In late 2025, under the UK government-funded Special Defence Advisor (SDA) Programme, the Ukrainian think tank StateWatch worked with Prozorro — Ukraine’s national e-procurement system, through which all public contracts are published and monitored — to introduce two new indicators into Prozorro’s risk module. The goal: to flag suspicious amendments made to public contracts after they are signed.

New Risk Indicators: What ARI 1-1 and ARI 1-2 Flag

The two new indicators are:

• ARI 1-1 — flags any contract that has received three or more amendments.
• ARI 1-2 — flags any contract where two or more amendments were justified using the clause “improvement of the quality of the procurement subject” — a broad, catch-all justification under Ukrainian procurement law that StateWatch’s research shows is often used to cover unrelated administrative or financial changes.

Together, these indicators surface contracts with a higher likelihood of unjustified changes to material terms — potentially masking price manipulation, scope changes, or other irregularities.

Early Results: 4,195 Flags in Two Weeks

In the first two weeks after the indicators went live, Prozorro’s risk module recorded 4,195 flags. The flagged contracts — issued by both defence and civilian contracting authorities — covered an estimated EUR 790 million in contract value, spanning fuel and energy supply, construction, and infrastructure maintenance. Some individual contracts had been amended up to 11 times.

Among the eight largest contracting authorities flagged, five triggered both indicators simultaneously — meaning they had multiple amendments and repeated use of the “quality improvement” justification. The remaining authorities triggered one of the two indicators, which StateWatch notes still warrants closer review.

Case Studies: Suspicious Contract Amendments

Specific cases include:

• Ukrnafta (state-owned oil company) planned to procure electricity worth UAH 3.34 billion. After signing, the parties added three amendments, officially justified by changes in external factors such as exchange rates and tariffs.
• SOE “Forests of Ukraine”, originally planning to procure fuel worth UAH 1.14 billion, signed contracts for UAH 1 billion, then added 11 amendments — citing unit-price adjustments and an agreed reduction in value. After the final amendment, the total contract value dropped to UAH 946 million.
• The Infrastructure Restoration and Development Service in Zakarpattia Oblast had planned to build the “Bila Tserkva–Sighetu Marmației” border crossing on the border with Romania. The estimated cost of the project was UAH 2.04 billion, and the contract was signed for UAH 1.99 billion. Two subsequent amendments — formally justified as “quality improvements” — actually involved changes to advance payments, banking details, and the reallocation of 2025 budget commitments.
• A subsidiary of Ukrainian Railways had planned to purchase diesel fuel worth UAH 1.46 billion. Following five amendments to the contract, the total value rose to 1.53 billion hryvnias. In two of these additional agreements, ‘improvements to the quality of the goods being procured’ were also cited as the reason for the changes.

Other flagged authorities among the top eight included the Kharkiv Regional Military Administration’s Capital Construction Department, the State Penitentiary Service of Ukraine, and the Mykolaiv Regional Local Roads Agency — all showing both indicators triggered simultaneously, suggesting an elevated risk of unjustified changes to material contract terms. This suggests an elevated risk of unjustified changes to material contract terms.

State Logistics Operator (DOT): 26 Contracts Worth UAH 23.36bn

StateWatch’s analysts also reviewed contracts already signed by Ukraine’s State Logistics Operator (DOT) — the centralised body responsible for major logistics procurement for Ukraine’s Armed Forces. Every one of the 26 contracts had at least two amendments to material terms — all formally justified as “improvement of the quality of the procurement subject.”

Across five procurement procedures, DOT had signed 26 contracts worth a combined UAH 23.36 billion (approximately USD 520 million / EUR 460 million):
– UAH 1.64 billion across 8 lots for diesel fuel
– UAH 22.19 billion across 18 lots for food supplies

At the same time, each contract contains at least two amendments to its material terms. Formally, all of these were justified as “improvement of the quality of the procurement subject.” However, StateWatch’s content analysis of the amendments found that most actually involved changes to counterparties’ bank details, tax/registration codes, or other administrative and financial corrections — with no real connection to the quality of what was being procured.

Why This Matters for Wartime Procurement Oversight

Ukraine’s public procurement system handles tens of billions of dollars annually under wartime pressure, with limited capacity for manual review. By embedding these two indicators directly into Prozorro’s risk module, regulators, journalists, and civil society organizations now have an automated, systematic way to surface contracts where the stated justification for post-signature changes does not match what actually changed. For Ukraine’s international partners, this is a concrete example of how a small, targeted analytical intervention — developed by an independent Ukrainian think tank and implemented directly into a national e-procurement platform — can scale to cover the entire procurement system going forward, strengthening accountability without requiring case-by-case manual audits.

This initiative was carried out under the UK Special Defence Advisor Programme.