Since the beginning of the war between Ukraine and Russia in 2014, the State Customs Service of Ukraine (SCS) has been demonstrating a high level of institutional resilience. Today, it secures about 30% of Ukraine’s public budget revenue – a percentage that has been stable over the past few years – which positions it as one of the leading institutions contributing to the State’s financial capacity. It employs approximately 10,000 staff, with around 670 officials working in the central office and the rest working at one of the 100 border crossing points located across the western border or at a Customs infrastructure, including 28 strategic road crossings dedicated to freight transport.

The Service puts a strong focus on digital transformation and the harmonization of Customs procedures with EU standards. It is also committed to increasing transparency and integrity. Through the targeted efforts of its Department for Prevention and Detection of Corruption, Ukraine has become one of the few countries to successfully conduct a Customs Integrity Perception Survey twice consecutively – in 2024 and 2025. This achievement was made possible through a strategic partnership with the WCO within the framework of the Anti-Corruption and Integrity Promotion Programme, which is funded by the Government of Norway.

The SCS Anti-Corruption Programme 2023-2025 not only established a set of measures to prevent and restrict corrupt behaviour, but also set out a comprehensive roadmap for institutional transformation, a principle also embedded in the new Anti-Corruption Programme 2026-2028. The Department for Prevention and Detection of Corruption, in charge of implementing the Programme, had to shift from only reacting to misconduct cases, to building an environment where corruption becomes technically impossible and unacceptable.

The SCS Programme is fully aligned with the 10 factors listed in the WCO Revised Arusha Declaration concerning good governance and integrity in Customs, while putting emphasis on the need to adopt an evidence-based approach to inform the development of policies and initiatives.

To collect data on corruption and integrity, the Service decided in 2024 to conduct a Customs Integrity Perception Survey (CIPS), the tool developed by the WCO to measure integrity behaviours and perceptions among Customs officials and private sector stakeholders.

The aim of the Department for Prevention and Detection of Corruption in conducting the survey was to be able to analyse feedback from Customs staff and the business community in order to:

• identify real “pain points” and
• assess the gap between anti-corruption instruments’ objectives and actual practice.

The SCS had been participating in the WCO Anti-Corruption and Integrity Promotion (A-CIP) Programme since May 2024, and therefore benefited from the support of WCO experts while preparing and conducting its first CIPS in September 2024. The survey was conducted by a third party, PwC Germany, using an on-the-ground data collection method, with the key objective of testing the instrument and establishing baseline indicators. The geographical scope was restricted to five key Customs offices located along Ukraine’s western border with the European Union – Kyiv, Zakarpattia, Lviv, Chernivtsi and Volyn. Approximately 430 Customs officers and 440 representatives of the business community participated.

Once the pilot had confirmed the system’s readiness for a larger-scale survey, it was decided to conduct a second survey, using the WCO Customs Integrity Perception Survey Online Tool (CIPS-OT).

This second survey was conducted from 15 to 30 September 2025 and marked a major breakthrough in terms of participation and coverage. Using the CIPS-OT not only enabled the SCS to reach citizens, business associations and Customs staff across the entire country, but also led to greater confidence in the capacity of the system to protect participants’ anonymity.

Over 5,000 individuals responded to the survey, positioning Ukraine as the country with the highest level of response to CIPS so far. The Department for Prevention and Detection of Corruption obtained a structured data set, allowing it to conduct analyses of corruption risks and compare the perception of the effectiveness of integrity measures between 2024 and 2025.

The evolution of CIPS from a pilot initiative to a nationwide benchmark demonstrates a growing level of trust in the process. With methodological support from the WCO and strong technical implementation by the Department for Prevention and Detection of Corruption, Ukraine has established one of the most advanced integrity monitoring systems in Customs in Europe.

CIPS questions are grouped into modules around each of the 10 key factors of the WCO’s Revised Arusha Declaration. For each of the target groups, a set of performance indicators has been developed to quantify the extent to which a certain goal is being achieved, with each individual indicator being linked to a question. The questions posed are intended to measure either perception or behaviour.

The metrics used to assess performance under each indicator are similar for both questionnaires. The main metric used is the extent of agreement with a specific statement, along a 4-point scale ranging from “Strongly agree” to “Strongly disagree”. A second metric employed regularly throughout the questionnaires is occurrence and frequency of occurrence (i.e. Always, Often, Sometimes, Never). This is used particularly to measure behaviour – i.e. whether and/or how often the respondent has engaged in certain behaviours. A specific type of behaviour-related question included in both questionnaires is a scenario test. In these questions (specific to each target group), the respondent is presented with a hypothetical scenario, along with some possible reactions to it.

The responses to the questions are scored on a 4-point Likert scale; a weighted mean, or score, can be calculated for each indicator. The most positive response has the greatest weighting, i.e. 3, and the least positive response, 0. The higher the score for a given indicator, the more positive the result.

Responses from individuals working for a business involved in cross-border trade showed a consistent trend of improvement across seven out of nine key factors of the Revised Arusha Declaration.

They highlighted the points below.

• The positive impact of digitalization.
• The increase in trust following the launch of the upgraded Anti-Corruption Portal.
• Clearer procedures for reporting corruption-related incidents, and improved confidence in the safety of submitting such reports – all respondents who had engaged with the SCS on integrity-related matters assessed this experience positively.
• The need for greater transparency regarding the outcomes of internal controls and investigations – “Audit and Investigation” was the only area where scores decreased.

Customs staff gave more critical answers than in the previous survey. The only factor showing improvement was “Human Resource Management”. Perceptions regarding “Regulatory Framework” and “Automation” remained stable. Perceptions deteriorated across seven key factors, with the most substantial decline related to “Morale and Organizational Culture”, as well as “Audit and Investigation”.

CIPS 2025 confirmed a gap between formal commitments and day-to-day practice. While staff acknowledged the existence of integrity and anti-corruption mechanisms, they did not always perceive them as effective or fairly enforced. Staff expressed a clear expectation of seeing tangible outcomes of internal investigations and disciplinary measures, proving that rules apply equally to everyone. Many respondents also noted that the current Code of Conduct was overly formal and that there was a need for practical case studies and clear action guidelines for complex ethical dilemmas.

The second survey also saw the participation of more female officers, lower-grade officers, and officers who had joined the organization more recently. The demographic composition of the second CIPS also reflected more closely that of the Administration. The results shed light on differences in perception between genders, age groups and roles: female officers had a less positive perception about reforms than did their male counterparts, and staff in lower positions were less positive than senior management. Moreover, while younger officers showed a readiness to serve as ambassadors for change, they also most acutely felt the gap between modern values and the “old habits” of the system. This highlighted the need to expand mentoring mechanisms and involve young staff more actively in decision-making.

Finally, questions related to threats were added to the second CIPS questionnaire for Customs officers, and one in five respondents (20%) reported that they had received threats from organized crime groups, showing that there is a need not only for training in how to handle these threats, but also for real physical and legal protection.

The preparation and implementation of CIPS in Ukraine was a stress test for the Department for Prevention and Detection of Corruption, which faced a range of unprecedented obstacles.

Conducting a survey in regions under constant threat of shelling, power outages, and unstable Internet connection made it necessary to extend the time limits for entering responses.

In response to the scepticism expressed by some members of staff regarding the anonymity of questionnaire respondents, an extensive communication and awareness campaign was launched, emphasizing that the survey was aimed not at punishment, but at systemic improvement and long-term transformation.

The 2025 experience demonstrated that the transition to a digital tool not only simplifies logistics, but also significantly increases trust.

The analysis showed that where Customs management actively explained the objectives and value of reforms, perceptions related to “Leadership and Commitment” remained stable or improved. The key lesson is that reforms cannot succeed without sustained dialogue with frontline and mid-level staff.

CIPS results became a powerful evidence base for the SCS in its engagement with national and international partners. Having documented organized crime threats through survey data, the Department for Prevention and Detection of Corruption can now credibly advocate for additional resources aimed at staff protection and social support mechanisms for Customs officers.

Improved private sector perception across seven out of nine factors demonstrated that even incremental steps towards transparency – such as launching the Anti-Corruption Portal – can generate immediate and positive feedback from the business community. This confirmed the strategic value of open partnership with stakeholders.

The deterioration of certain internal indicators in 2025 served as a “realism check”. It suggests that early reform steps often coincide with increased expectations and higher critical awareness among staff. This should not be seen as a failure.

The CIPS results formed the foundation of the SCS Anti-Corruption Programme 2026-2028.

The Department for Prevention and Detection of Corruption is now preparing official reports for each Customs office, which will demonstrate to their staff that their voices have been heard. It has also used the findings to develop a customized work programme adapted to each territorial Customs unit.

The SCS also participated in the first cycle of the WCO Performance Measurement Mechanism (PMM) by submitting data for the 2022 calendar year on a set of 49 key performance indicators (KPIs) related to 23 expected outcomes. As it continues to monitor these KPIs, it will be able to link integrity perception indicators for each Customs post to the PMM indicators, such as Customs revenue, clearance time, and levels of detection of fraud and illicit trade.

Based on the data collected during CIPS, the priority areas below have also been identified.

• Strengthening internal communication: there is a strong need to better explain the objectives and outcomes of reforms in order to increase staff engagement.
• Empowering young professionals: particular attention will be given to younger employees, ensuring that they have a meaningful “voice” in the change process. A dedicated platform for young staff to propose practical ideas for improving work processes is to be created.
• Enhancing training, with a focus on practical ethical cases rather than formal compliance and purely normative learning, as well as with the objective of providing clear guidance for staff on how to act in the event of threats, who to contact, and what safety steps to take.
• Reforming the Code of Conduct: staff at operational levels assessed the clarity and perceived fairness of the current Code of Conduct less positively. The Unit plans to review both the content of the Code and the approaches used to ensure its implementation.
• Strengthening Business-Customs cooperation: the fact that 100% of business respondents positively assessed their integrity-related engagement with the SCS represents a significant trust capital – one that the Department for Prevention and Detection of Corruption aims to translate into sustainable outcomes through 2028. Seminars bringing together Customs and business association representatives are already planned, with the objective of developing shared standards for ethical engagement and interaction.
• Modernizing the Anti-Corruption Portal to enable business not only to report corruption acts, but also to track progress of the procedure over time, and to view the outcomes of complaint reviews.
• Enhancing whistleblower protection by strengthening cooperation with the National Agency on Corruption Prevention (NACP), law enforcement bodies, and international security institutions to establish a rapid response system for cases of pressure on Customs personnel.
• Developing expertise on cross-border crime and corruption risks.

Thanks to funding provided by the Government of Norway, the State Customs Service of Ukraine will continue benefiting from the WCO A-CIP Programme until September 2028. This is a recognition of the SCS’ achievements and of its capacity, even in wartime conditions, to remain committed to transparency and integrity principles. With a clear action plan through 2028 and strong support from the WCO, the SCS is moving confidently towards its goal: becoming a modern, integrity-driven and high-tech service – a source of pride for Ukraine and a reliable partner for the global Customs community.