ZMINA, in coalition with civil society coordinated by the Agency for Legislative Initiatives, is preparing its third Shadow Report to the European Commission’s Enlargement Report
The Human Rights Centre ZMINA, in coalition with civil society organisations and coordinated by the Agency for Legislative Initiatives (ALI), is launching a new cycle of monitoring and assessing Ukraine’s progress in European integration. The results will be reflected in the 2026 Shadow Report. As in previous years, it will cover Chapter 23 “Judiciary and Fundamental Rights” and Chapter 24 “Justice, freedom and security”. This year, experts will also analyse another component of the “Fundamentals” cluster – “Functioning of Democratic Institutions”.
The Shadow Report is entirely a product of civil society, regardless of its sources of support. To strengthen the institutional independence of the process, we are launching a new approach this year: the Shadow Report will also be funded by independent civil society organisations. A significant portion of the funds for its development will be covered by the Agency for Legislative Initiatives and Transparency International Ukraine. The ALI assumes responsibility for ensuring maximum impartiality and objectivity in the preparation process, as it does every year.
The coalition working on the Shadow Report consists of nine civil society organisations. This year, it will be prepared by experts from the Agency for Legislative Initiatives, Transparency International Ukraine, the Human Rights Centre ZMINA, Tomorrow’s Lawyer, Europe Without Barriers, the Ukrainian Bar Association, the Civil Network OPORA, the Centre for Democracy and Rule of Law, and with informational support from European Pravda.
The report will include:
- Description of the current state of affairs regarding the functioning of democratic institutions, progress of reforms in this area, as well as recommendations from the perspective of civil society.
- Assessment of the progress made by Ukraine in Chapters 23 and 24 since the publication of the European Commission’s Report on Ukraine’s progress within the EU Enlargement Package in 2025 for each area, as well as taking into account the recommendations from previous Shadow Reports.
- Detailed analysis of the problems that arose in the reform process for each area of these chapters.
A separate section of the 2026 Shadow Report will cover specific recommendations from the coalition on how to solve the problems identified in each area. This will provide guidelines for the future direction of government policy in each area.
It should be noted that this year’s Shadow Report will, in line with established practice, be published ahead of the European Commission’s 2026 Report on Ukraine within the EU Enlargement Package.
For reference
The preparation of Shadow Reports is a regular practice for all candidate countries seeking to accede to the European Union. In Ukraine, this work has been carried out systematically since 2024, when a coalition of civil society organisations first prepared an alternative analysis to the European Commission’s Report on Ukraine’s progress within the EU Enlargement Package.
A Shadow Report is an independent alternative analysis of government policy and the candidate country’s fulfilment of its obligations to the EU. It is a systematic assessment conducted by experts from civil society organisations, which does not duplicate official government documents or the European Commission’s assessment. Instead, it serves as a tool for civic oversight and expert involvement in the reform process. At the same time, it assesses the alignment of Ukrainian legislation and the entire system with EU standards. One of the objectives of the Shadow Report is to identify gaps and facilitate effective implementation of reforms.
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