The institutional system for ensuring anti-corruption policy in Ukraine: a critical analysis of architecture, dysfunctions and the eu integration dimension

Abstract

The article provides a comprehensive analysis of the institutional system for ensuring anti-corruption policy in Ukraine through the lens of comparative administrative law and international standards. The conceptual framework of the study is defined: the notions of "anti-corruption policy", "institutional system" and "ensuring" are delineated as a complex of regulatory, organisational, personnel, financial and informational conditions for the functioning of anti-corruption institutions. Three basic models of institutional anti-corruption design (single-agency, multi-agency and networked) are systematised, and the requirements of the UN Convention against Corruption, the Jakarta Principles, GRECO and OECD standards on independence, specialisation and resource provision of anti-corruption agencies are analysed. The functional architecture of Ukraine's five specialised bodies (NAPC, NABU, SAPO, HACC, ARMA) and bodies with related competences (SBI, Accounting Chamber, HCJ/HQCJ) is examined. Systemic dysfunctions are identified: competition of competences between NABU, SBI and SSU, chronic problems with appointing heads of anti-corruption bodies, ARMA's systemic crisis, procedural gaps ("Lozovyi amendments"), as well as attempts at political subordination of independent bodies, culminating in the events of July 2025. The impact of martial law on anti-corruption infrastructure is analysed: increased corruption risks in defence procurement alongside the upward trend in NABU/SAPO indictments. In the EU integration context, the effectiveness of the European Commission's conditionality is assessed in a comparative perspective with the experience of Romania, Croatia and Bulgaria. The author's position is substantiated that the totality of Ukraine's anti-corruption institutions constitutes an "institutional archipelago" – capable but insufficiently coordinated bodies that require a transition to a networked model with formalised mechanisms of horizontal interaction.