Halyna Yakovleva — Public Procurement & Prozorro Expert
Anastasiia Dziuba — lawyer, Lighthouse Legal Advisory Steering committee member

SECO Call for Proposals (Second Pool): Why This Is NOT Prozorro and How Control, Contracting, and Reporting Really Work 

Why this matters now

On 9 January 2026, Switzerland opened the second SECO Call for Proposals for projects with Swiss companies that have a legal entity in Ukraine, with submissions open until 8 March 2026 (17:00 CET). It’s a large package  (up to CHF 150m), with single project contributions typically CHF 3m – 30m.

If you are a Ukrainian stakeholder trying to “track a project like a procurement”, or a Swiss stakeholder expecting a classic tender trail, you can easily look in the wrong place and conclude (incorrectly) that “nothing is happening” or “there’s no transparency”.

This article explains, in practical terms, what the SECO mechanism is, who plays which role, what the control and evidence trail looks like, and where you can (and cannot) expect to see execution data, using the Glas Trösch “32,000 windows” project as the lead case. 

Common misconception: “SECO Call for Proposals = a Prozorro tender”

It’s tempting to call this a “tender,” but SECO’s own documentation is explicit: selection and funding under the Call is not a Ukrainian-style public procurement procedure.

“Legally not a public procurement procedure” (SECO Main Document).

Procurement vs Contribution (plain-English comparison)

Question people ask	Prozorro / Law “On Public Procurement”	SECO Call for Proposals (financial contribution)
What is it legally?	A public procurement by a Ukrainian contracting authority under the public procurement law	A Swiss financial contribution/subsidy awarded to an implementer under Swiss rules (not a UA procurement procedure)
Who is the “customer”?	A Ukrainian procuring entity (“customer”) runs the procedure and signs the contract	SECO contracts with the implementer (Swiss company with UA entity) for a contribution; the “customer” logic is donor-style grant/contract management
Where do I see the contract, amendments, delivery, completion?	In Prozorro, with mandatory publication of key documents and an end-of-contract report	Often not in Prozorro at all; execution evidence sits in donor reporting + Ukrainian acceptance docs; public footprint is partial
How is misuse controlled?	Procurement transparency + state monitoring tools (audit/monitoring) + remedies	Milestones, reporting, audits, eligibility rules, and third-party monitoring; SECO can suspend/withhold disbursements based on compliance

In practice: If you go hunting for a “tender ID,” an “award notice,” or a “contract completion report” in Prozorro for many SECO projects — you may find nothing, because the mechanism is not designed to generate a Prozorro trail by default.

Who is who (roles you must not confuse)

The donor / funder

SECO (State Secretariat for Economic Affairs) provides the financial contribution and sets the compliance and reporting framework. 

The implementer (the “doer”)

A Swiss company with an established legal presence in Ukraine (for example, through a subsidiary or other registered entity)  submits the proposal, is selected, and implements the project — often using contractors or subcontractors. SECO funds part of the project costs via contribution rules, not via a Ukrainian procurement procedure.

The “end-beneficiary” (public, Ukrainian)

SECO’s call documents require that the main end-beneficiary be a public entity in Ukraine.

That “public entity” is typically the institution that owns or manages the asset (building/infrastructure) and signs off that the result is delivered and accepted.

The recipient (Ukrainian, gets the assistance)

Under Ukraine’s international technical assistance framework, a “recipient” is a Ukrainian resident (legal or natural person) who directly receives the assistance under the project. 

For a windows replacement project, “recipients” can be (depending on design): a municipality/utility/school/hospital operator — and ultimately the facility users.

Third-party monitoring (independent verification layer)

SECO’s monitoring framework (PMELP) foresees external/independent monitoring and structured reporting. This is a major reason why SECO control does not look like Prozorro control.

Ukrainian authorities (what is actually confirmed)

For the first call (2025 selection), SECO and the Ukrainian Ministry of Economy, Environment and Agriculture assessed and selected the projects, per the official Swiss press release.
For the second call (2026), SECO’s public page sets the timetable, scope, documents, and the submission channel; the exact Ukrainian-side evaluation mechanics should be taken from the call documents/Q&A once published. 

End-to-end: how a SECO project moves from “need” to “installed & accepted”

Below is the flow that readers typically expect to see in Prozorro — but in SECO, the same logic exists as milestones and evidence, not as a procurement notice trail.

Step 1 — Need identification (Ukraine-side “demand signal”)

A project must respond to a need in Ukraine. In the 2025 selection release, the condition is stated plainly: projects had to “meet a need in Ukraine,” and the company had to have a legal entity in Ukraine. 

Control point: documented justification of need + alignment with public infrastructure priorities.
Evidence trail: letters/endorsements, project rationale, baseline damage/needs data (often not fully public).

Step 2 — Proposal submission (SECO portal; not Prozorro)

Applications in the second pool must be submitted via SECO’s designated online application portal, within the stated window. 

Control point: eligibility and award criteria (document-based assessment; no “bid auction”). 

Step 3 — Selection (award of contribution)

For the first call, project proposals were assessed jointly by SECO and the competent Ukrainian ministry. The process included both an eligibility screening (formal compliance with the Call requirements) and a substantive evaluation based on predefined award criteria. Only proposals that met the formal requirements proceeded to scoring.

At the evaluation stage, projects were assessed comparatively – not through a price auction, but through qualitative and financial criteria such as relevance to Ukraine’s reconstruction needs, technical feasibility, implementation capacity, financial robustness, risk management, and sustainability. Particular attention was given to co-financing structure and the credibility of private-sector leverage.

Selection was also constrained by the overall budget envelope of the Call and portfolio considerations (sectoral and geographic balance). The outcome of this stage is not a public procurement award, but a decision to enter into a financial contribution agreement with the selected implementer.Control point: The selection decision must be based on documented scoring against published criteria, fit within the overall financial envelope of the Call, and confirm that the proposed co-financing structure is credible and financially sound.  

Step 4 — Contracting (SECO ↔ implementer)

This is the legal “spine”: SECO’s contractual relationship is with the implementer (financial contribution contract), which drives reporting, audits, milestones, and disbursements.

Control point: contractual milestones/deliverables, eligible costs, audit rights, and remedies for non-compliance.

Step 5 — Delivery & installation (often via subcontractors)

The implementer procures goods/works/services needed to deliver the outputs, frequently using subcontractors. Under Ukraine’s legally established International Technical Assistance (ITA) regime – governed by Cabinet of Ministers Resolution No. 153, which regulates the registration, coordination and monitoring of donor-funded projects – subcontractors may carry out procurement using ITA funds within the project. 

Control point: procurement integrity and documentation (donor rules + implementer controls; not necessarily Prozorro).

Step 6 — Acceptance (Ukrainian end-beneficiary confirms “received and comply with the agreed specifications ”)

This is where Ukrainian “real-world control” becomes tangible: the public end-beneficiary (asset owner/operator) signs acceptance documents and confirms volumes/quality/warranty terms.

Control point: acceptance acts, defect lists, commissioning confirmations, warranty records.
Evidence trail: signed acts, photo evidence, geotagging/site visits, sampling checks (what is published depends on the system and confidentiality rules).

Step 7 — Reporting & verification (donor compliance + third-party monitoring)

SECO’s PMELP is designed to structure: what must be reported, how progress is verified, and how independent monitoring supports evidence-based payments.

Control point: milestone verification before disbursement; independent monitoring reports; financial reporting.

Where to look for execution data (public vs semi-public vs internal)

Think of SECO projects as having multiple “data shells.” The closer you get to addresses and acceptance acts, the less likely it is to be fully public.

1) SECO public footprint (high-level, public)

SECO’s second call page gives: scope/sectors, timing, document pack, total envelope, and a reminder that Q&A will be published publicly on a set date. 

It also contains a public list of the twelve projects selected under the first call, explicitly noting they “are now being implemented”. 

2) Swiss government press releases (public, narrative)

The Swiss federal press release lists selected projects and funding amounts, including the 32,000 windows project (CHF 9.9m contribution), and explains the selection setup and funding split. 

3) Ukrainian ITA  registration (semi-public administrative layer)

SECO’s Main Document states that successful applicants will be required to register the project in Ukraine as international technical assistance (ITA).

Ukraine’s ITA procedure is set by the Cabinet of Ministers’ framework № 153 which:

• makes ITA projects subject to mandatory state registration; 
• defines roles (beneficiary, recipient, implementer, coordinator); 
• and foresees that a procurement plan for ITA-funded purchases is shared/recorded, with parts published except commercial secrets. 

What you can often confirm from ITA materials: donor/partner, implementer, Ukrainian beneficiary/recipient(s), geography, budget, duration, and responsible coordinators — i.e., “who is who” and “where”. 

4) DREAM / Single Project Pipeline (project lifecycle visibility, where used)

SECO explicitly flags that alignment with Ukraine’s Single Project Pipeline is “important and will be rewarded” — and even references DREAM-office webinars for applicants. 

Practical implication:Practical implication: if a SECO project is included in DREAM or the Single Project Pipeline, this platform may provide public visibility on the project’s status, geographic scope, and key implementation stages – but only to the extent that the relevant project entry is publicly accessible and regularly updated.

5) Prozorro (only in specific scenarios — not the default)

Prozorro becomes relevant if a Ukrainian contracting authority runs a procurement that is connected to the project (e.g., co-financing, complementary works, or the beneficiary procuring additional services with public funds).

When Prozorro applies, Ukraine’s procurement law creates distinct publication and oversight duties, including:

• publication obligations and end-of-contract reporting (execution report), 
• and formal monitoring of procurement procedures. 

Bottom line: “No Prozorro trail” does not automatically mean “no control.” It usually means “control sits in a different contour”.

Three lines of control (running in parallel)

SECO-style projects usually operate three simultaneous control lines. Confusing them is the № 1 reason stakeholders misread accountability.

Line A — Donor compliance (SECO)

• Milestone-based contracting logic and evidence requirements
• Eligibility rules for spending
• Reporting and audit trail
• Third-party monitoring as an independent verification layer

Line B — Ukrainian acceptance (end-beneficiary control)

• “We received it, installed it, and it works” control
• Acceptance documents, defect remediation, warranties
• ITA coordinators/responsible persons in the administrative framework 

Line C — Public procurement control (only if Prozorro applies)

• Publication of contracts/changes/execution reporting
• State monitoring of procurement procedures

Blind spots to expect (and how to interpret them):

• Exact addresses may be absent from Swiss public releases (security/privacy/operational reasons).
• Procurement lots may be internal to the implementer (not Prozorro).
• The “best” evidence may sit in acceptance acts and donor monitoring platforms — not in public registries.

Case study: Glas Trösch — “Replacement of over 32,000 windows”

The Swiss federal press release lists Glas Trösch Holding AG with a CHF 9.9m SECO contribution for “Replacement of over 32,000 windows damaged by the war in eastern Ukraine”. 

What “control” looks like in a windows project (the real evidence trail)

In a project like this, the donor and Ukrainian acceptance layers usually require an evidence chain that answers four simple questions:

1. Were the right windows delivered?

specs, quantities, batch/serial references (as applicable), delivery notes

2. Were they installed where intended?

site lists, work logs, photo evidence, geotags, sampling visits, beneficiary confirmations

3. Were they accepted as compliant?

acceptance acts, defect lists, sign-offs, commissioning statements, warranty registration

4. Were costs eligible and properly documented?

invoices/contracts, payment evidence, allocation to project budget lines, audit trail, compliance checks

Why you may not see the addresses publicly

Neither the SECO second call page nor the Swiss press release is designed to publish a building-by-building installation map for all projects. They provide public accountability at program level (what, who, how much). 

Where addresses usually exist (legally, operationally):

• the project’s internal site registers and annexes
• acceptance documentation signed by the Ukrainian public end-beneficiary/recipient
• ITA registration materials (often with geographic scope, sometimes with object-level detail)
• DREAM / Single Project Pipeline entries (when used and sufficiently public)

How to verify responsibly (without “leaking” sensitive data):

• ask the Ukrainian end-beneficiary institution for aggregate confirmation (which facilities category/which municipality; total counts; timeframe)
• request access through lawful information channels when public information rules apply
• use the ITA registration and DREAM card as “official anchors” for non-sensitive project identifiers 

Legal backbone (only what the reader truly needs)

Switzerland: why it’s a subsidy / financial contribution regime

SECO’s Main Document cites its legal basis in Swiss federal acts governing financial assistance/subsidies and international cooperation/humanitarian aid. 

Plain meaning: Switzerland controls the money as a contribution with conditions (eligibility, reporting, audits, remedies). That is structurally different from a procurement authority buying goods via a tender.

Ukraine: two different legal “tracks” may apply

1. International Technical Assistance (ITA) — the administrative framework for registration, roles, and monitoring of assistance projects. 
2. Public Procurement law — applies only when a Ukrainian contracting authority procures under the procurement regime; it creates publication and monitoring duties (including end-of-contract reporting and monitoring procedure rules). 

How this correlates with Ukraine Facility (results-based financing logic)

The EU’s Ukraine Facility is established by Regulation (EU) 2024/792 and uses a results-oriented architecture (support linked to reforms/investments and control/anti-fraud safeguards).

A key point for readers: Ukraine Facility is not “a big Prozorro tender” either. It is a funding instrument with layered controls, including an Audit Board mechanism referenced in EU acts on implementation. 

Takeaway: SECO’s model (milestones + reporting + verification) will feel familiar to anyone who understands results-based financing — even if it looks unfamiliar to someone trained only on Prozorro workflows.

Practical checklist (UA + CH): how to “check” a SECO project without guessing

If you are a Ukrainian citizen / journalist / civil society monitor

1. Start with the Swiss public anchors: project list, amount, implementer, sector. 
2. Look for the ITA registration footprint (project identifiers, beneficiaries/recipients, coordinators, geography). 
3. Check whether a DREAM / Single Project Pipeline entry exists (and whether it is public). 
4. Only then check Prozorro — but only if there are signs the Ukrainian side is procuring something connected. 

If you are a Swiss company / Swiss taxpayer / compliance stakeholder

1. Treat the project as a contribution contract: plan your evidence trail from day 1 (milestones, acceptance, audit readiness).
2. Make sure the Ukrainian public end-beneficiary role is real (not nominal), because acceptance is a core control layer.
3. Decide early what can be public (non-sensitive summaries) vs what must stay internal (site-level details), and document the “why”. 

Red flags (for both audiences)

• “We can’t name any Ukrainian public end-beneficiary” (incompatible with the call’s logic).
• No acceptance documentation, only invoices (weak evidence chain).
• Attempts to force the narrative into “Prozorro or nothing” (category error; wrong control lens).

Key takeaways

• SECO Call for Proposals is not a Prozorro procurement: it is a Swiss financial contribution mechanism with donor-style controls.
• The legal “spine” is the SECO ↔ implementer contribution contract; Prozorro may not appear at all.
• The main end-beneficiary must be a Ukrainian public entity, and Ukrainian acceptance acts are a central evidence layer.
• Expect three parallel control lines: donor compliance, Ukrainian acceptance, and (only sometimes) public procurement monitoring.
• Public sources show “what/who/how much”; object-level execution detail often sits in ITA registration, DREAM entries, and acceptance + monitoring documentation. 
• The 32,000 windows case illustrates the real metric: not “is there a Prozorro tender,” but “is there a verifiable evidence chain from delivery to acceptance to eligible cost reporting”. 
• This logic aligns with broader results-based funding models such as the Ukraine Facility, where financing is tied to verifiable conditions and layered oversight. 

Glossary (plain language)

• Prozorro — Ukraine’s e-procurement system for public procurement procedures (when the procurement law applies).
• DREAM — Ukraine’s digital ecosystem used to structure and track project lifecycles (when projects/objects are entered there). 
• Single Project Pipeline — standardized pipeline logic for public investment projects; SECO rewards alignment with it. 
• ITA (International Technical Assistance) — Ukraine’s administrative framework for registration/monitoring of assistance projects. 
• Implementer — the entity implementing the project under an agreement with the donor/partner. 
• End-beneficiary — the public Ukrainian entity that is the primary beneficiary/owner-side actor for the project results (SECO requirement).
• Recipient — a Ukrainian resident who directly receives ITA under the project.
• Milestone — a measurable delivery point used for verification and (often) payment decisions.
• Third-party monitoring — independent verification layer foreseen in SECO’s monitoring framework.
• Ukraine Facility — EU funding instrument established by Regulation (EU) 2024/792 with results-based logic and anti-fraud safeguards. 

Disclaimer

This publication is for general informational purposes only and does not constitute legal, financial, or compliance advice for any specific project or party.