“No Path to the EU Without Real Progress on Integrity”

An interview with Mattia Nelles (DUB) and Martyna Boguslavets (MEZHA) about the COSAC Reform Initiative.

In times when Ukraine’s resilience is tested daily, the country continues not only to defend its sovereignty but also to strengthen the rule of law and integrity at home. The fight against corruption has become one of the key benchmarks of Ukraine’s democratic transformation — a demand born out of the Revolution of Dignity, driven by civil society and supported by international partners.

To ensure that Ukraine’s progress in this area is seen, understood, and reinforced internationally, two organizations — German-Ukrainian Bureau (DUB) and MEZHA — have joined forces in the Continuing Successful Anti Corruption (COSAC) Reform Initiative, supported by the German Federal Foreign Office. The project amplifies Ukraine’s voice in Europe, advocates for ongoing anti-corruption reforms, and connects Ukrainian and EU institutions in dialogue on integrity and accountability.

Mattia Nelles and Martyna Boguslavets during an advocacy tour to Copenhagen, September 2025

Martyna, the project aims to continue Ukraine’s successful anti-corruption reforms. But what specific successes are we talking about? How did Ukraine change since the Revolution of Dignity?

Martina Boguslavets (MB): Indeed, the transformation of Ukraine in the area of anti-corruption truly began after the Revolution of Dignity in 2014. It was driven by strong public demand for change, the proactive stance of civil society, as well as the clear expectations of our international partners and donors.  As a result, Ukraine established a set of independent anti-corruption institutions — National Agency on Corruption Prevention (NACP), National Anti-Corruption Bureau of Ukraine (NABU), Specialized Anti-Corruption Prosecutor’s Office (SAPO), and later the High Anti-Corruption Court (HACC)— which became a cornerstone of the country’s reform agenda and one of its major achievements. The independence of these institutions was among conditionalities for international financial support, or for the political advantage from EU, from International Monetary Fund, and the U.S. government. In 2023, it became the part of the conditionalities in Ukraine Facility Plan from EU. And now it's a part of EU conditionalities for EU accession to open the negotiations of so-called fundamental cluster. 

But even these achievements need protection. In 2025, we saw attempts by the government and parliament to weaken their independence. Defending these institutions is now one of Ukraine’s biggest challenges — and successes.

Mattia, you came to focus on Ukraine during the Revolution of Dignity. How do you see the country’s progress over the last ten years?

Mattia Nelles (MN):  When Yanukovych fled, Ukraine was almost bankrupt and run like a mafia state. The Revolution of Dignity changed everything — people demanded justice and an end to impunity. Since then, civil society and international partners have made huge progress possible.

The creation of independent institutions — NACP, NABU, SAPO, and later the High Anti-Corruption Court — marked a historic breakthrough. These “islands of integrity” became truly effective, especially after the full-scale invasion, with more investigations and convictions than ever before. And beyond law enforcement, reforms like the e-declaration system for public officials and e-procurement system Prozorro brought transparency that has saved the country billions.

Yes, corruption still exists — but Ukraine today is not the Ukraine of 2014.

Ukrainians are still quite pessimistic when it comes to estimating the progress in fighting corruption. If you look at the polls over the years, people keep saying it’s one of the biggest problems, and they don’t really see much progress. But at the same time, when you ask whether they or their families have personally encountered corruption, those numbers have dropped a lot — from about 70% in 2015 (see the Study by Kyiv International Institute of Sociology) to around 20% now (see the Research by NACP). 

How would you describe the current state of anti-corruption reforms? What comes next, beyond defending what’s already been achieved?

MN: We have two goals — defensive and offensive. The defensive one is to protect the independence of existing anti-corruption institutions that deal with top-level cases. But we also need to move forward — to strengthen NABU and SAPO, give them proper tools like access to surveillance and independent forensics. Small steps like these can make a big difference.

Mattia Nelles at the expert launch of COSAC Initiative, Berlin 2025 (photo by Pavel Sepi)

The offensive goal is to expand these ‘islands of integrity’ — to bring the same professionalism and independence to other institutions like the Economic Security Bureau, Customs, and the Tax Service. That’s essential if Ukraine truly wants to meet EU standards.

MB: Exactly. One of the biggest challenges for NABU is the lack of its own independent forensic expertise. At the moment, there are a number of forensic institutions which operate under the Ministry of Justice, the Ministry of Internal Affairs, and the Security Service of Ukraine, and may delay or politicize the process.This dependency slows down investigations and creates conflicts of interest. That’s why establishing NABU’s own independent forensic institution is crucial — and it should become a clear requirement from Ukraine’s international partners and part of the EU integration agenda. 

Withing COSAC Initiative Mezha focuses on the National Police, Bureau of Economic Security, and Customs Service. Why did you choose these institutions? 

Martyna Boguslavets at the expert launch of COSAC Initiative in Berlin, June 2025 (photo by Pavlo Sepi)

MB: Well, the key point is that NABU handles only about 6% of all corruption cases in Ukraine — it focuses on top-level officials. But when people talk about corruption, they mean much more than that: everyday bribery, embezzlement, tax crimes — all the things that affect daily life. Around 70% of corruption cases are actually investigated by the National Police, not NABU. That’s why systemic reform across all law-enforcement institutions is just as important as protecting the independence of NABU and SAPO. 

Each institution we are focusing on is at a different stage of reform, so our goals vary. For the National Police, we’re working on legislation to introduce transparent competitions for leadership positions — a draft law was just registered, and we held a roundtable with the government and experts to discuss amendments.

In Customs, the law already exists, and the competition process has started, so our role is to monitor it and conduct integrity checks, just as we did for the Economic Security Bureau. The Bureau now faces a huge challenge — requalifying over 1,200 employees within 18 months — and our team has been invited to join the civil oversight board to help ensure transparency and integrity throughout the process.

Why is this important beyond Ukraine? How do international partners view these reforms?

MN: It’s crucial to follow these developments because Western support depends on trust. Corruption undermines that trust and could even affect military aid. Preventing corruption in the defense sector is vital, but it’s also about broader transparency. Simply put: there’s no path to the EU without real progress on integrity. 

At DUB, we help Western — especially German and European — stakeholders understand that these reforms are driven by Ukrainians themselves. Civil society demands them; our role is to amplify that voice and make sure Western aid stays linked to strong anti-corruption commitments. It’s what we call: unconditional support in the war, but conditional aid for reconstruction.

This summer in Ukraine was intense — activists took to the streets across the country to protect the independence of anti-corruption institutions. How was this seen from abroad? Did it affect trust in Ukraine as a partner?

MN: The attacks definitely hurt Ukraine’s leadership, both at home and in Western eyes. It showed that the government was willing to take risks with independent bodies — but it underestimated the backlash. The strong reaction from Ukrainians and their partners proved that people won’t tolerate backsliding. Trust was shaken, and only real action can restore it.

MB: And unfortunately, that was just the beginning. After the protests, the government switched to quieter tactics — using unreformed agencies, procedural delays, and even fabricated cases to pressure NABU and SAPO from within. It’s slower and less visible, but just as dangerous.

MN: Yes — it’s a death by a thousand cuts. Smear campaigns, draft laws, law enforcement pressure — all small steps that add up. That’s why civil society and Western partners must stay vigilant and react early.

Partners discuss the results of meetings with decision-makers in Copenhagen, September 2025

Now that U.S. engagement has shifted, how can the EU and its member states — especially Germany — best support reforms?

MN: The old mantra of “money now, reforms later” no longer works. Ukraine’s recent actions have made it clear that stronger scrutiny is needed. We need early, firm oversight — that same tough love approach. The goal isn’t punishment, it’s prevention: to act before trust and funding are at risk.

Martyna, what kind of support is most valuable for Ukraine right now — political, financial, or technical?

MB:  Opening the EU negotiation clusters will really help — it will move us from talk to concrete timelines and conditions. The EU should now take a tougher, more demanding role than the U.S. once did, making anti-corruption progress a clear condition for financial support. And finally, Ukraine urgently needs more support for independent watchdogs. Only about ten truly independent anti-corruption NGOs remain, and they’re struggling for resources. Visible political and financial backing from Brussels and member states is crucial — it shows that Europe stands with those who defend integrity every day.