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Ukraine Action Plan Review 2021-2022

This product consists of an IRM review of Ukraine’s 2021–2022 action plan. The action plan is made up of 14 commitments. This review emphasizes its analysis on the strength of the action plan to contribute to implementation and results. For the commitment-by-commitment data, see Annex 1. For details regarding the methodology and indicators used by the IRM for this action plan review, see Section IV: Methodology and IRM Indicators.

This publication was produced with the financial support of the European Union. Its contents are the sole responsibility of the Independent Reporting Mechanism (IRM) and do not necessarily reflect the views of the European Union. IRM assessments are conducted independently in collaboration with country researchers, reviewed by IRM staff and overseen by the International Experts Panel (IEP) to safeguard independence, objectiveness and evidence-based research.

Overview of the 2021–2022 Action Plan 

Many of Ukraine’s 14 commitments build on existing transparency initiatives. The three most promising commitments have clear objectives and substantial potential for results, while some other commitments are not relevant to open government or unclear about how they would overcome past obstacles to implementation. Reinstating the multistakeholder coordination framework needs to ensure effective oversight of implementation as well as relevant and ambitious commitments in future action plans.



Participating since: 2011

Action plan under review: 2021–2022

IRM product: Action plan review

Number of commitments: 14


Overview of commitments:

  • Commitments with an open gov. lens: 13 (93%)
  • Commitments with substantial potential for results: 3 (21%)
  • Promising commitments: 3


Policy areas

Carried over from previous action plans:

  • Beneficial ownership transparency
  • Budget transparency
  • Extractives industry transparency
  • Tools to digitize democracy

Emerging in this action plan:

  • Participation of young people
  • Gender disaggregated data

Compliance with OGP minimum requirements for co-creation:

  • Acted according to OGP process: Yes

Ukraine’s fifth action plan includes 14 commitments. Over half of the commitments focus on transparency in policy areas such as the state budget, public assets, beneficial ownership, the extractives industry, road and infrastructure projects, disability, and gender.

The plan includes three promising commitments on state budget transparency, reporting transparency in the extractives industry, and implementing a mechanism for monitoring infrastructure projects. They have substantial potential for results and are assessed in more depth in Section II.

An ad hoc oversight group of government, civil society, and international donors in Ukraine, which historically engaged in developing OGP action plans, oversaw the co-creation process. Ukraine’s official multistakeholder forum, the Coordination Council, had ceased to operate effectively because many members had moved on from their jobs in government and civil society, and had not been replaced by the start of the co-creation process.[1] Further affecting the action plan development process, the COVID-19 pandemic pushed engagement and consultations online; this led to a wider number of civil society organizations participating including organizations based outside Kyiv.[2] The ad hoc oversight group received and evaluated 241 proposals received during thematic meetings held online and via an electronic form, published feedback, and prepared a draft action plan which was put out for public consultation.[3] The final version was adopted in February 2021.

This action plan contains three commitments which the IRM assessed to have substantial potential for results, eight with modest potential, and three commitments with unclear potential for results.[4] The IRM could not establish the relevance to open government for the commitment on setting up an online platform for patenting and innovation development, which is new to Ukraine’s open government action plan.

The commitments on the verification of beneficial ownership information and on the application of e-democracy tools appear to continue and build upon unfinished actions from previous plans.

The involvement of new organizations contributed to a diversification of the thematic areas covered in the action plan, but not necessarily more ambitious commitments. These commitments on youth participation, accessibility for disabled people, training public officials on open data, and gender disaggregated data missed the opportunity to name new organizations as partners in the action plan and bring in relevant civil society organizations from sectors which have not previously engaged on open government topics. They have only modest potential for results because their objectives are unclear, or because they are standalone events or trainings.

On the other hand, commitments which have substantial potential for results have actions that clearly outline the permanent and positive impacts in their relevant policy area. The commitment on infrastructure project monitoring has an effective measure to introduce unique identifiers for infrastructure projects that would dramatically simplify their monitoring and reduce corruption risks. The extractives industry transparency commitment would expand the scope and establish real time data publication for local communities, and the digital contracting activities commitment would increase transparency and reduce corruption risks.

A strong international donor community in Ukraine supported and participated in the co-creation process. At least nine commitments explicitly have support or funding from international donors. However, as explained above, not all commitments are clearly relevant to open government or have ambitious potential for results. Commitments, including those supported by donors, need to be clearly relevant to open government, have ambitious potential for results, and be sustained by the Ukrainian government beyond the action plan cycle.

Furthermore, reinstating Ukraine’s Coordination Council framework should ensure support and oversight for implementing this action plan. This will require members to find solutions to obstacles and speak up where resources or political engagement are needed. A functioning council is also necessary for preparing the design and oversight of the next action plan cycle in 2023, including drafting ambitious and relevant commitments. The council should use the format for drafting commitments provided by OGP so that the problem, actions, ambition for results, and relevance to open government are clearly articulated.

Promising Commitments in Ukraine’s 2021–2022 Action Plan

The following review looks at the three commitments that the IRM identified as having the potential to realize the most promising results. This review will inform the IRM’s assessment of implementation in the results report. The results report will build on the early identification of potential results from this review to contrast with the outcomes at the end of the action plan implementation period. This review also analyzes challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Commitments 1 (publishing budget program indicators and e-contract modules), 8 (extractives industry transparency), and 13 (mechanisms for monitoring infrastructure projects) are analyzed further as promising commitments because they present substantial potential for results in their respective policy areas.

Commitment 2 on public asset transparency is a positive step that primarily would digitize and streamline the process of updating the Unified Register of State-Owned Assets. However, the text does not clearly outline the level of detailed information that would be published online.

Commitment 3 on creating a distance e-learning system would lead to the availability of educational materials online that are regularly updated with state educational standards and curricula. However, it is not clear from the action plan if these materials would be available via open licenses for reuse or what supporting actions would need to be taken to ensure their effective take up by students and schools.

The IRM was unable to identify a clear open government lens for Commitment 5 because it is unclear that setting up an online platform for patenting and innovation development would make public policy, institutions, or decision-making processes more transparent, participatory, or accountable.

While Commitment 4 on open science policy includes limited participatory activities with stakeholders, potentially substantial results are more likely in future action plans that commit to greater open data disclosure. This is also true for Commitment 12 that opens information on road infrastructure but could have greater results in future plans if data is made available.

Commitment 6 was carried over from the previous action plan, but no institution or public body appears to have the responsibility for implementing the verification process that is needed to improve Ukraine’s beneficial ownership transparency regime. The milestone establishing and implementing the unified verification system lacks clarity on the tools to be used and additional scope or channels of information to be made publicly available. The trainings and independent audit process are a welcome but modest step that appear mainly driven by civil society.

Commitment 7 on e-democracy tools seeks to digitize and centralize some of these tools rather than engage the public to change and improve their functioning to be more open, participatory, or accountable. Reforming digital public consultations has the greatest ambition within the commitment, and notably the Ministry of Digital Transformation is particularly interested in implementing the platform for e-democracy tools. However, its potential for results is limited because stakeholders have highlighted the need for legal changes which would ensure consultations are used more broadly than just by government institutions, and that such legal changes have been delayed multiple times in the past (even though in principle they are not a precondition to developing the tools and platform).[5]

The training activities envisaged for Commitment 9 on establishing the National Centre for Open Data Competence and Commitment 11 on facilitating more active youth participation, do not appear to institutionalize changes in government practice. Commitment 11 could show more impactful results if the training was tailored to specific policy areas or if it included direct youth engagement in specific policies or legislation.

Implementing Commitment 10 (ensuring digital accessibility for persons with disabilities) would benefit from the active inclusion of disabled people and civil society groups. This is also true of Commitment 14, which would benefit from working with local Ukrainian women’s groups to establish which policy areas or datasets should be prioritized to have the greatest impact on facilitating gender equality, rather than a general and unspecific commitment to apply a gender lens to all datasets.

Table 1. Promising commitments

Promising Commitments
1. Improve budget transparency and implement e-contracts: Budget program indicators would be made more easily understandable for users of open data of local spending units. The e-contracts module would digitize the process of signing contracts with public institutions, turn them into publicly available and machine-readable data, and enable quicker analysis and public oversight of contracts in Ukraine.
8. Introducing the electronic system for reporting by extractive industries: A new online reporting system for companies would mean information submitted is published in real time. It would also provide more detailed information that could help communities to better understand how much money governments receive from extractive industries.
13. Creation of additional infrastructure project monitoring mechanisms: This would develop an algorithm to establish unique identifiers for infrastructure projects in Ukraine. Making these identifiers public would reduce opportunities for corruption and make it possible for officials and the public to accurately identify and follow the implementation of infrastructure projects.

[1] Natalia Oksha (OGP Coordination Council Secretary and Secretariat of the Cabinet of Ministers of Ukraine), interview by IRM researcher, 22 Jun. 2021.

[2] Secretariat of the Cabinet of Ministers of Ukraine, “Зміни у впровадженні Ініціативи “Партнерство “Відкритий Уряд” у 2020 році” [Changes in the implementation of the Open Government Partnership Initiative in 2020] (Gov. Portal, 23 Mar. 2020),; Oksha, interview.

[3] Secretariat of the Cabinet of Ministers of Ukraine, Звіт про врахування пропозицій, які надійшли за результатами обговорень в рамках підготовки плану дій із впровадження Ініціативи “Партнерство “Відкритий Урядˮ у 2021 – 2022 роках [Report on consideration of proposals received based on the results of discussions in the preparation of the action plan on the implementation of the Open Government Partnership Initiative in 2021-2022] (2018),; Oksha, interview.

[4] The action plan for 2018–2020 was only slightly less ambitious overall than the 2021–2022 action plan, although it had more commitments.

[5] Oksana Mizik (Ukrainian Center for Independent Political Research), interview by IRM researcher, 19 Jul. 2021


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