In a country where the police face wartime challenges—ranging from maintaining public order to combating organized crime—the issue of internal discipline takes on critical importance. According to the National Police, 10,000 complaints about law enforcement officers’ actions are filed each year, and Transparency International, in its 2024 report, notes that corruption in the security sector remains one of Ukraine’s key problems, with a Corruption Perceptions Index score of 35 out of 100.

The draft law “On Amendments to the Disciplinary Statute of the National Police of Ukraine Regarding the Improvement of the Procedure for Conducting Internal Investigations and Ensuring the Independence of Disciplinary Commissions” (Reg. No. 13713).

Registered on August 29, 2025, by the Cabinet of Ministers of Ukraine at the request of the Ministry of Internal Affairs, the draft is currently under review by committees of the Verkhovna Rada. This document is not merely a technical amendment but an attempt to integrate public oversight into a system where internal investigations often stall due to conflicts of interest. However, will it be able to overcome corruption risks, or will it merely add to the red tape?

Key Changes: From Restrictions on Investigations to Public “Watchdogs”

The draft amends the Disciplinary Statute of the National Police of Ukraine (Law No. 2337-VIII of 2018), focusing on two pillars: optimizing internal investigations and strengthening the independence of commissions. The main innovations are aimed at making the process more transparent and less vulnerable to manipulation.

First, the grounds for internal investigations are clarified (amendments to Article 14). While investigations can currently be initiated based on any report, complaint, or statement, the draft bill restricts this (introducing additional filters): for complaints regarding the actions (or inaction) of a police officer, the only grounds are an established fact of a violation of a person’s rights or the law following a preliminary review of the complaint through a special procedure (if such a procedure is provided for, for example, through a court or the prosecutor’s office). This eliminates “haphazard” investigations based on unsubstantiated allegations. Furthermore, the provision stating that materials related to administrative offenses constitute grounds for holding a police officer disciplinarily liable without conducting an internal investigation is removed.

Second, the reform of commissions (the new version of Article 15 and the added Articles 15¹–15³). Two types are established: regular commissions for general investigations (temporary, collegial, composed of police officers with the necessary expertise) and special “disciplinary commissions on human rights” — permanent advisory bodies for misconduct involving human rights violations (e.g., unlawful detention, torture, gender-based discrimination). The composition of the latter must include representatives of the public based on the principle of proportionality (at least half of the members must be respected human rights defenders with an impeccable reputation). The composition of the commissions is approved by the Minister of Internal Affairs or the Head of the National Police. The term of office is three years, with the possibility of termination due to a criminal conviction, a conflict of interest, or systematic absences.

Third, safeguards for independence (Articles 15²–15³). The commissions are granted the right to send requests to government agencies, the police, and legal entities to gather evidence (the response deadline is 5 business days, with a possible extension to 10). Interference in the commissions’ work is prohibited. Commission members are protected from prosecution for their findings (except in cases of malicious violations), and conflicts of interest are regulated by the anti-corruption law. For investigations involving senior leadership (deputy chiefs of the National Police), employees of the Ministry of Internal Affairs are involved. Human rights commissions may return materials for further review (up to 2 days), and decisions are made by vote (in the event of a tie, the chairperson’s vote is decisive).

Weaknesses of the draft: from uncertainty to delayed implementation

Despite the progress, the draft has significant flaws. First, the criteria are vague: “impeccable reputation” and “public standing” are subjective concepts that carry the risk of arbitrary interpretation. Without a transparent selection process (for example, through a public integrity council), this could lead to the handpicked selection of loyal individuals.

Second, the declaratory nature of the provisions: human rights commissions are advisory bodies, and the head may ignore their recommendations simply by justifying the relevant decision (Article 19). This does not guarantee independence, especially within the hierarchical structure of the police.

Third, practical risks: implementation is postponed for one year after martial law ends (final provisions), which, in the context of a protracted war, effectively puts the reform “on hold.” During wartime, human rights commissions are suspended (Article 26), which weakens oversight precisely when violations are on the rise. The commissions’ inquiries (Article 15³) are a good idea, but the deadlines (5–10 days) are unrealistic for bureaucratic bodies without penalties for noncompliance.

Conclusion: Reform is necessary but requires further refinement

Bill No. 13713 is a timely step toward reforming the disciplinary accountability procedure for police officers, where public oversight can serve as a barrier against abuse, thereby increasing trust and ensuring compliance with EU standards. It implements the state strategy, but its weaknesses—ranging from uncertainty to a delayed launch—could render it ineffective. Citizens should demand further refinements: clear selection criteria, stronger powers for the commissions, and pilot testing. As a lawyer, I see the potential, but without these amendments, the reform risks becoming a “paper shield.” Follow the committee review in parliament, because an independent police force is the key to a safe Ukraine.