500+ Recommendations for Ukraine’s Path Towards the EU: Coalition of CSOs Releases a Shadow Report, ZMINA analyzed the human rights situation

The Human Rights Centre ZMINA in partnership with The Agency for Legislative Initiatives (ALI), Transparency International Ukraine, Tomorrow’s Lawyer, Europe Without Barriers, the Ukrainian Bar Association, and European Pravda, with the support of the EU Project Pravo-Justice, has released a Shadow Report complementing the European Commission’s 2024 Report on Ukraine. The document assesses Ukraine’s progress under Chapters 23 (“Judiciary and Fundamental Rights”) and 24 (“Justice, Freedom and Security”) of Negotiation Cluster 1, “Fundamentals of the Accession Process”. Progress in this cluster plays a decisive role in Ukraine’s EU accession negotiations.

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 roadmap is the result of close cooperation between state authorities, civil society representatives, and international experts.

The Shadow Report highlights not only Ukraine’s progress but also the challenges and shortcomings in implementing European standards in areas such as the rule of law (courts, prosecution, legal profession, legal education), the fight against corruption and organised crime, the protection of fundamental human rights and freedoms, as well as visa policy, migration and related fields.

Experts from the participating civil society organisations (CSOs) have formulated over 500 recommendations, ranging from legislative amendments 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.

“After preparing a pilot Shadow Report for the European Commission last year, this year ZMINA, together with a coalition of civil society organisations led by the Agency for Legislative Initiatives, once again took part in its drafting. 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 emphasise 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.

The preparation of shadow reports is a standard practice for all EU candidate countries. In Ukraine, this work has been carried out systematically since 2024, when a coalition of CSOs first produced an alternative analysis to the European Commission’s Report. That document was positively received by the European Commission and the expert community, with its recommendations subsequently reflected in the Rule of Law Roadmap.

“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”, — emphasised Oksana Tsymbrivska, Team Leader of the EU Project Pravo-Justice.

Despite the challenges surrounding the opening of Cluster 1, Ukraine must continue to pursue reforms with consistency and strengthen its institutions, demonstrating its ability to meet European standards regardless of external political dynamics. This approach not only enhances the prospects for successful accession negotiations but also reinforces the state from within. The 2025 Shadow Report, prepared by the CSO coalition, serves as an important instrument for public oversight — helping to identify gaps and encouraging more effective implementation of reforms that bring Ukraine closer to EU membership.

The Report includes the following sections:

• Judicial and prosecution reform, combating organised 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 organised crime — Transparency International Ukraine;
• Protection of fundamental rights and freedoms, selected topics on combating organised 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 Shadow Report was prepared by a coalition of civil society organisations, led by the Agency for Legislative Initiatives, within the framework of the EU Project Pravo-Justice grant, implemented by Expertise France. Its contents are the sole responsibility of the authors and do not necessarily reflect the position of the European Union.

The report is available in English and Ukrainian.