An analysis of the initiative that grants the National Police access to registries of citizens’ property and the authority to trace and seize assets—and why the scope of these powers raises questions.

What It’s About

On May 19, 2026, Member of Parliament Maksym Pavliuk, together with his colleagues, submitted a bill to the Verkhovna Rada No. 15260, “On Amendments to the Code of Ukraine on Administrative Offenses and Other Legislative Acts Regarding the Improvement of Measures to Identify Unjustified Assets and Gather Evidence of Their Unjustified Nature.”

At first glance, this seems like a story about government officials and the fight against corruption—something that doesn’t concern the average citizen. In reality, however, it involves a significant expansion of the regular police’s powers: the right to access state property registries, track down assets, seize property, and demand information from any institution under threat of a fine. And the group of people this could affect is much broader than the title suggests.

What Are “Unjustified Assets” and Why Is It Important to Understand This?

To evaluate the bill, one must first understand the mechanism it serves. Ukraine has a system of civil forfeiture of unjustified assets. The essence of this system is as follows: if a public official has acquired property whose value significantly exceeds their lawful income, the state can, through the courts, seize that property for the state’s benefit.

A key feature of this mechanism is that it differs fundamentally from ordinary criminal proceedings. In civil forfeiture cases, the presumption of lawful acquisition of property does not apply: the court does not assume that the property was acquired legally; on the contrary, the legality of its origin is subject to scrutiny and can be rebutted. A lower standard of proof also applies—“balance of probabilities”: the court sides with the party whose evidence appears more convincing, rather than requiring proof “beyond a reasonable doubt,” as in a criminal case.

Simply put: in this category of cases, a person is effectively required to prove the lawful origin of their property themselves. And although the mechanism was formally created for public officials, confiscation applies not only to the official themselves but also to individuals and legal entities associated with them (relatives, friends, companies),  if it is proven that the assets were acquired in their interest or at their direction.

That is precisely why the question of who will gather evidence in such cases—and with what authority—is critically important. After all, this is a procedure in which the burden of proof de facto lies with the individual, not with the state.

Who was responsible for this before—and what is changing

Until now, the identification of unjustified assets and the collection of evidence of their unjustified nature were handled by a narrow circle of specialized agencies: the National Anti-Corruption Bureau (NABU) and the Specialized Anti-Corruption Prosecutor’s Office (SAPO), and, in cases specified by law, the State Bureau of Investigations and the Office of the Prosecutor General. These are agencies with special status, subject to enhanced external oversight and special jurisdiction, focused on high-level corruption.

Bill No. 15260 adds the National Police of Ukraine to this list—the country’s largest and most extensive law enforcement agency, with territorial units in every district. The authors explicitly justify this: thanks to the police’s territorial network, the time required to gather evidence will be reduced, and the number of officials who “go unnoticed” will decrease.

The logic is clear. But as the system expands, so do the risks—and it is precisely these risks that warrant close scrutiny.

What specific powers will the police receive?

The bill amends Article 23 of the Law “On the National Police” with four new provisions. To put it in plain language, the police will be granted the right to:

• identify unjustified assets and gather evidence of their unjustified nature, after which they will forward the materials to the prosecutor’s office to file a petition with the court to forfeit the property to the state;

• to trace and seize funds and property that show “signs of being of unjustified origin” and may be confiscated for the state;

• obtain information free of charge from any state registries, databases, and automated systems—including information with restricted access—from state agencies, local government bodies, and legal entities;

• engage specialists and experts to assess the value of assets showing signs of being unjustified.

Separately, the bill sets strict deadlines: any entity that receives a request from the police is required to provide the information within three days or, no later than ten days, to explain why it is unable to do so. Furthermore, Article 185-13 of the Code of Administrative Offenses is amended to provide that failure to provide information to the police, providing false information, late submission, or notifying third parties about the collection of information is punishable by a fine ranging from 250 to 400 non-taxable minimum incomes.

Risks Everyone Should Be Aware Of

Risk #1: The scope of access to private data.

The most specialized anti-corruption agencies (NABU, SAPO) work with a narrow circle of high-ranking officials and are subject to strict oversight. The National Police, on the other hand, consists of tens of thousands of officers across the country. Granting such a massive agency the right to freely and promptly access property registries, banking databases, and other databases—including those with restricted access—dramatically expands the circle of individuals who will have the technical capability to access citizens’ private financial information. The broader the scope of access, the higher the risk of abuse, data leaks, and the use of data for unintended purposes.

Risk Two: The Vague Concept of “Signs of Unjustifiedness.”

The bill allows the police to search for and initiate the seizure of property that “shows signs of being unjustified.” However, the law does not establish a clear, legally defined criterion for what exactly constitutes such a “sign” at the stage of a police investigation—prior to trial. This creates broad discretion: in effect, the decision as to whose property “looks suspicious” is made at an early, pre-trial stage by a police officer.

Risk Three: Expansion of the Group of Persons Under Scrutiny.

The explanatory note explicitly states that the mechanism will apply not only to top officials but also to “B” and “C” category civil servants, local government officials, and members of city, district, town, and even village councils. That amounts to tens, if not hundreds, of thousands of people across the country. And since civil forfeiture also extends to associated individuals, their relatives, business partners, and affiliated companies—that is, people who do not hold any public office—potentially fall within the scope of the law.

Risk Four: A Lower Standard of Protection.

Since all of these activities support the civil forfeiture procedure—where the presumption of lawful acquisition of property does not apply and the “balance of probabilities” is used—an individual finds themselves at a disadvantage even before the trial. The police gather evidence, while the individual must subsequently prove the lawful origin of their property. Expanding the range of agencies that compile such evidence increases the burden on citizens to prove their “financial innocence.”

Risk Five: Pressure Due to the Duty of Silence.

Particular attention is drawn to the provision regarding liability for “notifying third parties” that information is being collected about them. In practice, this means that an institution, bank, or registrar, upon receiving a police request regarding a specific individual, is not permitted to notify that person—otherwise, a fine will be imposed. An individual may only learn that their assets were investigated after the fact, once the materials have already been collected.

Why This Is Not a “Minor Technical Amendment”

Supporters of the bill emphasize that the goal is noble—fighting corruption, identifying illicit enrichment, and returning stolen assets to the state. And these are indeed important objectives. Corruption in Ukraine remains a serious problem, and the mechanism of civil forfeiture is a recognized tool for combating it, used in many countries.

The issue is not the goal, but the instrument and its scope. It is one thing to grant powers to a narrow, specialized body under strict oversight. It is quite another to transfer those same powers to a mass law enforcement agency without simultaneously introducing proportionate safeguards: judicial oversight of access to registries, clear criteria for “signs of groundlessness,” restrictions on the circle of employees with access to data, and mechanisms for accountability for abuse and leaks.

It is precisely these safeguards that are missing from the bill. It spells out in detail what powers the police will receive, but says almost nothing about how these powers will be monitored or what will protect ordinary citizens from being wrongfully or maliciously targeted for “investigation.”

Conclusion: Expanding powers requires expanding safeguards

Bill No. 15260 is not a cosmetic change but a significant shift in the balance between the state and the individual. It transforms the detection of unjustified assets from a relatively narrow, specialized function into a mass-scale operation, with access to citizens’ private data across the entire police hierarchy.

The very idea of strengthening the detection of illicit enrichment is justified. However, an expansion of state powers must always be accompanied by a proportional expansion of safeguards for the individual. Access to property registries must be limited and controlled; “indicators of unjustified wealth” must be clearly defined; the circle of individuals with access to the data must be narrow; and accountability for abuse must be real. Without these elements, this noble goal risks becoming a tool of excessive control from which no one is immune—not even a person who has never held any public office.

Parliament should consider this bill not only through the lens of the effectiveness of the fight against corruption, but also through the lens of a simple question: Are we prepared to grant a mass law enforcement agency such broad access to citizens’ private lives, and does the law provide sufficient safeguards to ensure that this access is not misused?