To the Prime Minister of Ukraine

Yulia SVYRYDENKO

To the Minister of Finance of Ukraine

Serhiy MARCHENKO

To the Chairman of the Verkhovna Rada of Ukraine

Ruslan STEFANCHUK

To the Chairman of the Verkhovna Rada of Ukraine

Committee on Finance, Tax, and Customs Policy

Danylo GETMANTSEV

First Deputy

Chairman of the Verkhovna Rada Committee

on Finance, Tax, and Customs Policy

Yaroslav ZHELEZNYAK

Copy: Director of the Economic Security Bureau of Ukraine
Oleksandr TSIVINSKYI

 

 

 

Regarding Adequate Financial Support

for the Economic Security Bureau of Ukraine

Dear Sirs and Madams!

The Ukrainian Business Council (hereinafter referred to as the UBC), an umbrella organization of business associations established to consolidate the business community and implement socially significant reforms for the country’s sustainable economic development, comprising 130 business associations whose members include 27,000 enterprises across various sectors of the economy, – extends its respect to you and submits the following:

On February 27, 2026, a conference titled “Cooperation Between the Renewed Economic Security Bureau and Conscientious Businesses – First Half-Year” was held in Kyiv, marking the first public event summarizing the six-month work of the renewed Economic Security Bureau of Ukraine.

During the event, the leadership of the BEB presented the results of six months of work on de-shadowing key markets, while representatives of business associations provided their own assessment of these changes and systemic proposals. Representatives of business associations noted positive trends in the EBS’s work across a number of sectors where businesses and the EBS have collaborated through analytical partnerships and joint problem-solving.

At the same time, to ensure the EBS’s effective operation across all sectors of the economy, a number of measures must be implemented, including:

1. Ensure adequate funding for the BEB

The basis for calculating BEB employees’ salaries must be brought in line with that of other law enforcement agencies. Currently, BEB detectives’ salaries are 2.5 times lower than those of employees at other anti-corruption and law enforcement agencies (in particular, NABU and SAPO). The Bureau is only 28% staffed: with an estimated need for 4,000 employees, only 1,145 are currently working, and since August 2025, approximately 150 more people have resigned. One of the reasons is the establishment of an underestimated base salary calculation rate for the BEB—2,102 UAH—while for other agencies it is 3,328 UAH.

Resolving this issue requires the inclusion of relevant provisions in the Law of Ukraine “On the State Budget of Ukraine for 2026” and subsequent years.

An adequate level of financial support for BEB employees is critically important not only for staffing the agency but also for effectively combating economic crimes. According to experts, even a slight reduction in the shadow trade of excise goods could provide the state budget with additional revenue that far exceeds the costs of maintaining the Bureau.

2. Grant the BEH special status

Designating the BEH as a central executive body with special status—to effectively ensure its independence, strengthen its analytical capacity, attract more staff, and ensure adequate staffing—is in line with the European Commission’s recommendations set forth in its report on the results of the screening of Ukrainian legislation. Implementing this recommendation is a key component of Ukraine’s fulfillment of its obligations in the process of negotiations on accession to the European Union.

Such a status for the BEB would be fully consistent with the definition of relevant bodies within the system of state authorities, taking into account the specific tasks and powers established by Ukrainian law, the special procedures for subordination and accountability, as well as the appointment and dismissal of BEB leadership.

Regulating the BEB’s activities in accordance with the current state of affairs will make it possible to align the provisions of legislation regarding the activities of central executive bodies with special status and extend their application to the BEB, which will undoubtedly strengthen the agency’s independence. The absence of special status for the BEB in 2026 will lead to a reduction in the pay of BEB civil servants to the level of an unskilled worker.

This would effectively undermine the original legislative intent behind the creation of the BEB as an analytical body, since establishing a unique, unified information system—as a powerful tool for identifying economic risks and preventing criminal offenses—is impossible without the involvement of high-level specialists.

The inability to provide IT professionals with adequate compensation precludes the Economic Security Bureau from fulfilling its international obligations to strengthen its analytical capabilities. Resolving this issue requires amendments to the laws of Ukraine “On the Economic Security Bureau of Ukraine,” “On Central Executive Bodies,” and “On the Cabinet of Ministers of Ukraine.”

3. Introduce compensation for personal income tax

Currently, in accordance with the provisions of Resolution No. 44 of the Cabinet of Ministers of Ukraine dated January 15, 2004, “On Approval of the Procedure for the Payment of Monthly Monetary Compensation for Personal Income Tax Amounts Withheld from Salaries, Monetary Rewards, and Other Payments Received by Military Personnel, police officers, and personnel of the rank-and-file and command staff,” compensation for personal income tax is paid to employees of all law enforcement agencies, including those not part of the security and defense sector: the State Bureau of Investigation (SBI) and the National Anti-Corruption Bureau (NABU). The list of agencies in the resolution also includes the tax police.

In light of this, we consider it necessary to amend paragraph 2 of the Procedure for the Payment of Monthly Monetary Compensation for Personal Income Tax Withheld from Salaries, Monetary Rewards, and Other Payments Received by Military Personnel, police officers, and personnel of the rank-and-file and command staff, approved by Resolution of the Cabinet of Ministers of Ukraine No. 44 dated January 15, 2004.

The adoption of such a law will ensure the proper implementation of social guarantees for persons holding special ranks in the Economic Security Bureau (ESB), on par with military personnel, police officers, and rank-and-file and commanding personnel of other agencies, while ensuring compliance with the guarantees of the ESB’s independence as defined in Article 5 of the Law of Ukraine “On the Economic Security Bureau of Ukraine.”

4. Expand the territorial presence of the Economic Security Bureau

It is advisable to provide additional funding to open at least one regional office of the Economic Security Bureau of Ukraine in regions where such offices are currently absent.

A significant portion of the illegal trade in excise goods is concentrated precisely in these regions. The absence of regional offices of the State Fiscal Service leads to a systematic shortfall in state budget revenues and creates conditions for the unpunished operation of shadow schemes, makes it impossible to respond promptly during the investigation of crimes, contributes to the impunity of organized criminal groups, and, as a result, leads to a further increase in budget losses, and the state effectively loses the ability to systematically respond to the scale of the shadow market.

5. Make technical amendments to the regulatory framework

It is necessary to make changes (technical amendments) to Cabinet of Ministers Resolution No. 267 (2001), providing for the inclusion of the BEB in the relevant list of agencies, which in turn will enable the BEB to procure special technical equipment for covert investigative (search) operations and more effectively combat economic crimes.

6. Strengthen criminal liability for offenses in the sphere of production and circulation of excise goods (Article 204 of the Criminal Code of Ukraine).

7. Improve legislation governing the circulation of excise goods

Amend legislation to regulate the market for excise goods by establishing transparent rules for their circulation. This will contribute to the comprehensive de-shadowing of the industry, minimize illegal trade, and optimize the activities of the State Fiscal Service by closing regulatory gaps.

8. Introduce IMEI code tracking during customs clearance of goods that use SIM cards (smartphones, tablets, etc.) to compile statistics and enable verification of the legality of their import during subsequent supplier audits.

9. Introduce a system of performance indicators for the State Bureau of Investigations (SBI) that focuses not on the number of criminal cases opened, but on the results of bringing the economy out of the shadows—namely, increased budget revenues from high-risk sectors, a reduction in the tax gap, and the satisfaction of law-abiding businesses. In particular, these could include the following indicators:

• Year-over-year trend in the tax compliance gap, calculated using the OECD methodology
• Ratio of criminal cases entered into the Unified Register of Pre-trial Investigations to cases referred to court.
• The ratio of the number of indictments sent to court to the number of convictions and acquittals that have become final.
• The ratio of the amounts of material damages caused to the amounts of their compensation and material assets seized through special confiscation (in proceedings where the investigation has been completed).
• The number of searches conducted without a warrant from an investigating judge.
• The number of complaints from businesses (to the Business Ombudsman and leading business associations) by economic sector.
• The ratio of vacant to filled positions at the Bureau.

The implementation of these measures will contribute to the effective operation of the Bureau, which is crucial for the country’s economic security and the fight against economic crime and the shadow economy. Reducing the scale of the shadow economy and curbing the circulation of illegal or “gray” goods will generate additional tax revenue for the budget, improve operating conditions for legitimate producers, and level the playing field, which, in turn, will undoubtedly become one of the drivers of the country’s GDP growth.

Ukrainian business counts on your support in addressing these issues and ensuring adequate funding for the Economic Security Bureau of Ukraine.

The business community is ready to participate in the further development of these initiatives and provide expert support for the relevant legislative changes.

 

Sincerely,

Member Business Associations

of the Ukrainian Business Council