Coalition of Ukrainian organizations, including ZMINA, publishes shadow report on EU accession

Date: 20 October 2025
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A coalition of Ukrainian civil society, including ZMINA Human Rights Centre, published a shadow report on Ukraine’s progress in meeting the requirements of Chapters 23 and 24 of the upcoming EU accession negotiations.

The report, prepared by independent analysts in consultation with the European Commission and with the support of the EU project Pravo-Justice, monitors and assesses Ukraine’s progress in fulfilling candidate-country obligations under Chapter 23 (Judiciary and Fundamental Rights) and Chapter 24 (Justice, Freedom and Security). These chapters fall under Cluster 1 (Fundamentals), which is the core of the entire accession negotiation process.

The Report includes the following sections:

  • Judicial and prosecution reform, combating organized crime (selected topics excluded), cooperation in the field of drug control, counter-terrorism, and judicial cooperation in criminal, civil, and commercial matters — Agency for Legislative Initiatives;
  • Fighting corruption and certain aspects of combating organized crime — Transparency International Ukraine;
  • Protection of fundamental rights and freedoms, selected topics on combating organized crime, legal and illegal migration, and granting asylum to refugees (asylum seekers) — the Human Rights Centre ZMINA;
  • Bar reform — Tomorrow’s Lawyer;
  • Legal education reform — Ukrainian Bar Association;
  • Visa policy, Schengen and external borders, certain aspects of legal and illegal migration, and euro counterfeiting — Europe Without Barriers.

The period reviewed by experts spans from September 2024 to August 2025 for Chapter 23 and includes earlier data up to August 2025 for Chapter 24. One of the key achievements during this period was the approval of the Rule of Law Roadmap, whose recommendations will serve as guidance for opening negotiations under Cluster 1.

The report includes more than 500 recommendations, ranging from legislative changes to institutional reforms. These are designed to help public authorities address current challenges, secure sustainable results, and, together with international partners, set clear reform priorities.

The full report became available in English and Ukrainian on October 20, 2025.

Tetiana Pechonchyk, Head of the Board of the Human Rights Centre ZMINA, said that after preparing a pilot Shadow Report for the European Commission last year, this year ZMINA, together with a coalition of civil society organizations led by the Agency for Legislative Initiatives, once again took part in its drafting.

Tetiana Pechonchyk

“Moreover, we managed to expand the scope of our work — in addition to Chapter 23, this time we also worked on Chapter 24. Overall, our part of the report covers a much wider range of human rights issues than the European Commission Enlargement Report. We hope that this information will serve as an important supplement and guide in the further process of reforming the country on its path towards the European community. The Roadmaps approved in May confirm this, although there is still much work to be done. In the Shadow Report, we once again emphasize that in the process of European integration, it is important to take into account the protection of persons affected by Russian aggression”, — said Tetiana Pechonchyk, Head of the Board of the Human Rights Centre ZMINA.

“European integration is a nationwide project for which the state, civil society, business, and international partners must all work together. The shadow report is a medium for such dialogue, as its independent conclusions and recommendations can form the foundation for practical steps in the area of reform. The EU Project Pravo-Justice systematically supports this cooperation, because it is the synergy between the state and the civil sector that guarantees successful change”, — emphasized Oksana Tsymbrivska, Team Leader of the EU Project Pravo-Justice.

By way of background, on September 30, 2025, European Commissioner for Enlargement Marta Kos announced that Ukraine and the European Union had completed the screening of Ukrainian legislation as part of EU accession negotiations. 

Previously, ZMINA reported that Ukraine has completed 17 of 46 measures regarding fundamental rights in its roadmap for EU accession, with 27 other measures partially implemented. This chapter covers issues concerning the protection of personal data, the prevention of torture, the rights of national minorities, and anti-discrimination efforts.

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