Combating corruption in Customs: What has changed in its perception by business and customs officers over the past year?

How successfully is the State Customs Service of Ukraine progressing along the path of overcoming corruption? A unique opportunity to assess trends from the perspective of both customs officers and the private sector was provided by the Customs Integrity Perception Survey (CIPS), which was conducted for the second consecutive year in 2025 by the State Customs Service in cooperation with the World Customs Organization.

Based on the indicators that underpinned our analysis last year, changes have occurred that, while not tectonic, are nevertheless positive. These relate to the level of perceived corruption at customs among the two surveyed groups, the number of respondents who consider bribery an effective way of resolving issues and those who have themselves offered bribes, the perceived negative impact of complex customs rules on the ability to conduct business, the demotivating effect of the lack of inevitable consequences, the personal example set by management, and other factors.

Positive shifts do not mean a complete victory over corruption. However, they make it possible to identify where progress is being made and which areas require additional attention.

Increased representativeness

In 2025, an online tool used to conduct the survey made it possible to collect responses from a larger and more representative group. In 2024, responses were received from 448 customs officers, of whom 85% were managers and only 15% were non-managerial staff. In 2025, the number of customs officers surveyed increased by an order of magnitude to 4,199, of whom 23% were managers and 77% non-managers, more accurately reflecting the personnel structure of the State Customs Service. As for the private sector, the number of respondents increased from 477 to 1,033.

Perception of corruption and tolerance towards it: one year on

To assess the level of perceived corruption in the country, we primarily look at the share of business respondents who believe that life can be “made easier” through bribes. Whereas this share stood at 35% the previous year, it has now decreased to 32% of those who agree or mostly agree with this statement. Notably, the share of those who partially or strongly disagree has also changed, increasing from 53% to 59%.

The trend towards improvement is confirmed by two additional indicators. The share of “practitioners” – those who have offered bribes – fell over the year from 11% to 6%. The share of “theoreticians” who believe that a bribe could help them circumvent certain customs requirements also declined, from 47% to 41%.

As more than twice as many entrepreneurs were surveyed this year, the study is more representative than the previous one. Therefore, the observed reduction of 3–6% in the “support group for corruption” (or “group tolerant of corruption”) among entrepreneurs, across various indicators, points to a positive trend.

I reiterate that this does not mean corruption at Ukrainian customs has been eradicated. However, it allows us to record optimistic changes in this sensitive issue for society. The dynamics of factors that provoke corruption make it possible to identify the most influential causes and determine promising points for further progress.

One of the key factors that provoke corruption is the complexity of customs rules. In this area, perhaps the most noticeable positive changes have occurred. If a year ago 65% of surveyed entrepreneurs believed that the complexity of customs rules negatively affected their ability to do business, the share of those who partially or fully agree with this statement has now decreased to 53%. Meanwhile, the number of those who strongly disagree has almost doubled, from 13% to 24%.

The study does not identify the specific reasons for these shifts, but they may include, among other things, the introduction of customs simplifications accessible to a wider range of businesses and the digitalisation of a number of customs procedures.

Expectations of punishment for corruption and whistleblower safety

Among the factors that foster corrupt practices and discourage an active stance against corruption are, traditionally, the absence of inevitable negative consequences for corrupt actors and risks to whistleblowers themselves.

This year, the proportion of customs officers who believe that reporting corrupt behaviour does not lead to any action increased slightly compared to the previous survey – from 10% to 13%. The share of those who do not believe that reports of corruption are investigated fairly also rose, from 6% to 7%. In my view, however, this is linked to the change in the structure of surveyed officials, among whom the proportion of non-managerial staff increased significantly (from 15% to 77%).

As for confidence in personal safety when reporting integrity violations, a significant group of customs officers (12%) still do not feel safe doing so. Moreover, this figure has slightly increased compared to the previous survey (10%).

The 2025 CIPS survey for the first time revealed the scale of threats faced by State Customs Service employees from organised crime as well. A significant share – 20% of customs officers – reported having received threats; 14% psychological threats and 6% physical threats. As in the case of whistleblowers, this concerns the fundamental value of safety, which must be ensured during service. Therefore, the issue requires a priority response from the agency’s leadership to create a safe environment, ensure the protection of customs personnel by the State Customs Service, and, consequently, support integrity.

Leadership: setting an example, not interfering

It is evident that the stance of leadership has a significant impact on corruption in the customs sphere. In this area, the survey also demonstrated positive, though not decisive, trends.

The share of customs officers who feel encouraged by management to report corruption increased from 87% to 90%. At the same time, the proportion of entrepreneurs who do not believe that the customs administration’s leadership is taking measures against corruption decreased from 16% to 14%.

However, a substantial share – 13% – believes that customs leadership does not set a positive example of integrity, and this figure has increased compared to the previous survey (10%).

Although somewhat weakened, the influence of direct supervisors on decision-making by customs personnel remains strong. Thus, 44% of respondents (compared to 46% previously) feel insufficiently informed about the reasons why a manager asks them to deviate from standard procedures. Meanwhile, 20% (compared to 21% previously) do not apply standard procedures without undue interference from other officials.

These results may raise concerns about improper interference in administrative processes. A high level of authority vested in middle management can be misused. A lack of transparency or collegial oversight may lead to abuses of power.

Another important aspect should be noted. Only 12% of respondents are inclined to report violations to internal investigative bodies and only 3% to external ones, indicating a very low level of trust in administrative procedures and official anti-corruption mechanisms. By contrast, 73% of respondents (down from 80% previously) are ready to report corruption to their immediate supervisor, confirming the strong authority of direct management. The key question is what happens to observations reported in this manner.

Changes: general conclusions

The results demonstrate that perceptions of integrity have changed over the past year. There has been an improvement in how the private sector and external audiences perceive the efforts of the State Customs Service to enhance integrity. This indicates cooperation between the State Customs Service and business stakeholders and the public through external communication channels. The somewhat less favourable perception among surveyed customs officers in 2025 may be a consequence of the larger sample size and the more accurate representation of non-managerial staff.

According to the World Customs Organization (WCO), CIPS 2024 identified – and CIPS 2025 confirmed – that the State Customs Service generally has sufficiently developed documentation on integrity principles. However, a gap still exists between the formal existence of integrity principles and their actual implementation. The same conclusion is reflected in the most recent report of the Organisation for Economic Co-operation and Development (OECD): while the regulatory framework on customs integrity is quite strong, fostering a culture of integrity requires a principled approach in everyday practice. Therefore, pressure should be applied to ensure the enforcement of rules in daily operations and to lead by example.

A high level of awareness of anti-corruption opportunities should be noted. Positive changes have been identified, but overall problems remain largely unchanged. Building an organisation resilient to corruption requires years of consistent effort, yet we can already observe a positive impact between 2024 and 2025.

The recommendations following last year’s study concerned the simplification of procedures, the introduction of EU-compatible standards, the expansion of information available to business through guidelines, instructions, trainings/webinars, hotlines, communication campaigns, and similar measures. Activity has taken place in all of these areas.  For example, the State Customs Service launched an “Anti-Corruption” page on its portal and is conducting a communication campaign under the slogan: “Do not offer – we do not take. One step, and you are both parties to a criminal case.” However, it is difficult to directly assess the effectiveness of each of these measures, as individual tools were not measured separately. Nevertheless, the overall anti-corruption policy has had an impact both on the State Customs Service itself and on its assessment by the business community.

Recommendations

The results of the 2025 survey and their comparison with 2024 should help define recommendations for anti-corruption activities in the coming period in order to achieve further progress.

As already noted, the survey confirmed that the State Customs Service has fairly well-developed documentation on integrity principles; however, there is a gap between rules and practice, particularly from the perspective of its own staff, as well as new threats from organised crime and a weak reporting culture.

Developing a culture of integrity that is demonstrated on a daily basis requires not only knowledge of legal provisions and the consequences of corruption, but also training on “how to respond” in practice to typical integrity dilemmas. One possible approach is to review the Code of Ethics to make it easier to read and interpret, as well as to develop practical guidance as a basis for regular dialogues and integrity seminars targeted at new and mid-career staff. Strengthening understanding and confidence can ultimately influence day-to-day practice.

The communication gap can be addressed through a set of measures aimed at building trust between customs officials and the anti-corruption unit, in order to strengthen the communication channel on situations that generate corruption risks. One possible tool is the publication of responses to stakeholder feedback (for example, “You said – we did” reports). Promoting successful whistleblowing stories and ensuring transparency regarding investigation outcomes and sanctions will help build trust. This should be considered not only with regard to whistleblower reports on corruption, but also in relation to any reports of misconduct and improper behaviour, which should be received, analysed, and addressed.

Given the threats to staff from organised crime faced by around one fifth of employees, a dedicated threat management protocol should be developed and implemented, including psychological support and resilience training for frontline staff. This should be complemented by regular security risk assessments, rotation of staff in high-risk positions, and easy access to specialised psychological counselling. Rapid response procedures for staff under threat must be established and tested, while consistently communicating that safeguarding integrity is inseparable from ensuring both the physical and psychological safety of employees.

Staff support for anti-corruption policy is closely linked to their perception of involvement in reforms and modernisation. Over the past year, the sense of engagement and officials’ belief in the effectiveness of modernisation programmes has declined, particularly among newly recruited staff, whose “strongly agree” responses on this issue dropped sharply. Separately implemented modernisation projects across different areas of the State Customs Service (HR, IT, management, etc.) require the presentation to staff of an overarching modernisation plan and a communication strategy, which could be a task for the newly appointed leadership of the State Customs Service.

The CIPS results require prioritisation, need to be translated into concrete actions by the State Customs Service, and should be incorporated into an Integrity Action Plan as an annex to the Anti-Corruption Programme of the State Customs Service. This plan should take into account:

• actions to improve internal and external communication;
• training for managers and non-managers;
• the introduction of internal procedures/policies and their application in daily practice.

All these actions should be assigned to a responsible person or unit and monitored against expected results and timelines. Any initiatives aimed at mobilising integrity and shaping attitudes will not work without the involvement of managers at all levels who, through their influence on staff on the ground, must lead by example, support communication, and motivate their subordinates.

This aligns with the recommendation expressed in the survey results that customs managers should assume a strong leadership role and an appropriate HR level of responsibility and accountability for upholding high integrity standards in all aspects of customs work.

Jacek Kapica

International Anti-Corruption Expert

EU Public Finance Management Support Programme in Ukraine (EU4PFM)