Shadow report for European Commission highlights gaps in ombudsman legislation in Ukraine

No progress has been made over the past year in the work of Ukraine’s national human rights institution, according to a new shadow report on the implementation of European Commission recommendations within the “Fundamentals of EU Accession” cluster, prepared for the European Commission by a coalition of civil society organisations with the participation of the Human Rights Centre ZMINA.

Throughout 2025 and 2026, the number of appeals to Ukraine’s human rights ombudsman has been growing, yet the situation regarding the regulatory and legal framework governing the ombudsman’s activities has remained unchanged. In particular, legislation to strengthen the institution’s powers has still not been adopted.

In 2025, the number of appeals submitted to Ukraine’s Human Rights Ombudsman rose to 152,592, a 24% increase from 2024. As of 9 July 2026, the ombudsman had received 87,704 appeals, the largest number of which concerned:

• the protection of the rights of military personnel, veterans, prisoners of war and their families;
• procedural rights and compliance with rights in custodial settings;
• the right to submit appeals, access to information and personal data protection;
• and the protection of the rights of people affected by Russian armed aggression.

The overall situation regarding the regulatory and legal framework governing the ombudsman’s activities has not changed since 2025, the shadow report notes. Bill No 13181, which updates the law on the ombudsman, was registered in Ukraine’s parliament, the Verkhovna Rada, in April 2025. In May 2026 the parliament supported the document in the first reading.

Among the positive changes proposed by the bill are lowering the age threshold for candidates for the position of ombudsman and increasing the ombudsman’s financial independence. At the same time, human rights organisations expressed a number of criticisms, notably concerning the opaque and non-inclusive procedure for appointing the ombudsman without a public competition and the participation of civil society, which they say fails to comply with the Venice and Paris Principles.

The text of the bill should be revised with the involvement of civil society representatives, human rights organisations and international partners, the shadow report states. An appeal calling for the creation of a relevant working group has been sent to the parliamentary committee on human rights.

Additionally, since 2025, no amendments have been made to Article 12 of the law On the Legal Regime of Martial Law regarding the possibility of dismissing the ombudsman during martial law if parliament expresses no confidence in the ombudsman, a ground for dismissal that was introduced in 2022. Experts in the shadow report emphasise that this situation threatens the institution’s independence.

Bill No 13597, which is under consideration in parliament, would allow authorised employees of the ombudsman’s secretariat or the ombudsman’s representatives to draw up protocols on violations of legislation in the field of prevention and combating discrimination.

“The issue of expertise and resources for this activity arises, given that every year the number of reports of discrimination received by the ombudsman is increasing,” the shadow report notes.

Despite Ukraine amending the legislation on the ombudsman to fulfil EU accession commitments, the procedure for appointing the ombudsman remains practically unchanged in the relevant bill. Read about how to ensure the independence of Ukraine’s human rights institution on its path to the EU in this article.

Earlier, ZMINA reported that the bill on the ombudsman does not comply with Ukraine’s commitments for EU accession and unjustifiably expands the range of entities subject to the ombudsman’s oversight, notably to include public associations, as stated in an analysis of the bill conducted by analysts at the Human Rights Centre ZMINA.

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