Corruption in the security and defense sector during an armed conflict poses a fundamentally different threat to society than corruption in civilian sectors. Embezzlement in weapons procurement, fictitious fortification projects, and inflated prices for critically important equipment result not only in budgetary losses but also have a direct impact on the army’s combat readiness and the safety of its personnel. In 2024–2026 alone, dozens of criminal cases were recorded in the field of defense procurement, resulting in losses amounting to hundreds of millions of hryvnias.

The key systemic problem lies not in the absence of reports of corruption, but in the lack of real protection for those who file them. Service members and mobilized personnel who report corruption offenses within their units find themselves in a legally vulnerable position: they are subordinate to the very same chain of command, whose representatives are often implicated in the relevant cases. Current legislation lacks mechanisms that would take this specific situation into account. The result is a high level of hidden corruption in the military and the de facto refusal of most eyewitnesses to file any reports.

On March 18, 2026, Member of Parliament Serhiy Hryvko introduced Bill No. 15089 in the Verkhovna Rada “On Amendments to Certain Legislative Acts of Ukraine Regarding the Improvement of Procedures for Ensuring the Safety of Whistleblowers in the Security and Defense Sector,” aimed at addressing the described problem.

Where exactly does the current legislation fall short?

To evaluate the bill, we must first honestly ask: What exactly isn’t working right now?

The General Law “On Preventing Corruption” (as amended in 2019–2021) provides for whistleblower status, protection against dismissal and transfer, and a reward of up to 10% of the damages incurred. Article 18 of the Law “On Ensuring the Safety of Persons Participating in Criminal Proceedings” regulates the protection of military personnel. Formally, this is sufficient. In practice, however, the system is not adapted to the military hierarchy.

First, in a context of complete subordination, a “transfer” is not a punishment but a “routine” rotation. It is nearly impossible to prove that it constitutes persecution of a whistleblower. Second, mobilized personnel found themselves in a legal vacuum: the current version of Article 18 applied exclusively to career military personnel, leaving mobilized personnel without special protection, without the right to choose their unit, and without a deferral to change their place of service. Third, decisions on security measures were made in a bureaucratic manner—without clear deadlines and without accountability for violations. The result is widespread “silence” among those who see everything: the level of latent corruption in military units is critically high precisely because of the lack of effective safeguards for those who dare to speak out.

What the bill specifically proposes

The document introduces targeted amendments to three laws.

The first section is a revised version of Article 18 of the Law of Ukraine “On Ensuring the Safety of Persons Participating in Criminal Proceedings.” The key innovation is the distinction between three separate categories: career military personnel, conscripts, and mobilized personnel. Each category has its own set of measures.

For career military personnel who come forward with information: the right to transfer to any branch or service of the Armed Forces or another military formation, as well as a one-time paid leave of 90 calendar days to process the transfer. For mobilized personnel and those subject to military service: the right to independently choose a place of service in any unit of the Armed Forces of Ukraine, as well as a 90-day deferral from conscription to undergo voluntary recruitment and be assigned to the chosen unit.

The wording regarding the grounds for filing a petition is particularly important. The law provides for the right to seek protection in two distinct cases: first, if there is evidence of a real threat to life, health, housing, or property; second, at any time after a suspect is detained or charged. The first ground allows for protection to be obtained immediately after filing a report of corruption, even before any detention—if there are already signs of pressure or persecution. This is a proactive mechanism, not merely a reactive one.

Finally, the revised Article 18 establishes financial compensation: 10% of the monetary value of the subject of the crime or the losses incurred by the state after the conviction becomes final, but not more than three thousand times the minimum wage established at the time the crime was committed. As of January 1, 2026, the minimum wage is 8,647 hryvnias, meaning the maximum payment is approximately 25.9 million hryvnias. This provision effectively duplicates the general Law “On Preventing Corruption,” but specifically extends its application to the defense sector, thereby eliminating potential conflicts in its application.

The second section consists of an amendment to Article 10-1 of the Law of Ukraine “On Social and Legal Protection of Military Personnel and Members of Their Families.” A procedural mechanism is established: a 90-day leave is granted based on a procedural decision by the prosecutor, which must be issued within three days of the submission of the request. The leave is granted with full pay, without being divided into parts, and includes periods during a state of emergency. This is a fundamental change: previously, leave depended entirely on the commander’s discretion; now, it is a state obligation, backed by a specific timeframe and a specific entity responsible for its implementation.

The third set of amendments concerns the Law “On Mobilization Preparation and Mobilization.” A new clause 23-1 has been added to the list of grounds for deferment from conscription: the status of a whistleblower exposing corruption in the security and defense sector. The deferral lasts 90 days, based on a procedural decision by the prosecutor issued within three days.

What Raises Legal Concerns

Despite its conceptual soundness, the draft law contains gaps that must be addressed during committee review.

The first is the lack of accountability for missing the deadline. The prosecutor is required to issue a decision within three days, but the bill does not provide for any sanctions for failing to meet this deadline. In Ukrainian procedural practice, a deadline without consequences for non-compliance is more of a guideline. The simplest technical solution would be either the automatic application of a security measure after the three-day deadline expires, or the right of the whistleblower to file an expedited judicial appeal against the prosecutor’s inaction.

The second issue is voluntariness without guarantees of free will. Most security measures are provided “at the request” of the whistleblower, which formally reflects respect for their autonomy. However, given the military hierarchy and psychological pressure, a refusal of protection may be coerced and not reflect the individual’s true decision. The Committee should consider a provision requiring the prosecutor to explain the whistleblower’s rights before formalizing any waiver of protective measures.

Third—the risk of abuse. The provision allowing for a 90-day leave of absence or deferral, granted upon request, creates an incentive to file reports that lack any real substance regarding corruption. This does not invalidate the mechanism, but it requires regulation at the level of subordinate legislation: clear criteria for verifying the content of a report before granting protective measures, and enhanced criminal liability for knowingly false reports.

Fourth—the lack of liability for retaliation. The draft law expands the rights of whistleblowers but does not establish sanctions against a commander or official who exerts pressure following a report of corruption. In practice, the provisions of general anti-corruption legislation in this area are rarely applied in the military environment. A specific penalty for actions that restrict the rights of a whistleblower would significantly enhance the law’s deterrent effect.

Conclusion: Support—and refine

Bill No. 15089 is a step in the right and necessary direction. It eliminates a real legal vacuum for mobilized personnel, introduces specific procedural deadlines, grants whistleblowers the right to choose their unit first, and establishes a financial incentive for reporting crimes.

At the same time, adopting the bill without further refinement will leave practical vulnerabilities: an ineffective 3-day deadline for implementing security measures with no penalties for noncompliance, the risk of forced “voluntary” waiver of protection, and the potential for abuse of the system to obtain leave and other benefits.

Parliament should support the bill in the first reading and refine it in committee by adding: a mechanism for automatic protection in the event of a prosecutor’s inaction, a procedure for preliminary verification of reports, a provision on liability for persecuting whistleblowers, and a mandatory explanation of the right to protective measures.

Corruption in the defense sector during wartime harms not only the state budget but also the country’s defense capabilities directly. Those who report it take on a significantly greater personal risk than any civilian whistleblower. That is precisely why the level of legal protection in this area should not be lower than, but rather higher than, the general standard. Draft Law No. 15089 brings the legislation closer to this standard—provided it is properly refined.