Georgia - Russia - WAR WATCH

Russia remains the occupying power in areas of South Ossetia (officially the ‘Tskhinvali Region’ under Georgian law) and Abkhazia, which are internationally recognized as forming part of Georgia. Russia maintains a military presence in the breakaway regions of South Ossetia and Abkhazia on the basis of agreements concluded with these entities without the consent of Georgia. While Russia and a few other States recognize these entities as independent States, the overwhelming majority of States consider them as part of the internationally recognized territory of Georgia. Russia also exercises its authority over these regions through its control of the separatists, who acts as the proxies of Russia.

The law of military occupation is set out in the 1907 Hague Convention (IV) Respecting the Laws and Customs of War on Land and its Annex: Regulations Concerning the Laws and Customs on Land, the 1949 Geneva Conventions (IV) Relative to the Protection of Civilians Persons in Time of War and the 1977 Additional Protocol I applicable to international armed conflicts. Both Georgia and Russia are parties to the four Geneva Conventions of 1949 and Additional Protocol I of 1977. Customary international humanitarian law is also applicable during occupation, which complements the protection granted by treaties and binds all the parties to the conflict.

The early 1990s independence of Georgia and subsequent secessionist conflicts

Georgia declared independence from the Soviet Union in 1991. Since then, it has experienced tension and conflict with secessionist wars fought in South Ossetia and Abkhazia. These conflicts have left thousands of individuals dead, displaced thousands more, and created a politically unstable situation, with both territories subject to the de facto authority of separatist governments.¹South Ossetia, which has a population of approximately 56,500, formally declared independence from Georgia during the armed conflict between Georgian forces and South Ossetian separatist forces in 1991–92. The conflict concluded in the summer of 1992 when the warring parties signed the Sochi Agreement. This agreement established a comprehensive ceasefire, the withdrawal of all armed groups from the designated security corridor, and the deployment of joint peacekeeping forces, including Russian troops.²

Similar to South Ossetia, Abkhazia fought a separatist conflict with Georgia in 1992–94. Abkhazia, which has a population of approximately 244,000, sought to declare its independence through promulgation of a constitution in 1994, and then by formal statement in 1999.³ The Georgian-Abkhazian conflict ended upon the signature of the so-called Moscow Agreement in 1994, which also foresaw the deployment of the peacekeeping force of the Commonwealth of Independent States.⁴ The number of peacekeeping force members varied between 1’500 and 3’000 before 2008, and the force was responsible for about one third of the overall territory of Abkhazia. It was notably deployed in Sukhumi and Gudauta.⁵

Between 1993 and 2008, many resolutions of the United Nations (UN) Security Council referred to ‘Abkhazia, Republic of Georgia’ and reaffirmed Georgia’s sovereignty and territorial integrity. within its internationally recognized borders.⁶ Although officially within Georgia’s borders, Abkhazia and South Ossetia have been under the control of separatist authorities since that time. In parallel, tensions and incidents increased between Georgia and Russia, as well as between Georgia and the separatist regions, leading to the August 2008 conflict (see below).⁷

Georgia’s application for NATO membership

One year after independence, Georgia established relations with the North Atlantic Treaty Organization (NATO). In 2002, Georgia stated its aspiration to join NATO, and, in April 2008, the alliance unanimously agreed that Georgia would become a NATO member, provided it meets the necessary requirements. During the August 2008 conflict (see below), NATO members consistently expressed their support for Georgia and called for Russia’s withdrawal. Since then, Georgia and NATO’s cooperation has grown, encompassing joint military exercises and Georgia’s continuing contributions to NATO troops. Additionally, Georgia has enhanced its capabilities in view of its future membership. Nonetheless, as of July 2026, Georgia has not yet joined NATO. ⁸

The August 2008 conflict

After a period of heavy fighting between Georgian Armed Forces and South Ossetian forces, Russian troops entered South Ossetia on 8 August 2008. The fighting soon involved Russian, Georgian, South Ossetian, and Abkhaz forces. During the intervention, Russian troops moved beyond the traditional boundaries of South Ossetia and launched strikes near the Georgian capital, Tbilisi. The Russian forces succeeded in defeating the main Georgian forces, forcing a retreat. By August 10, the Russians had consolidated their position in South Ossetia. Russia also entered Georgia through Abkhazia and drove out the Georgian forces therein, taking full control of the region.⁹ In justifying the presence of its forces, Russia claimed that it was acting to protect Russian citizens in the regions.¹⁰ On 12 August 2008, Georgia and Russia signed the European Union (EU)-mediated ceasefire agreement – the EU-mediated Six-Point Agreement.¹¹ On 8 September 2008, the Agreement on Implementing Measures was adopted to reinforce the commitments from the 12 August agreement via a series of implementing measures.¹² On 17 September 2008, Russia and both breakaway regions signed the ‘Treaty on Friendship, Cooperation and Mutual Assistance Between South Ossetia and the Russian Federation’, respectively the ‘Treaty on Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Republic of Abkhazia’.¹³ The instruments paved the way for cooperation and integration across military, political, economic, humanitarian, and cultural domains, and would serve as a basis for the dozens of subsequent bilateral agreements concluded between the two self-proclaimed ‘republics’ and Russia (see below).¹⁴

Declaration of Independence of Abkhazia and South Ossetia and subsequent lack of international recognition

In the aftermath of the 2008 conflict, Abkhazia and South Ossetia reiterated their declaration of independence from Georgia. On 26 August 2008, Russia recognized them as independent States.¹⁵ Since 2008, only Russia, Nicaragua, Venezuela, Nauru, Tuvalu and Syria have recognized the independence of Abkhazia and South Ossetia.¹⁶ The European Union and the Organization for Security and Co-operation in Europe (OSCE) condemned the recognition.¹⁷

‘Borderization’ of administrative boundary lines and incidents of violence

Russia, with the help of local authorities and ethnic militias, has undertaken the ‘borderization’ of the areas, namely the process of cordoning off the separatist regions. First, pursuant to the 2009 agreements on ‘joint efforts in protecting the border’, Russian border guards have been stationed along the administrative boundary lines separating Abkhazia and South Ossetia from Georgia.¹⁸ Second, a series of measures have been gradually implemented, including physical barriers, ‘border’ markers, patrols, surveillance equipment, restrictive crossing procedures and closure of official crossing points, to limit the movement of persons and goods across the administrative boundary lines. In some cases, the ‘borderization’ involves the seizure of lands that were under the control of Georgia.¹⁹ This process has been vehemently denounced by Georgia, the EU, and the United States, among others, as a serious violation of Georgia’s sovereignty. It has also severely impaired the freedom of movement, livelihoods, and access to health and education for local communities and increased risks of detention of individuals attempting to cross the administrative boundary lines.²⁰ As a result, the EU Monitoring Mission in Georgia (EUMM) (see below) decided in 2013 to patrol the areas and document ongoing activities.²¹

In parallel, since the early 1990s, ethnic Georgians living in Abkhazia and South Ossetia have been violently targeted by Abkhaz and South Ossetian militants, sometimes with the help or the participation of local authorities and Russian forces. Violence included murder and attempted murder, torture, robbery, and arbitrary deprivation of liberty, including hostage-taking.²² In response, on 26 June 2018, the government of Georgia approved the creation of a list of perpetrators to be blacklisted and sanctioned, the so-called Otkhozoria-Tatunashvili list.²³ Incidents of violence perpetrated by Russian forces stationed in the separatist regions against Georgian civilians living near the administrative boundary line have also been reported.²⁴

Reinforcement of Russian control and progressive integration into Russia

Russian troops have been present in the breakaway regions ever since the 2008 war. Abkhazia and South Ossetia signed treaties with Russia allowing it to maintain military bases and to station up to 3,800 soldiers in each those two regions.²⁵ Over time, breakaway republics have become increasingly dependent on Russia as Russia has tightened its control in military, political and economic terms, including by signing the Treaty on Alliance and Strategic Partnership with Abkhazia in 2014 and the Treaty on Alliance and Integration with South Ossetia in 2015.²⁶ Among other things, these 2014 and 2015 agreements established a joint military command between Russia and Abkhazia and incorporated the South Ossetian military wing into the Russian armed forces. Both treaties also provided support to the ‘republics’ with military equipment. ²⁷

The 2014 treaty, adopted in the aftermath of the election of a prominent pro-Russian politician, Raul Khajimba, as ‘president’ following a period of civil turmoil, also provided a roadmap for the incorporation of Abkhazia into the Russian sphere of defence, security, economic and social affairs. In particular, the treaty established a common Russian-Abkhazian security space and provided that the Russian army would control Abkhazia’s borders and airspace.²⁸ It has resulted in increased dependence of Abkhazia on Russia and the expansion of Russian influence, while maintaining Abkhazia’s formal ‘independence’ and attributes of ‘statehood’, as Abkhazian authorities have always defended their idea of independence.²⁹ Abkhazia’s stance on independence was notably confirmed in March 2022, when Abkhaz leaders rejected the idea of holding a referendum on integration with the Russian Federation and reaffirmed their intention to secure independence for the breakaway region.³⁰ Since then, Abkhazia, and in particular the local population, has continued to express its desire for independence.³¹

Conversely, the South Ossetian authorities have consistently expressed the desire to integrate the region into Russia, and the 2015 treaty, which contained mainly the same provisions as the 2014 one but also effectively abolished the border between Russia and South Ossetia, was greeted by local authorities as the first step towards this goal.³² In late March 2022, the leader of breakaway South Ossetia, Anatoly Bibilov, announced the intention of the region to join Russia following ‘presidential’ elections.³³ A referendum on South Ossetia’s annexation by Russia was initially scheduled to take place on 17 July 2022. However, the newly elected “president”, Alan Gagloev, cancelled the referendum, invoking ‘uncertainty of the legal consequences of the issue submitted to a referendum’.³⁴

Both treaties have been regarded by Georgia as an annexation of Georgian territories by Russia.³⁵

Additionally, acquisition of Russian citizenship for inhabitants of both breakaway regions has been increasingly facilitated since 2002 through a succession of agreements and unilateral measures.³⁶ More specifically, since 2002, following Russia’s adoption of a new citizenship law, Russian passports have been widely distributed to the inhabitants of Abkhazia and South Ossetia, paving the way for a trend that has grown further in the following decades.³⁷ In September 2021, South Ossetia and Russia signed an agreement on dual citizenship based on the 2008 and 2015 treaties (see above).³⁸ Likewise, Abkhazia and Russia signed a dual citizenship agreement on 27 September 2022.³⁹ On 17 May 2025, Russia signed a decree to facilitate the procedure for Abkhazians and South Ossetians to obtain Russian citizenship. In particular, under this new decree, applications can be made directly from Abkhazia and South Ossetia.

The massive distribution of Russian citizenship has resulted in the vast majority of inhabitants of both breakaway regions holding Russian citizenship (95 per cent of South Ossetians held Russian citizenship in 2019 and 80 per cent of Abkhazian residents held Russian citizenship in 2025), allowing them to travel abroad since only very few nations have recognized the entities as States.⁴⁰

Persistent internal displacement

The armed conflicts of the early 1990s, the 2008 August war, and subsequent occupation remain the main drivers of displacement in Georgia. The conflicts displaced more than 300,000 people, of whom 26,000 could not return to their homes due to the Russian presence and the destruction of their villages.⁴¹ So far, no significant progress has been achieved in a return of displaced persons and refugees.⁴² At the end of 2022, 293,000 people were internally displaced in Georgia, and by the end of 2025, 301,000 IDPs were recorded.⁴³ The issue of IDPs and refugees has prompted the UN General Assembly to adopt recurring resolutions reaffirming their right to return and the necessity to respect their property rights, and condemning related forced demographic changes.⁴⁴

International and regional initiatives

European Court of Human Rights (ECtHR) proceedings

In March 2007, Georgia lodged the first of a series of complaints before the European Court of Human Rights (ECtHR) against Russia concerning the conduct of separatist authorities and/or Russia. This includes expulsion of Georgian nationals by Russia;⁴⁵ deprivation of liberty by the South Ossetian separatist regime;⁴⁶killings during the active phase of hostilities and the occupation phase; ill treatment and torture; looting and destruction of property; prevention of the return of forcibly displaced Georgians; looting and destruction of education facilities as well as intimidation of pupils and teachers;⁴⁷ and harassment, arrests and detention of Georgian nationals attempting to cross the administrative boundary line.⁴⁸ The ECtHR held Russia responsible for its direct actions as well as the behaviour of separatist regimes infringing the European Convention of Human Rights on multiple occasions.⁴⁹

European Union and Organization for Security and Co-operation in Europe (OSCE) initiatives

On 15 September 2008, the European Union established the EU Monitoring Mission in Georgia (EUMM), deploying more than 200 unarmed civilian monitors to oversee adherence by all parties to both the Six-Point Agreement and the Agreement on Implementing Measures (see above).⁵⁰ While the EUMM is mandated to monitor the entire territory of Georgia, access to the territories under their control has so far been denied by both breakaway regions.⁵¹

In October 2008, following the Six-Point Agreement and the OSCE’s call for establishing a mediation forum for security and stability in the South Caucasus, an international mediation process was initiated. This process, called the Geneva International Discussions or Geneva Talks, is chaired by the EU, the OSCE, and the UN, and includes the United States, Georgia, Russia, as well as representatives from Abkhazia and South Ossetia.⁵²Achievements have remained limited, although discussions continue.⁵³

On 2 December 2008, the Council of the EU also established the Independent International Fact-Finding Mission on the Conflict in Georgia (IIFFMCG), marking the first time that the EU has ‘intervene[d] actively in a serious armed conflict’.⁵⁴ The IIFFMCG was tasked with investigating the origins and the course of the conflict, including with regard to IHL and human rights.⁵⁵ In September 2009, the IIFFMCG delivered a three-volume report presenting the results of its fact-finding inquiry.⁵⁶

In 2009, an Incident Prevention and Response Mechanism (IPRM) was established. Those meetings are co-chaired by the OSCE and the EUMM (see above) and act as forums for all parties to discuss the security and humanitarian challenges faced by the inhabitants near the administrative boundary line. They take place on a monthly basis in Gali (Abkhazia) and Ergneti (South Ossetia).⁵⁷ The EUMM also manages a Hotline as an adjunct of the IPRM and through which all the parties may communicate with one another 24/7.⁵⁸

International Criminal Court (ICC) proceedings

On 27 January 2016, the Prosecutor of the International Criminal Court (ICC) was authorized to open a proprio motu investigation on the situation in Georgia regarding alleged war crimes and crimes against humanity perpetrated in and around South Ossetia during the August 2008 war and the surrounding period (1 July–10 October 2008).⁵⁹ On 30 June 2022, the ICC issued three arrest warrants against two Russian nationals and one Georgian national for alleged war crimes committed between 8 and 27 August 2008.⁶⁰ On 16 December 2022, due to the lack of ‘new lines of inquiry’ and the death of a fourth Russian national suspect, Vyacheslav Borisov, the ICC Prosecutor announced the conclusion of the investigation phase.⁶¹ Until June 2026, the warrants remain pending execution, and the Office of the Prosecutor is dedicated to tracking the suspects, who remain at large, and to preparing the trial.⁶²

Georgia’s application for EU membership

In March 2022, Georgia applied for EU membership and, in December 2023, was granted candidate status. However, following the actions taken by the Georgian government in 2024 and related developments (see below), the accession process was de facto halted in 2024.⁶³

Partial normalization between Georgia and Russia

In May 2023, Russia restored visa-free travel for Georgian citizens and lifted its 2019 ban on direct flights between the two countries. Days later, Georgian Airways resumed direct flights to Russia. Georgia also allows Russians to access Georgia without visa and full work rights for one year. This represented a warming of Russia-Georgia relations which were suspended since October 2006,⁶⁴ even though formal diplomatic ties remained broken since 2008.⁶⁵

‘Foreign agent’ bill and related protests, and contested Georgian parliamentary election results

In March 2023, Georgian Dream, Georgia’s ruling party since 2012, proposed the ‘foreign agent’ bill to the Parliament. The bill, which targeted non-governmental organizations (NGO) and media that receive over 20 percent of funding from abroad, was met with massive protests and widespread international criticism, including from the EU, which deemed incomtabile with EU law.⁶⁶ After initially withdrawing the bill, the ruling party resubmitted it, and it passed on third reading in May 2024. Although vetoed by President Salome Zourabichvili, Gorgia’s parliament eventually overrode the presidential veto in late May 2024 and enacted the bill into law in March 2026.⁶⁷

On 26 October 2024, Georgian Dream won the parliamentary elections,⁶⁸ amid reports of intimidation and coercion targeting voters and journalists.⁶⁹ The pro-western opposition coalition described the outcome a ‘constitutional coup’, and videos showing ballot stuffing and voter intimidation circulated online. The results marked a further shift toward Russia and an increasingly authoritarian stance, while polls indicated that up to 80 percent of the population was favourable to joining the EU.⁷⁰

Territorial integration

In October 2023, after meeting with Putin, Abkhazia’s self-proclaimed president, Aslan Bzhania, said that Abkhazia was considering joining the Russia-Belarus union State in the foreseeable future. Still, Belarus had to recognize the breakaway region’s independence first.⁷¹

In parallel, Russia and the Abkhaz authorities announced in October 2023 an agreement for a permanent Russian naval base at Ochamchire, on the Black Sea coast in Abkhazia. This prompted criticism from Georgia, which denounced a “gross violation” of its sovereignty, anc concerns from the EU.⁷² In January 2024, Abkhaz officials said the base might become operational in 2024, ⁷³ and satellite images have since reportedly shown progress in the construction of the Russian naval base.⁷⁴ Previously, Russia’s coast guard patrols and the 7th Russian military base had already been stationed in Ochamchire.⁷⁵

In late 2025, Georgia and the European Union criticized Russia’s unilateral decision to initiate regular commercial passenger flights to Sukhumi and to enhance rail and maritime passenger services with Abkhazia, which demonstrated Russia’s consolidation of authority over the occupied territory.⁷⁶

Renewed discussions over South Ossetia annexation

On 9 May 2026, Russia and Ossetia further deepened integration efforts and signed a ‘Treaty on Deepening Allied Cooperation’. The treaty stipulates that Russia and South Ossetia ‘shall expand cooperation with the aim of ensuring regional peace and stability, pursuing coordinated foreign policy and policies in the areas of defence and security, as well as border policy, … improving socio-economic conditions, developing infrastructure and human potential, harmonizing legal norms, and creating a favourable environment for the free movement of capital, goods, services, and labour between the Contracting Parties’. It notably provides that citizens of one side ‘may hold state and municipal positions’ in the other, enabling Russia to place its officials in South Ossetian ‘government’, the closer alignment of South Ossetia’s laws to Russia’s.⁷⁷ The ‘president’ of South Ossetia stated that the treaty ‘will be the beginning of the reunification of the Ossetian people’.⁷⁸ The treaty was fiercely condemned by Georgia during the 135^th session of the Council of Europe’s Committee of Ministers, labelling it as evidence of Russian attempts to annex Georgia’s regions.⁷⁹

In the aftermath of this agreement, the ‘prime minister’ of South Ossetia, Dzambolat Tadtoyev, resigned in early June 2026, paving the way for a former Russian official, Marat Kambolov, to take up the post and oversee the implementation of the integration treaty.⁸⁰ Kambolov was formally appointed as ‘prime minister’ on 16 June 2026 and has since then repeatedly promoted deepening integration with Russia.⁸¹ On 23 June 2026, South Ossetia ‘president, Alan Ggaloeve, resigned after being appointed as an adviser to Putin and tasked to ‘reunite with North Ossetia, reunite with Great Russia’. Accordingly, Marat Kambolov became the acting ‘president’ of South Ossetia.⁸² On 25 June 2026, additional measures were implemented to incorporate South Ossetia into the Russian legal framework through multiple agreements. These agreements deepen the integration of Russia and South Ossetia’s legal systems under the pretext of enhancing ‘law and order in Russia and South Ossetia’ and represent another move toward establishing a ‘single legal and economic space.’⁸³

Persistence of ‘borderization’ and incidents of violence, and subsequent condemnation of Russia

The ‘borderization’ processes and related restrictions of freedom of movement (see above) have continued. ‘Borderization’ measures involved the installation of surveillance booths, additional barriers, ‘border signs’ and barbed wire, observation posts, the use of modern surveillance equipment such as cameras and motion detectors, and the digging of anti-fire trenches.⁸⁴ Likewise, illegal detentions, extrajudicial killings, ill-treatment and torture, and other acts of violence perpetrated against ethnic Georgians (see above) have persisted.⁸⁵ On 9 April 2024, the ECtHR held Russia responsible for a systematic violation of human rights, including excessive use of force, ill-treatment, unlawful detention, destruction and looting of property, and unlawful restrictions of movement across the administrative boundary lines,⁸⁶ the ECtHR awarded in total €253,018,000 for the non-pecuniary damages suffered by more than 29,000 victims.⁸⁷

Continuation of the International and regional initiatives and their stalemate

In 2025, the Geneva International Discussions and the IPRM (see above) continued, but without achieving a political breakthrough. In particular, Abkhazia and South Ossetia renewed their demand for Georgia to officially commit to not use of force to resolve territorial issues through the signing of a binding agreement, while Russia insisted on the necessity to ensure lasting security in the breakaway regions. Georgia and the EU continued to call on Russia to implement the 2008 ceasefire, permit the return of IDPs and refugees to Abkhazia and South Ossetia, allow international access, and address de facto integration and ‘borderization’ activities.⁸⁸

As of 16 July 2026, these formats were still active but unresolved.

On its side, the UN General Assembly has continued to adopt resolutions reiterating the right of return of IDPs and refugees in Abkhazia and South Ossetia.⁸⁹

Military occupation of Georgia by Russia

Legal Criteria

The European Court of Human Rights (ECtHR) developed its own test of effective control over territory for the purposes of establishing State’s extra-territorial jurisdiction under Article 1 of the European Convention on Human Rights. Its significant indicators are: (i) the number of soldiers deployed by the State in the territory in question; (ii) the extent to which the State’s military, economic and political support for the local subordinate administration ‘provides it with influence and control over the region’. Accordingly, ‘Stat[e] […] exercise[s] effective control over an area outside [its] national territory as a result of military action – lawful or otherwise – either directly, by means of the State’s armed forces or through a subordinate local administration’.⁸

In its judgment in Georgia v Russia (II), the ECtHR found that Russia exercised effective control over South Ossetia and Abkhazia and the ‘buffer zone’ from the signature of ceasefire agreement on 12 August 2008 to 10 October 2008 (the day of the withdrawal of the Russian troops from the buffer zone) and beyond. The Court pointed to ‘the strong Russian presence and the South Ossetian and Abkhazian authorities’ dependency on the Russian Federation, on whom their survival depends’), thereby establishing Russia’s extra-territorial jurisdiction under Article 1 of the European Convention on Human Rights there.⁹ In examining the case, the ECtHR also referred to the existence of Russia’s occupation of these regions after 12 August 2008.¹⁰ . Additionally, in its judgment in Mamasakhlisi and ors v. Georgia and Russia, the ECtHR considered that Russia exercised effective control and decisive influence over Abkhazia prior to 2008.¹¹ Although the ECtHR considered only the situation in Abkhazia, the same reasoning applies to South Ossetia before 2008. Pre-Trial Chamber I of the ICC thus said there was ‘sufficient indication that the Russian Federation exercised overall control over the South Ossetian forces, indicating that also the period before the direct intervention of Russian forces may be seen as an international armed conflict’.¹²

In parallel with the reinforcement of Russian support and control over the de facto authorities of the breakaway regions described above and below, Russian troops have remained present in Abkhazia and South Ossetia since Russia’s direct military intervention in August 2008. They have conducted military drills there, although their frequency has diminished since Russia’s full-scale invasion of Ukraine, owing to the relocation of Russian military personnel and assets in Eastern Europe. These military exercises include the deployment of Russian drones and military helicopters and have led to repeated violations of Georgian airspace.¹³ Moreover, Russian border guards patrol the administrative boundary lines, and Russian troops have, on some occasions, been directly involved in acts of violence targeting ethnic Georgians (see above).

Abkhazia

International Crisis Group estimates there are around 5,000 Russian personnel in Abkhazia, including 3,500 military and 1,500 Federal Security Service (FSB) officers and border guards.¹⁴ Russia spent $465 million over four years to refurbish and develop military installations in the Black Sea coastal area, including Bombora airbase – the largest military airfield in the South Caucasus, in Gudauta – and a naval port in Ochamchire (see above).¹⁵.

On the basis of the 2010 agreement between Russia and Abkhazia (which is valid for 49 years, after which it automatically extends every fifteen years), Russia operates its 7th military base in Abkhazia in Gudauta.¹⁶ In the Georgia v Russia (II) case, Russia itself acknowledged the creation of this military base after the signing of the agreement with Abkhazia in 2010, stating it hosted ‘3,923 servicemen and 873 items of military equipment’.¹⁷ Under another treaty signed between Russia and Abkhazia in 2009, Russia also assists in securing and patrolling the administrative border with Georgia (see above).

The ‘Treaty on Alliance and Strategic Partnership’ signed between Russia and Abkhazia on 24 November 2014 aims to incorporate the region into the Russian military, economic, social and legal space and also to create a common security and defence space (see above).¹⁸ This treaty provides for the mutual defense pact and foresees the creation of the Joint Group of Armed Forces to repel aggression. A separate agreement to this end was signed between Russia and Abkhazia in 2015. This deal foresees the joint conduct of military exercises and stipulates that ‘the Joint Group of Armed Forces is composed of the joint Russian military base stationed on Abkhazian territory, as Russia’s component, and two motorized rifle battalions, an artillery group and an aviation group, as well as a special forces detachment as Abkhazia’s component’.¹⁹ Analysts have described ‘Russia’s military and security footprint in Abkhazia [a]s the cornerstone of Moscow’s control’.²⁰

Compared to South Ossetia, fewer Russian citizens occupy high military and security posts in Abkhazia, though there are some notable exceptions. It is estimated that the separatist armed forces of Abkhazia are small, somewhere between 1,000 and 5,000 troops. Reportedly, due to the Russian military presence, investment in equipping separatist forces has declined.²¹

More broadly, Russia also supports Abkhazia in other areas, including by provision of direct financial support (see above)²² which accounted in 2025 for thirty per cent of Abkhazia’s global budget.²³ This trend is not new, as Russia had already started to pay pensions to residents in Abkhazia prior to 2008, for an amount equivalent to about half of the Abkhazian public budget.²⁴ Nearly the entire Abkhazia population and military personnel in Abkhazia hold Russian citizenship (see above).²⁵ The ECtHR referred to various reports containing the information as to “the relationship of dependency not only in economic and financial, but also in military and political terms between the Russian Federation and Abkhazia.”²⁶ Accordingly, in the Court’s view, Abkhazia has only been able to survive because of Russia’s support. Consequently, Russia has exercised continued, effective control and decisive influence over Abkhazian territory, whether before or after the August 2008 conflict.²⁷

In sum, Russia occupies Abkhazia through its direct military presence underpinned by the series of agreements with the separatist entity. According to the International Crisis Group, given Russia’s control over Abkhazia’s ‘borders’, roads, and sea, Russia does not need to maintain a heavy permanent presence, ‘as it can move military equipment and troops into and out of the entity at will’.²⁸ Moreover, through the development of Ochamchire military port and Sukhumi airport, Russia has enhanced its capacity to rapidly deploy troops into the area.²⁹ In parallel, the local separatist armed groups serve as Russian proxies given the high level of coordination with the Russian Armed Forces and the military and financial support provided by Russia, supporting the fulfilment of the requirements of an overall control test.

South Ossetia

Since 2008, Russia has established a significant military presence in South Ossetia (see above). In Georgia v Russia (II), Russia itself acknowledged a substantial military presence in South Ossetia after hostilities had ceased, and then also from 23 August 2008 until the creation of a joint military base (comprising the 693rd motor rifle regiment with 4,307 servicemen, 33 tanks, 220 fighting infantry vehicles, 30 artillery systems, and 14 air-defence systems).³⁰ On the basis of an agreement with South Ossetia, Russia operates the 4th Military Base in Tskhinvali in South Ossetia, which hosts tactical missiles and anti-missile rockets, among other weapons. A small component is located in the second largest city of Java.³¹ In Georgia v Russia (II), Russia itself acknowledged the creation of the 4th military base after the signing of the agreement with South Ossetia in 2010 and claimed it ‘had held 3,285 servicemen and had 305 items of military equipment’.³² Russian Armed Forces also conduct large military exercises in South Ossetia.³³

Similar to Abkhazia, under another treaty signed between Russia and South Ossetia in 2009, Russia assists in securing and patrolling the administrative border with Georgia (see above).³⁴ It is estimated there are 1,500 Russian FSB border guards.³⁵ Russian troops installed wire fences and other equipment on the administrative border between South Ossetia and Georgia, sometimes moving the border further into the Georgian territory, through the process known as ‘borderization’ (see above).³⁶

The 2015 Alliance and Integration Treaty between Russia and South Ossetia foresees the formation of a common defence and security space and provides for a mutual defence pact (see above). In fact, under the treaty, Russia ensures the defence and security of South Ossetia, including its border with Georgia.³⁷ As established by the 2015 Alliance and Integration Treaty, an intergovernmental agreement was signed between South Ossetia and Russia in 2017 specifying the modalities of incorporation of some military units of South Ossetia into the Russian Armed Forces. However, the agreement requires that the soldiers who decide to serve in the Russian Armed Forces first resign from the so-called South Ossetian army.³⁸ In fact, the negotiations preceding the conclusion of the 2017 intergovernmental agreement raised the question whether the separate South Ossetian army should be maintained at all. Ultimately, some separate defence structures were preserved.³⁹ Nevertheless, the so-called South Ossetian army is rather small, amounting up to 800 troops. Moreover, a number of senior security officials in South Ossetia are in fact seconded from Russia.⁴⁰J. Kucera, ‘South Ossetia Keeps Its Military, For Now’, Eurasianet, 19 January 2017;⁴¹ ⁴²

More broadly, as detailed above, since 2008 and even earlier, Russia has increased its presence in military, political and economic terms. Demonstrative of Russia’s level of control is the fact that it provides direct financial aid to South Ossetia. Since 2008, this aid comprises ninety-nine per cent of South Ossetia’s budget and more than half of the government staff are from Russia.⁴³ The ECtHR referred to various reports containing the information as to ‘the relationship of dependency not only in economic and financial, but also in military and political terms between the Russian Federation and South Ossetia’.⁴⁴; see ⁴⁵ Russia controls decision making in key spheres such as the border, public order and external relations.⁴⁶ Additionally, Russia has repeatedly provided military supplies to South Ossetia.⁴⁷

In sum, Russia occupies South Ossetia through the presence of its regular troops underpinned by a series of agreements with the separatist territory. In addition, the local separatist armed groups act as Russia’s proxies given their rather modest size, high level of coordination with the Russian Armed Forces, command structures staffed by Russian citizens, and the military and financial support provided by Russia.

Although not decisive, Georgia also considers Abkhazia and South Ossetia occupied by Russia,⁴⁸ as reflected in its law on occupied territories adopted on 30 October 2008, whereas Russia denies being an occupying power.

Similarly, after the 2008 war, the Parliamentary Assembly of the Council of Europe denounced the Russian use of force as ‘a violation of Council of Europe principles’ and pointed out that it ‘led to the occupation of a significant part of the territory of Georgia’.⁴⁹ While not expressly calling Russia an occupying power, the Committee of Ministers of the Council of Europe stated in May 2017 that ‘Georgia, as the only sovereign State under international law over its regions of Abkhazia and Tskhinvali region/South Ossetia, is still prevented from exercising legitimate jurisdiction over these regions due to the illegal actions of the Russian Federation, including its continuing military presence therein’.⁵⁰ Additionally, in 2018, the High Representative of the European Union declared that ‘Russian military presence in both Abkhazia and South Ossetia continues in violation of international law’, in response to the 10th anniversary of the conflict.⁵¹ The United States has repeatedly described Abkhazia and South Ossetia as being occupied by Russia.⁵² The 2017 Consolidated Appropriations Act, which was signed and became law in May 2017, included a provision referencing the ‘Russian occupied Georgian territories of Abkhazia and Tskhinvali Region/South Ossetia’.⁵³

1
International Committee of the Red Cross (ICRC), 2016 Commentary, para 324. See also: Article 42, Hague Convention (IV) Respecting the Laws and Customs of War on Land and its Annex: Regulations Concerning the Laws and Customs on Land, 1907; Eritrea-Ethiopia Claims Commission, Central Front, Ethiopia’s Claim 2, Partial Award, 2004, para 29.
2
ICRC, 2016 Commentary, para 304. See also: T. Ferraro, ‘Determining the beginning and end of an occupation under international humanitarian law’, International Review of the Red Cross, Vol. 94, No. 885, 2012; ICRC, ‘How is the Term “Armed Conflict” Defined in International Humanitarian Law’, 2024, pp 11–12.
3
T. Ferraro ‘Determining the Beginning and End of an Occupation Under International Humanitarian Law’, International Review of the Red Cross, Vol 94, No 885 (2012) 158ff. N. Kalandarishvili-Mueller, Occupation and Control in International Humanitarian Law, Routledge, 2021, p 57; ICRC, ‘How is the Term “Armed Conflict” Defined in International Humanitarian Law’, 2024, p 12.
4
International Criminal Tribunal for the former Yugoslavia, Prosecutor v Duško Tadić, Judgment (Appeals Chamber), (Case No IT-94-1-A), 15 July 1999, para 137.
5
ICRC, 2025 Commentary, para 3124.
6
ICRC, 2025 Commentary, para 3127.
7
ICRC, 2025 Commentary, para 3128.
8
Council of Europe/European Court of Human Rights, ‘Guide on Article 1 of the European Convention on Human Rights: Obligations to Respect Human Rights – Concepts of “Jurisdiction” and Imputability’, updated on 31 December 2019, p 17.
9
ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, paras 174–75.
10
ECtHR, Georgia v Russia (II), Grand Chamber, Judgment, App no 38263/08, 21 January 2021, paras 52 (headline), 83, 145 (headline), and 173.
11
ECtHR, Mamasakhlisi and ors v. Georgia and Russia, Judgment, 7 March 2023, paras 320–40.
12
ICC, Pre-Trial Chamber I, Situation in Georgia, Decision on the Prosecutor’s request for authorization of an investigation, No. ICC-01/15, 27 January 2016, para 27.
13
Council of Europe, Consolidated report on the conflict in Georgia (April – September 2024), SG/Inf(2024)36, 20 November 2024, para 38; Council of Europe, Consolidated report on the conflict in Georgia (October 2024 – March 2025), SG/Inf(2025)12, 23 April 2025, para 39; Council of Europe, Consolidated report on the conflict in Georgia (April – September 2025), SG/Inf(2025)37, 07 November 2025, para 38; Council of Europe, Consolidated report on the conflict in Georgia (October 2025 – March 2026), SG/Inf(2026)13, 23 April 2026, para 40.
14
International Crisis Group, ‘Abkhazia: The Long Road to Reconciliation’, Report No 224, 10 April 2013, p 3.
15
International Crisis Group, ‘Abkhazia: Deepening Dependence’, Report No 202, 26 February 2010, pp 3-4; International Crisis Group, ‘Abkhazia: The Long Road to Reconciliation’, Report No 224, 10 April 2013, pp. 3-4
16
‘Russia Gains Military Base in Abkhazia’, RFERL, 17 February 2010.
17
ECtHR Grand Chamber, Case of Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, para 151; see also para 165.
18
See also A. Bellal (ed), The War Report. Armed Conflict in 2014, Oxford University Press, 2015, p 85.
19
‘Law on Ratification of Russia-Abkhazia Agreement on Joint Group of Forces’, Kremlin, 21 November 2016; ‘Russian Parliament Ratifies Agreement on Joint Russia-Abkhazia Group of Forces’, TASS, 2 November 2016.
20
I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Eurasia Daily Monitor, 3 May 2026
21
International Crisis Group, ‘Abkhazia: Deepening Dependence’, Report No 202, 26 February 2010, p 5.
22
See also International Crisis Group, ‘Abkhazia: The Long Road to Reconciliation’, Report No 224, 10 April 2013, pp 6–8.
23
I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Jamestown, Eurasia Daily Monitor, 3 May 2026.
24
ECtHR, Mamasakhlisi and others v. Georgia and Russia, Judgment, 7 March 2023, para 336.
25
See also M. Mackinnon, ‘Back to the USSR: Putin and the new Cold War’, The Globe and Mail, 16 March 2018, International Crisis Group, ‘Abkhazia: Deepening Dependence’, Report No 202, 26 February 2010.
26
ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, para 16; and see also paras 166, 168 and 174.
27
ECtHR, Georgia v. Russia (II), Judgment (Grand Chamber), 21 January 2021, para 174; ECtHR, Mamasakhlisi and others v. Georgia and Russia, Judgment, 7 March 2023, paras 337 and 339.
28
International Crisis Group, ‘Abkhazia: The Long Road to Reconciliation’, Report No 224, 10 April 2013, p 5.
29
Council of Europe, Consolidated report on the conflict in Georgia (April–September 2024), SG/Inf(2024)36, 20 November 2024, para 17; Council of Europe, Consolidated report on the conflict in Georgia (October 2024–March 2025), SG/Inf(2025)12, 23 April 2025, para 17; Council of Europe, Consolidated report on the conflict in Georgia (April–September 2025), SG/Inf(2025)37, 7 November 2025, para 17; Council of Europe, Consolidated report on the conflict in Georgia (October 2025–March 2026), SG/Inf(2026)13, 23 April 2026, para 18; I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Eurasia Daily Monitor, 3 May 2026.
30
ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, para 165 and see para 150.
31
International Crisis Group, ‘South Ossetia: The Burden of Recognition’, Report No 205, 7 June 2010, pp 7–8;‘Russian Military Bases Abroad: Facts and Details’, Sputnik, 7 October 2016.
32
ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, para 150 and see para 165.
33
‘Russia Concludes Drills Involving Some 4,000 Troops in South Ossetia’, Sputnik, 26 September 2016.
34
R. Coalson, ‘Russia Steps Up Cooperation with Breakaway Georgian Regions’, RFERL, 30 April 2009; International Crisis Group, ‘South Ossetia: The Burden of Recognition’, Report No 205, 7 June 2010, p 7; ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, para 172.
35
S. Saari, ‘The New Alliance and Integration Treaty between Russia and South Ossetia: When Does Integration Turn Into Annexation?’, The Finnish Institute of International Affairs, March 2015.
36
A. North, ‘Georgia Accuses Russia of Violating International Law Over South Ossetia’, The Guardian, 14 July 2015; Global Security, South Ossetia.
37
‘Russia and South Ossetia to Sign Treaty on Alliance and Integration’, TASS, 18 March 2015; M. Otarashvili, ‘Russia’s Quiet Annexation of South Ossetia’, Foreign Policy Research Institute, 11 April 2017.
38
L. Fuller, ‘Putin Gives Green Light For Incorporating Some South Ossetian Units Into Russian Army’, RFERL, 20 March 2017.
39
J. Kucera, ‘South Ossetia Keeps Its Military, For Now’, Eurasianet, 19 January 2017.
40
S. Saari, ‘The New Alliance and Integration Treaty between Russia and South Ossetia: When Does Integration Turn Into Annexation?’, The Finnish Institute of International Affairs, March 2015;
41
42
ECtHR, Georgia v Russia (II), Judgment (Grand Chamber), 21 January 2021, paras 169–70.
43
International Crisis Group, ‘South Ossetia: Rise of a New Politics and Foreign Policy’, 17 February 2012; and ‘South Ossetia: The Burden of Recognition’, Report No 205, 7 June 2010.
44
ECtHR, Grand Chamber, Georgia v Russia (II), Judgment, Application no. 38263/08, 21 January 2021, para 167
45
also paras 166, 168, and 174.
46
International Crisis Group, ‘South Ossetia: The Burden of Recognition’, Report No 205, 7 June 2010. For a similar assessment of the Russian influence, see N. Kalandarishvili-Mueller, ‘On the Occasion of the Five-year Anniversary of the Russian-Georgian War: Is Georgia Occupied?’, EJIL: Talk!, 1 October 2013.
47
See e.g. Council of Europe, Consolidated report on the conflict in Georgia (October 2025 – March 2026), SG/Inf(2026)13, 23 April 2026, para 41.
48
International Court of Justice (ICJ), Case Concerning Application of the International Convention on the Elimination of All Forms of Racial Discrimination (Georgia v Russian Federation), Decision on Request for the Indication of Provisional Measures, 15 October 2008, para 44; ECtHR, Georgia v Russia (II), Admissibility Decision, 13 December 2011, paras 24–25.
49
Parliamentary Assembly, Resolution 1633 (2008), See also Parliamentary Assembly, Resolution 1683 (2009), 29 September 2009, para 10, where the General Assembly points out that ‘under international law, Russia bears responsibility for violations of human rights and humanitarian law in those areas that fall under its de facto control.’
50
Council of Europe, Committee of Ministers, The Council of Europe and the Conflict in Georgia, Decision, Doc CM/DEL/DEC(2017)1285/2.1, 1285th Meeting, 3 May 2017.
51
General Secretariat of the Council, Press office, ‘Declaration of the High Representative on behalf of the EU on the 10 years anniversary of the conflict between Russia and Georgia’, 7 August 2018.
52
Ambassador Daniel B. Baer, Violations of the Rights of Residents of Georgia’s Occupied Regions: Statement at the PC, Statement to OSCE Permanent Council, 3 March 2016.
53
Consolidated Appropriations Act, 2017, Sec 7070 (C)(1). See also ‘Donald Trump signs legislative act, which recognizes Abkhazia and Tskhinvali as regions occupied by Russia’, Georgia Today, 8 May 2017; A. Wigglesworth, ‘Trump Welcomes Georgia’s Prime Minister’, Los Angeles Times, 8 May 2017.

State Parties

Georgia
Russia, including through its proxies (the separatist authorities in Abkhazia and South Ossetia)

1
N. Kalandarishvili-Mueller, ‘On the Occasion of the Five-year Anniversary of the Russian-Georgian War: Is Georgia Occupied?’, Blog entry, EJIL: Talk!, 1 October 2013; International Crisis Group, ‘South Ossetia: The Burden of Recognition’, Report No 205, 7 June 2010, p 2; Agreement on Principles of Settlement of the Georgian Ossetian Conflict (Sochi Agreement), 24 June 1992; A. Bellal (ed.), The War Report. Armed Conflict in 2014, Oxford University Press, 2015, p 83ff. For an in-depth review, see Independent International Fact Finding Mission on the Conflict in Georgia, Report, Volume II, 2009, p 61ff.
2
Global Security, South Ossetia; ‘South Ossetia Profile’, BBC, 21 April 2006.
3
‘Chronology for Abkhazians in Georgia’, 2004; ‘Abkhazia Profile’, BBC, 10 August 2017.
4
Agreement on a Cease-Fire and Separation of Forces (Moscow Agreement), 14 May 1994; UNOMIG, ‘Background’, 2009. See also: European Court of Human Rights, Mamasakhlisi and ors v. Georgia and Russia, Judgment, 7 March 2023, para 325. The Commonwealth of Independent States is an association of states formed by Russia in 1991 and comprising eleven other republics that were part of the Soviet Union. It initially included (in order of adhesion) Ukraine, Belarus, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan, Armenia, Azerbaijan, Georgia and Moldova. In the meantime, Georgia and Ukraine left it, respectively in 2008/2009 and 2018. ‘Commonwealth of Independent States’, Britannica.
5
European Court of Human Rights, Mamasakhlisi and ors v. Georgia and Russia, Judgment, 7 March 2023, para 326.
6
UNSC Resolution 849, 9 July 1993, second preambular para; UNSC Resolution 876, 19 October 1993, operative para 1; UNSCResolution 1808 (2008), operative para 1.
7
Independent International Fact-Finding Mission on the Conflict in Georgia (IIFFMCG), Report, Vol. I, September 2009, pp 5 and 10; European Court of Human Rights, Georgia v. Russia (I), Judgment (Grand Chamber), 3 July 2014, para 22.
8
Ministry of Foreign Affairs of Georgia, ‘NATO – Georgia Relations’; NATO, ‘Partnerships and cooperation: Relations with Georgia’, 3 March 2026.
9
A. Bellal (ed.), The War Report. Armed Conflict in 2014, Oxford University Press, 2015, p 83ff; Human Rights Watch, Up in Flames. Humanitarian Law Violations and Civilian Victims in the Conflict over South Ossetia, Report, 23 January 2003; Independent International Fact Finding Mission on the Conflict in Georgia, Report, Volume 1, 2009.
10
International Crisis Group, Georgia-Russia: Still Insecure and Dangerous, Europe Policy Briefing No 53, 22 June 2009; Independent International Fact Finding Mission on the Conflict in Georgia, Report, Volume 1, 2009, p 21.
11
‘Six-Point Ceasefire Plan’, 12 August 2008.
12
EU External action/the Diplomatic Service of the European Union, ‘EUMM Georgia: The European Union Monitoring Mission in Georgia – Civilian mission’, 30 November 2020.
13
The Prime Minister of the Russian Federation, ‘Russian-Abkhazian relations’, 12 August 2009; Z. Anjaparidze, ‘Russia Lures Georgia’s Secessionist Regions by Dual Citizenship’, Jamestown, The Caucasus, Vol. 18, No. 160, 21 October 2021.
14
The Prime Minister of the Russian Federation, ‘Russian-Abkhazian relations’, 12 August 2009; President of Russia, ‘Agreement between Russia and Abkhazia on cooperation in customs has been submitted to the State Duma for ratification’, 29 July 2011; Ministry of Foreign Affairs of The Republic of South Ossetia, ‘On the seventeenth anniversary of the signing of the Treaty on Friendship, Cooperation and Mutual Assistance between the Republic of South Ossetia and the Russian Federation’, 17 September 2025.
15
Institute for War & Peace Reporting, August 2008 Russian-Georgian War: Timeline.
16
G. Lomsadze, ‘Syria Formally Recognizes Abkhazia and South Ossetia’, Eurasianet, 29 May 2018; G. Lomsadze, ‘Abkhazia: Vanuatu Changes Its Mind Again’, Eurasianet, 18 March 2013.
17
‘EU Condemns Moscow’s Recognition of South Ossetia and Abkhazia’, Spiegel Online, 1 September 2008; OSCE, OSCE Chairman Condemns Russia’s Recognition of South Ossetia, Abkhazia Independence, OSCE Press Release, 26 August 2008.
18
K. Kakachia, ‘How the West Should Respond to Russia’s “Borderization” in Georgia’, Ponars Eurasia, 15 April 2018; ECtHR, Georgia v. Russia (IV), Judgment, 9 April 2024, para 8.
19
M. Antidze, ‘Georgia says Russia violating sovereignty with border markers’, Reuters, 13 July 2015; ‘Abkhazia closes all but one Gali checkpoint’, OC Media, 7 March 2017; K. Kakachia, ‘How the West Should Respond to Russia’s “Borderization” in Georgia’, Ponars Eurasia, 15 April 2018; ECtHR, Georgia v. Russia (IV), Judgment, 9 April 2024, para 8.
20
M. Antidze, ‘Georgia says Russia violating sovereignty with border markers’, Reuters, 13 July 2015; ‘Abkhazia closes all but one Gali checkpoint’, OC Media, 7 March 2017; K. Kakachia, ‘How the West Should Respond to Russia’s “Borderization” in Georgia’, Ponars Eurasia, 15 April 2018; Amnesty International, ‘Georgia: Russia and de facto authorities in the South Ossetia/Tskhinvali region must reopen closed crossing points and guarantee freedom of movement of civilians’, Public statement, 22 November 2019; Delegation of the EU to the Council of Europe, ‘1482nd Meeting of the Committee of Ministers (29 November 2023), EU Statement on the Secretary General’s 28th consolidated report on the conflict in Georgian’, 29 November 2023.
21
EU Monitoring Mission in Georgia (EUMM), ‘EUMM voices concern about the impact of fences on local communities’, Press Release, 2 August 2013.
22
‘Government Unveils Tatunashvili-Otkhozoria List’, Civil Georgia, 27 June 2018; ‘3 Members of ‘Gagra Group’ on Otkhozoria-Tatunashvili List Found Guilty’, Civil Georgia, 12 October 2022. See also: Delegation of the EU to the Council of Europe, ‘1482nd Meeting of the Committee of Ministers (29 November 2023), EU Statement on the Secretary General’s 28th consolidated report on the conflict in Georgia’, 29 November 2023.
23
‘Government Unveils Tatunashvili-Otkhozoria List’, Civil Georgia, 27 June 2018.
24
‘Russian troops shoot and kill a Georgian civilian near the breakaway province of South Ossetia’, AP News, 7 November 2023.
25
ECtHR, Georgia v. Russia (IV), Judgment, 9 April 2024, para 7.
26
W. Górecki, ‘Abkhazia’s ‘creeping’ incorporation. The end of the experiment of a separatist democracy’, Centre for Eastern Studies, OSW Commentary, 10 March 2015; N. Kalandarishvili-Mueller, ‘Guest Post: The Status of the Territory Unchanged: Russia’s Treaties with Abkhazia and South Ossetia, Georgia‘, Opinio Juris, 20 April 2015.
27
N. Kalandarishvili-Mueller, ‘Guest Post: The Status of the Territory Unchanged: Russia’s Treaties with Abkhazia and South Ossetia, Georgia‘, Opinio Juris, 20 April 2015; ECtHR, Case of Georgia v. Russia (IV), Judgment, 9 April 2024, para 7.
28
L. Harding, ‘Georgia angered by Russia-Abkhazia military agreement’, The Guardian, 25 November 2014; M. Mehdiyev, ‘Georgia erupts in anger as Putin signs treaty with breakaway Abkhazia’, Azernews, 25 November 2014; W. Górecki, ‘Abkhazia’s ‘creeping’ incorporation. The end of the experiment of a separatist democracy’, Centre for Eastern Studies, OSW Commentary, 10 March 2015; G. Menabde, ‘Russia’s Restoration of Sukhumi Airport May Lead to Full Annexation of Abkhazia’, Jamestown, Eurasia Daily Monitor, Vol. 20 No. 179, 20 November 2023.
29
W. Górecki, ‘Abkhazia’s ‘creeping’ incorporation. The end of the experiment of a separatist democracy’, Centre for Eastern Studies, OSW Commentary, 10 March 2015.
30
Freedom House, Freedom in the world 2023: Abkhazia
31
‘Protesters storm parliament in Georgia separatist region Abkhazia over deal with Russia’, France 24, 15 November 2024; T. Kelmendi and S. Kapanadze, ‘Occupational therapy: Frozen conflicts, Russian aggression and EU enlargement’, European Council of Foreign Relations, 4 August 2025.
32
W. Górecki, ‘Abkhazia’s ‘creeping’ incorporation. The end of the experiment of a separatist democracy’, Centre for Eastern Studies, OSW Commentary, 10 March 2015; S. Saari, ‘The New Alliance and Integration Treaty between Russia and South Ossetia’, The Finnish Institute of International Affairs, FIIA Comment 9, March 2015.
33
‘South Ossetian Leader Says Breakaway Georgian Region Seeks Vote To Join Russia’, Radio Free Europe/Radio Liberty, 31 March 2022; G. Menabde, ‘Georgia’s Separatist Region of South Ossetia Plans to Join Russia’, Jamestown, Vol. 19 No. 50 (4 August 2022).
34
‘Georgia’s South Ossetia cancels referendum on joining Russia’, Al Jazeera, 31 May 2022.
35
N. Kalandarishvili-Mueller, ‘Guest Post: The Status of the Territory Unchanged: Russia’s Treaties with Abkhazia and South Ossetia, Georgia‘, Opinio Juris, 20 April 2015.
36
Z. Anjaparidze, ‘Russia Lures Georgia’s Secessionist Regions by Dual Citizenship’, The Caucasus, Vol. 18, No. 160 (21 October 2021); N. Ostiller, ‘Putin signs decree simplifying process for Abkhazians and South Ossetians to become Russian citizens’, OC Media, 19 May 2025; I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Eurasia Daily Monitor, 3 May 2026.
37
Z. Anjaparidze, ‘Russia Lures Georgia’s Secessionist Regions by Dual Citizenship’, The Caucasus, Vol. 18, No. 160, 21 October 2021; I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Eurasia Daily Monitor, 3 May 2026.
38
Z. Anjaparidze, ‘Russia Lures Georgia’s Secessionist Regions by Dual Citizenship’, The Caucasus, Vol. 18, No. 160, 21 October 2021.
39
‘Sokhumi, Moscow Sign Dual Citizenship Agreement’, Civil Georgia, 28 September 2022.
40
N. Ostiller, ‘Putin signs decree simplifying process for Abkhazians and South Ossetians to become Russian citizens’, OC Media, 19 May 2025; I. Laitadze, ‘Kremlin Suspends Internal Russian Passport Issuance in Abkhazia’, Jamestown, Eurasia Daily Monitor, 3 May 2026.
41
J. Kharashvili, ‘20 years of internal displacement in Georgia: the international and the personal’, Forced Migration Review; Humanity Centered Data, ‘What is causing displacement in Georgia in 2026?’, 19 April 2026.
42
Delegation of the EU to the Council of Europe, ‘1482nd Meeting of the Committee of Ministers (29 November 2023), EU Statement on the Secretary General’s 28th consolidated report on the conflict in Georgia’, 29 November 2023.
43
Internal Displacement Monitoring Centre (IDMC), ‘Country Profile: Georgia’, 2026; Council of Europe, Consolidated report on the conflict in Georgia (October 2025 – March 2026), SG/Inf(2026)13, 23 April 2026, para 71.
44
See e.g. UN General Assembly Resolution 77/293: ‘Status of internally displaced persons and refugees from Abkhazia, Georgia, and the Tskhinvali region/South Ossetia, Georgia’, 12 June 2023, operative paras 1–3. See also: ‘UN General Assembly Adopts Georgia IDP Resolution with 107 Votes in Favor’, Civil Georgia, 05 June 2026.
45
ECtHR, Grand Chamber, Georgia v. Russia (I), Judgment, 3 July 2014, paras 22–77.
46
ECtHR, Georgia v. Russia (III), Decision, 16 March 2010; ECtHR, Georgia v. Russia (II), Judgment (Grand Chamber), 21 January 2021, paras 53–54.
47
ECtHR, Georgia v. Russia (II), Judgment (Grand Chamber), 21 January 2021, paras 30–56.
48
ECtHR, Georgia v. Russia (IV), Judgment, 9 April 2024, para 7.
49
ECtHR, Georgia v. Russia (I), Judgment (Grand Chamber), 3 July 2014, paras 167 et seq; ECtHR, Georgia v. Russia (II), Judgment (Grand Chamber), 21 January 2021, paras 109 et seq; ECtHR, Georgia v. Russia (IV), Judgment (Grand Chamber), 9 April 2024, para 25 et seq.
50
EUMM, ‘About us’; EUMM, ‘Our Mandate’; EU External action/the Diplomatic Service of the European Union, ‘EUMM Georgia: The European Union Monitoring Mission in Georgia – Civilian mission’, 30 November 2020.
51
EUMM, ‘Our Mandate’.
52
N. Mikhelidze, ‘The Geneva Talks over Georgia’s Territorial Conflicts: Achievements and Challenges’, Istituto Affari Internazionali, Documenti IAI 1025, 25 November 2010, p 2.
53
N. Mikhelidze, ‘The Geneva Talks over Georgia’s Territorial Conflicts: Achievements and Challenges’, Istituto Affari Internazionali, Documenti IAI 1025, 25 November 2010; Georgia Makes ‘Unilateral Pledge’ of Non-Use of Force’, Civil Georgia, 23 November 2010; S. Kapanadze, ‘Non-Use of Force in Geneva Talks – No Can Do’, Civil Georgia, 28 March 2018; ‘66th Round of Geneva International Discussions’, Civil Georgia, 20 March 2026.
54
IIFFMCG, Report, Vol. I, September 2009, pp 2-3.
55
Council of the EU, Decision 2008/901/CFSP, 2 December 2008, Article 2(1).
56
IIFFMCG, Report, Vol. I, September 2009; IIFFMCG, Report, Vol. II, September 2009; IIFFMCG, Report, Vol. III, September 2009.
57
EU External action/the Diplomatic Service of the European Union, ‘Trust building measures by the EU Monitoring Mission Georgia: a success story’, 7 October 2019.
58
EU External action/the Diplomatic Service of the European Union, ‘Trust building measures by the EU Monitoring Mission Georgia: a success story’, 7 October 2019.
59
ICC, Pre-Trial Chamber I, Situation in Georgia, Decision on the Prosecutor’s request for authorization of an investigation, No. ICC-01/15, 27 January 2016.
60
ICC, Pre-Trial Chamber, Situation in Georgia, Arrest warrant for David Georgiyevich Sanakoev, Public redacted version, No. ICC-01/15-42-Red, 30 June 2022; ICC, Pre-Trial Chamber, Situation in Georgia, Arrest warrant for Gamlet Guchmazov, Public redacted version, No. ICC-01/15-41-Red, 30 June 2022; ICC, Pre-Trial Chamber, Situation in Georgia, Corrected version of the Arrest warrant for Mikhail Mayramovich Mindzaev, Public redacted version, No. ICC-01/15-40-Red, 30 June 2022.
61
ICC, ‘The Prosecutor of the International Criminal Court, Karim A.A. Khan KC, announces conclusion of the investigation phase in the Situation in Georgia’, Statement, 16 December 2022.
62
ICC, Georgia: Situation in Georgia, ICC-01/15.
63
European Council, ‘Georgia’, 16 December 2025.
64
ECtHR, Georgia v. Russia (I), Judgment (Grand Chamber), Application no. 13255/07, 3 July 2014, para 22.
65
F. Light, ‘Russia restores visa-free access for Georgians, lifts flight ban; Tbilisi happy’, Reuters, 10 May 2023; ‘Georgia to resume flights to Russia this week, drawing EU and Ukrainian criticism’, Reuters, 20 May 2023.
66
P. Kirby, ‘Georgia drops ‘foreign agents’ law after protests’, BBC News, 9 March 2023; Human Right Watch, ‘Georgia: Drop Repressive ‘Foreign Agents’ Bill’, 26 March 2025.
67
P. Kirby, ‘Georgia drops ‘foreign agents’ law after protests’, BBC News, 9 March 2023 ; F. Light, ‘Georgian parliament passes ‘foreign agent’ bill, prompting US anger, new protests’, Swiss Info, 15 May 2024; F. Light, ‘What is Georgia’s ‘foreign agents’ bill and why does it matter?’, Reuters, 28 May 2024; M. Homan, ‘Georgia House passes bill targeting political spending from ‘hostile’ foreign agents’, Gorgia Recorder, 16 March 2026.
68
P. Sauer, ‘Georgia’s ruling pro-Russia party retains power in blow to EU aspirations’, The Guardian, 27 October 2024.
69
OSCE Office for Democratic Institutions and Human Rights, Georgia: Parliamentary Elections 26 October 2024, Final Report, 20 December 2024.
70
P. Sauer, ‘Georgia’s ruling pro-Russia party retains power in blow to EU aspirations’, The Guardian, 27 October 2024.
71
J. C. K. Daly, ‘Russian Black Sea Fleet Intends to Establish Base in Abkhazia’, Jamestown, Eurasia Daily Monitor, 07 January 2025.
72
G. Faulconbridge, ‘Russia plans naval base in Abkhazia, triggering criticism from Georgia’, Reuters, 5 October 2023.
73
‘Russia may launch naval base in Georgian breakaway region in 2024’, Reuters, 12 January 2024.
74
T. Kelmendi and S. Kapanadze, ‘Occupational therapy: Frozen conflicts, Russian aggression and EU enlargement’, European Council of Foreign Relations, 4 August 2025.
75
J. C. K. Daly, ‘Russian Black Sea Fleet Intends to Establish Base in Abkhazia’, Eurasia Daily Monitor, 7 January 2025.
76
Russia Launches Direct Flights to Occupied Abkhazia’, Civil Georgia, 3 May 2025; Ministry of Foreign Affairs of Georgia, ‘Statement by the Ministry of Foreign Affairs of Georgia on the 65th Round of the Geneva International Discussions’, 12 November 2025; Delegation of the European Union to the International Organisations in Vienna, EU Statement on the 65th round of the Geneva International Discussions, 27 November 2025.
77
‘In Moscow, Putin and Tskhinvali’s Gagloev Sign ‘Treaty on Deepening Allied Cooperation’, Civil Georgia, 12 May 2026.
78
M. Powers, ‘South Ossetia and Russia Make Further Steps Toward Annexation’, Jamestown, Eurasia Daily Monitor, 26 June 2026.
79
M. Gvadzabia, ‘Tbilisi says Russia advances annexation steps in Georgia after new South Ossetia deal’, OC Media, 15 May 2026.
80
‘South Ossetia Prime Minister Resigns, Clearing Way for Russian Technocrat to Lead Integration’, The Moscow Times, 8 June 2026.
81
M. Powers, ‘South Ossetia and Russia Make Further Steps Toward Annexation’, Eurasia Daily Monitor, 26 June 2026.
82
M. Powers, ‘South Ossetia and Russia Make Further Steps Toward Annexation’, Jamestown, Eurasia Daily Monitor, 26 June 2026.
83
M. Powers, ‘South Ossetia and Russia Make Further Steps Toward Annexation’, Jamestown, Eurasia Daily Monitor, 26 June 2026.
84
Council of Europe, Consolidated report on the conflict in Georgia (April–September 2023), SG/Inf(2023)38, 15 November 2023, para 29 and 50; Council of Europe, Consolidated report on the conflict in Georgia (April–September 2024), SG/Inf(2024)36, 20 November 2024, paras 35 and 40; Council of Europe, Consolidated report on the conflict in Georgia (October 2024–March 2025), SG/Inf(2025)12, 23 April 2025, paras 39 and 41; Council of Europe, Consolidated report on the conflict in Georgia (October 2025–March 2026), SG/Inf(2026)13, 23 April 2026, paras 39 and 43.
85
S. Kincha, ‘Russian troops fatally shoot Georgian in South Ossetia’, OC Media, 7 November 2023; Council of Europe, Consolidated report on the conflict in Georgia (April–September 2023), SG/Inf(2023)38, 15 November 2023, para 29 et seq; Council of Europe, Consolidated report on the conflict in Georgia (April – September 2024), SG/Inf(2024)36, 20 November 2024, para 38 et seq; Council of Europe, Consolidated report on the conflict in Georgia (October 2024–March 2025), SG/Inf(2025)12, 23 April 2025, paras 39ff; Council of Europe, Consolidated report on the conflict in Georgia (October 2025–March 2026), SG/Inf(2026)13, 23 April 2026, para 39 et seq.
86
ECtHR, Case of Georgia v. Russia (IV), Judgment, 9 April 2024, para 25 et seq.
87
ECtHR, Georgia v. Russia (IV), Judgment (Just satisfaction), 14 October 2025, para 10 et seq.
88
OSCE Chairpersonship, Press communiqué of the Co-Chairs of the Geneva International Discussions, 26 June 2025; Ministry of Foreign Affairs of Georgia, ‘Statement by the Ministry of Foreign Affairs of Georgia on the 65th Round of the Geneva International Discussions’, 12 November 2025; Delegation of the European Union to the International Organisations in Vienna, EU Statement on the 65th round of the Geneva International Discussions, 27 November 2025; G. Menabde, ‘Russia Seeks Georgia’s Concession on Breakaway Regions’, Jamestown, 20 January 2026.
89
See e.g. UN General Assembly, ‘Status of internally displaced persons and refugees from Abkhazia, Georgia, and the Tskhinvali region/South Ossetia, Georgia’, UN Doc. A/80/L. 73, 28 May 2026. See also: ‘UN General Assembly Adopts Georgia IDP Resolution with 107 Votes in Favor’, Civil Georgia, 05 June 2026.

Georgia – Russia

July 2023 - July 2026

The early 1990s independence of Georgia and subsequent secessionist conflicts

Georgia’s application for NATO membership

The August 2008 conflict

Declaration of Independence of Abkhazia and South Ossetia and subsequent lack of international recognition

‘Borderization’ of administrative boundary lines and incidents of violence

Reinforcement of Russian control and progressive integration into Russia

Persistent internal displacement

International and regional initiatives

European Court of Human Rights (ECtHR) proceedings

European Union and Organization for Security and Co-operation in Europe (OSCE) initiatives

International Criminal Court (ICC) proceedings

Georgia’s application for EU membership

Partial normalization between Georgia and Russia

‘Foreign agent’ bill and related protests, and contested Georgian parliamentary election results

Territorial integration

Renewed discussions over South Ossetia annexation

Persistence of ‘borderization’ and incidents of violence, and subsequent condemnation of Russia

Continuation of the International and regional initiatives and their stalemate

Military occupation of Georgia by Russia

Abkhazia

South Ossetia

State Parties

Georgia – Russia

July 2023 - July 2026

Overview

Historical background

The early 1990s independence of Georgia and subsequent secessionist conflicts

Georgia’s application for NATO membership

The August 2008 conflict

Declaration of Independence of Abkhazia and South Ossetia and subsequent lack of international recognition

‘Borderization’ of administrative boundary lines and incidents of violence

Reinforcement of Russian control and progressive integration into Russia

Persistent internal displacement

International and regional initiatives

European Court of Human Rights (ECtHR) proceedings

European Union and Organization for Security and Co-operation in Europe (OSCE) initiatives

International Criminal Court (ICC) proceedings

Georgia’s application for EU membership

Key developments (between 2023 and 2026)

Partial normalization between Georgia and Russia

‘Foreign agent’ bill and related protests, and contested Georgian parliamentary election results

Territorial integration

Renewed discussions over South Ossetia annexation

Persistence of ‘borderization’ and incidents of violence, and subsequent condemnation of Russia

Continuation of the International and regional initiatives and their stalemate

Non-International Armed Conflicts

Abkhazia

South Ossetia

Parties to the Conflict

State Parties