Conclusion of the Accounting Chamber of Ukraine: the exclusion of provisions on the advisory group of experts and deadlines for external audit requests creates significant risks

26.09.2025 09:21

The Accounting Chamber does not support the norms of the draft law “On Amendments to Certain Legislative Acts of Ukraine Regarding the Restoration of Ukraine's State Sovereignty” (reg. No. 13697 of 25.08.2025) in the parts concerning the activities of the institution. The relevant decision was made at a meeting on September 23.

In particular, the draft law proposes to exclude from the Law of Ukraine «On the Accounting Chamber»:

  • a norm on an advisory experts group (domestic and international) that conducts preliminary selection of candidates for the position of member of the Accounting Chamber;
  • the terms of the Accounting Chamber's appeal to the International Organization of Supreme Audit Institutions (INTOSAI) regarding the external evaluation of the activities of the supreme audit institution in Ukraine.

The Accounting Chamber believes that the proposed changes contradict Ukraine's international obligations and the principles of independence of supreme audit institutions enshrined in the Lima and Mexico Declarations of INTOSAI, as well as the resolutions of the UN General Assembly.

The existence of an advisory experts group is an important component of the institution's independence, as it enhances the openness and transparency of the selection process for members of the Accounting Chamber. The creation of the group is provided for in the memoranda with the IMF and the recommendations of the European Commission. Excluding this mechanism could undermine the confidence of international partners and create risks for Ukraine's future financing.

“This is one of the conditions that was agreed upon by Ukraine and signed together with the IMF. We have fulfilled this condition, so we see enormous risks for Ukraine if the relevant bill is adopted,” emphasized Olha Pishchanska, Chairwoman of the Accounting Chamber.

With regard to external evaluation of the institution, in line with international practice, the legally established terms for its conduct make it possible to ensure systematic control of the Accounting Chamber's compliance with international standards and to obtain independent assessments and recommendations for improving its effectivenes

However, abolishing such terms would contradict the principles of transparency and could weaken the institutional capacity and guarantees of independence of the supreme audit institution. Therefore, the Accounting Chamber does not support this legislative proposal.