The NGO “Ecology-Law-Man” has completed a public review of the powers and institutional capacity of the State Agency for Water Resources of Ukraine.
Structurally, the review is divided into three key sections covering a comprehensive analysis of the Agency’s regulations, the impact of legislation on water user organizations on the Agency’s functions, and a detailed assessment of the Agency’s institutional capacity, including its human resources, financial, and IT capabilities. To verify the actual status of task implementation, the EPL team reviewed the Agency’s performance reports for 2021–2025, budget program specifications, and other documents, and conducted a detailed review of the Agency’s information resources.
The key findings of the public review point to a deep systemic crisis in Ukraine’s water resources management, which continues to be dominated by a focus on water consumption by economic sectors. The first section of the review presents a critical analysis of the State Agency for Water Resources’ (SAWR) activities in accordance with the functions outlined in the Regulations on the State Water Agency, the Water Code of Ukraine, and other regulatory acts governing relations in the water resources sector. The agency’s reporting structure does not align with its list of functions, which significantly complicates public oversight. The analysis identified the following key issues: failure to implement measures for the protection and restoration of water resources and the ecological rehabilitation of surface waters; inadequate monitoring of water resources; limited and fragmented research on the impact of the war on river pollution; problems with the implementation of river basin management plans and the functioning of basin councils, the lack of legal liability for failure to implement river basin management plans, and the closed nature of the Water Cadastre data, insufficient public access to information and participation in decision-making regarding water resources management, overlapping functions between the State Water Agency and the State Agency of Ukraine for Land Reclamation, Fisheries, and Food Programs, particularly regarding the management of water infrastructure facilities.
New legislation in the field of land reclamation has initiated a process to separate resource management from network operations, with the State Water Agency set to become the resource regulator. The analysis identified a risk of conflict of interest due to parallel water accounting at the local level of the OVC and the national level of the Agency, which requires clear digital synchronization and clarification of the provisions of the Water Code.
One of the identified shortcomings in the State Water Agency’s operations, which affects water policy as a whole, is the critically low level of state monitoring. As of early 2026, it covers no more than 10% of surface water bodies, making it impossible to objectively assess the condition of most of the country’s river basins. Although the agency reports a high percentage of coverage of planned monitoring points, an analysis of the online services’ functionality revealed that public digital platforms are not functioning properly. For example, the “Monitoring and Environmental Assessment of Water Resources” system includes monitoring points whose data has not been updated since 2018, and the website’s interface often displays outdated information even where measurements are taken monthly.
We also noted significant limitations on access to geospatial data. The “Water Resources of Ukraine” geoportal was not operational at the time of the audit, and access to the National Geoportal of the National Institute of Geodesy and Cartography (NIGC), where updated Water Cadastre data—as reported by the State Water Agency in 2025—are supposed to be published, remains restricted. The Agency’s institutional capacity is in doubt due to a rather drastic reduction in staff from nearly 19,000 in 2021 to a planned 11,600 by 2026. Concerns about the quality of service delivery arise from the small number of interregional sectors, which are forced to process vast amounts of documentation, particularly regarding the issuance of permits for special water use.
The State Water Agency’s financial model also demonstrates a significant imbalance, as the vast majority of funds are spent on the ongoing maintenance of outdated hydraulic infrastructure, while minimal resources are allocated to the ecological restoration of rivers and scientific research. The expert assessment highlights a catastrophic funding gap for European integration measures, as the agency’s annual budget is 87 times smaller than the capital investments required to implement river basin management plans by 2030. In addition to financial problems, there is a lack of legislative accountability for failure to implement the measures outlined in the basin plans.
Based on the findings of the expert review, the EPL recommends fundamentally changing the priorities of the State Water Agency, expanding its scope of management, and implementing a genuine “polluter pays” principle to finance the restoration of aquatic ecosystems.
The expert group that worked on the document included leading specialists from the organization, among them Legal Counsel Oksana Kizima, Executive Director Olena Kravchenko, Senior Legal Counsel and Ecologist Anatolii Pavelo, ecologists Kateryna Polyanska and Anna Yalova, as well as Senior Lecturer at the National University of Kyiv-Mohyla Academy Mykhailo Khorev. The review process began pursuant to an order issued by the Agency itself on January 13, 2026, which provided access to the necessary working materials and the agency’s internal documentation. The full text of the public review and the resulting recommendations can be found at the following link: https://davr.gov.ua/gromadska-ekspertiza
This material was prepared with the support of the European Union and the International Renaissance Foundation as part of the joint initiative “Joining the EU Together.” The material reflects the authors’ views and does not necessarily reflect the views of the European Union or the International Renaissance Foundation.
Source: Ecology-Law-Human
