Since the Criminal Procedure Code of Ukraine was introduced, researchers have repeatedly suggested the removal of the institution of operational search activities, arguing that all investigative (search) actions could be conducted within criminal proceedings or by adopting a new law. The study aimed to analyse the theoretical and legislative problems of adapting the European experience of regulating these institutions. To achieve the purpose of the study, the general scientific and special legal research methods were used: comparative legal, systemic and structural, and logical and legal analysis. The study established that the Law of Ukraine “On Operational Investigative Activity”, adopted in 1992, as of 2025, does not meet regulatory, institutional and social realities, is constructively obscure and inconsistent with European law. The law is not consistent with the Criminal Procedure Code of Ukraine adopted in 2012. The study critically analysed the researchers' vision of the state and prospects of the development of criminal intelligence. Based on the analysis of international experience (the United States of America, the United Kingdom, the Federal Republic of Germany, the Czech Republic, the Slovak Republic, the Republic of Slovenia, and Hungary), the study identified the main approaches to possible further development of national criminal intelligence legislation. Positive and controversial aspects of each of them are identified. The study provided suggestions and recommendations regarding the Draft Law of Ukraine “On Criminal Intelligence”. The results of the study can be used to develop and adopt new legislation in the field of criminal intelligence
Tarasenko et al. (2025) studied this question.