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Ukraine Mid-Term Report 2016-2018

Ukraine’s third action plan covers several major priority areas, including flagship transparency commitments on public contracting, disclosure of asset declarations, and beneficial ownership. Moving forward, the government could improve the next action plan’s development process by clearly identifying the intended changes for targeted policies.


Commitment Overview Well-Designed?*
5. Ultimate beneficial owners’ verification system Improve the verification mechanism for information on ultimate beneficial owners.


✪8. Openness and transparency in public procurement Promote transparency and openness for public procurement.


✪9. Implement EITI Pass draft law on information disclosure in extractives industries and publish EITI reports.


* Commitment is evaluated by the IRM as specific, relevant, and has a transformative potential impact
✪ Commitment is evaluated by the IRM as being specific, relevant, potentially transformative, and substantially or fully implemented


The action plan development process was participatory and involved in-person and online consultations to gather commitment proposals. The Coordination Council acts as the multistakeholder forum, and monitors the action plan implementation through four thematic working groups.

Did not act contrary to OGP process

A country is considered to have acted contrary to process if one or more of the following occurs:

  • The National Action Plan was developed with neither online or offline engagements with citizens and civil society
  • The government fails to engage with the IRM researchers in charge of the country’s Year 1 and Year 2 reports
  • The IRM report establishes that there was no progress made on implementing any of the commitments in the country’s action plan


Ukraine’s third action plan covers a variety of important issues in the country, such as transparency on ultimate beneficial owners, extractives and construction industries, and urban planning, as well as public monitoring of pollution. While two commitments were fully completed during the first year of the action plan, significant progress has been made on several others.

IRM Recommendations

  1. Make commitments more specific and results oriented.
  2. Involve Parliament in action plan development for commitments that require legislative action
  3. Create an automated system for verifying e-declarations and sanctioning public officials who violate the law.
  4. Prioritize the implementation of the verification system on beneficial ownership.
  5. Include a commitment to develop a user-friendly online system for monitoring the budget and public spending.


Filed under: IRM IRM Report

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