Why Illegally Detained Civilians Remain without Comprehensive Social Protection from the State

The document is the result of 1,5 year of monitoring the processes of adopting the Law, analyzing attempts to implement it and practice of its application. We seek to make the problems outlined in this report the subject of discussions and further changes in the current legislation regarding social and legal protection of illegally deprived Ukrainian citizens, as well as in the approaches of the Minreintegration to the procedure of establishing the fact of deprivation of personal liberty as a result of russian armed aggression against Ukraine, and the CMU to provide all the types of assistance guaranteed by the Law to such persons.

TEAM OF AUTHORS

Kateryna Levchenko, a lawyer, head of the legal department of the Association

Ihor Kotelianets, Head of the Association

Nataliia Hladynets, an analyst, PhD in Economics

Svitlana Odintsova, a legal analyst

Nataliia Savchenko, editor and translator

We express our special gratitude to Daria Svyrydova,a lawyer and expert at the Ukrainian Legal Advisory Group, for her consultative assistance.

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December 18, 2025

Analytical Report on the Conducted Public Review

The NGO “Association of Relatives of the Kremlin’s Political Prisoners” publishes an analytical report prepared based on the results of a public review of the activities of the Commission for Establishing the Fact of Deprivation of Personal Liberty as a Result of Armed Aggression against Ukraine. The report systematizes the regulatory framework governing the Commission’s work, analyzes its administrative practice, and identifies key shortcomings in decision-making procedures and in victims’ access to social guarantees. Particular attention is paid to issues related to the burden of proof, the determination of the political motive of persecution, and the safeguarding of applicants’ right to be heard. Based on a legal analysis, a review of the Commission’s decisions, and surveys of affected individuals, the report formulates recommendations aimed at improving the regulatory framework, institutional capacity, and procedural fairness in order to strengthen state support for victims of unlawful deprivation of liberty.

December 31, 2024

Analytical review of the activities of the NGO “Association of Relatives of Political Prisoners of the Kremlin” on documenting the war crimes of the Russian Federation against civilians in Ukraine in December 2024

Since 2022, we have interviewed 422 witnesses of enforced disappearances, arbitrary detentions and crimes against civilians, including shelling of civilian infrastructure, appropriation of private property by the occupiers, and illegal deprivation of liberty. As of the end of December 2024, information on 274 civilians who were arbitrarily detained by representatives of the Russian Federation or groups controlled by the aggressor country was found, of which 17 were identified during the processing of testimonies in December 2024.