Report on the Results of Monitoring the Implementation of Measures under the Roadmap on the Functioning of Democratic Institutions (RFDI)

Introduction. Monitoring Methodology

The Roadmap on the Functioning of Democratic Institutions (hereinafter — the RFDI or the Roadmap) was approved by the Cabinet of Ministers of Ukraine on 14 May 2025. The RFDI defines priority areas and reform objectives in the fields of ensuring democracy, electoral processes, parliamentary reform, and the functioning of civil society. For each reform area, the RFDI sets out a list of measures to be taken to achieve the reform objectives, along with deadlines for their implementation. All reforms in the RFDI are divided into four groups, covered by four separate sections: “General Framework of Democracy”, “Electoral Processes”, “Functioning of Parliaments in a Democratic System”, and “Role of Civil Society”.

Throughout May – July 2026, the Civic Network OPORA conducted a preliminary assessment of the state of implementation of reforms across all sections of the Roadmap on the Functioning of Democratic Institutions (RFDI). In August 2026 the results of this assessment were shared with the relevant ministries, committees of the Verkhovna Rada of Ukraine, other state bodies (the Central Election Commission, the National Agency on Corruption Prevention, the National Council of Ukraine on Television and Radio Broadcasting, and others), as well as with Ukrainian civil-society and international organisations, for additional verification, comments and proposals aimed at improving both the report itself and the assessment of progress on individual RFDI measures. The great majority of the proposals received were taken into account in the updated version of the report, which was finalised on 15 October 2026. The report also reflects developments in the implementation of RFDI measures that occurred between July and October 2026.

The assessment of each measure under every section of the RFDI was carried out according to two parameters: the importance of the measure for achieving the objectives of the relevant reform and the status of its implementation. Depending on its importance, each measure was assigned a weight from 1 to 3 points (the full list of RFDI measures by reform priority is avaliable in Annex 2). If the implementation of a measure would allow substantial progress in the overall implementation of the reform (for example, improving parliamentary oversight or the legislative process significantly enhances the institutional capacity of the Verkhovna Rada) or is critical to Ukraine’s European integration path, it was given a weight of 3 points. If a measure has a secondary impact on reform implementation (for example, holding a round table or information campaign on a newly adopted law), its weight is 1 point. The full assessment of the implementation status of all RFDI measures is provided in Annex 1.

The status of implementation was assessed on a scale from 0 to 5 points, where 0 points corresponds to the complete absence of any activity towards implementation, and 5 points corresponds to full implementation in accordance with the wording of the measure in the RFDI. Measures whose implementation is impossible without the lifting of martial law, or (in the case of elections) measures that are to be implemented after the start of the electoral process for the first post-war elections, were excluded from the assessment.

This document presents the results of the monitoring of RFDI implementation across all sections of the Roadmap as of October 15, 2026, as well as general recommendations for improving the effectiveness of RFDI implementation.

1. General Framework of Democracy

Implementation of measures under the “General Framework of Democracy” section is the least satisfactory of all those analysed by OPORA.

The only notable success in this section has been the Government’s approval of the Strategy for reforming local self-government and the territorial organisation of power under martial law, and the submission to the Verkhovna Rada of several bills addressing specific, narrow, local self-government issues. These include bills on the division of powers between levels of public governance, ensuring the continued functioning of local councils under martial law, and defining the status of staff in military administrations of communities (bills Nos. 14412, 14405, 14319 and 15543). However, even this success is limited: the submitted bills do not resolve all problems facing local self-government under martial law; the government strategy itself is vague and requires further revision; and its implementation requires the Ministry of Reconstruction to approve an action plan, which is still being drafted.

No meaningful progress has been made on any other measures in this section. Instead of restoring local self-government on Ukrainian-controlled territory, there has been a trend towards its further curtailment through the transfer of local authority powers to military administrations. Periodic review of the justification for rights and freedoms restrictions introduced under martial law is not being carried out at central level. No legal framework has been established for such reviews, no responsible body has been designated, and there are no provisions on its powers, the frequency of reviews or the procedure for documenting their outcomes. Between early August and 15 October 2026 no further progress was made on the measures in this section.

2. Electoral Processes

The most visible achievements in electoral reform (Section II of the Roadmap) have been the launch in December 2025 of systematic updating of the State Voter Register database and the submission to parliament of several important bills: on reforming legislation on political parties (No. 14289), on exceptions to the residency requirement and ensuring the effectiveness of gender quotas in elections (No. 11300), and on improving oversight of election campaign financing (No. 11462). At the same time, the fact that none of them has even been adopted at first reading casts serious doubt on the existence of genuine political will to pursue either electoral reform or the reform of party legislation, including the financing of political parties and election campaigns.

Systematic updating of the State Voter Register database is critical to enabling voters to exercise their right to vote, preventing abuse/fraud during voting, and ensuring the overall administration of elections. However, full updating is hampered by mass forced migration of voters, the occupation of part of Ukraine’s territory, the lack of data on voters in occupied areas, the inability of register-maintenance bodies to operate in active combat zones, and the absence of reliable data on voters abroad. Until these issues are resolved, the SVR database will still require updating. Even after comprehensive updating, the accuracy and relevance of the data should be verified through an independent external audit, for which no legal basis has yet been created.

In other important areas of electoral work, noticeable progress remains absent. The OSCE/ODIHR recommendations on improving electoral legislation continue to go unimplemented by Parliament, even though the Central Election Commission prepared concrete proposals for their implementation as long ago as 2025. Despite the CEC’s active role in advancing electoral reform, that role remains constrained either by the lack of budgetary funding (which prevents the Commission, among other things, from establishing territorial offices, ensuring the proper functioning of the Training Centre for Election Process Participants, and introducing certain other changes) or by the absence of further steps on the part of Parliament to support and enact the Commission’s legislative proposals.

Considerable hopes had been placed on the Working Group established by the Speaker of the Verkhovna Rada in December 2025 to prepare legislative proposals for elections in the special or post-war period. This WG was tasked with drafting a special law on the conduct of the first post-war nationwide elections, which was expected to take into account most of the European Commission’s 2025 recommendations, i.e. concerning voting rights for military personnel and displaced persons (external migrants and IDPs), regulation of political advertising, countering disinformation and cyber threats, and updating and auditing the SVR. The WG was formed on an inclusive basis, and its seven thematic sub-groups produced proposals for the bill in February–March 2026. However, work on the draft effectively ceased since May 5, 2026, even though the Verkhovna Rada’s leadership publicly stated that the WG will further focus on specific election-related issues, such as election system reform, lustration of elected officials/candidates for elections, and election dispute resolution. Despite these statements, no WG schedule and agendas for its meetings in the next few months have been made public so far. Even if the Working Group was to finalise the draft special law and if the bill was agreed upon by the stakeholders and submitted to the Verkhovna Rada, this would not have guaranteed its swift adoption as proposed by the WG. The group’s role in electoral reform is also significantly limited by the fact that its mandate covers only the first post-war nationwide elections. It does not cover first post-war local elections, referendums, implementation of ODIHR recommendations (except for regulation of media in elections) and other non-war-related issues.

3. Functioning of Parliaments in a Democratic System

Achievements in parliamentary reform (Section III of the Roadmap) are even more modest than in electoral legislation reform. The greatest progress has been made in increasing the transparency of parliament’s work and implementing the Law “On Lobbying in Ukraine”. While the implementation of the Law “On Lobbying in Ukraine” formally complies with the RFDI, many civil-society organisations take the view that it creates significant risks for the functioning of civil society. Their legitimate activities in representing the public interest risk being interpreted as “commercial interest” within the meaning of the Law. In that event they would be subjected to disproportionately burdensome reporting requirements, disclosure of “lobbying” contacts, and possible restrictions on access to information and premises of public authorities under the pretext of registration as lobbyists. The Law also creates the risk of sanctions being applied to civil-society organisations for failure to register as lobbyists. Despite these risks, no initiatives have been introduced in Parliament to address them, nor have any bills been tabled to remedy the other shortcomings of the Law that stakeholders highlighted during discussions of the draft in the Working Group attached to the relevant parliamentary committee.

Other achievements include the registration/adoption at the first reading of bills necessary for the reform of parliamentary service (No. 4530), an accelerated procedure for considering European-integration bills (Nos. 8242, 13653 and 13653-1), and the submission of a draft Code of Ethics (No. 8327). However, as with the electoral bills, doubts remain about the political will to adopt them: some have been awaiting consideration for more than five years, and only one (No. 4530) was adopted at least in first reading.

The key tasks of parliamentary reform – legislative regulation of the status of the parliamentary opposition, improvement of the quality of the law-making process, enhancement of parliamentary oversight, and prevention of corruption and undue influence on the legislative process – remain unfulfilled. The postponement of the entry into force of the Law “On Law-Making Activity” (one year after the lifting of martial law) has a negative impact on the introduction of ex-ante and ex-post monitoring (although some parliamentary committees, with support from the Westminster Foundation for Democracy and/or in co-operation with the Agency of Legislative Initiatives, are running pilot projects in this regard). Certain advances towards the introduction of procedures necessary for the approximation of Ukrainian legislation to EU law cannot compensate for the continued absence of comprehensive legislative regulation of such procedures at the level of Ukrainian statutes.

As with electoral reform, a Working Group on the Preparation of Comprehensive Legislative Proposals for Amendments to Ukrainian Laws in the Field of Parliamentary Law was established by the Speaker of the Verkhovna Rada back in 2021. In the nearly five years since its creation, its main outputs have been only a few bills (including the aforementioned draft No. 8327), which do not provide for comprehensive reform of parliamentary legislation. From the beginning of August to 15 October 2026 there has been no progress – not even minimal – in the implementation of parliamentary reform.

4. Role of Civil Society

Progress in implementing the measures under the RFDI Section “The Role of Civil Society” is the most noticeable compared with the other Sections of the Roadmap, yet it remains largely formalistic. In practice, civil-society organisations continue to encounter a range of obstacles that adversely affect their institutionalisation and functioning, as well as their ability to perform oversight of public institutions and to participate in the development and implementation of public policy.

Key successes include the implementation of the majority of the Action Plan for the Implementation in 2025–2026 of the National Strategy for Promoting the Development of Civil Society in Ukraine for 2025–2026 (at least, formally). Notable progress has also been made in the introduction of training programmes for public servants and representatives of civil society organisations on civic participation in decision-making by public authorities (although the target audience and overall intensity of such training need to be further strengthened), in measures to involve the non-governmental sector more actively in the provision of social services, the exemption of all social service providers from VAT, the introduction of additional tax incentives for charity and support for volunteer activity (including foreign volunteers), and in the implementation of pilot projects to establish citizens’ assemblies. An important step towards strengthening electronic interaction between the public and government was the launch of the “VzaiemoDiia” electronic platform in pilot operation.

At the same time, the implementation of a number of important measures under Section IV of the RFDI is still at an initial stage. In particular, no new version of the Law “On Bodies of Self-Organisation of the Population” has been registered or adopted in Parliament. Instruments of co-operation between law-enforcement bodies (including the prosecution service) and civil society, as well as instruments of public oversight of those bodies, remain ineffective overall. The pace of drafting the secondary legislation required for the implementation of the Law “On Public Consultations” is slow (even though the legislation permits the adoption of such acts after the end of martial law). The Law itself contains a number of shortcomings, notably the absence of a requirement to hold public consultations on bills initiated by Members of Parliament. The non-mandatory nature of such consultations will allow the Government to table bills through individual MPs, thereby circumventing the inter-ministerial co-ordination procedures of central executive authorities and avoiding public consultations on those drafts, thus undermining the positive aspects of the Law. The state of implementation of the European Commission’s recommendations on promoting the involvement and effective participation of citizens and civil-society institutions in policy-making, updating procedures for competitive selection of NGO projects financed from the state budget, also remains unsatisfactory.

The principal obstacles facing civil-society organisations have not been removed, while the RFDI itself, for the most part, does not provide for concrete, clearly defined measures to eliminate them. In particular, the registration of civil-society organisations via the Diia application on the basis of a model statute is being conducted as an experiment that will end in April 2027 (permanent electronic registration of civic associations requires Parliament to adopt draft law No. 8084 which has not been adopted so far). Although civic associations in most cases have no ultimate beneficial owners, they are not exempt from the obligation to determine the presence or absence of such owners – unlike political parties, trade unions and certain other associations – and must therefore continually update their data with the banks where their accounts are held. When verifying clients that are civic associations, banks focus on checking their founders, who after the organisation’s establishment neither influence its activities nor own its assets. This approach is inconsistent with FATF recommendations. The ability of civil-society organisations to conduct anti-corruption investigations, identify conflicts of interest and monitor the integrity of candidates for public office has been substantially narrowed by Law of Ukraine No. 4576-IX of 21 August 2025, which introduced restrictions on access to data in public registers, including those relating to legal entities and real-estate objects, during martial law and for one year after its termination. Under the pretext of enhancing the security of defence enterprises, the Law effectively allows their actual locations to be concealed and reduces the volume of information on property rights by removing precise addresses and cadastral numbers of land plots.

The most noticeable advances in the implementation of Section IV measures of the RFDI between August and October 2026 were: the submission to Parliament of draft law No. 16117 “On the Protection of Persons Exercising Civic Participation from Manifestly Unfounded Claims or Abuse of Court Process”, prepared in an inclusive manner with the involvement of stakeholders and taking account of European standards in the relevant field; the adoption by the Cabinet of Ministers of Ukraine of Resolution No. 1031 on institutional support for youth and children’s civic associations and the launch of the corresponding competition; and the establishment in September 2026 of a civil-society–government platform for the preparation of a new Strategy for the Promotion of Civil-Society Development.

5. Conclusions

Overall, the main achievements in implementing RFDI measures remain modest and isolated in nature. Most have amounted to little more than submitting draft bills to the Verkhovna Rada of Ukraine that pursue narrow objectives or address very specific issues. Moreover, in the vast majority of cases, none of the key bills submitted to Parliament have even been passed at first reading. The implementation of many core RFDI measures has either not begun at all or remains at the planning stage or the stage of preparing proposals that may, in future, form the basis of corresponding legislative initiatives. For almost one-third (28.57 %) of the measures across all four sections of the RFDI there has been no activity whatsoever; 27.47 % of measures are still at the initial planning stage, while the share of measures that have been completed or are nearly completed stands at only 14.29 %.

The least successful area has been the implementation of reforms under Section I of the RFDI, “General Framework of Democracy”, where only 6.67% of reforms have been put in place. By contrast, the most successful has been Section IV, “Role of Civil Society”, where 41.89% of reforms have been implemented. Progress on reforms relating to parliament and elections has been particularly limited (with overall implementation rates, taking into account the importance of the measures, standing at 21.07% and 26.89% respectively). Even in the most successful block – strengthening the role of civil society – a number of important measures designed to enhance the institutional capacity of civil society organisations, their role in public decision-making, and public oversight of government bodies have yet to be carried out.

6. Recommendations

The Verkhovna Rada of Ukraine should accelerate consideration and final adoption of bills that implement Roadmap measures, in particular bills Nos. 8084, 8242, 8327, 11300, 11462, 12111, 14289, 15165, and 16117. Any further refinement after first reading should be conducted openly with the involvement of all interested parties.
Parliament and the Cabinet of Ministers should prioritise legislative reforms related to the following issues:

Under Section I “General Framework of Democracy”:
creation of a legal basis for the periodic review of restrictions on human rights and freedoms during martial law (including designation of the responsible body, its powers, review frequency and procedure for recording outcomes);
definition of the grounds for establishing military administrations; and
ensuring the functioning of local self-government under martial law and its comprehensive reform through the adoption of necessary legislation.
Under Section II “Electoral Processes”:
accelerated adoption of a special ad hoc law on the conduct of the first post-war nationwide and local elections, taking into account the recommendations of the European Commission’s 2025 Ukraine Report;
continuation of comprehensive updating of the State Voter Register, establishment of procedures for its independent external audit, and conduct of that audit before the start of the first post-war electoral process;
definition of the grounds and procedures for decisions on the impossibility of holding elections in certain parts of Ukraine due to security or other factors;
amendments to the Electoral Code and related legislation to address problems identified during the 2019–2020 election campaigns and to implement relevant OSCE/ODIHR recommendations (concerning voting rights of specific voter groups, strengthening the professionalism and independence of election administration, reform of campaign financing, revision of grounds for cancelling elections or declaring them invalid, improvement of appeal procedures and the system of sanctions for electoral violations, etc.); and
substantial and systemic updating of legislation on political parties, in particular bringing it into line with European standards, enhancing the transparency of party and campaign financing, and establishing effective mechanisms to prevent corruption in the financing of parties and election campaigns (which requires the adoption in full of draft laws Nos. 14289 and 11462, as well as the submission to the Verkhovna Rada of a draft law improving the regulation of liability for violations in the sphere of party and campaign financing, prepared by a working group comprising representatives of civil-society organisations, experts, the National Agency on Corruption Prevention and other stakeholders).

Under Section III “Functioning of Parliaments in a Democratic System”:

internal reform of parliament, improvement of parliamentary oversight and government accountability procedures, and reform of the legislative process in line with the recommendations of the Report and Roadmap on Internal Reform and Enhancement of the Institutional Capacity of the Verkhovna Rada of Ukraine prepared by the European Parliament’s Needs Assessment Mission chaired by Pat Cox;
further expansion of the use of pilot projects for ex-ante and ex-post monitoring by parliamentary committees, and comprehensive legislative regulation of the specific features of the consideration and adoption of European-integration bills;
introduction of effective mechanisms to prevent corruption and ensure integrity in parliamentary activity; and
regulation of the status of the parliamentary majority (coalition of deputy factions and groups) and of the opposition in the Verkhovna Rada of Ukraine (that would require bringing the Rules of Procedure of the Verkhovna Rada into line with the current wording of the Constitution of Ukraine, defining in the Rules the rights and guarantees of the opposition, the procedure for the formation of a coalition, changes in its composition and termination of its activity, the legal facts confirming the acquisition or loss by a faction of the rights of a coalition, the procedure for calculating the time limit for forming a coalition, etc.);

Under Section IV "Role of Civil Society":

removal of practical obstacles to the registration and financial and economic activity of CSOs – ensuring online registration of civic associations (which requires Parliament to adopt draft law No. 8084), inclusion of civic and charitable associations in the list of exceptions from the obligation to determine the presence or absence of ultimate beneficial owners of legal entities, removal of restrictions on access to public registers, etc.;
acceleration of the finalisation of the draft National Strategy for the Promotion of Civil-Society Development in Ukraine for 2027–2032 and of the Government Action Plan for its implementation, with the involvement of civil-society organisations in their drafting and taking into account wartime challenges as well as the practical obstacles and problems faced by non-governmental organisations;
further strengthening of civil-society organisations by stimulating charitable and volunteer activity, enhancing competitive conditions in the social-services market and expanding access of non-governmental organisations to “government grants” – programmes for financing civil-society projects from the state budget – and narrowing the possibilities for applying anti-money-laundering measures (for example, the blocking of accounts) to non-governmental organisations engaged in lawful activity;
introduction of effective instruments of public oversight of the activity of law-enforcement bodies, including the prosecution service, as well as mechanisms for effective co-operation between these bodies and the public;
improvement of the Law “On Public Consultations” (in particular by introducing mandatory public consultations on bills tabled by Members of Parliament), adoption the secondary legislation needed for its proper implementation, and establishment of an adequate legislative basis for the development of democracy at local level and the activities of bodies of self-organisation of the population;
introduction of effective mechanisms for the involvement of under-represented groups in decision-making at central and local levels; and
ensuring the protection of persons exercising civic participation from manifestly unfounded claims or abuse of court proceedings (which requires the adoption in full of draft law No. 16117 as a law).

3. The main role in providing legislative support for reforms in the areas of parliamentarism and elections should be given to the Working Groups already established by the Speaker of the Verkhovna Rada: the Working Group on the Preparation of Legislative Proposals for Elections in the Special or Post-War Period and the Working Group on the Preparation of Comprehensive Legislative Proposals for Amendments to Ukrainian Laws in the Field of Parliamentary Law. The work of these groups should be conducted transparently with the involvement of all interested parties, and their mandates should cover all issues requiring legislative regulation in the course of these two reforms.

Annex 1. Assessment of RFDI Implementation

Annex 2. Implementation of RFDI by Reform Priority, Section, and Specific Measure

This material was produced as part of the project “Inclusive Dialogues for Democratic Reform in Ukraine”, funded by the Department of Foreign Affairs and Trade of Ireland. However, the views expressed herein do not reflect the official policy of the Government of Ireland.