant authority, in line with legal requirements. 

Unlike the current Procedure, Law No. 3841-IX somewhat narrows the scope of public consultations, limiting them to the preparation of draft programme documents and regulatory legal acts, leaving out current issues related to the implementation of state policy.

Also, the requirement for mandatory public consultations covers numerous regulatory legal acts of varying legal force and significance. This creates additional workload for state authorities and raises the risk of them being unable to manage the volume of consultations, particularly when it comes to processing received proposals effectively within the timeframes set by the Law, which may undermine the very essence and purpose of this procedure. 

Law No. 3841-IX states that consultation reports by consulting authorities should include only generalised summaries of received proposals and generalised information about their acceptance or rejection, with justification for the decisions made. However, the Law fails to define how generalised the received proposals may be (their number, substance, etc.), leaving authorities free to report in an arbitrary manner and depriving stakeholders of clear information on whether their proposals were considered.

The Laws of Ukraine ‘On Public Consultations’ and ‘On Lawmaking’ are interconnected, as public consultations are an important element of law-making, although the latter somewhat downplays their role. These laws also use different terminology (for example, the term ‘programme document’), which creates inconsistencies and calls for harmonisation.

Special attention is needed to harmonise the principles underlying law-making activities and the conduct of public consultations. The Law of Ukraine ‘On Lawmaking’ statesArticle 45 of the Law of Ukraine ‘On Lawmaking’. that public consultations are held to implement the principles of openness and transparency in law-making. However, the list of law-making principles defined in this very Law does not actually includeArticle 3 of the Law of Ukraine ‘On Lawmaking’. these concepts. It is Law No. 3841-IX that establishesArticle 4 of the Law of Ukraine ‘On Public Consultations’. the principles of participation, openness, and transparency, though only in the context of public consultations.

Another measure provided for in the Plan for reengineering the process of conducting public consultations is directly linked to the implementation of Law No. 3841-IX. Yet, according to the final and transitional provisions of this Law, the government is required to adopt and/or update regulations arising from this Law only six months after the termination or cancellation of martial law to ensure that the relevant regulations come into force simultaneouslyParagraphs 1 and 4 of Section IV ‘Final and Transitional Provisions’ of Law No. 3841-IX. with the Law. Until then, the existing requirements for conducting public consultations, regulated by the current Procedure, remain in effect.  

Online Consultations

Law No. 3841-IX also provides for the creation of an online public consultation platform for interaction with citizens and civil society institutions. The Cabinet of Ministers is tasked with determiningArticle 14 of Law No. 3841-IX. the operation procedure, functional requirements, and technical administrator of the platform.

The introduction of a unified platform is seen as beneficial, as it would allow stakeholders to access consultations across all state authorities and local government authorities. It would also simplify the identification and verification of stakeholders and help standardise the process of submitting proposals. Currently, ministries and other central executive authorities publish information about public consultations and reports on their results on their own websites. 

However, the future of this platform remains uncertain. Law No. 3841-IX stipulates that until the technical capacity for holding electronic consultations on a specialised online platform is created, such consultations are to be carried outParagraph 2 of Section IV ‘Final and Transitional Provisions’ of Law No. 3841-IX. on the websites and/or social media pages of the consulting authorities. Additionally, the Law does not set a deadline for creating the online platform, specify when it should become operational, or clarify what exactly is meant by ‘creating technical capacity’. As a result, there is a risk that the ‘creation of technical capacity’ could be delayed, blocking the launch of the platform for an unknown period.

The VzaemoDiia portal was initially expected to include a public consultation module, but it currently functions only as a platform for conducting competitions within NGO projects and for submitting petitions to local self-government authorities. 

In December 2022, changes were made to the Strategy that narrowed the scope of one of the tasks under the ‘Effective Governance’ pillar by removing the provision on implementing a public consultation module on an online platform for interaction between executive authorities, citizens, and civil society institutions. This suggests that implementing online consultations is currently not a priority in public administration.

Recommendations

Public consultations serve as a tool for public participation in shaping and implementing state policy and decision-making. To ensure effective communication between consulting authorities and stakeholders, the following measures are needed:

  1. making public consultations mandatory for MPs and Verkhovna Rada committees, since MPs initiate most draft laws;
  2. setting clear deadlines for creating an online public consultation platform;
  3. ensuring analytical and reporting components in the consultation process: public consultations should not just collect proposals from stakeholders but also analyse them properly. State authorities must review received proposals, justify decisions to accept or reject them, and publish reports on the results of consultations;
  4. harmonising Law No. 3841-IX with the Law of Ukraine ‘On Lawmaking’;
  5. making necessary amendments to Law No. 3841-IX and the Law of Ukraine ‘On Lawmaking’ before they come into force, which would facilitate proper implementation of the processes they regulate.

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Professional Training for Civil Servants as a Guarantee of High-Quality State Policy

Public participation is an integral part of the democratic policymaking process. Engaging stakeholders in discussions on pressing policy issues, including draft regulatory legal acts, allows them to voice their opinions, provide recommendations or comments, and fosters effective dialogue between state authorities and society. One of the OECD/SIGMA Principles of Public Administration stipulates that policy development should involve active consultations with key internal and external stakeholders, as well as the public.

Professional trainingProfessional training — the acquisition and improvement of professional knowledge, skills and abilities that ensure the appropriate level of professional qualification of a civil servant for their professional activities (paragraph 9, part 1, Article 2 of the Law of Ukraine ‘On Civil Service’). for civil servants is both their right and their duty.

Civil servants play a leading role in ensuring the formulation and implementation of state policy, so improving the quality of their professional training is a key factor in modernising the public administration system. Based on continuous analysis of policy and law enforcement practices, they generate proposals for further development of state policy, formalise the ideas and strategic plans of the state’s top leadership in documentary form (draft legal acts and other acts) and ensure the practical implementation of adopted decisions. 

Therefore, the more motivated and professionally competent civil servants are, the higher the effectiveness of state policy and the likelihood of achieving the desired results. 

The basis for changes in the professional training of civil servants is currently contained in the Strategy for Public Administration Reform in Ukraine for 20222025 (hereinafter — the Strategy), which identifies several problems in professional training, such as:

  • the system for forming and placing state orders for the training and advanced training of civil servants and local government employees is ineffective, which hinders the development of the postgraduate education market and creates unequal conditions for educational institutions of different forms of ownership;
  • mechanisms for determining professional training needs do not meet current needs and do not contribute to the proactive development of the competencies of civil servants and local government employees;
  • a significant proportion of civil servants and local government employees are unable to fully meet their training and advanced training needs;
  • the content of training programmes does not correspond to the real challenges and needs of civil servants and local government employees;
  • insufficient funding for the system of training and advanced training;
  • the professional training system does not provide timely preparation for future challenges and strategic priorities in public administration development.

One of the tasks of the Strategy in the area of ‘Professional Public Service and Human Resource Management’ is to create a modern, comprehensive, mobile and flexible professional training system with a developed infrastructure, effective management and adequate resource potential. 

The task for implementing the reform of the professional training system includes the following components:

  • identifying professional training needs;
  • forming, placing and executing state orders;
  • encouraging people to improve their professional competence;
  • ensuring the functioning and development of the market for the provision of educational services in the field of professional training;
  • monitoring and evaluating the quality of training.

The indicators used to assess progress in achieving results in this area of the Strategy are:

  • percentage of civil servants who have undergone advanced training out of the total number of civil servants: in 2022 — 55%; in 2023 — 60%; in 2024 — 65%; in 2025 — 70%;
  • the share of government spending on advanced training of civil servants and the wage bill: in 2022 — 1%; in 2023 — 1.5%; in 2024 — 1.75%; in 2025 — 2%.

The Strategy provides for the professional development of local government employees, but does not contain indicators for tracking progress in the training of this category of civil servants. The Law of Ukraine ‘On Service in Bodies of Local Self-Government’, adopted in 2023 (to enter into force after the abolition or termination of martial law), contains more specific provisions on the professional development of such persons, unlike the current Law.

State of Play and Progress in Implementing the Reform

The active phase of reforming professional training for civil servants lasted from 2018 to 2022 and began with the Government’s approval of the Concept for Reforming the System of Professional Training of Civil Servants and, subsequently, the Action Plan for its implementation. The National Agency of Ukraine on Civil Service (hereinafter — NAUCS) played a key role in these processes as the main developer of legislative changes in the area of ‘Professional Public Service and Human Resource Management’. 

In 2023, the NAUCS Coordination Council approved the Strategy for the Development of the Professional Training System for Civil Servants until 2027, which contains a detailed description of the problems identified in the professional training of civil servants. In the same year, the Government approved the Action Plan for Professional Training until 2027.

Continuous professional training of civil servants and analysis of their training needs are based on the European Principles of Public Administration developed by OECD/SIGMA and is in line with the Public Administration Reform Roadmap within the framework of Ukraine’s European integration aspirations.

Of the whole range of activities in the field of professional training for civil servants, the following are worth noting:

The professional training of civil servants has, since 2025, been conducted under the educational and professional Master’s degree programme in speciality D4 ‘Public Governance and Administration’Until 2025, the area of study ‘Public Management and Administration’ was identified by code 281 and belonged to field 28 ‘Public Management and Administration.’ within the field ‘Business, Administration and Law’, as well as under general (specialised) professional (certificate) or general (specialised) short-term advanced training programmes. Professional training can also be carried out through self-education or internships. According to the NAUCS annual monitoring studies on the achievement of the Strategy’s indicators: 

  1. in 2022, 56,737 civil servants underwent professional training (33%The NAUCS analysed information on 99% (170,152) of civil servants out of the actual number (171,469) as of 1 January 2022. of those actually working, which is 22% less than the expected result);
  2. in 2023 ― 74,417 civil servants (46%The NAUCS analysed information on 98% (161,826) of civil servants out of the actual number (165,422) as of 1 January 2023. of those actually working, which is 14% less than the number planned in the indicator);
  3. in 2024, 63,053 civil servants (43%The NAUCS analysed information on 99.7% (147,750) of civil servants out of the actual number (148,209) as of 1 January 2024. of those actually working, which is 22% less than the expected result).

Based on the results of professional training, civil servants are awarded credits under the European Credit Transfer and Accumulation System (hereinafter — ECTS). During the year, a civil servant must earn at least one ECTS creditRegulations on the system of professional training for civil servants, heads of local state administrations, their first deputies and deputies, local self-government officials and local council deputies: Resolution of the Cabinet of Ministers of Ukraine No. 106 of 6 February 2019..

Civil servants undergo advanced training through general or special programmes approved by the NAUCS. Advanced training can take various forms — full-time, distance learning or blended learning. As of 1 July 2025, the Register of Advanced Training Programmes approved by the NAUCS contains 2,149 programmes aimed at developing various competencies of civil servants. Compared to 2021–2023, the Register has been updated in terms of both the areas covered by the programmes, taking into account the current needs of participants (e.g. regarding the specifics of European integration processes), and the list of education providersFor example, through programmes funded by international technical assistance..

The selection of programmes for each civil servant is based on the results of an annual assessment of their performance, which takes into account the tasks and key indicators of performance, efficiency, and quality of service, as well as self-assessment of their competencies and professional needs. According to analytical materials from the NAUCS, in recent years, civil servants have expressed a need to improve their professional knowledge, particularly in the areas of European and Euro-Atlantic integration, cybersecurity, digital literacy, corruption prevention and integrity, gender equality, etc.

In accordance with the Action Plan, the NAUCS conducts research on the state of the professional training system based on specific indicators. Thus, according to data on the monitoring of the quality of advanced training, more than half (54.8%) of the respondents participating in professional training (32,060)A total of 32,060 people participated in the survey, including 29,153 civil servants, which represents 18% of the actual number of employees (158,091) as of 30 July 2024. are completely satisfied with the match between supply and demand (in terms of training topics) in the market for advanced training education services; one third of respondents (34.7%) are partially satisfied; in total, 89.5% of respondents. 

A significant step forward in ensuring the accessibility of training for civil servants is the activity of the NAUCS in creating (2020) and continuously improving the Knowledge Management Portal. This digital product allows civil servants to familiarise themselves with the list and conditions of available educational programmes (using convenient filters), register for them and view information about completed programmes. In turn, education providers, lecturers and human resource management services can take advantage of other functionalities. Thanks to this Portal, local government employees also have the opportunity to improve their qualifications through general and specialised programmes in accessible formats.

In 2022, the High School of Public Governance (hereinafter — the High School) was established as a new type of postgraduate education institution aimed at the professional development and advanced training of civil servantsPersons holding political office, civil servants, heads of local state administrations, their first deputies and deputies, local government officials, and local council members.. In fact, this institution was formed by renaming the Ukrainian School of Governance, and therefore, at the time of its launch, it already had a developed institutional and material base. The High School has nine centres responsible for different areas of activity (e.g. development of management competencies; professional development in European and Euro-Atlantic integration; learning the official languages of the European Union; digitisation of professional training and development, etc.).

According to the High SchoolThe data were obtained from annual reports on the performance of the High School by summing up the number of civil servants of central executive authorities (hereinafter — CEAs) and local executive authorities (hereinafter — LEAs) who upgraded their qualifications in the respective year: in 2022 — 23,028 employees of CEAs and 702 employees of LEAs; in 2023 — 20,683 employees of CEAs and 1,110 employees of LEAs; in 2024 — 25,188 employees of CEAs and 2,932 employees of LEAs., it provided advanced training for 23,730 civil servants in 2022; in 2023 — 21,793; in 2024 — 28,120.

Educational services in the field of professional training for civil servants are provided by the High School of Public Governance, educational institutions, companies, institutions and organisations of any form of ownership that carry out educational activities in the field of professional training, international or foreign institutions and organisations that implement relevant programmes, international technical assistance projects and others registered on the Knowledge Management Portal. As of July 2025, the Portal contains information on 175 education providers.

Since 2022, the selection of education providers for the professional training of civil servants under the state order of the NAUCS has been carried out automatically form on a competitive basis using the capabilities of the Knowledge Management Portal. According to information from the NAUCS, three such competitive procedures have already been conducted. On 12 July 2025, the NAUCS announced another competitive selection of educational service providers.

Reform Issues Remaining Unresolved

Despite obvious progress, there are a number of problematic issues in professional training reform that require special attention:

  1. Over the years, funding for professional training and advanced training of civil servants has remained uneven and insufficient. The level of actual spending on training civil servants remains extremely low compared to the planned results. In 2022, government spending on training amounted to only 0.02% of the annual wage bill; it was 0.03% in 2023, and only in 2024 did it reach the pre-war level of 0.05% (2021). As an alternative to state funding, civil servants can undergo training at the expense of local budgets, international technical assistance, or at their own expense. The savings made by governmental authorities on the training of their employees may be linked to the desire to allocate these funds to remuneration and thus minimise staff turnover. However, this does not reduce the burden on the state budget. In particular, in 2024, the NAUCS spent over UAH 50 million on the advanced training of 47,925 employees, including 45,421 civil servants (i.e., 72% of the total number of civil servants who underwent training).
  2. There is a limited number of free advanced training programmes for this many civil servants. According to the Knowledge Management Portal, there are 570 free advanced training programmes (all types combined) for civil servants, but only 12 of them are open for registration. Some programmes have restrictions on participation by target groups (e.g. category A, human resources management employees, remuneration group, etc.). In practice, civil servants are actually forced to ‘hunt’ for free programmes, and if they fail, they have to pay for training out of their own pockets. There is another way out of this situation: in order to obtain the required number of ECTS credits, civil servants choose any available free courses, regardless of their relevance or practical value. And then the process of professional training and advanced training becomes formal.
  3. The relevance and timeliness of the topics offered by education providers for advanced training still do not meet expectations, especially given the specifics of certain areas of state policy. As already mentioned, one-tenth of the respondents participating in professional training believe that providers do not offer the necessary topics for advanced training.
  4. During 2021–2024, and especially under martial law, the remote format of advanced training for civil servants remains a priority (within 93%). At the same time, participants note that training activities take place mainly during working hours, and they often have to combine participation in the training process with the performance of their professional duties. Management does not exempt such employees from work for the duration of the training. As a result, civil servants are forced to either perform work tasks outside of working hours or be less than fully engaged in training, which undermines their effectiveness.
  5. The remote format of training can potentially affect its quality, as noted in the Strategy itself. Factors such as rolling blackouts, instability or lack of access to the Internet hinder civil servants in acquiring knowledge. In addition, during the monitoring of the quality of advanced training for 20212023, the NAUCS found that 27% of civil servants surveyed (8,851 people) did not have the technical capabilities for training (computer equipment with the necessary accessories — camera, speaker, or headphones).
  6. Even high achievements in acquiring new knowledge and applying it in practice are, in most cases, not a guarantee of higher pay or career advancement for civil servants. It all comes down to the need to complete an individual professional development programme for the relevant year.
  7. The current Law No. 5499-VI limits the list of providers of NAUCS state-funded education services to educational institutions and scientific institutions owned by the state or municipalities, which makes it impossible for education providers of other forms of ownership to participate in the competition. As a result, the potential for competitiveness and quality development of the professional training system is reduced. In 2021, Parliament adopted as a basis government draft law No. 5467 in the first reading, which was supposed to resolve this issue, but in 2023, this draft law was withdrawn from consideration.

As a result, the problematic issues described above have a negative impact on the motivation of civil servants to participate in professional training and, in the broader perspective, on the quality of state policy as a whole. 

Recommendations

The professional training of civil servants needs to be further developed with due regard to the following measures:

  1. Increasing the number of training programmes available to civil servants free of charge, in particular by expanding the capabilities of the High School.
  2. Timely updating of the list of topics for special programmes for civil servants, taking into account changes in legislation, trends in state policy and the conditions of martial law.
  3. Conducting explanatory work and joint meetings between the NAUCS and heads of governmental authorities on: 1) the need to increase the volume of such authorities’ own expenditures, as well as to attract other sources of funding for employee training; 2) providing civil servants with the opportunity to improve their qualifications (in accordance with an approved individual professional development programme) while taking a break from their official duties, within the time frame provided for in the training programme, in particular by reducing the workload of civil servants for the period of advanced training, so that such training is not merely formal; 3) providing civil servants with the necessary technical equipment (at least for the period of training), especially those working in territorial offices.
  4. Gradual annual increase in state funding for professional training of civil servants under the relevant NAUCS programme in the State Budget of Ukraine.
  5. Amending Law No. 5499-VI, in particular regarding the possibility for educational institutions, companies and organisations of various forms of ownership to participate in competitions for the provision of educational services under the state order of the NAUCS. Such changes will contribute to increased competition between education providers and, accordingly, to an improvement in the quality of professional training programmes for civil servants. At the same time, civil servants themselves will have more opportunities to meet their educational needs owing to a wider choice of training programmes and education providers.

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Implementation of the Public Sector Remuneration Reform

Remuneration is one of the most problematic aspects of civil service. Unsatisfactory salary levels and a non-transparent mechanism for incentive payments are among the key demotivating factors for civil servants, which not only reduce their interest in delivering results but also call into question the rationale for continuing a career in civil service.

According to data from the National Agency of Ukraine on Civil Service (NAUCS), the outdated and inefficient remuneration system had 11 components, with base salaries accounting for only 39–49% of total pay. About 50% of payments were variable: bonuses, allowances, and incentive payments, the amount of which was typically determined by managers, often based not on performance but on subjective judgement and personal attitudes towards employees.

NAUCS surveys conducted between 2019 and 2023 to determine the level of organisational culture in civil service recorded a low level of satisfaction among civil servants with their salaries (21–22%). Only about 60% of civil servants agreed that bonuses depend on the quality of their work, while roughly half believed that performance evaluation is based onAnalytical paper based on the results of interviews with civil servants on organisational culture, 2019–2021, National Agency of Ukraine on Civil Service; and Analytical paper on the study of organisational culture, ‘Public Service in Ukraine: Your Point of View’, National Agency of Ukraine on Civil Service, 2023. actual results.

Internal tension was further exacerbated by the remuneration of civil servants in positions of Reform Support Specialists (RSS)According to the Concept for the Introduction of Positions for Reform Specialists, positions for reform specialists are civil service positions in categories ‘A’, ‘B’ and ‘C’ with job responsibilities that include preparing and implementing reforms in relevant areas (identifying problems, preparing proposals and action plans to address them, preparing draft legislation, organising and participating in the implementation of these action plans, evaluating the results of their implementation, performing other analytical functions), as well as performing the main tasks related to strategic planning of the activities of a state authority, ensuring the formation and/or implementation of state policy in the relevant areas, to which special conditions of remuneration apply within the general system of remuneration of civil servants., whose special working conditions entitled them to a monthly allowance for high-priority tasks. 

Until 2022, this allowance was funded by donor programmes without burdening the government payroll budget. Starting from 1 January 2022, funds for RSS salaries were included in the payroll budgets, intensifying tension and ultimately leading to the liquidation of directorates in most ministries. 

Thus, a comprehensive strategic solution was needed to address the duality of remuneration (RSSs vs. other civil servants) and to introduce a transparent, easy-to-administer remuneration model that would ensure:

  • a fair distribution of remuneration under the principle of ‘equal pay for equal work’ (both within a single government body and between other bodies for similar positions);
  • the competitiveness of the public sector compared to the private sector.

The remuneration system reform is one of the key initiatives to reboot public administration and is being implemented under the Strategy for Public Administration Reform in Ukraine for 2022–2025, specifically under the pillar ‘Professional Public Service and Personnel Management’.

The Strategy outlines the following tasks regarding motivation and remuneration:

  • introduction of a civil service position classification system;
  • implementation of a comprehensive reform of the remuneration system, including increasing the fixed component while limiting the variable one, reducing the number of salary elements, eliminating pay gaps, and bringing salaries closer to the levels available in the private sector;
  • prevention of salary reductions for civil servants, in particular, for specialists involved in implementing the public administration reform (RSSs).

A key indicator for tracking progress in implementing this part of the Strategy is the share of civil service positions covered by the new classification-based remuneration system: 1% in 2022–2023, 75% in 2024, and 90% in 2025.

The communication measures of the Strategy include an information campaign to raise awareness of civil servants of the remuneration system reform and its position classification approach.

The reform aims to optimise state budget expenditures during wartime and fulfil the EU integration commitments of Ukraine. Its implementation aligns with the European Principles for Public Administration developed by OECD/SIGMA and is a requirement of the Ukraine Facility programme, under which Ukraine receives up to €50 billion from the EU by 2027. 

State of Play and Progress in Implementing the Reform

As of year-end 2024 and mid-2025, the reform has shown some positive progress.

In March 2025, the Parliament adopted the long-awaited Law of Ukraine ‘On Amendments to Certain Laws of Ukraine Regarding the Introduction of Unified Approaches to the Remuneration of Civil Servants Based on Position Classification’ (Law No. 4282). 

At the time Law No. 4282 took effect, an interim reform had already introduced remuneration adjustments based on position classification under the State Budget Laws for 2024 and 2025. The classification of positions was conducted according to the Catalogue of Standard Positions and Qualification Criteria, approved by the Parliament in October 2023.

The Parliament and NAUCS ensured the timely preparation of regulatory acts necessary to implement Law No. 4282, which entered into force together with the Law:

  • Resolution of the Cabinet of Ministers of Ukraine No. 369 of 1 April 2025 ‘Certain Issues of Civil Service Position Classification’, which: 1) updates approaches to defining role functions, agreeing on classification results, and interacting with NAUCS; 2) approves an updated Catalogue of Civil Service Positions with clarified and supplemented standard role descriptions; 3) introduces a procedure for reclassification; 4) provides for the decentralisation of the position classification approval in local state administrations. 

This government decision is expected to ensure greater consistency and transparency in assessing the functional workload of each position. 

  • NAUCS Order No. 45–25 of 7 April 2025, which: 1) transfers the authority to approve the results of position classification in local state administrations to the NAUCS territorial bodies; 2) introduces an important restriction: an NAUCS territorial body is not allowed to process documents from the territory within which it operates to ensure objectivity and avoid potential conflicts of interest. 

Since April 2025, the NAUCS has actively worked to clarifyOn 11 April 2025, a seminar entitled ‘Classification of civil service positions: novelties in legislation in 2025’ was held; an online course entitled ‘Classification of civil service positions’ is now available on the StudyiЯ High School of Public Governance platform for training, in particular, individuals involved in organising and conducting the classification of civil service positions in state authorities. Source: Classification of Civil Service Positions 2024: Current Status, Challenges and Prospects, National Agency of Ukraine on Civil Service. May 2025. P. 45. the new legislative provisions. In 2022–2024 and the first quarter of 2025, the classification of civil service positions was conducted by government bodies in accordance with the Algorithm for Classifying Civil Service Positions Under Martial Law and the Catalogue of Standard Civil Service Positions, approved by the Parliament in 2023. By mid-2024, 146,333 positions across over 4,000 government bodies were classified (74% of the 198,638 total positions according to staffing tables). 

The comprehensive reform of the remuneration system has been implemented in most government bodies, ensuring predictability and transparency of the remuneration system and simplifying the process of payroll budget planning. Key changes include a reduced number of salary components and limited discretionary powers of managers in establishing allowances, particularly for work intensity and high-priority tasks. As a result, the salary structure has been balanced, with a target ratio of 70% of fixed pay and 30% of variable pay.

In 2024, the average salary of civil servants showed an upward trend compared to 2023. The salary for category ‘B’ positions in district state (military) administrations amounted to UAH 22,210 in 2024, compared to UAH 13,781.2 in 2023. For similar positions in first-tier government bodiesOn 11 April 2025, a seminar entitled ‘Classification of civil service positions: novelties in legislation in 2025’ was held; an online course entitled ‘Classification of civil service positions’ is now available on the StudyiЯ High School of Public Governance platform for training, in particular, individuals involved in organising and conducting the classification of civil service positions in state authorities. Source: Classification of Civil Service Positions 2024: Current Status, Challenges and Prospects, National Agency of Ukraine on Civil Service. May 2025. P. 16. of the first jurisdiction (e.g., the Secretariat of the Cabinet of Ministers of Ukraine, the Secretariat of the Ukrainian Parliament Commissioner for Human Rights, the Ministry of Economy of Ukraine), the average salary in 2024 was UAH 49,955 (compared toSummarised statistical report on the results of monitoring the remuneration of civil servants in 2023, National Agency of Ukraine on Civil Service, 2024. P. 22. UAH 35,698.47 in 2023).

In January 2025, the Accounting Chamber of Ukraine launched an important compliance audit for further reform monitoring, titled ‘Reforming the Remuneration System in Public Administration’, covering the period from 2023 through the first half of 2025 and lasting until August 2025Work plan of the Accounting Chamber of Ukraine for 2025, approved by the decision of the Accounting Chamber dated 19 December 2024, No. 58–5 (as amended). Clause 1.26.. Auditors are examining the implementation of measures aimed at increasing the competitiveness of salaries of civil servants, eliminating pay disparities in state authorities, and strengthening the role of the fixed component while limiting the variable one. In particular, they are conducting a comparative analysis of the salaries paid to civil servants for two periods: 2023 (before the reform) and 2024 (the first year of its implementation).

Challenges in Reform Implementation

Most planned measures remain at the previous implementation stage, with only minor improvements. Overall, the objectives set out in the Strategy have so far been only partially achieved, in particular:

The process of classifying civil service positions was hindered by an actual ‘refusal’ to carry it out in some government bodiesAdministration of the State Special Transport Service, Antimonopoly Committee of Ukraine, Secretariat of the Verkhovna Rada of Ukraine, Economic Security Bureau of Ukraine, State Customs Service of Ukraine, State Tax Service of Ukraine, Ministry of Internal Affairs of Ukraine, Ministry of Defence of Ukraine, National Securities and Stock Market Commission, National Energy and Utilities Regulatory Commission, National Agency on Corruption Prevention, National Anti-Corruption Bureau of Ukraine, Specialised Anti-Corruption Prosecutor’s Office.. The reasons for this include both the prolonged process of adopting and signing Law No. 4282 and potential losses in salary levels after the classification of positions. Specifically, the average salary in government bodies that carried out the classification of positions in 2024 was UAH 37,249, compared toStatistical report on the results of monitoring the remuneration of civil servants in 2024. May 2025. pp. 16, 20. the average salary under the old system — UAH 59,078. This is due to structural differences and varying approaches to bonuses and incentive payments, as defined by special legislation regulating salaries in the respective government bodies.  

As of early 2025, the number ofSome state authorities did not provide the NAUCS with information on the results of position classification as of December 2024. The State Treasury Service refused to provide information, the Chernihiv Regional State Administration did not provide data in the prescribed manner, and the State Bureau of Investigations, the Foreign Intelligence Service of Ukraine, and the Intelligence Department of the State Border Guard Service of Ukraine provided confidential information. Source: Classification of civil service positions 2024: current status, challenges and prospects. National Agency of Ukraine on Civil Service, May 2025. P. 6. classified positions (over 146,000 civil service positions across more than 3,000 government bodies) remained unchanged from the level recorded in the first half of 2024. 

A significant number of reclassifications of civil service positions were recorded — 1,640. Most often, this was due to changes in the structure, staffing schedule, and functions of the government body (91%), employee requests or other reasons related to appointments/transfers to positions (5%), changes in the payroll fund (3%), or all of these factorsClassification of civil service positions 2024: current status, challenges and prospects, National Agency of Ukraine on Civil Service, May 2025. P. 49. combined (1%). Not all decisions were properly formalised — specifically, 20 reclassifications were conducted in violation of the Algorithm, without a corresponding decision from the authorised body. This practice has led to the lack of up-to-date statistics and the risk of losing control over classification outcomes.

Processing the results of position classification is still carried out manually, slowing down the process and explaining the absence of up-to-date statistics. NAUCS has prepared proposals for the draft terms of reference for developing an information system, ‘Classification of Civil Service Positions’. However, further development and implementation of such a system will require time and financial resources, which are currently limited.

Despite the established formula for distributing salary portions between fixed and variable components at a 70/30 ratio, the actual distribution for classified civil service positions is 85% fixed and 15% variable.

The highest variable salary portionStatistical report on the results of monitoring the remuneration of civil servants in 2024. May 2025. P. 8. is observed in Type 1.3 jurisdiction government bodies (17%), while the lowest is in Type 1.1 jurisdiction bodies (13%).

Along with the overall increase in salaries of civil servants, significant disparities persist within the same category of positions across bodies of different jurisdiction types, as well as between different categories of positions within the same body.

For example:

  • for category ‘B’ positions, the gap in the average salary level between national-level bodies (jurisdiction 1.3) and regional-level bodies (jurisdiction type 2) in 2024 amounted to 27% (compared to 24% in 2023);
  • for category ‘C’ positions, this gap reached 32% in 2024 (compared to 33% in 2023).

Significant pay disparities also exist between categories of positions within the same jurisdiction. In particular, the difference between average salaries for category ‘B’ and ‘C’ positions was:

  • 73% in ministries (jurisdiction 1.2) in 2024 (compared to 33% in 2023);
  • 58% in regional state (military) administrations (jurisdiction 2) in 2024 (compared to 45% in 2023).

The largest gaps were recorded at the central level (jurisdiction 1.1):

  • the difference in salaries between categories ‘A’ and ‘B’ in 2024 amounted to 88% (compared to 112.5% in 2023);
  • between ‘B’ and ‘C’ — 72% (compared toStatistical report on the results of monitoring the remuneration of civil servants in 2024. May 2025. P. 18. Summarised statistical report on the results of monitoring the remuneration of civil servants in 2023, National Agency of Ukraine on Civil Service, 2024. P. 22. 71.7% in 2023).

Such salary disparities complicate the recruitment of highly qualified personnel to the civil service and may also indicate the lack of a comparable level of salaries between the public and private sectors.

The provision of Law No. 4282 regarding the alignment of salary levels in typical civil service positions with salary levels in the private sector in Ukraine will only enter into force on 1 January 2027. As a result, salary planning for civil service positions in 2026 will not account for the principle ofThe principle of competitiveness implies that government agencies offer competitive remuneration to attract highly qualified specialists to the labour market. competitiveness.

Comparing salary levels in the public and private sectors is complex, particularly due to the lack of reliable sources of information on pay levels:

  • official statistics collect data on average salaries by types of economic activity, but do not provide a detailed breakdown by profession or position;
  • commercial job platforms (such as Work.ua, grc.ua, and Jooble) do have some data, but it is not always representative, as it is based on job postings rather than actual payroll records.

Accurate salary comparisons are also hindered by structural differences in remuneration between the public and private sectors, as well as variability in salary levels: in the public sector, they depend on the body and type of jurisdiction, and in the private sector, on the region and type of economic activity.

There is currently no methodology for comparing similar positions in the public and private sectors in terms of functions, responsibilities, and salary levels. Law No. 4282 also does not include provisions for approving such a methodology, which casts doubt on the fairness of civil service salaries and could undermine the future success of the reform.

Following position classification, 88% of government bodies still report a need for additional training for responsible staff. This includesClassification of civil service positions 2024: current status, challenges and prospects, National Agency of Ukraine on Civil Service, May 2025. pp. 45, 52. the need for clarifications regarding legislative changes, practical aspects of reviewing classification results, conducting reclassification, and addressing common mistakes made during this process.

The significant number of reclassifications, combined with legislative changes, underlines the need for better outreach activities regarding the classification of positions. This applies to both HR departments and civil servants whose positions are subject to classification or reclassification.

The lack of complete and reliable information about the composition of the civil service in the Human Resource Management Information System (HRMIS) in government bodies is a major obstacle to implementing the remuneration reform.

Recommendations

The state should become a competitive employer, attracting top talent and motivating employees to achieve results. Successful implementation of the reform requires the following key measures:

  1. Automation of the position classification process remains a priority task. It will ensure transparency of the procedure and enable up-to-date information on its status. This requires assessing the resources needed for software development and launch, training responsible staff to work with the system, and determining sources of project funding.
  2. Improve the classification procedure based on analysis of best practice and international experience, particularly regarding: 1) grouping similar positions into job families with shared tasks and main responsibilitiesFor example, the families of positions ‘information security and cyber defence (12)’, ‘management of information and communication systems (23)’, ‘management of informatisation projects (25)’, whose main functionality involves working with information and communication technologies., while identifying sub-familiesFor example, the family of positions ‘public policy analysis and rule-making (3)’ includes functions that can be divided into a sub-family of positions, in particular, regarding the formation of public policy/strategic planning/conducting legal, scientific and/or professional expertise and preparing conclusions on draft legislation, expertise on adopted legislation. with narrower specialisation; 2) standardising approaches to determining job families for positions with typical functions that belong to the same jurisdiction and type of government bodies, including local-level bodies.
  3. Enhance outreach efforts regarding the procedures for organising and conducting classification and reclassification of civil service positions, as well as implementing and executing measures of the civil service remuneration reform.
  4. Continue addressing significant disparities in salary (grades) between individual positions, job families, and types of government jurisdictions, taking into account state budget constraints.
  5. Ensure a justified and transparent comparison of salary levels for typical civil service positions with salary levels in the private sector in Ukraine by: 1) conducting a pilot comparison of salary levels during the preparation of the draft salary scale for civil service positions for 2026. Independent labour market experts should be involved to ensure impartiality, and the pilot comparison findings should inform the development of the methodology for comparing salary levels for typical civil service positions with those in the private sector; 2) introducing amendments to Part Three of Article 51 of the Law of Ukraine ‘On Civil Service’ regarding the powers of the relevant legislative body to approve such a methodology; 3) approving the methodology under which such a comparison of salary levels will be conducted, starting 1 January 2027Date of entry into force of paragraph six of subparagraph 4 of paragraph 2 of Section I of Law No. 4282.. This approach will facilitate the timely adoption of well-grounded decisions on remuneration, more efficient use of budget funds, and increased trust in the state as a competitive employer.
  6. It is essential to ensure that the future HRMIS information system is capable of administering the modified remuneration system.

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Administrative Procedure in Action: Implementation of the Law of Ukraine ‘On Administrative Procedure’ in the Public Administration System

The introduction of an administrative procedure has long been a necessityThe need to adopt legislation regulating administrative procedures in Ukraine was outlined back in 1998 as a component of the Concept of Administrative Reform, the aim of which is, in particular, to form a system of public administration that meets the needs and demands of the people, to create conditions for the exercise of citizens’ rights and freedoms, and to provide them with a wide range of public and administrative services.. Until 2022, Ukraine remained the only European state without a law on administrative procedure (except for russia, which is not a benchmark for democratic governance). All areas of interaction between the state and citizens or businesses were regulated by different rules (special laws, decrees, instructions, etc.). The introduction of an administrative procedure was driven by the need to address a number of issues, such as:

  • the absence of several important individual rights in relations with public administration (e.g., the right to be heard and to access case materials, the right of an interested party to participate in proceedings, etc.);
  • the dominance of departmental interests and predominantly subordinate regulation of procedures;
  • inconsistent approaches across different areas of public administration;
  • inefficiency of many procedures (particularly appeals) or a complete lack of regulation (e.g., regarding the early termination of administrative acts).

The necessity of adopting and applying the Law ‘On Administrative Procedure’ (LAP) is also driven by the OECD/SIGMA European Principles of Public Administration, particularly Principle 17, which states that the right to good administration is upheld, among other means, through administrative procedure. Full implementation of this Law is a requirement of the European Union, and its swift introduction into the practical activities of civil servants is an important element of the European integration process. The EU emphasised the importance of this step in its annual reports on Ukraine’s progress within the Enlargement Package in 2023 and 2024. The LAP implementation is one of the requirements of the Ukraine Facility Plan for 2024–2027. Its implementation is expected to help reduce corruption risks in public administration, increase public trust in the state, and improve the functioning of the business environment. The introduction of the LAP, modelled after similar acts in other countries, aims to ensure the right to good administration enshrined in Article 41 of the Charter of Fundamental Rights of the European Union and to bring public administration in Ukraine closer to modern European standards and practices.

The implementation of an administrative procedure that is user-friendly and understandable for citizens and businesses is one of the tasks of the Public Administration Reform Strategy for 2022–2025 (hereinafter — the Strategy) under the High-Quality Services and User-Friendly Procedures pillar. Adoption and implementation of the Law ‘On Administrative Procedure’ are defined as priorities for the development of administrative services and procedures.

The key tasks for implementing this area of the Strategy related to administrative procedures are:

  • introducing an administrative procedure and aligning regulatory legal acts with the Law ‘On Administrative Procedure’;
  • conducting training for civil servants and increasing public awareness of a general administrative procedure.

Progress of the reform in achieving these tasks is assessed using the following indicators:

  • the share of draft laws necessary for the implementation of the Law submitted to the Verkhovna Rada of Ukraine: 80% in 2023, 90% in 2024;
  • the share of civil servants who need training on the new principles of administrative procedure and have undergone such training: 20% in 2022, 40% in 2023, 60% in 2024, 80% in 2025.

State of Play and Progress of Reform

The implementation of the tasks outlined in the Strategy began withThe Ministry of Justice worked on draft law No. 3475. Representatives of the Secretariat of the Cabinet of Ministers of Ukraine, ministries, other central executive authorities, the judiciary, experts and specialists from the EU Delegation to Ukraine, the German Foundation for International Legal Cooperation, experts from the SIGMA Programme and the project Support to Comprehensive Reform of Public Administration in Ukraine (EU4PAR). the drafting and adoption of the Law ‘On Administrative Procedure’ on 17 February 2022. The Law was signed by the President in June 2022 and entered into force on 15 December 2023

This event marked the start of the process of aligning existing legislation with the LAP provisionsParagraph 8 of the Final and Transitional Provisions of the Law ‘On Administrative Procedure’.. Upon completion of this harmonisation process, by the end of 2025, the Cabinet of Ministers of Ukraine must inform the Verkhovna Rada of Ukraine about the status of implementation of the Law ‘On Administrative Procedure’. 

Drafting Legislation and Aligning the Existing Laws with the Law ‘On Administrative Procedure’

By June 2023, the government was required to submit proposals to Parliament for aligning legislative acts of Ukraine with the LAP. By December 2023, it was to take measures to adopt and/or update regulatory acts of executive authorities to comply with the new rules, ensuring they took effect simultaneously with the Law ‘On Administrative Procedure’.

To achieve this, experts analysed about 400 laws related to289 days to go: how ministries and government agencies are preparing to implement administrative procedures. Public administration reform. 2023. various aspects of administrative procedures. In October 2023, draft law No. 10161 was registered in Parliament, aimed at aligning legislation with the LAP. A year later, the Verkhovna Rada of Ukraine adopted Law No. 4017, which amended 196 legislative acts. As a result, the 2023 Strategy Implementation Report declared that the target indicator for this task had been achieved. The 2024 Strategy Implementation Report is not publicly available.

The process of harmonising legislation with the LAP is accompanied by several challenges:

  1. As of mid-2025, full implementation of the LAP has not yet been achieved. The European Commission 2024 Report on Ukraine noted that by the end of 2025, Ukraine must achieve full implementation of the Law ‘On Administrative Procedure’, including harmonisation of sectoral and implementing legislation and aligning digital procedures with the Law. However, a number of legislative acts still require alignment with the provisions of the LAP, particularly in the areas of taxation, customs, land regulation, citizen appeals, and administrative offences. Draft laws concerning some of these changes are still awaitingFor example, draft Law No. 11082 ‘On Appeals’ and draft Code of Ukraine on Administrative Offences No. 11386. consideration in Parliament. The government is expected to report on the status of LAP implementation by the end of 2025. Although, there are reasonable doubts that full harmonisation of legislation with the LAP will be achieved within the established timeframe. These doubts are further reinforced by the fact that the Public Administration Reform Roadmap envisions certain steps regarding LAP implementation to be carried out throughout 2026.
  2. Some state authorities are attempting to exempt themselves from the scope of the LAP regulation, arguing that their areas of competence fall under exceptions. The 2023 SIGMA Monitoring Report contains information about initiatives in Ukraine aimed at removing public institutions from the scope of the LAP regulation. In public discourseOne year with the Law ‘On Administrative Procedure’: key findings from experts. Public administration reform. 2024., such attempts have been discussed in relation to the State Environmental Inspectorate, the Antimonopoly Committee, the State Tax Service, and the Ministry of Internal Affairs. These initiatives are not supported by the SIGMA Programme, whose representatives maintain that special legislation (instead of the LAP) should apply only in exceptional cases, justified byPublic Administration in Ukraine: Assessment of Compliance with Public Administration Principles. SIGMA. December 2023. P. 10. the specifics of a particular administrative field. The European Commission expressed similar concernsReport on Ukraine for 2023. European Commission. 2023. pp. 19–20., particularly regarding the State Tax Service. Ukrainian experts share this view, emphasising the need to extend the application of the Law ‘On Administrative Procedure’ to a significant portion of the powers of executive authorities (though certain exceptions should apply depending on the specific functions).
  3. The technical aspect of implementing the LAP in digital procedures requires improvement. Effective application of the LAP requires ensuring proper information interaction between public electronic registers. However, the current system of interaction does not meet the requirements of full interoperability.

Training and Raising Awareness of Civil Servants on the Implementation of the Law ‘On Administrative Procedure’ in Their Respective Authorities

The Strategy stipulates that at least 20% of civil servants requiring training on LAP implementation should complete it each year, with the overall rate reaching 80% by the end of 2025. 

During 2022, 2,168 civil servants and 709 local self-government officials (a total of 2,877 persons) underwentPublic Administration in Ukraine: Assessment of Compliance with Public Administration Principles. SIGMA. December 2023. P. 10. relevant training at the Ukrainian School of Administration and regional professional development centres. The 2022 Strategy Implementation Report claims this indicator was met. However, the report presents the target value and actual performance using different units of measurement. This makes it impossible to clearly determine whether the reported number of trained individuals corresponds to the target of 20% of the total number of civil servants who required such training.

In 2023Report on the implementation in 2023 of the Strategy for Public Administration Reform in Ukraine for 2022–2025. P. 43., the National Agency of Ukraine on Civil Service developed and approved 12 training programmes on administrative procedures for civil servants and local self-government officials. The number of civil servants, local self-government officials, and employees of Administrative Service Centres who underwent relevant training exceeded 4,400 persons. According to the 2023 results, the necessary Strategy performance indicator was achieved (90% reported against the required 40%). This time, the report included the actual number of individuals needing training in 2023. 

Additionally, civil servants can take online courses and training. The Zrozumilo! platform hosts an online course titled ‘General Administrative Procedure’, a handbook for civil servants, and train-the-trainer programmes for offline and online training on a general administrative procedure (60 trainersReport on the implementation in 2023 of the Strategy for Public Administration Reform in Ukraine for 2022–2025. P. 20. were trained by the end of 2023For example, training courses are conducted within the framework of the project Support to Comprehensive Reform of Public Administration in Ukraine (EU4PAR) and the USAID Hoverla project in partnership with the Higher School of Public Governance.).

Also, there is a dedicated information portal that offers answers to over 200 frequently asked questions about applying the LAP and provides document templates, checklists, and other practical materials.

A social media group titled ‘Administrative Procedure: Professional Community’ was created for representatives of state authorities involved in the general administrative procedure and LAP implementation, allowing practitioners and scholars to exchange opinions and experiences regarding LAP application.

Despite satisfactory reporting indicators, certain challenges persist for the effective implementation of the LAP in terms of training: 

  1. Insufficient quality and comprehensiveness of training materials. A survey of central executive authorities (CEAs) on their readiness to apply the LAP, conducted between December 2024 and January 2025, showed that 59% of respondents noted the need for staff training, 40% required assistance in developing templates and standard documents, and 35% needed expert advisory support. Category A civil servants were the most knowledgeable about the provisions of the LAP. Though nearly half of the surveyed Category B and C civil servants had yet to fully understand the details. Respondents indicated the need for additional clarification of the essence of administrative procedure principles, particularly those of proportionality, reasonableness, formality, the presumption of legality of actions, and the requirements of individuals.
  2. Not all civil servants are adequately informed about the LAP implementation in their respective authorities. The CEA survey showed that more than 50% of respondents could not say whether their institution had begun the adaptation of legislation to the LAP, and over 70% were unaware of whether their institutions had identified the list of regulatory legal acts to be aligned with the LAP. This indicates a need to improve institutional awareness and internal communication regarding the implementation of the LAP in central executive authorities.

The survey is not representative (due to uneven distribution of respondents by type and level of state authorities), but it demonstrates general trends in the readiness of civil servants to apply the LAP.

Public Awareness of Administrative Procedures

One of the tasks of the Strategy is to raise citizens’ awareness of the general administrative procedure. However, there are no indicators to track progress on this task. Citizens can participate in training on the Zrozumilo! Platform. In 2024, more than 22,000 persons completed this online course. Also, the information portal contains useful materials explaining the LAP provisions and their practical value for citizens and businesses. Nevertheless, the lack of indicators makes it impossible to assess progress in fulfilling this task. 

Recommendations

The current state of implementation of the Public Administration Reform Strategy for 2022–2025 regarding the enforcement of the Law ‘On Administrative Procedure’ is largely satisfactory, with most tasks either fully completed or in progress. However, further reform efforts require the following measures:

  1. Minimising cases where state authorities are exempt from the Law ‘On Administrative Procedure’, particularly those performing public service functions. The non-application of LAP provisions to certain public institutions sets a precedent that undermines the role of the LAP in the public administration reform. The use of special legislation instead of the LAP may still exist, but additional justification is required on a case-by-case basis.
  2. Ensuring full implementation of the LAP by aligning tax, customs, land legislation, the Law of Ukraine ‘On Appeals of Citizens’, and the Code of Ukraine on Administrative Offences with its provisions and by adopting subordinate regulatory legal acts necessary for the implementation of the LAP and Law No. 4017.
  3. Introducing amendments to current legislation to address the application of the LAP in automated procedures to ensure full realisation of the principles of efficiency and formality, particularly regarding e-interaction between information systems, technical implementation of complex procedural mechanisms (e.g., leaving applications without progress), and applicant access to case files.
  4. Improving the quality of training materials for civil servants undergoing professional development on administrative procedure. Optimisation should focus on:1) clarifying the essence of LAP principles and terminology; 2) resolving potential conflicts between the LAP and special laws; 3) analysing specific practical cases and addressing possible ambiguities in LAP interpretation; 4) technical aspects of using information systems within administrative procedures.
  5. Enhancing awareness among civil servants, particularly categories B and C, regarding the application of LAP provisions.
  6. Intensifying the implementation of the LAP in state authorities, while providing clear guidance to their staff on the essence and algorithm of such implementation.  
  7. Expanding public outreach campaigns to raise awareness about the significance and practical value of the LAP for citizens when applying to state authorities. 

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Digital Transformation of the Human Resource Management System in the Civil Service

Digitalisation of the human resource management system, as a key element of rebooting public administration, is implemented in accordance with the Strategy for Public Administration Reform in Ukraine for 2022–2025 under the area ‘Professional Civil Service and Personnel Management’.

The main objectives of this strategic direction regarding personnel management capacity are:

  • implementation of a Human Resource Management Information System (HRMIS) in state authorities, enabling the collection and analysis of quantitative and qualitative indicators on the representation of women and men in various civil service positions;
  • conducting an analysis of the needs of state authorities in ensuring the necessary number of civil servants with appropriate qualifications to address strategic tasks.

The key performance indicator for these objectives of the Strategy is the share of state authorities that have implemented HRMIS: 25% in 2022, 50% in 2023, 65% in 2024, and 80% in 2025.

Additionally, as part of the communication measures outlined in the Strategy, the implementation of HRMIS is accompanied by the development and introduction of an effective mechanism for internal communication, interaction, and feedback within the civil service. For instance, the National Agency of Ukraine on Civil Service (NAUCS) provides methodological support to HR departments in state authorities, makes inquiries, and conducts surveys. The final output of these efforts includes clarifications and training.

The digitalisation of human resource management aims to address the lack of comprehensive data and analytical information regarding the number of employees in state authorities. Fragmented and limited information on the effectiveness of the public administration system in Ukraine highly complicates the process of optimising the number of employees in executive authorities. While state authorities do have their own personnel management information systems, the information stored in these systems is often insufficiently transparent and does not allow for a comprehensive analysis of the overall human resource management system in the civil service.

The digitalisation of civil service and human resource management is one of Ukraine’s EU integration commitments in the area of public administration reform, which is carried out in line with the OECD/SIGMA European Principles of Public Administration and is also one of the requirements of the Ukraine Facility programme, under which Ukraine will receive up to €50 billion from the EU during 2024–2027.

State of Play and Progress of Reform

From a practical perspective, the reform will result in upgrading all outdated digital HR systems in state authorities (including their interregional and territorial bodies). On the one hand, this will ensure the formation of accurate data on staffing levels in state authorities and enable operational and transparent monitoring of the number of their employees. On the other hand, it will improve the efficiency of decision-making processes related to staffing.

Tools for Addressing Key Issues

The key steps of the reform to ensure the digitalisation of HR management functions in public administration include:

  • implementation of the Human Resource Management Information System (HRMIS) as a centralised database of civil servants and other public sector employees, aimed at automating and digitalising processes related to personnel management functions;
  • operation of the Unified Portal of Civil Service Vacancies (career.gov.ua) as a key platform for posting current job openings in state authorities, providing information on competitive selection procedures, and enabling electronic document submission;
  • use of the Unified State Web Portal of Electronic Services Diia for employment purposes.

Human Resource Management Information System

The HRMIS system was launched on 31 March 2021, with EU support within the Public Finance Management Support Programme for Ukraine (EU4PFM). The share of state authorities that implemented the HRMIS, as a key indicator of the Strategy, has been steadily growing: 67% in 2022Reports on the implementation of budget programmes for 2017–2022. National Agency of Ukraine on Civil Service. (against a target of 25%), 80% in 2023Reports on the implementation of budget programmes for 2017–2022. National Agency of Ukraine on Civil Service. (against a target of 50%), 82% in 2024Reports on the implementation of budget programmes. National Agency of Ukraine on Civil Service. (against a target of 65%), and 87% as of May 2025XXXIV Coordination Council on Public Administration Reform. Public administration reform. (against a target of 80%). According to NAUCS, over 90% of state authorities are expected to be connected to the system by June 2025.

The implementation of the HRMIS information system in state authorities faces several obstacles, including:

  • insufficient material, technical, and staffing capacity of certain state authorities to connect to the system. NAUCS has repeatedly emphasised the shortage of specialists, particularly in system implementation support, cybersecurity, and business analytics, which hinders the scaling of HRMIS adoption;
  • overburdening of HR departments in state authorities due to the duplication of functions for populating the HRMIS and maintaining internal digital HR systems or databases, including in paper format. Although most state authorities are connected to HRMIS, data completeness across functional modules remains insufficient. For instance, the HRMIS Public Portal lacks data on gender, length of civil service, types of positions, and age of employees;
  • insufficient knowledge, skills, and competencies of HR staff in state authorities regarding the use of the HRMIS.

According to an NAUCS study, as of 1 October 2024, 66.4% of surveyed respondents identified HRMIS implementation and operation as their greatest need for methodological support. The most pressing needs for methodological support among respondents from state authorities where the HRMIS is being implemented include: 54.5% — working with the ‘Personnel’ and ‘Personnel Orders’ functional modules; 47.6% — working with the ‘Self-Service Account’ subsystem (the ‘Personal Account’ module); 30.9% — working with the ‘Organisational Structure’ functional module.

Due to delays in populating the HRMIS, there is a lack of accurate personnel data and difficulties in making decisions on human resource management. 

In addition, several information systems (applications and web platforms) are currently in operation, including the NAUCS dashboard on the quantitative composition of civil servants in Ukraine, the Ministry of Finance dashboard on the number and salaries of all public sector employees, the HRMIS, NAUCS statistical data, and others. However, the information on the number of civil servants and other employees differs significantly across these systems. 

For instance, according to the NAUCS dashboard on the number of civil servants in Ukraine, as of the first quarter of 2025, the number of established positions amounted to 191.89 thousand, and the actual number of employees was 156.79 thousand. Whereas the HRMIS contained informationHRMIS portal. Information as of 11 July 2025, 15:00. on 70.7 thousand positions, with 48.7 thousand actual employees.

Accelerating the implementation and population of the HRMIS is necessary for making effective management decisions, particularly for strategic workforce planning in the civil service. This is especially important given the recent trend of staff outflow from the civil service: in 2023, 36.2 thousand individuals were appointed to positions, while 40.2 thousand were dismissed; in 2024, 35.1 thousand were appointed, while 37.7 thousand were dismissed.

The HRMIS is still in the process of integration with payroll systems, which ultimately leads to a lack of transparency and delays in obtaining accurate salary data within the framework of public administration reform. The Law of Ukraine ‘On Civil Service’ (as amended) stipulates that salaries for civil service positions should be established based on the catalogue of standard civil service positions, criteria for assigning such positions, and a comparison of civil service salaries with those in the private sector in Ukraine. Since the comparison of salary levels has been postponed until 1 January 2027, and the HRMIS has not yet been implemented in all state authorities, this hinders the ability to assess the effectiveness of HR management in the civil service.

Unified Portal for Civil Service Vacancies

Since the onset of the full-scale invasion, the Unified Portal for Civil Service Vacancies has been suspended due to a technical failure. However, according to the 2022 NAUCS Work Plan Implementation Report, the main reasons for suspending the Portal were the protection of personal data of citizens and the prevention of cyberattacks on the system. 

The suspension of the Portal for more than three years complicates staffing processes for state authorities and creates obstacles for job seekers, who do not have access to complete and up-to-date information on available vacancies.

The situation is further complicated by the suspension of competitive selection for civil service positions, which in turn leads to limited access for potential candidates to vacancies, a lack of transparency in appointments, staffing shortages, and increased corruption risks during the recruitment process.

Experts and international partnersRichelieu Forum ‘Civil Service in Wartime: Rethinking Identity’. have repeatedly called for the resumption of competitive selection for civil service positions and the provision of automated tools to ensure safe hiring processesThere was a discussion on access to public service and the competitive procedure. Centre of Policy and Legal Reform.. However, the relevant draft law on improving the procedure for entering, serving, and terminating civil service has not yet been registered. According to the Ukraine Facility Plan, legislative changes are expected to take effect in the third quarter of 2025, and the operation of the Unified Portal of Civil Service Vacancies is planned to be restored in the first quarter of 2026.

In addition, the Unified Portal of Civil Service Vacancies requires upgrades, taking into account the need to improve the procedures for entering, serving, and terminating civil service and to expand its functionality to include vacancies in local self-government authorities. This will contribute to competency-based recruitment, increased transparency of human resource management, and the formation of reliable statistical data on all types of competitive procedures and vacancies.

Unified State Web Portal of Electronic Services Diia

Before the Unified Portal of Civil Service Vacancies resumes its operation, the government has supported the proposal by the Ministry of Digital Transformation to implement a two-year experimental project on the use of the tools of the Unified State Web Portal of Electronic Services Diia for employment in civil service positions. Within this project, it is planned to publish information about current vacancies in certain pilot bodies and institutions (the Ministry of Digital Transformation, the NAUCS, the Ministry of Economy, and the state enterprise ‘Diia’ — with their consent), as well as staff selection without competitive recruitment procedures.

It is expected that the implementation of this project will help address staffing issues in the pilot state authorities and later be scaled up to other state authorities and institutions. Within two months from the date of the government’s decision entering into force (by 23 July 2025), the Ministry of Digital Transformation must ensure the technical implementation of the use of the Unified State Web Portal of Electronic Services for employment purposes.

However, the Diia portal is primarily aimed at providing electronic public and other services and is not a specialisedRegulations on the Unified State Web Portal of Electronic Services, approved by Resolution of the Cabinet of Ministers of Ukraine No. 1137 dated 04.12.2019 (as amended by Resolution of the Cabinet of Ministers of Ukraine No. 937 dated 16.08.2022). application for posting vacancies and job searching. Solving the staffing problem in the civil service using the Diia portal appears quite questionable. Moreover, in the absence of integration, information exchange, and interaction with other job search websites and employment platforms, the issue of comparing salaries in civil service positions with those in the private sector remains unresolved, which complicates evidence-based salary planning within the civil service system.

Recommendations

On the path towards reforming the digitalisation and automation of the human resource management system in the civil service, only partial steps have been taken to implement the objectives of the Strategy. The successful implementation of the reform requires the following key measures:

  1. Accelerate the implementation and data population of the HRMIS in all state authorities, including their interregional and territorial units.
  2. Provide systematic methodological support to HR departments of state authorities on personnel management, particularly regarding the use of the HRMIS and work organisation within the system, including the ‘Personnel’ and ‘Personnel Orders’ functional modules.
  3. Reinstate competitive selection procedures for all categories of civil servants in government-controlled territories, utilising digital tools to ensure safe and transparent recruitment processes.
  4. Resume and modernise the Unified Portal of Civil Service Vacancies (career.gov.ua), particularly regarding the optimisation of competitive selection procedures and the expansion of functionality to post vacancies for local self-government authorities.
  5. Ensure integration, information exchange, and interaction between the Unified Portal of Civil Service Vacancies, the HRMIS, state cybersecurity systems, and other job search platforms to create a coherent, secure, and transparent ecosystem for human resource management in the public sector.

This publication has been prepared within the framework of the ‘Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress’ Project with the support of Switzerland. The content of this publication is the sole responsibility of the NGO ‘Agency for Legislative Initiatives’. The opinion of the authors does not necessarily reflect the views of the donor.

Three Consequences of a Government Change for Public Administration

The term of this Government can generally be characterised as one of constant crisis. Just days after its formation, quarantine measures were introduced in Ukraine due to the outbreak of the COVID-19 pandemic. Then, on 24 February 2022, the full-scale invasion by the russian federation began, forcing state institutions to respond swiftly to threats to national security. Under normal, peacetime circumstances, this Government would have already resigned following the election of a new Verkhovna Rada. However, due to the constitutional prohibition on holding parliamentary elections during martial law, both Members of Parliament and the Prime Minister have remained in their posts. At the same time, Denys Shmyhal’s resignation triggers the dismissal of the entire Cabinet of Ministers of Ukraine. Therefore, the change affects not only the head of Government but also the majority of ministries, which will undoubtedly impact the future development of the public administration system.

Legal Grounds for Government Renewal

In the new Government, Denys Shmyhal is expected to take on the role of Minister of Defence of Ukraine. Despite not having the corresponding constitutional authority, the President has proposed Yuliia Svyrydenko — currently Deputy Prime Minister and Minister of the Economy — for the post of Prime Minister. Under the Constitution of Ukraine, the initiative to nominate candidates to the Cabinet of Ministers lies with the coalition of parliamentary factions (or, in the case of the 9th convocation of the Verkhovna Rada, the so-called mono-majorityThe parliamentary faction, which includes the majority of MPs from the constitutional composition. The proposal of the coalition is the basis for the President’s nomination of candidates for the post of Prime Minister of Ukraine. The Minister of Defence of Ukraine and the Minister of Foreign Affairs of Ukraine are appointed by the Verkhovna Rada of Ukraine upon the proposal of the President of Ukraine, while other members of the Cabinet are appointed by the Verkhovna Rada of Ukraine upon the proposal of the Prime Minister of Ukraine, to whom the coalition also submits proposals for candidates.).

Some Members of Parliament, however, refer to Article 10 of the Law of Ukraine “On the Legal Regime of Martial Law”, which stipulates that the powers of certain state bodies — including the Cabinet of Ministers — cannot be terminated during martial law. A group of MPs has even registered a draft law proposing to remove this restriction in relation to the Cabinet. Nonetheless, despite the stance of some lawmakers, it appears that the Ukrainian Parliament does not intend to act on this proposal or amend the law before proceeding with the Government reshuffle.

The Constitution does not impose any restrictions on changing the composition of the Cabinet of Ministers during martial law; such provisions must be detailed at the legislative level. The authors of Article 10 of the Law of Ukraine “On the Legal Regime of Martial Law” likely did not intend to introduce a blanket prohibition on replacing the Prime Minister. Rather, these provisions were meant to protect the state from a potential coup — where the President, the Verkhovna Rada (at least theoretically), or a group of military officials might attempt to dismiss the Cabinet and assume its powers themselves.

According to the Constitution, a Cabinet whose resignation has been accepted by the Verkhovna Rada continues to exercise its powers until a newly formed Government begins its work. As past practice shows, the most recent change of Government in March 2020 — which involved both the dismissal and appointment — took just one plenary day. Therefore, a lengthy transitional period is not anticipated.

Consequences of Government Renewal

Once the transitional period ends — even if it lasts less than a day — the new Cabinet of Ministers will be faced with the consequences of the government change:

Withdrawal of Draft Laws

The outgoing Government will take its legislative initiatives with it. According to the Rules of Procedure of the Verkhovna Rada of Ukraine, any draft law submitted by the Cabinet of Ministers is considered withdrawn if the Cabinet’s powers are terminated before the draft is adopted at first reading as a basis. Such a draft law is then removedWith appropriate notes on this in a single automated system. Currently, the Parliament has more than 300 government draft laws at various stages of preparation for the first reading. from consideration. These draft laws will be returned to their originators (ministries, other central executive bodies, etc.) for review of their relevance. The Rules of Procedure of the Cabinet of Ministers of Ukraine stipulate that, if a withdrawn draft law is deemed still relevant, it may be resubmitted to the Government for consideration within one month.

The withdrawal and subsequent resubmission of draft laws will inevitably prolong the timeline for their consideration. Even if a draft is deemed relevant by its originating body, it will still need to undergo the following steps: 1) Reconsideration by the Cabinet of Ministers of Ukraine, prior to its submission to the Verkhovna Rada; 2) Review within parliamentary committees and structural divisions of the Secretariat of the Verkhovna Rada, responsible for conducting expert assessments of draft legislation.

Changes in Ministerial Leadership

The resignation and formation of a new Government involves more than just a change of ministers. Under the Law of Ukraine “On Central Executive Authorities”, the dismissal of a minister automatically results in the dismissal of their first deputy and deputy ministers. For some deputy ministers, this is likely to be a formality, as they will probably be reappointed; however, deputies serving under ministers who lose their posts will be less fortunate. Changes in ministry leadership will bring shifts in policy direction, new priorities, and potentially alterations to the ministry’s organisational structure.

Changes in ministry leadership and organisational structure are typically accompanied by up to six months of delays involving paperwork, reapproval of regulations, staff reappointments, and behind-the-scenes personnel struggles. During this period, the effectiveness of government bodies tends to be low. A recent and illustrative example of such “grand state-building” is the Ministry for National Unity, established at the end of last year. While the number of issued regulatory acts is not a definitive measure of its effectiveness, it is notable that the Ministry registered only one order with the Ministry of Justice during its entire existence — concerning criteria for reserving conscriptsCriteria for determining enterprises, institutions and organisations under its jurisdiction as those that are of great importance for the national economy, which allows for the reservation of employees liable for military service in such enterprises, institutions and organisations..

The Ministry for National Unity lasted for around half a year and is now, according to rumours, likely to be merged elsewhere. A swift and polished solution has proven ineffective. Tangible results are plainly absent — but realistically, they could not have been expected after just six months spent primarily on organisational and staffing matters to get basic operations off the ground. This leaves one inevitable question: has the time already come to start placing bets on which ministries will next be split, merged, dissolved, or newly created by the end of 2025?

A New Programme of Activity of the Cabinet of Ministers of Ukraine?

The previous revised Programme of the Cabinet of Ministers led by Denys Shmyhal was never approved by the Verkhovna Rada, despite the direct requirement of the Constitution. The newly formed Cabinet will have up to one month to submit its Programme of Activity to Parliament. It remains unclear whether this Programme will be based on the President’s “priority tasks” or on the coordinated political positions and policy commitments of the ruling coalition, as stipulated by the Law of Ukraine “On the Cabinet of Ministers of Ukraine”. Once approved, however, the Programme effectively grants the Government a form of political immunity: under the Constitution, the Verkhovna Rada cannot consider a motion of no confidence in the Cabinet for one year following the Programme’s approval. Nevertheless, as Ukrainian political pragmatism has shown, this does not preclude the Government’s dismissal by other means — for instance, through the collective resignation of the Cabinet before a newly elected Parliament or following the resignation of the Prime Minister.

The Programme of Activity of the Cabinet of Ministers is a key constitutional document around which the entire decision-making process — including legislative activity, the work of the Cabinet of Ministers, and the functioning of the Verkhovna Rada — should be structured. Despite holding office longer than any of his predecessors, Denys Shmyhal never succeeded in having his government’s programme approved by Parliament. The new Cabinet is being appointed just ahead of yet another announced 50-day russian offensive. Naturally, public and political attention will be focused on the front line, not on the rearrangement of chairs in ministerial offices. Yet it is precisely during this period that Ukraine’s core strategic governance document must be drafted and adopted. This will serve as a key indicator of whether the government reshuffle will result in meaningful reform of public administration — or whether we will once again be presented with “creative” and “honest” excuses for why it didn’t happen.

The government reshuffle is a fait accompli; however, this fact alone does not resolve questions about its justification or its alignment with current challenges. The change of government should not be a mere formality — a simple “musical chairs” exercise involving unjustified restructuring of ministries, which could halt government operations for a considerable period, merely as a way to release steam, especially given that neither the Parliament nor the President can be changed at this time.

Organisational Architecture of the Cabinet of Ministers of Ukraine and Central Executive Authorities

Digitalisation of the human resource management system, as a key element of rebooting public administration, is implemented in accordance with the Strategy for Public Administration Reform in Ukraine for 2022–2025 under the area ‘Professional Civil Service and Personnel Management’.

One of the directions of the Public Administration Reform Strategy for 2022–2025 (hereinafter — the Strategy) is Effective Governance, which entails creating conditions under which government bodies shape state policy based on analytical results and communication with stakeholders, as well as ensuring its implementation for the sustainable development of the state. Key challenges in this area include the insufficiently effective system of central executive authorities, the lack of a clear division between policy development and policy implementation, an imperfect mechanism for directing and coordinating the activities of ministries, and the unregulated system of state strategic planning. The Strategy stipulates that ministries should focus on policy development, assigning the relevant powers to directorates, while delegating policy implementation functions to other central executive bodies.

The separation of policy development and implementation functions between ministries and other central executive authorities is also outlined in the Public Administration Reform Roadmap, which is one of the key documents under Cluster 1: Fundamentals in Ukraine’s EU accession negotiations. The Roadmap sets the strategic goal for Ukraine to achieve by the end of 2026: ministries are focused on policy development, possess optimal institutional capacity, and effectively use human resources, while policy implementation functions (such as managing state-owned enterprises or providing services) are transferred to other central executive authorities. To achieve this, a range of measures is envisaged, including the introduction of a unified structure for ministries.

Another issue identified in the Strategy is the flawed procedure for establishing and dissolving central executive authorities, particularly the inadequate justification for their creation and the unclear definition of their areas of competence. Additionally, the lack of a clearly defined legal succession mechanism leads to problems related to the transfer of property obligations from a dissolved authority and ensuring the proper execution of functions reassigned to another central executive authority. As a result, the principle of continuity of public authority is violated, and the process of dissolving central executive authorities sometimes takes years.

The tasks for implementing this aspect of the Strategy include:

  • improving the organisation and procedures of central executive authorities, including enhancing mechanisms for guidance and coordination, organisational structure, clearly defining and distributing functions and powers, eliminating duplication, and introducing accountability for their performance;
  • streamlining the procedures for establishing and dissolving central executive authorities as legal entities of public law, as well as defining a clear legal succession mechanism in case of changes within the system of central executive authorities;
  • continuing the process of relieving ministries of non-core functions and powers, particularly by reallocating such functions and powers to other central executive authorities or transferring them to local executive authorities or local self-government bodies as part of decentralisation efforts, or even discontinuing state involvement in their execution.

However, no indicators have been defined for these tasks that would allow tracking progress in their implementation.

State of Play and Progress of Reform

Repeated announcements by the Prime Minister regarding plans to reduce the number of ministries have not been implemented. Instead, only name changes and redistribution of competences within the Government are carried out, or new policy areas emerge that require regulation. For example, following the reorganisation of the Ministry of Reintegration of Temporarily Occupied Territories of Ukraine, some of its powers were transferred to the Ministry of Social Policy of Ukraine. The emergence of new areas of state policy, where ministries are responsible for policy development and implementation, is a natural result of evolving societal relations and technological advancements. A clear example is the Ministry of Digital Transformation of Ukraine being granted powers to ensure the development and implementation of state policy in the field of artificial intelligence.

Architecture of the Cabinet of Ministers of Ukraine, ministries, and other central executive authorities 

The creation, reorganisation, and liquidation of ministries and other central executive authorities in accordance with the law fall under the constitutional powers of the Cabinet of Ministers of Ukraine. However, frequent, unjustified, or poorly reasoned changes in the system of central executive authorities, in their guidance and coordination schemes, and the redistribution of competences destabilise the work of ministries and other central executive authorities, forcing them to readjust their operations to new conditions. This negatively affects citizens and businesses, creating uncertainty and unpredictability in public policy planning and undermining trust in the institutional capacity of the Government.

For instance, in December 2024, the renaming of the Ministry of Reintegration of Temporarily Occupied Territories of Ukraine into the Ministry of National Unity of Ukraine was accompanied by the transfer of some powers of the former Ministry of Reintegration to the Ministry for Development of Communities and Territories of Ukraine and the Ministry of Social Policy of Ukraine. Some functions were left without a clearly defined responsibility, leading to a ‘governmental vacuum’ in the area of protecting the rights of internally displaced persons, as noted by both authorities and civil society representatives

The current Procedure for Implementing Measures stipulates that executive authorities are established, reorganised, or liquidated by the Cabinet of Ministers of Ukraine upon submission of the Prime Minister of Ukraine, based on a proposal from a member of the Cabinet of Ministers. Such proposals should consider Government priorities and the need to ensure the exercise of executive powers, avoid duplication of competences, and include justification for the feasibility of establishing, reorganising, or liquidating the body, along with relevant financial and economic calculations. However, the decision to establish the Ministry of National Unity was influenced more by political motives than by a substantiated need for a new ministry.

The areas where the Ministry of National Unity ensures the development and implementation of state policy, as defined in its regulations, lack legal definitions in Ukrainian legislation. This applies, in particular, to such matters as ‘national unity of Ukraine and joint development’ and ‘Ukrainian national self-awareness’. In December 2022, the Verkhovna Rada adopted the Law of Ukraine ‘On the Fundamentals of State Policy in the Field of Affirming National and Civic Identity’, and later the Government designated the Ministry of Youth and Sports as the central executive authority responsible for developing and implementing state policy in this area. The Ministry of National Unity was tasked with ‘promoting the establishment of Ukrainian national identity and Ukrainian civic identity’. This raises an open question: what exactly constitutes ‘Ukrainian national self-awareness’ or ‘national unity’, as these terms are not defined in legal acts, leaving room for broad interpretation of the responsibilities of the ministry. 

Additionally, the new ministry’s activities aim at ensuring the rights and interests of Ukrainian citizens abroad and creating conditions for their return to Ukraine. This partially duplicates the powers of the Ministry of Foreign Affairs of Ukraine, which is responsible for protecting the rights and interests of Ukrainian citizens abroad. 

Also, the role of the ministry in ensuring information policy regarding the unity of Ukraine and strategic communications (within its powers regarding national unity of Ukraine) overlaps with the powers of the Ministry of Culture and Strategic Communications of Ukraine. However, the absence of a clear definition of ‘national unity of Ukraine’ calls into question the division of competencies between these ministries in the field of information policy and strategic communications.

An analysis of the regulations of the Ministry of National Unity suggests that the ministry has limited autonomy in implementing some of its powers. For example, it works jointly with the Ministry of Education and Science of Ukraine to facilitate education for Ukrainians abroad and cooperates with the Ministry of Foreign Affairs to engage with organisations and media to protect the interests of these citizens. 

Currently, the existence of the Ministry of National Unity is in question, in particular due to the criminal charges of abuse of office and illicit enrichment on a particularly large scale brought against Vice Prime Minister of Ukraine and Minister of National Unity, Oleksii Chernyshov, as well as the relatively low effectivenessAlthough the number of regulatory acts issued cannot be an indicator of the effectiveness of this ministry, it is worth noting that the Ministry of Justice of Ukraine has registered only one order during the entire period of the Ministry of National Unity’s activity — regarding the criteria for determining enterprises, institutions, and organisations belonging to its sphere of management as those that are important for the national economy, which allows for the reservation of employees of such enterprises, institutions, and organisations who are subject to military service. of the ministry.

As part of the implementation of the Strategy, procedures for the establishment and dissolution of central executive authorities have been streamlined at the procedural level through the adoption of the Law of Ukraine ‘On Amendments to Certain Legislative Acts of Ukraine in Connection with the Adoption of the Law of Ukraine “On Administrative Procedure”’. This Law introduced changes to the Law of Ukraine ‘On Central Executive Authorities’, clarifying the procedure for transferring powers and functions from an existing ministry or other central executive authority to a newly established one, as well as the procedure for transferring powers and functions without establishing a new authority. In addition, the Law requires that the relevant act of the Cabinet of Ministers of Ukraine determine the legal successors of the property, rights, and obligations of a ministry or other executive authority subject to liquidation.

The lack of a clearly formulated policy on the organisation of the Government and the role of central executive authorities complicates the reform of individual ministries, the system of central executive authorities, and the Government as a whole. On the one hand, unjustified reorganisations of ministries lead to duplication of functions. On the other hand, they create a ‘governmental vacuum’, waste state resources, and halt the formation and implementation of state policy.

The architecture of the public administration system is not discussed with the public. Additionally, the Law of Ukraine ‘On Legislative Activity’ and the Law of Ukraine ‘On Public Consultations’ exclude legal acts related to the establishment or dissolution of state authorities from their scope. As a result, the establishment or dissolution of a new authority does not require an assessment of its impact on social relations or the conduct of public consultations with stakeholders.

Another aspect of the reform is the delineation of functions related to the development and implementation of policy between ministries and other central executive authorities. In May 2021, the Government submitted Draft Law No. 5469 to Parliament, proposing changes to the procedures governing the preparation of draft regulatory legal acts by ministries and other central executive authorities that are directed and coordinated by the Government through the relevant minister. The draft law provided that such central executive authorities would lose the competence to develop and submit regulatory legal acts (e.g., draft laws) for consideration by the relevant minister. Instead, they would submit proposals to the minister to support policy formation and, at the minister’s request, ensure the participation of their representatives in the preparation of regulatory legal acts. The proposed amendments aimed to ensure that only ministries could engage in policy development (or at least in the development of policy documents). Importantly, the Draft Law also sought to clarify the areas of state policy and areas of activity for which the Government would be responsible, with the distribution of competencies among Government members covering all areas and directions of its activity. In September 2021, the Main CommitteeThe Committee on Organisation of State Power, Local Self-Government, Regional Development and Urban Planning has been designated as the main committee for the preparation and preliminary consideration of the draft law. issued a revised opinion on the Draft Law, recommending its adoption as a basis in the first reading, with subsequent refinement in preparation for the second reading. In September 2024, the Draft Law was withdrawn by its initiator. Despite this, its adoption remains one of the measures set out in the Strategy Implementation Plan. 

At present, most central executive authorities directed and coordinated by the Government through respective ministers are responsible only for the implementation of state policy and for submitting proposals to the respective ministers on developing/ensuring the development of state policy. The only exception is the Ukrainian State Film Agency (hereinafter — USFA). In November 2021, the Cabinet of Ministers of Ukraine decided to transfer the direction and coordination of USFA activities from the Minister of Culture and Information Policy of Ukraine directly to the Cabinet of Ministers. As a result, USFA was granted direct authority to exercise legal and regulatory functions in the field of cinematography, including the adoption of regulatory legal acts in this area. In March 2023, the traditional core function of such central executive authorities (‘submitting proposals for ensuring the development of state policy’) was replaced with ‘ensuring the development of state policy in the field of cinematography’. Consequently, the Ministry of Culture and Information Policy of Ukraine lost one of its competencies — the field of cinematography — which was transferred to USFA. However, in February 2025, a reverse process took place: USFA was returned under the oversight of the Ministry of Culture and Strategic Communications of UkraineThe Ministry of Culture and Information Policy of Ukraine was renamed the Ministry of Culture and Strategic Communications of Ukraine in September 2024. (hereinafter — MCSC), which regained its authority to ensure the development and implementation of state policy in the field of cinematography and to exercise legal and regulatory functions in this area. The new regulations governing USFA excluded its authority to exercise legal and regulatory functions in the field of cinematography. However, its task of ensuring the development of state policy in cinematography remained unchanged, leading to duplication and competition with similar functions of the ministry now overseeing USFA. 

The recent ‘experiments’, such as the establishment of the Ministry of National Unity and the redistribution of competencies between MCSC and the Government regarding the coordination of USFA, demonstrate the lack of a strategic vision for the system of central executive authorities in connection with state policy areas. There is no established tradition of relations between ministries and their subordinate central executive authorities that would clearly define the scope of autonomy and accountability of such authorities to the respective ministries. Ministries should functionJohnsøn, J., L. Marcinkowski and D. Sześciło (2021), ‘Organisation of public administration: Agency governance, autonomy and accountability’, SIGMA Papers, No. 63, OECD Publishing, Paris. as the primary centres for state policy development, while other central executive authorities should focus on collecting and providing data on the implementation of laws and policies, as well as offering comments and proposals on ministerial initiatives.

Internal Organisation of Ministries

Aligning the organisational structure of ministries with established requirements remains one of the measures of the Public Administration Reform Strategy Implementation Plan. The creation of directorates within ministries as structural units responsible for policy development, coordination, and monitoring of its implementation, as well as the creation of a separate Directorate for Strategic Planning and European Integration, was one of the key objectives outlined in the Concept for Optimising the System of Central Executive Authorities and the Concept for Introducing Reform Support Specialist Positions. These directorates were intended to become the central hubs for policy development and strategic planning within ministries.

Draft Law No. 5469 proposed toCurrently, the typical structure of the central executive authorities is defined in a resolution of the Cabinet of Ministers of Ukraine. legally formalise the structure of the apparatus of the ministry, consisting of directorates and a secretariat, while also allowing for the creation of other independent structural units (departments, administrations, etc.) and the introduction of positions outside the framework of these structural units. 

The 2023 SIGMA Report provides a critical assessment of the ministry structure reform. It notes that the establishment of directorates has led to the creation of parallel, sometimes even competing, units (directorates and departments) within certain ministries, failing to achieve the goal of building capacity for reform development and implementation due to weak institutional support. Since 2021, the number of directorates in most ministries has been steadily decreasing.

In April 2024, the Coordination Council on Public Administration Reform presented an improved model structure for the apparatus of the ministry. It proposed the creation of structural units along three main lines of work: 1) units for policy development and implementation (directorates); 2) units for specific functions related to policy implementation (departments and divisions responsible for administrative services, management of state-owned assets, etc.); 3) support units (secretariat). However, legislative changes necessary to ensure the implementation of this structure have not yet been adopted, and the creation of new directorates within ministries has been temporarily suspended.

Recommendations

  1. Ensure the decision-making on the establishment, reorganisation, or dissolution of central executive authorities based on impact assessment, not just political considerations. For instance, such decisions should be preceded by: 1)  functional analysis of existing authorities to assess whether the proposed functions could be assigned to an authority operating in a related policy area; 2) evaluation of the potential effectiveness of planned changes to ensure that establishing, restructuring, or dissolving an institution is truly necessary and will not cause adverse consequences for citizens, businesses, or the state as a whole.
  2. Strengthen justification requirements for decisions related to changes in the system of central executive authorities.
  3. Consider engaging civil society and the business community in discussions concerning decisions on structural changes within the system of central executive authorities.
  4. Review and unify the internal structure of the apparatus of ministries and other central executive authorities. This will enhance policy development in areas of shared responsibility between multiple ministries and foster the development of horizontal linkages between them, which is a particularly important aspect in the context of Ukraine’s European integration. The updated structure should take into account the specific policy domains for which ministries are responsible and ensure an effective distribution of functions within the apparatus.

Agency for Legislative Initiatives in 2024: Results and Achievements

We share the most essential things, and thank all our partners for their support. Our systemic work allows us to continue fulfilling our mission, expanding it, and developing our expertise in analytics and civic education.

Analytics about and for the Parliament

In 2024, we prepared several Parliamentary Monitors, which have been an important component of the ALI’s research for many years. Trends, main and side issues of Verkhovna Rada’s work processes, a lot of data and accompanying analytics on a number of factors – all this is analysed and reflected in the Monitors because based on data and regular monitoring, we can analyse the activities of the Parliament and strengthen its institutional capacity as the most important body in a democratic state.

You can read the ALI’s analytics on the Parliament for the 9th, 10th and 11th sessions here:

In addition, ALI released two issues of the Parliament Journal in 2024:

  • Temporary commissions in the Parliament: oversight without the ability to influence, where ALI analysed in detail what MPs did within the framework of temporary ad hoc and temporary investigative commissions, the effectiveness of their work, and what problems prevent temporary commissions from being an effective tool for solving the problems that concern citizens the most.
  • Challenges Faced by Ukraine in the Context of International Armed Conflict: War Crimes and the Crime of Genocide. Since the first days of Russia’s full-scale war against Ukraine in February 2022, Ukraine, as well as the entire international community, has been facing the issue of qualifying crimes committed against Ukraine – it has become a real challenge in practice. That is why ALI’s research raises the following questions: “Do the norms of national legislation comply with the norms and principles of international law in terms of international crimes: war crimes and genocide?” and “How to legally justify the qualification of Russia’s crimes against Ukraine as the crime of genocide?”.

As well as periodic summary articles:

  • Code of Parliamentary Ethics: Easy to violate, difficult to adopt, impossible to negotiate. Regulation of the rules of MPs’ ethical conduct in the public space is a long-standing “homework” for the Verkhovna Rada. After all, rash actions damage the image and undermine trust not only in individual MPs but also in the entire current convocation and the parliament as an institution. In other countries, unethical conduct can even result in the loss of a mandate. However, the Ukrainian parliament still has significantly limited ways to influence MPs’ actions, and these methods are currently not effective enough to prevent unethical actions and public scandals involving MPs outside the session hall.
  • Achievements, Failures, Records and Myths of the Verkhovna Rada, 9th Convocation. On the occasion of the fifth anniversary of the 9th convocation of the Verkhovna Rada, ALI recalled the most memorable moments in the work of the parliament over the years – what surprised, pleased and worried the 9th convocation.
  • On the Beaten Path: What Should the Verkhovna Rada of Ukraine Do to Get Closer to the European Union? The European Commission presented its Enlargement Report, which assessed the annual progress made by the candidate countries, including Ukraine. The Agency for Legislative Initiatives analysed the part of the report concerning the Verkhovna Rada, highlighted these points and explained why they are a priority for the parliament and its development as an institution that embodies Ukrainian democracy.

The work of the Parliament is systemically monitored thanks to the support of Sweden, which is ALI’s institutional partner.

In the context of challenges posed by Russia’s full-scale war against Ukraine, ALI has also prepared a Military Justice in Ukraine Green Paper, which is an analytical document covering information on the international experience of regulating and functioning of military justice, considering previous work on military prosecutors, advocacy, military police, military counterintelligence and military courts, and highlighting the challenges of creating new bodies of the military justice system in Ukraine.

The Green Paper was prepared within the framework of the Parliament and Accountability of the Security Sector in Ukraine (PASS Ukraine) project, which the Agency implements jointly with the Parliamentary Centre (Canada) in cooperation with the Verkhovna Rada of Ukraine and with the support of the Global Affairs Canada within the framework of the Peace and Stabilization Operations Program (PSOPs).

Parliamentary diplomacy

Throughout the year, we helped establish interparliamentary relations between Ukraine and several other countries, primarily our Canadian partners. Within the framework of the Parliament and Accountability of the Security Sector in Ukraine (PASS Ukraine) project, there were several working visits of Ukrainian parliamentarians to share experience in the field of military justice and law enforcement, practices of working with classified information, external audit processes in the security and defence sector, building civil-military culture, and the experience of Canadian colleagues in exercising parliamentary oversight of the armed forces and defence agencies. During these visits, the Ukrainian delegation joined events in the Canadian Parliament and, inter alia, the plenary session of the NATO Parliamentary Assembly in Montreal.

A new area of work – the rule of law

An important and honourable achievement for us was the new Rule of Law area of work led by Karina Aslanyan, which we launched in 2024: In Coalition with other NGOs, we prepared and presented to the European Commission the Shadow Report on Title 23 Justice and Fundamental Rights, held discussions on its key findings, and regularly issued expert materials on judicial reform, its related problems and challenges, competitive selection of judicial institutions, etc.

Decentralisation, communities and recovery

The current state of de-occupied communities and their recovery was a separate focus of our research. In particular, ALI published:

  • The Assessment of the state of public services in de-occupied communities (Kherson Oblast) shows the unique experience of de-occupied territorial communities in Kherson region. These communities continue to provide public services to their residents despite lacking financial and human resources. Analysing this experience is extremely important, as it will help aggregate it and prepare for possible challenges after the de-occupation of other regions of Ukraine.
  • The Analysis of the Socio-Economic Situation in De-Occupied Communities: Kherson Oblast research highlights the general trends in the development of de-occupied communities in Kherson Oblast. Special attention is paid to five key indicators: socio-demographic, financial, infrastructure accessibility, migration processes and cooperation. This is unique data that is needed to plan the recovery of de-occupied territories in a balanced manner.

These studies were prepared within the Parliamentary Accountability of the Security Sector in Ukraine (PASS Ukraine) project.

The growth of social demands and the complexity of their provision are illustrative, but not exhaustive, challenges faced by the central government, local governments, NGOs, and charities in building an effective social services market in Ukraine. Therefore, the Agency conducted the Social Services in Ukraine: Current Status, Problems and Limitations research, which describes the state of social services in the context of a full-scale invasion and provides recommendations for improvement. The research was carried out with the support of the International Renaissance Foundation.

Public administration reform

In 2024, the Agency for Legislative Initiatives continued to work on public administration reform. In previous years, ALI comprehensively monitored the implementation of the reform. Returning to this topic, we have prepared a series of info briefs on various aspects and challenges of public administration reform.

The info briefs were developed with the support of Switzerland as part of the Improvement of Governance in Ukraine: Enhancing Policy Making for Social Progress Project. 

Outreach activities

Of course, the Agency for Legislative Initiatives continued to implement the programme of the Ukrainian School of Political Studies, an educational project launched by ALI and the Council of Europe in 2024. In addition to the annual USPS-2024 programme, we managed to implement the You Are Important programme designed to support servicewomen and women veterans and hold six thematic USPS Clubs and two USPS Alumni Programmes. Moreover, a new video course, “Political Science with Ivan Gomza,” was released as part of the USPS Lectorium.

In addition, we held a series of training events for representatives of the Verkhovna Rada Secretariat and other government agencies:

In the report “The Role of Legal Education in Shaping Students’ Understanding of the Law,” we focused on how students perceive the law, how law and legal education affect their lives, and what legal instruments they tend to use to solve practical situations. This report was prepared with the support of Sweden, an ALI’s institutional partner.

We would like to thank all the partners and friends of the Agency for Legislative Initiatives who helped strengthen the Ukrainian state in 2024. Thanks to your support, we continue to work hard and diligently to implement our mission.