Executive summary
Today, the National Police has politically dependent leadership appointed through non-transparent procedures, ineffective disciplinary mechanisms, and structural weaknesses in HR policy.
The Ministry of Internal Affairs and the National Police disregard these issues, as evidenced by their anti-corruption programs:
- The National Police Anti-Corruption Program for 2025-2027;
- The draft Ministry of Internal Affairs Anti-Corruption Program for 2026-2028.
The content of the programs is based on the outdated Anti-Corruption Strategy, which both institutions implemented formally, and whose relevance will expire with the adoption of a new strategy.
The attempt by the MIA and the National Police to structure their work for 2027-2028 around old measures while ignoring real problems demonstrates their actual approach.
To ensure meaningful change, the Ministry of Internal Affairs and the National Police must align their programs with the new Anti-Corruption Strategy and adapt them to the current reform framework.
1. The MIA and NPU anti-corruption programs fail to address the police’s political dependence.
- According to the Law “On National Police,” the Head of the National Police is appointed and dismissed by the Cabinet of Ministers upon the MIA’ submission with no transparent criteria, allowing broad discretion for political authorities.
- In its Screening Report, the European Commission emphasized the need for transparent selection procedures for leadership positions in central and regional NPU units, with significant involvement of independent experts delegated by international partners.
- The Anti-Corruption Center “MEZHA” conducted a study on the National Police’s political dependence on the Government and the potential to overcome it through competitive selection procedures.
- The study contributed to the new Anti-Corruption Strategy, which prioritizes introducing competitive selection procedures as a key reform measure for the National Police.
- MIA opposed the proposal to replace ministerial “coordination” with competitive selection procedures, arguing that such changes require further justification.
- Alongside the new Anti-Corruption Program, the Ministry of Internal Affairs is drafting its 2026–2028 strategy, which completely ignores existing issues with non-transparent appointments in the National Police.
- The 2025-2027 Anti-Corruption Program of the National Police similarly ignores these issues, incorporating a draft law developed in 2023–2024, before the program, which the NACP deemed corrupt and which is inconsistent with international obligations.
2. Through its new Anti-Corruption Program, the Police are attempting to maintain an ineffective disciplinary system
In 2024, more than 30,000 police officers (or 30% of the total personnel) were subjected to disciplinary action. These figures indicate a significant number of disciplinary violations within the NPU that require suitably thorough investigation and response.
At the same time, not all NPU personnel are subject to proper disciplinary proceedings.
NPU Chief Ivan Vyhivskyi was revealed to be using property registered to relatives without sufficiently declared income, while his sister had business ties with individuals involved in criminal proceedings. Despite public outcry, the Minister of Internal Affairs refused to initiate an internal investigation.
In October 2024, journalists reported that Serhii Shaikhet, Head of the Migration Police Department and reportedly linked to the Office of the President, spent working hours attending to personal matters and was present at the office for only 1–2 hours a day. He faced no accountability for this misconduct.
An attempt to improve internal investigation procedures
On August 29, 2025, Draft Law No. 13713 amending the Disciplinary Statute of the NPU was registered. It is a requirement under the State Anti-Corruption Program provisions; one aiming to improve the procedures for conducting internal investigations and improve the formation of disciplinary commissions. However, the proposed draft does not fully comply with SAP requirements, in particular:
- the draft indicates no requirement to include at least half of the disciplinary commission members from civil society, contrary to the SAP;
- the draft includes no list of offenses for which the disciplinary commission can recommend dismissal from the position or police service, contrary to the SAP;
- the draft asserts that leaders have discretion to determine the format of disciplinary commission meetings (open or closed sessions).
The Police, through the new Anti-Corruption Program, seek to preserve an ineffective disciplinary system, incorporating an inappropriate 2023-2024 draft law into its action plan.
3. The MIA and the National Police have not changed their position on introducing an effective police officer certification system
In accordance with the requirements of Measure 2.1.6.3.1, the MIA and the NPU were required to reform the police officer certification procedure and introduce mandatory performance evaluation. In addition to existing criteria, the following evaluation standards were to be included: integrity, managerial competencies (for senior officers), and overall performance outcomes.
However, these requirements have not been implemented: Draft Law No. 13716 of 29 August 2025 did not introduce performance outcomes as an additional evaluation criterion, and the measures on performance evaluation and use of certification results in managerial decisions were applied only to officers in leadership positions.
The Ministry of Internal Affairs fully ignores this issue, whereas the National Police incorporated the old draft law into its 2025–2027 action plan, disregarding concerns raised by the NACP and civil society.
4. Anti-corruption programs ignore internal HR issues in the National Police, including high turnover and low remuneration
In 2024, the Ministry of Internal Affairs published a report on improving HR policy and police remuneration to enhance the competitiveness of police service in the labour market.
The MIA report notes that the police force experiences high personnel turnover, driven by both dismissals and voluntary resignations. According to official data, in 2022 only 3,801 individuals were recruited, compared to 14,087 individuals in 2017. Meanwhile, 10,747 officers left the service in 2022, up from 8,831 in 2017. The number of unfilled positions also rose, reaching 22,073 in 2022.
A further important consideration is the deployment of 17,000 police officers to counter the russian federation’s armed aggression on the frontlines while, according to the Head of the NPU, the total number of police officers rests at approximately 100,000. Such a situation increases the workload of active personnel, also contributing to staff attrition.
Given the current personnel crisis in the NPU, the Ministry of Internal Affairs has been compelled to acknowledge that the salary structure of the police in Ukraine places officers in a vulnerable position of dependence. As of 2023, a full 75% of their income consists of bonuses, while only 10% comes from the base salary, 3% from rank-based salary, and 12% from allowances for specific service conditions. This overreliance on discretionary bonuses not only undermines fair and stable pay but also increases officers’ vulnerability to undue influence and internal pressure.
Similarly, the Ministry of Internal Affairs overlooks this issue, whereas the National Police only refers to a 2024 analytical study, without implementing any follow-up measures through 2027.
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