Co-authored by Pavlo Kaplia, Senior Manager, Forensic & Anti-Bribery Services, Deloitte Ukraine.
Corruption remains one of the most persistent challenges confronting Ukraine - a reality widely acknowledged by the government, society, international partners, and experts alike. Yet this broad diagnosis raises a deeper question: what lies behind it? The situation is somewhat similar to medicine. It is not enough to state that a patient is unwell; one must also determine which systems of the body are failing and what symptoms and indicators reveal the underlying causes.
This article explores different approaches to evaluating the corruption environment in Ukraine. To do so, we review five sources which, in our view, help provide an answer to this question:
The Corruption Perceptions Index (CPI), published by Transparency International, is among the best-known and most frequently cited measures of corruption. Proper use of the CPI requires a clear understanding of its conceptual foundations and the methodology behind its calculation, which are explained in detail in Transparency International’s supporting materials. Here, we highlight a few key points.
First, the CPI is an index of perception, not a measure of the actual level of corruption. Public perceptions of corruption and real experiences with corruption can differ substantially. A wide range of factors influences the perception of corruption, from media coverage and the activities of anti-corruption bodies to historically established social practices. A notable example is Portugal. According to Eurobarometer surveys in the EU, Portugal has one of the highest levels of perceived corruption among European countries, while its actual experiences of corruption are among the lowest. In this sense, proper use of the CPI requires a clear understanding that it reflects societal perceptions rather than objective corruption levels. It is also important to recognize who constitutes the “perceivers.” In the case of the CPI, it is not the general population, but representatives of business, international and national experts who participate in various international surveys, whose responses are then aggregated to produce the overall CPI according to the methodology described by Transparency International.
Second, the CPI measures perceptions of corruption specifically in the public sector. However, it is important to recognize that the public sector is large and diverse, and private businesses - both in Ukraine and globally - interact with it in different ways. For some companies, the state is a key client or important supplier; for others, it serves as a regulator, making decisions on critical permits and licenses necessary for conducting their business; while others have only minimal interaction with the state, such as paying taxes. The greater a business’s dependence on the public sector, the more relevant the corruption perceptions index becomes, and vice versa. It is also important to remember that corruption in the public sector takes different forms: political corruption involving politicians and government officials; corruption in interactions between business and the state, for example in public procurement, licensing, customs administration, etc.; and petty corruption, which citizens encounter in areas such as healthcare, education, and other public services. According to Eurobarometer data, on average 51% of the EU population considers corruption widespread among political parties (with the highest levels in Spain (79%), Greece (69%), and Cyprus (67%)), while perceptions of corruption in tax authorities or at the everyday level are significantly lower. A similar trend is observed in Ukraine’s annual surveys conducted by the NACP: political corruption is perceived as the most problematic area, whereas interactions with tax authorities are seen as carrying comparatively lower corruption risks. The aggregate CPI combines all these dimensions and can vary in response to events affecting particular types of corruption (for example, political corruption), a factor that should be borne in mind when interpreting the results in a given analytical context.
Third, the CPI should be used with an awareness of its methodological limitations, which have a direct impact on result interpretation. In particular, Transparency International Ukraine notes on its website that CPI scores for a given year, released by Transparency International at the start of the following year, may not fully account for reforms and other changes carried out during that year. Considering the rapid pace of anti-corruption initiatives in Ukraine, this factor can be highly relevant for the correct application of the index in the context of our analysis.
According to the methodology for calculating the 2024–2025 CPI and the detailed source descriptions available on the Transparency International Ukraine website, the CPI for Ukraine was constructed as an average of eight international surveys, with data collected at different points in time. For the 2024 CPI, the surveys covered the period from early 2021 to the third quarter of 2024, while for the 2025 CPI, they covered from early 2023 to the third quarter of 2025. Furthermore, in two instances for the 2025 CPI, data from surveys previously used for the 2024 CPI - covering 2023 - were included due to the lack of updated data for those sources.
For illustrative purposes, the table below presents the questions from three of the eight surveys underpinning Ukraine’s CPI, providing readers with the opportunity to evaluate the comparability and relevance of the question wording in relation to assessing the corruption environment and the intended purpose of such an evaluation.
Because the questions in the surveys are not fully equivalent, the resulting scores may differ. To illustrate, we present a comparison of the three indices included in the calculation of the 2024 CPI.
According to the Country Ratings, calculated using the Economist Intelligence Unit’s Country Risk data, Ukraine received a score of 18 — the lowest of the five possible ratings (18, 35, 51, 67, 83). This score is shared by 30 countries ranked below Ukraine in the CPI, including Kenya (121st), Uzbekistan (121st), Pakistan (135th), Iraq (140th), Iran (151st), Congo (151st), Azerbaijan (154th), Sudan (170th), Syria (177th), and Venezuela (178th). Meanwhile, 20 countries ranked below Ukraine in the CPI have a higher Country Rating (35), such as Turkey (107th), Belarus (114th), Egypt (130th), Uganda (140th), Mozambique (146th), and Paraguay (149th). Interestingly, among countries ranked above - and sometimes significantly above - Ukraine in the CPI, there are also countries with a score of 35, including the Czech Republic (46th), Greece (59th), Malta (65th), Bulgaria (76th), Moldova (76th), and Albania (80th). In effect, according to the Economist Intelligence Unit, the Czech Republic and Malta have the same rating as Belarus, Uganda, and Paraguay, whereas Ukraine’s score is on par with Syria and Venezuela.
The Transformation Index is produced by the Bertelsmann Foundation, a well-known German think tank established in 1977. In this ranking, Ukraine received the same score as countries positioned much higher, including Poland (53rd), Malaysia (57th), Armenia (63rd), and Bulgaria (76th), as well as countries at roughly the same level, such as Argentina (99th).
The comparison between the Bertelsmann Foundation and Economist Intelligence Unit rankings makes the overall picture more complex. Of the 63 countries ranked above Ukraine in the CPI that have Bertelsmann Foundation scores, 32 have a lower score than Ukraine according to Bertelsmann but a higher score according to the Economist Intelligence Unit.
A notable example is Saudi Arabia, which shares 38th place with Latvia in the 2024 CPI and received:
This demonstrates that the Country Ratings and the Transformation Index can portray quite different situations for some countries.
The World Economic Forum Executive Opinion Survey, which gathers the views of business managers, also provides interesting insights. According to this survey, Ukraine scores higher than a number of countries ranked above it in the overall CPI, including Kazakhstan (88th), Latvia (38th), Slovakia (59th), and Croatia (63rd). At the same time, the business communities in these countries assess their national level of corruption at roughly the same level as respondents in Serbia (105th) and Pakistan (135th).
Opposite examples can also be observed. In Egypt (130th), the business community rates the national level of corruption similarly to Germany (15th). This highlights the variation in subjective perceptions of corruption across countries: behaviors considered highly corrupt in one context may be perceived as standard practice in another. These differences shape survey responses and, in turn, influence a country’s position in the corruption perception index.
Our comments are not meant to question the CPI, which is widely regarded as a valuable and authoritative benchmark. Instead, we aim to stress the importance of its informed and proper use, and we strongly advise reviewing the additional methodological materials published by Transparency International to ensure the index is applied in the most suitable context. Notably, the documentation accompanying the 2025 Corruption Perceptions Index shows that Transparency International Ukraine continues to provide increasingly detailed explanations and commentary, supporting a more thorough understanding of the index’s findings.
When reviewing the corruption environment, it is also important to take into account the anti-corruption measures being implemented in Ukraine, aimed at reducing overall corruption in the long term. In this context, the assessments conducted under the Istanbul Anti-Corruption Action Plan, supported by the OECD Anti-Corruption Network, are particularly useful. According to the NACP, the OECD Anti-Corruption Network is a regional program established in 1998 within the OECD Working Group on Bribery. Its mission is to assist ten member countries - Ukraine, Armenia, Kazakhstan, Kyrgyzstan, Moldova, Mongolia, Tajikistan, Azerbaijan, Uzbekistan, and Georgia - in preventing and combating corruption. One of the main instruments of this support is the Istanbul Action Plan, which evaluates various aspects of anti-corruption efforts and integrity development in member states.
Since 2003, Ukraine has completed five assessment cycles under the Istanbul Anti-Corruption Action Plan. The methodology of the most recent (fifth) round covers nine areas linked to anti-corruption efforts and integrity development; for Ukraine, a condensed review was conducted, encompassing five of these areas (see the table below). Each area comprises a set of indicators, with each indicator evaluated using a series of detailed, concrete questions.
Other countries that also underwent the fifth round of assessment include Kazakhstan, Kyrgyzstan, Tajikistan, Moldova, Azerbaijan, and Armenia. The corresponding reports were published on the OECD website in 2024.
How can Ukraine’s results be compared with those of other countries?
A comparison between Ukraine and three higher-ranked countries in the 2024 CPI - Kazakhstan (88th), Moldova (76th, ahead of Albania and Hungary and equivalent to Bulgaria), and Armenia (63rd, ahead of Romania and equivalent to Croatia) - indicates that Ukraine scores higher on specific indicators.
In particular, Ukraine received the highest rating for its asset declaration practices and ranked second on indicators related to the activities of anti-corruption bodies and enforcement of corruption offenses.
Unfortunately, such evaluations - based on clear indicators and metrics - are applied only to countries participating in this OECD regional program, and none of them are EU member states. Can anti-corruption measures in Ukraine be compared with those in European countries? Not fully. However, a different assessment conducted within the OECD framework, discussed below, allows for a partial comparison.
The OECD has developed the Corruption & Integrity Framework, an assessment model designed to evaluate anti-corruption policies and integrity systems. The framework covers six key areas: anti-corruption strategy, corruption risk management and audit, conflict of interest, lobbying, political finance, and transparency of public information.
According to the National Agency on Corruption Prevention (NACP), Ukraine joined this initiative in March 2023 and became one of the first non-OECD countries to participate. The initiative, launched by the OECD Working Party on Public Integrity and Anti-Corruption, seeks to assist more than 30 countries in shifting from subjective assessments in this field to evidence-based, objective data.
The most recent report on Ukraine was published in 2025, with a summary of the assessment presented in the Fact Sheet. However, a time lag exists between data collection and publication. As indicated in the Fact Sheet, the assessment of the anti-corruption strategy relied on 2023 data, while the evaluation of conflict of interest, lobbying, political financing, and transparency of public information was based on 2024 data.
What do the results indicate?
Some of these results appear counterintuitive. Several countries that Ukraine surpasses in internal control and risk management have a long-standing reputation for strong governance systems and are often viewed as benchmarks of international best practice. This underscores both the importance of careful interpretation of governance indicators and the broader challenge of designing methodologies that ensure meaningful cross-country comparability.
A useful source for assessing the corruption environment and its evolution is the annual nationwide surveys of citizens and business representatives conducted as part of the comprehensive assessment of corruption in Ukraine. Since 2017, six waves of these surveys have been carried out by specialised research organisations commissioned by the NACP. Each wave covered more than 1,000 business representatives and over 2,000 members of the general public, providing a sufficiently long time series to identify key trends. As a result, the surveys constitute a systematic and valuable source of empirical information on various aspects of corruption in Ukraine.
Below we highlight several findings from the Analytical Report based on the 2024 survey of citizens and businesses:
Taken together, these annual surveys provide a rich empirical basis for understanding the corruption environment in Ukraine.
Comparisons with EU countries are possible only to a limited extent, primarily through the results of the Eurobarometer survey, discussed below.
The Eurobarometer survey, initiated by the European Commission, examines the level of corruption perception among EU citizens as well as their personal experience with corruption. Since its first edition in 2005, the survey has been conducted ten times.
Below we present several findings from the 2025 survey that may be useful for comparison with the results of similar studies conducted in Ukraine.
On average, 69% of EU citizens believe that corruption is widespread in their country: 23% consider it to be very widespread and 46% fairly widespread. In Ukraine, according to the NACP’s 2024 survey, 91.4% of respondents viewed corruption as either somewhat widespread (30.2%) or very widespread (61.2%).
Which EU countries demonstrate a level of perceived corruption comparable to that observed in Ukraine? These include Greece (97%), Croatia (92%), Portugal (91%), Cyprus (90%), and Hungary (89%). At the same time, the share of citizens who consider corruption very widespread is lower in these countries than in Ukraine: Greece (56%), Croatia (51%), Portugal (34%), Cyprus (57%), and Hungary (33%).
It is worth noting that, as emphasized by the NACP in its studies, perceptions of corruption and actual experiences of corruption are distinct concepts. Public perceptions of corruption are shaped by a wide range of factors. This is also reflected in the Eurobarometer results: the countries with the highest levels of reported personal corruption experience are not necessarily those where the largest share of citizens believe corruption to be very widespread.
For example, 12% of respondents in both Bulgaria and Croatia reported having personal experience with corruption, compared with 11% in Slovakia and 9% in Greece and Cyprus. By contrast, in Portugal, where 91% of respondents believe corruption is widespread - including 34% who consider it fairly widespread, a relatively high figure by EU standards - only 1% reported direct personal experience with corruption, the lowest rate in the EU.
In Ukraine, according to NACP data, 18.7% of surveyed citizens reported personal experience with corruption, which is higher than in the EU countries mentioned above and significantly higher than the EU average of 5%.
Readers interested in exploring these findings further may wish to consult the data visualization available on the NACP website, which provides a helpful overview of these indicators.
Another noteworthy indicator concerns the share of EU citizens who consider it acceptable to provide services or material benefits to public officials as gratitude for their work. According to the survey results, 28% of respondents consider providing reciprocal favours acceptable, 25% consider giving gifts acceptable, and 19% consider giving money acceptable. At the same time, 4–5% believe such practices are always acceptable, while the remaining respondents regard them as acceptable only occasionally. Conversely, 71% of respondents believe reciprocal favours should never be acceptable, 74% say the same about gifts, and 80% about money. For comparison, in Ukraine, the share of citizens who believe that giving a bribe, informal service, or gift - even if necessary to resolve an important issue - can never be justified reached 48.1%, according to the 2024 national survey. Although this indicator has been improving each year, it still remains significantly below the European average. At the same time, neighbouring Poland ranks among the top ten EU countries in terms of the share of respondents who consider such practices never acceptable: 73% regarding reciprocal favours, 72% regarding gifts, and 82% regarding money. In Portugal, citizens demonstrate the lowest tolerance in the EU toward such practices: 89%, 90%, and 98% respectively consider reciprocal favours, gifts, and money to be never acceptable. This may partly explain why Portuguese society evaluates corruption in the public sector very critically, while at the same time reporting the lowest level of personal corruption experience in the EU.
It is worth noting that attitudes toward corruption can differ widely among various groups, and the trajectory of actual corruption in a country may align more closely with changes in the mindset of certain segments of the population. In Lithuania, a country that ranks highly in anti-corruption measures, annual surveys track both perceived and experienced corruption across sectors and demographic groups. Notably, the level of tolerance for corruption—the belief that it can help solve problems—has fallen over time: among the general population from 75% to 65%, among corporate executives from 75% to 33%, and among public servants from 68% to 13% between 2008 and 2023.
Corruption in Ukraine remains a significant challenge, and measuring it is equally complex. Corruption is a multidimensional phenomenon that hardly could be captured by a single metric.
Each measure provides a different perspective: perception vs. actual experience, laws vs. practice, the public sector as a whole vs. specific segments. Relying on a single number, without context, can mislead as much as ignoring it entirely.
As Albert Einstein noted, “The formulation of a problem is often more important than its solution.” A company with minimal interaction with the state faces a very different corruption environment than one for which the state is a key client or regulator. Societal perception of corruption and the actual experience of businesses are not equivalent.
For businesses, the corruption environment is not abstract - it consists of specific risks, procedures, and interaction points with the state. Any universal measure inevitably oversimplifies complex reality and carries the risk of misleading conclusions. The appropriateness of simplification depends on the purpose of the analysis.
In this regard, the quality of conclusions depends on the quality of the questions asked. Context, rather than any single index, should serve as the starting point for a responsible assessment of the corruption environment. Fortunately, a range of international metrics and national studies can help reveal more pieces of the puzzle and enable a more holistic assessment of corruption risks.