Since the beginning of the ongoing full-scale invasion, we have been working in the recovery field for 4 years (since March 2022) by developing legislative acts, monitoring the use of funds and providing state authorities with expertise on how to make the recovery process more transparent and accountable, as well as building a network of regional activists and journalists through the Anti-Corruption School.
Our activities consist of precise monitoring, legislative and analytical work, advocacy, investigations, and stakeholder engagement:
1. Shaping legislation and advocating a robust recovery architecture.
In 2023-2024, when the recovery framework was being actively shaped, we played a proactive role and contributed to key my developments within the smart recovery architecture. Key achievements include progress with the first and largest recovery financing mechanism, the Fund for the Liquidation of the Consequences of Armed Aggression, where transparency safeguards were established, as well as with the Agency for Restoration, notably the creation of a Central Procurement Organization to manage procurement processes.
In addition, we actively defended the institutional independence of local self-government bodies and consistently emphasized the importance of maintaining decentralization and preventing its backsliding. Thus, we have consistently advocated for fair access to the resources, for example stood for the independence of local government bodies in submitting projects for funding on their own, rather than through the presidential administrative vertical.
We also promoted civil participation and the engagement of local self-government bodies in decision-making processes, emphasizing the importance of their involvement, particularly in commissions where they have generally been excluded. This work reinforces the role of civil society and communities in shaping reconstruction policies and ensures that governance is more inclusive and accountable.
For this reason, we have systematically emphasized the need to implement the highest level of transparency during projects financing: the ability for local government bodies to submit projects for funding independently; publication of clear project criteria; clear prioritization of projects; publication of announcements for meetings, agendas, minutes, and decisions made; and inclusiveness of decision-making.
Below are some examples of our input:
- Through our consistent advocacy in 2022-2024, we have managed to define several transparency safeguards in the mechanism of the Fund for the Liquidation of the Consequences of Armed Aggression, namely: prioritization (the methodology for which we were developing together with the RISE community), the requirement to publish minutes, agendas, and submitted proposals to make the whole process transparent. See details in our brief regarding the Fund for the Liquidation of the Consequences of Armed Aggression at the link.
- According to RDNA4 13 percent of the total housing stock was damaged or destroyed, affecting more than 2.5 million households. In 2023, we examined the procedure for fund allocation under the eRecovery program (a state subsidy program for damaged and destroyed property) and advocated for the introduction of transparent mechanisms in determining compensation amounts for damaged housing. Specifically, we recommended moving away from a fixed-package approach and instead calculating compensation based on the cost of each specific type of repair work. Moreover, based on MEZHA`s anti-corruption examination conclusion and advocacy campaign, the eRecovery commission should include representatives of civil society (a third of the composition). As a result, the discretionary powers of local commissions were reduced, enabling people to receive fair compensation based on actual damage in a more transparent and fair way. Moreover, the mechanisms we have improved will apply to at least 2.5 million people.
- In 2023, we were the first and only organization to comprehensively analyze the entire regulatory framework of the United24 platform, through which donations from around the globe are being collected to support Ukraine’s reconstruction. The platform has already raised nearly €2.9 billion in total. This work was particularly important because international partners and ordinary citizens around the world place significant trust in this instrument, making transparent implementation essential. We advocated for the list of measures including the clear separation of accounts for collecting voluntary contributions on the United24 platform from regular ministry accounts; the establishment of key provisions for public reporting on fund usage; the definition of priority funding areas, among other actions, to enhance transparency and enable effective civic monitoring, and others. As a result, the regulations have been amended.
- In addition, we made a significant contribution to blocking potentially harmful initiatives, such as the presidential draft law on reconstruction fund. Although it was publicly announced, civil society persuaded the authorities to abandon the idea due to the identified risks, namely: the absence of objective criteria, which would allow reconstruction projects to be selected based on political influence; the neglect of local government’s role, with key decisions being concentrated in the presidential vertical. As a result, the draft was never formally submitted.
2. Monitoring of funds allocation and prompt response to detected violations.
We have monitored the allocation of over UAH 64 billion (approx. EUR 1,2 billion) from the Fund for Liquidation of the Consequences of Armed Aggression and UNITED24 accounts (approx. EUR 33 mln) from the very start, ensuring transparency and accountability for the past four years. We first advocated for regulatory changes to ensure transparency and enable civil society monitoring, and subsequently carried out this monitoring ourselves.
Below are some examples of our results:
- We blocked the use of funds for suspicious projects amounting to almost UAH 655.8 million (EUR 12.7 million). For example, we blocked the creation of the State Online Monitoring System and the purchase of services for its operation in the amount of UAH 62.4 million . In 2021, a procurement was already conducted for the development of this system, but the expected cost was over 10 times lower – UAH 5.4 million. Moreover, in September 2023, in the regulatory impact analysis of the CMU Resolution “On Approval of the Procedure for the Functioning of the State Online Monitoring System,” the expenses for creating this system amounted to 46 million. Thus, different prices were indicated – 62.4, 46, 5.4 million UAH and doubts arose about the justification of the specified cost. It is also important to note that the state institution which requested those funds was later liquidated, meaning that these funds would not have led to any tangible results.
- Based on our monitoring we informed state authorities, including the State Audit Service of Ukraine, about violations because bringing them to justice is extremely important for us. For example, our team identified an overstatement of the cost of building materials amounting to UAH 25,6 million for construction of the treatment and rehabilitation building at the State Institution “M.M. Amosov National Institute of Cardiovascular Surgery of the National Academy of Medical Sciences of Ukraine”. The State Audit Service took this into account during the audit.
(You can read more about our work in our reports: for the period from August 2023 to February 2024 – at this link; for the period from March 2024 to August 2024 – at this link; and from September 2024 to January 2025 – at this link).
3. Analytics and search for solutions to minimize corruption in reconstruction.
Since 2022, we have prepared nearly 15 analytical researches in the recovery sphere aimed at identifying risks and gaps, as well as providing recommendations on how to improve procedures, fund allocation, and the institutional capacity of the authorities involved. Our research covered both financial mechanisms (such as the Fund for the Liquidation of the Consequences of Armed Aggression, the United24 accounts, EIB financial instruments, and initiatives to establish various recovery funds), institutions, including the Agency for Restoration, as well as procedures and the legislative framework. We applied a unique methodology that went beyond an analysis of legislation and included the practice of its implementation and interviews.
You can see some of them at the following links below:
- Research on Financing Mechanisms for Recovery Projects in 2022–2024 (2025). We examined how recovery projects were financed based on a sample of 100 selected projects across four regions, whose implementation began in 2022–2024. The study identified a range of procedural risks and provided recommendations to mitigate them.
- Research on Humanitarian Aid Distribution Procedures (2025).We analyzed approximately 30 communities to assess how systems for receiving and distributing humanitarian aid are organized and whether internal regulations have been adopted to ensure accountability of the process. Based on the findings, we developed a set of practical recommendations for communities to strengthen transparency and accountability.
- Draft Law “On the Principles of Recovery of Ukraine”: A Framework Law or a Tool for Transparent Recovery (2024). The study examined key issues related to prioritization issues, regulation of the activities of the State Agency for Restoration, development of recovery planning documents, as well as procurement-related risks arising in the recovery process.
- What Challenges Does Civil Society Identify in the Recovery Process? (2024). The purpose of this analytical brief is to raise awareness among the society and international partners about Ukraine’s recovery processes. The brief reflects the vision of civil society on what the recovery architecture should look like and how transparency and effectiveness in recovery processes can be ensured.
- Fund for the Liquidation of the Consequences of Armed Aggression: Procedural Shortcomings (2023). This was our first in-depth analysis devoted to the Fund and the risks associated with the use of its resources, particularly regarding prioritization, public access to decision-making, process transparency, and the risks of politically motivated decisions.
- State Agency for Restoration: Anti-corruption Challenges (2023). We analyzed the legal and organizational structure of the Agency for Restoration and the Restoration Services under its oversight, reviewed their anti-corruption programs, and identified operational risks. Practical recommendations were provided to address these issues and strengthen accountability.
- United24: Transparent and Accountable Use of Recovery Funds through Accounts for Support of Ukraine (2023). We analyzed 10 regulations governing the procedures for using funds from United24 donation accounts for Ukraine’s support, as well as their practical implementation. We examined publicly available information on procedure implementation and conducted interviews with representatives from ministries managing the accounts. The study systematized the shortcomings in transparency and accountability in fund usage procedures and provided recommendations for their mitigation.
Our work also focuses on developing internal procedures and strengthening key institutions, including the Ministry for Restoration. In close cooperation with the Ministry, we contributed to the development of approximately 30% of the measures included in its Anti-Corruption Program for 2023–2025.
In addition, we continuously monitor and inform the society and other stakeholders about key developments, as well as institutional and legislative changes in the reconstruction process, with particular emphasis on identified risks. Our latest overview, reflecting the situation as of summer 2025, can be found at the following link.
To deliver concrete results, we maintain connections with the entire stakeholder community, and discuss our recommendations together. Below is one of our latest presentations on the risks in allocating funds for recovery projects, along with the follow-up from the event, available at the following link.
4. Civic anti-corruption investigations.
Our uniqueness lies in the fact that we operate not only as an analytical and advocacy center, but also conduct investigations ourselves. This allows us to see how initiatives are implemented on the ground, identify the factors that facilitate it, and, as a result, develop a holistic view.
Our investigations are broadcast on national Suspilne TV and 24 Channel. For example, one of them revealed information about Serhii Natrus, an official of the Donetsk Regional Military Administration. He organized the procurement of specialized equipment for addressing the consequences of russian aggression at an inflated cost, overpriced by UAH 30 million, personally profiting by UAH 10 million during his time in public service. This investigation is available via the link on YouTube.
Moreover, our investigations are published on high-profile media outlets. For example, one of our investigations into the procurement of wood for fortifications from fictitious companies, worth UAH 400 million, was published on Ukrainska Pravda and gathered over 140,000 views. This led to the dismissal of some public officials involved in the scheme (for example, the Deputy Head of the Kharkiv Oblast Administration), and numerous criminal proceedings were initiated.
5. Building a network of regional investigators, journalists – Anti-Corruption School.
Municipalities and local governments own most of the affected facilities (civilian and critical infrastructure), as they have received more powers and resources following the decentralization reform. At the local level, they are the ones who decide what to rebuild and what not to rebuild, which projects to submit for funding, manage resources, and most importantly, organize procurement, and thus exercise those powers where there are the greatest corruption risks. Thus, anti-corruption activities, civic monitoring and control at the local level are becoming critical.
That is why, we founded the Anti-Corruption School – a powerful community of regional anti-corruption activists, investigators and journalists.
The idea of the community is as follows:
1) A six-day offline intensive course, where the best top experts in the field of anti-corruption (for example, Mykhailo Tkach, Maksym Savchuk, Vitaliy Shabunin, Yurii Nikolov, etc.) teach selected participants from all regions of Ukraine.
2) The alumni of the Anti-Corruption School become members of the Anti-Corruption School community and get access to the entire infrastructure of the Anti-Corruption School: Help Desk (24/7 consultations and support on different matters), education component, experience exchange, community building, etc.
We already have 50 graduates who have joined a powerful community of regional activists and investigators (alumni of the Anti-Corruption School) all over Ukraine and continue to expand this community.
For more details, see the following publication.
6. Stakeholders engagement.
We actively collaborate with local government authorities (partnerships with 15 mayors across Ukraine), state authorities (including the NACP, the Ministry of Restoration, the Ministry of Digital Transformation, the Secretariat of the Cabinet of Ministers of Ukraine, the Agency for Restoration, the Accounting Chamber, the State Audit Service of Ukraine, etc.), as well as civil society.
In 2024 our Head, Martina Boguslavets, was a Chair of the Board, Rise.Ukraine – a coalition of over 50 civil society organizations working for Ukraine’s Reconstruction Integrity, Sustainability and Efficiency.
(Our team on a field visit to Chuhuiv, Kharkiv region).
7. Trusted partnership with international stakeholders.
Cooperation with international partners is critically important to us, as their contribution to Ukraine’s recovery will be decisive. Ukraine will never have sufficient domestic resources alone to fully finance the reconstruction process. At the same time, it is essential that international partners receive objective, reliable information from independent civil society actors.
Within this framework, we consistently promote Ukraine’s interests internationally, while also highlighting successes and best practices that should be scaled up, and advocating for the changes necessary to ensure effective and transparent recovery. Since 2022 MEZHA has undertaken nearly 40 advocacy trips to EU countries and the United States, including to promote reforms necessary, in particular for transparent reconstruction.
We advocate for Ukraine’s interests on different international platforms and through important contacts:
- Ukraine Recovery Conferences in London, Berlin and Rome;
- International Anti-Corruption Conference in Vilnius;
- participation in different panels discussions, roundtables, etc. (for example, a panel discussion alongside the Head of the Restoration Agency, the Director of NABU);
- non-public meetings, such as Wilton Park Conference;
- well-established communication with Members of the European Parliament and European Commission institutions, including DG ENEST, DG Home, and DG Justice, World Bank, European Investment Bank, International Monetary Fund, etc.;
- cooperation with U4, where our Head acted as a national expert.
