Ukraine

The international armed conflict (IAC) that began in 2014 between the Russian Federation and Ukraine continued during the period under review. There is an active IAC with intense hostilities between the two parties and Russian occupation of some Ukrainian territory – Crimea, the city of Sevastopol, and parts of the regions of Kherson, Zaporizhzhia, Donetsk and Luhansk. Attempts at ending the conflict through a peace deal have so far failed.

During the reporting period, a Ukrainian counter-offensive in the Russian region of Kursk resulted in occupation of a portion of Russian territory for several months until Russia recovered control over almost all of the region in April 2025. The intervention in the conflict by armed forces of the Democratic People’s Republic of Korea (North Korea) made North Korea a party to the IAC as a co-belligerent alongside Russia. Although several other States were, to various degrees, involved in the conflicts, either through weapons delivery, the provision of military intelligence , publicly available information indicates that none had become parties to the conflict.

First Phase of Conflict (2014–2022)

A political crisis erupted in Ukraine as a consequence of the decision of then President Viktor Yanukovich not to sign an association agreement with the European Union in November 2013. Demonstrators occupied Independence Square (Maidan) in Kyiv and mounted large-scale protests in other places across Ukraine over the course of several months. Police and other law enforcement agencies responded with excessive force, culminating in the events of 19 to 20 February 2014 that resulted in the death more than one hundred demonstrators and thirteen law enforcement officials.¹ An agreement on the settlement of the political crisis signed on 21 February 2014 by President Yanukovich and opposition leaders following mediation efforts by the European Union and Russia, was not implemented. President Yanukovich left the country after being removed from power by Ukraine’s parliament on 22 February 2014.

Against this background, from the end of February 2014 onwards, armed men in unmarked military uniforms started to deploy in Crimea and take control of strategic positions, including, on 27 February, the Supreme Council of the Autonomous Republic of Crimea. The same day, the Council appointed Sergey Aksyonov as Crimea’s ‘Prime Minister’. While Russia initially denied any involvement, Russian President Vladimir Putin subsequently acknowledged that these armed men had been Russian servicemen.² Since President Yanukovich was no longer in office, any written request to Russia could not amount to consent to foreign use of force, making the Russian intervention a belligerent occupation.³ From 16 to 18 March 2014, a ‘referendum’ on the future status of Crimea was held in the Autonomous Republic of Crimea and the City of Sevastopol, followed by a declaration of independence by the de facto authorities. The claimed independence of this new entity was swiftly recognized by Russia and was soon followed by the conclusion of a ‘treaty of accession’ to Russia.

In April 2014, armed men started occupying public buildings in the Luhansk and Donetsk regions of eastern Ukraine. The situation soon evolved into armed confrontations with Ukrainian security forces, after acting President Turchynov announced the deployment of the army as part of an ‘anti-terrorist operation’ to regain control of the seized areas.⁴ Following ‘independence referendums’ on 11 May 2014, pro-Russian separatists declared their independence as the ‘Donetsk People’s Republic’ (DPR) and the ‘Luhansk People’s Republic’ (LPR). Presidential elections were held in June 2014, resulting in the election of Petro Poroshenko as president of Ukraine. President Poroshenko vowed to continue military operations in the Donbas. However, the Government of Ukraine has since then failed to reestablish its authority over the cities of Donetsk and Luhansk, as well as other parts of these regions controlled by the DPR and LPR. A peace plan and ceasefire agreements were concluded in Minsk, in the framework of negotiations between Ukraine, Russia, and the Organization for Security and Co-operation in Europe (OSCE) with the mediation of France and Germany in September 2014,5 and February 2015 6. However, hostilities have continued ever since, albeit with varying degrees of intensity. Volodymyr Zelensky was elected president at the presidential elections held in Spring 2019.

Legal Classification of the Conflict during the First Phase (2014–2022)

Based on these facts, the situation in Eastern Ukraine was often described as a non-international armed conflict (NIAC) opposing Ukrainian governmental forces and the forces of the DPR and LPR.⁷

Russia long denied any involvement in the conflicts in the Donbas. Reports soon emerged, however, that Russia had been sending military personnel and providing arms and engaging in cross-border artillery shelling of Ukrainian positions.⁸ Ukraine’s position is that, through the DPR and LPR acting as its proxies, Russia occupied Eastern Ukraine, starting in 2014.⁹

In parallel to the above-mentioned NIAC, the direct involvement of Russian armed forces on Ukrainian territory triggered an international armed conflict between the two States, in addition to the belligerent occupation of Crimea¹⁰. In 2019, the Office of the Prosecutor of the International Criminal Court also indicated that it had ‘considered information that suggest[ed] that the Russian Federation [might] have exercised overall control over armed groups in eastern Ukraine for some or all of the armed conflict’. ¹¹ In a judgment issued on 17 November 2022, the Hague District Court considered that Russia had exercised ‘overall control’ over the DPR from mid-May 2014.¹²

A similar position was adopted by experts appointed in 2022 by the OSCE in the framework of the Moscow Mechanism. They affirmed that ‘ [c]ertain parts of the Donetsk and Luhansk regions ha[d] also been under the effective control of Russia since 2014’. They considered that ‘[t]his control [was] exercised through a subordinate local administration of the so-called Donetsk and Luhansk “People’s Republics”, over whose acts Russia exercise[d] (at least) overall control.’¹³

The European Court of Human Rights has also had to decide whether Russia exercised its jurisdiction over an area in the region of Donetsk at the time of the shooting down of flight MH17¹⁴) The Court observed that ‘by the time of the 11 May 2014 “referendums”, the separatist operation as a whole was being managed and coordinated by the Russian Federation’¹⁵ and that available evidence ‘demonstrate[d] beyond reasonable doubt that, as a result of Russia’s military presence in eastern Ukraine and the decisive degree of influence and control it enjoyed over the areas under separatist control in eastern Ukraine as a result of its military, political and economic support to the separatist entities, these areas were, from 11 May 2014 and subsequently [until at least 26 January 2022], under the effective control of the Russian Federation’¹⁶. In a subsequent decision, the Court made clear its view that ‘these areas continued to be under the effective control of the respondent State throughout the period falling within the temporal jurisdiction of the Court, namely up until 16 September 2022.’¹⁷

Large-Scale Invasion of Ukraine (from 2022 onwards)

In 2021, tensions escalated between Russia, on the one hand, and Ukraine and several Western States, on the other. After US President Joseph Biden took office in January 2021, Ukrainian President Volodymyr Zelensky adopted a more assertive stance towards Russia, and sought to initiate discussions about the possibility of Ukraine joining NATO. President Putin ordered massive deployments of Russian troops along the Ukrainian border. In January and February 2022, diplomatic attempts to de-escalate proved unsuccessful.¹⁸

On 21 February 2022, President Putin announced his decision to formally recognize ‘the independence and sovereignty’ of the DPR and LPR.¹⁹ On 22 February 2022, the Russian Federation concluded two so-called ‘Treaties on Friendship, Cooperation and Mutual Assistance’ with the DPR and LPR.²⁰. On 24 February 2022, President Putin announced his decision to conduct a ‘special military operation’ in Ukraine, in response to requests for assistance sent by the DPR and the LPR.²¹ The same day, Russian forces entered Ukraine from both Russia and Belarus and began their advance with the apparent purpose of extending full Russian control over the territory of Ukraine. By early March 2022, nearly all of the 190,000 Russian troops previously deployed on the border were in Ukrainian territory – in the north, south and east.

During a later phase of the invasion, which continued from March to June 2022, Russia focused on eastern Ukraine, taking the city of Mariupol after a long siege, while Ukrainian troops engaged in counter-offensives in the north and south of the country. The month of July 2022 marked the beginning of a new phase of the conflict, as Russia sought to take control of Kherson and Zaporizhzhia in the south. During the last week of September 2022, Russian-installed officials organized ‘referendums’ in four Ukrainian regions partially occupied by Russia, namely Donetsk, Kherson, Luhansk, and Zaporizhzhia. On 28 September 2022, Kremlin-controlled authorities of the four Russian-occupied areas of Ukraine announced that the majority of residents had voted in favour of the incorporation of these regions into the Russian Federation. On 29 September 2022, President Putin signed decrees on the recognition of the ‘State sovereignty and independence’ of the regions of Kherson 22 and Zaporizhzhia 23. The decision to ‘incorporate’ these territories into Russia was then formalized on 30 September 2022, with the conclusion of ‘treaties of accession’ with the DPR and LPR, as well as Kherson, and Zaporizhzhia regions.²⁴ In November 2022, Russian forces withdrew from the city of Kherson as a result of the progress of the Ukrainian counter-offensive.

At the beginning of January 2023, Russia focused on gaining control over the towns of Soledar and Bakhmut in Donetsk. On 21 May 2023, after eight months of combat, President Zelensky announced that forces belonging to the Wagner Group, together with Russian troops, had completely destroyed the city of Bakhmut. Fighting continued over the course of the following months. At the beginning of January 2023, Russia had focused on gaining control over the towns of Soledar and Bakhmut in Donetsk. It was reported that Wagner was fighting in the Donbas with a view to taking control over Soledar. The group claimed to be fighting ‘heavy, bloody battles’ in the region to support Russian military operations.²⁵

On several occasions, Ukraine demonstrated its ability to conduct air strikes on Russian territory, sometimes far from the Ukrainian battlefields. This included a number of drone strikes on Moscow in May 2023.²⁶ Presidential elections initially scheduled to be held in Spring 2024 were postponed due to the martial law in force in Ukraine since February 2022.²⁷

Foreign Involvement

The question of whether Belarus became a party to the conflict due to its support for Russia remains somewhat unclear and controversial. According to the Appeals Chamber of the International Criminal Tribunal for the former Yugoslavia (ICTY), an international armed conflict ‘exists whenever there is a resort to armed force between States’.²⁸ Ukraine believes that Belarusian troops took an active part in the invasion, despite President Alexander Grigoryevich Lukashenko’s official denials.²⁹ Press reports also emerged in early 2023 pointing towards the active involvement of Belarusian troops in the early phases of the invasion. ³⁰ If this did occur, Belarus would have been a party to the armed conflict for the duration of its active military involvement. The Geneva Academy has not, however, confirmed the active involvement of Belarusian armed forces.

In the early stages of the invasion, Belarus certainly provided support to Russia by allowing Russian troops and tanks to invade Ukraine from Belarusian territory, using Belarusian infrastructure, including roads and railways, and providing them with fuel³¹ During a press interview, Belarusian President Lukashenko even declared that Belarusian military forces ‘could take part in Russia’s military operation against Ukraine if needed’.³² In subsequent statements, President Lukashenko made clear that Belarus was not actively involved in the conflict.³³

The experts appointed by the OSCE in the framework of the Moscow Mechanism considered, as of 1 April 2022, that this fact alone was insufficient to make Belarus a party to the conflict because Belarus itself did not ‘commit acts of violence or other acts that would constitute direct participation in the hostilities by persons attributable to Belarus’.³⁴ Ukraine expressed its disagreement with this part of the report.³⁵ Ukraine argued that the act of a State that places its territory at the disposal of another State is sufficient to trigger an IAC³⁶. Ukraine referred to Article 3(f) of the Definition of Aggression adopted by the UN General Assembly.³⁷

The Geneva Academy agrees with the position taken by the OSCE experts. However, it was also reported in the press that Russian missiles had been launched from Belarusian territory and airspace on several occasions, even after Ukraine had regained control over regions close to the border with Belarus.‘³⁸ Open-source intelligence collected by a group of Belarusian dissidents claimed to have identified at least 721 missile launches from Belarusian territory from the beginning of the full-scale invasion until 6 October 2022. It also claimed to have documented the provision of military training grounds for the training and accommodation of the Russian military, the use of airfields by Russian aircraft for the provision of logistical supply and support, the provision of fuel, the transfer of armaments, and the establishment of military bases.³⁹ As such, depending on the precise facts, it is possible that the involvement of Belarus could constitute a sufficiently direct connection to harm caused to Ukraine to make it a party.⁴⁰

During the reporting period, hostilities continued between the armed forces of the Russian Federation and Ukraine. Starting on 6 August 2024, a Ukrainian counter-offensive in the region of Kursk had the effect of opening a new front in the north-east of Ukraine and, for the first time, saw combat on the territory of the Russian Federation. The operation resulted in Ukraine taking control of a substantial part of Russian territory in the regions of Kursk and Belgorod. The Ukrainian armed forces reportedly opened a military commandant’s office in the region for the purposes of administrating the areas under its authority. According to Colonel General Oleksandr Syrskyi, Commander of the Ukrainian Ground Forces, the office ‘must ensure order and also all the needs of the local population’.⁴² Russian efforts to regain control over the region intensified in late 2024 and early 2025. On 26 April 2025, Chief of the General Staff of the Russian Armed Forces, Valery Vasilyevich Gerasimov, reported to President Putin that Russian forces had reestablished their authority over the last populated area in the Kursk region that had been occupied by Ukrainian forces and the creation of a ‘security zone’ in the Sumy region of Ukraine.⁴³

From October 2024, reports emerged that servicemen from North Korea had been deployed to the Kursk region and were undergoing training with a view to an imminent deployment on the battlefield.⁴⁴ Videos shared on social media appeared to show North Koreans in Russian uniforms. In December 2024, reports of the capture of North Korean soldiers by Ukraine confirmed that North Korean troops were engaged in combat.⁴⁵ On 26 April 2025, in a meeting with President Putin, General Gerasimov underlined the role played in the hostilities in Kursk by North Korean troops.⁴⁶ The same day, a report from the state-run North Korean Central News Agency (KCNA) confirmed this information.⁴⁷

During the reporting period, an IAC was ongoing between Russia and Ukraine along with belligerent occupation by Russia of parts of Ukrainian territory (Crimea, the city of Sevastopol and parts of the regions of Kherson, Zaporizhzhia, Donetsk and Luhansk), which were ‘placed under the authority’ of Russian armed forces.⁴⁸

International armed conflict between the Russian Federation and Ukraine

During the reporting period, an international armed conflict (IAC) was ongoing between Russia and Ukraine along with belligerent occupation by Russia of parts of Ukrainian territory (Crimea, the city of Sevastopol and parts of the regions of Kherson, Zaporizhzhia, Donetsk and Luhansk), which were ‘placed under the authority’ of Russian armed forces.¹

International armed conflict between the Russian Federation and Ukraine

From the time of the entry into force of the ‘treaties’ on the incorporation of the DPR and LPR into the Russian Federation concluded on 30 September 2022, members of the armed forces of the DPR and LPR have been granted the status of members of the regular Russian armed forces.² From that point, such armed forces therefore qualify as de jure organs of the Russian Federation, and their acts are attributable to the Russian Federation irrespective of the degree of control exercised over them by the latter. ³

Belligerent occupation of parts of the territory of Ukraine

Legal Criteria

Since March 2014, Crimea has been occupied by Russia. Furthermore, Russia has been occupying large territories in the south and the east of Ukraine since at least February 2022. The Grand Chamber of the European Court of Human Rights had no difficulty concluding that Russia had exercised effective control over large areas of Ukraine.⁵

The purported annexation of the Autonomous Republic of Crimea and the city of Sevastopol, decided on 21 March 2014 after the organization of a widely condemned ‘referendum’, does not alter the status under international law of these regions or of their inhabitants.⁶ The Autonomous Republic of Crimea and the city of Sevastopol have been under Russian military occupation ever since.⁷ The same reasoning applies to the annexation of the regions of Donetsk, Kherson, Luhansk and Zaporizhzhia. A UN General Assembly resolution adopted on 12 October 2022 affirms that the regions of Donetsk, Kherson, Luhansk and Zaporizhzhia are or have been, in part, ‘under the temporary military control of the Russian Federation, and the subsequent attempted illegal annexation of these regions, have no validity under international law and do not form the basis for any alteration of the status of these regions of Ukraine.’⁸ Irrespective of the views of Russia, all Ukrainian territory placed under the authority of Russian armed forces remains under belligerent occupation.

Belligerent occupation of part of the Kursk region by Ukraine

A Trial Chamber of the ICTY in the Naletilić and Martinović identified a number of guidelines to provide assistance in the determination of whether the authority of an occupying power has actually been established. ⁹ It appears that Ukrainian forces were for several months able to substitute their authority to that of Russian authorities over an area extending to more than 1,000 square kilometers that includes dozens of localities, following the withdrawal of Russian forces. Moreover, Ukraine also announced the opening of an office with a view to administering the territory. It can be considered that parts of the Kursk region were under belligerent occupation from August 2024 until Russia regained control over them.¹⁰

The fact that the Kursk region was not entirely under the authority of Ukrainian forces is no obstacle to the application of the law of belligerent occupation to those areas where such forces did enjoy effective control. According to the jurisprudence of the ICTY, ‘[t]here is no requirement that an entire territory be occupied, provided that the isolated areas in which the authority of the occupied power is still functioning “are effectively cut off from the rest of the occupied territory”’.¹¹

Involvement of North Korea in the international armed conflict between Russia and Ukraine

The concrete modalities of the cooperation between the Russian Federation and the DPRK have not been made public – although some reports indicate that Russia is paying the North Korean government significant sums of money in exchange for its military assistance,¹² while other sources claim that the assistance is provided by North Korea in exchange for ‘technology related to Russia’s nuclear and weapons programs, as well as oil’.¹³ Article 4 of the Treaty on Comprehensive Strategic Partnership between the Russian Federation and the Democratic People’s Republic of Korea of 19 June 2024 provides for the mutual duty of the States Parties to provide each other mutual assistance in case of armed aggression.¹⁴ On 28 April 2025, President Putin confirmed that this provision constituted the legal basis for Russia’s request for military assistance from the DPRK.¹⁵

While the fact that North Korean soldiers have been handed Russian uniforms and disguised as members of Russian ethnic minorities indicates that Russia and North Korea were, at least initially, willing to give the appearance that the troops were acting in the exercise of the governmental authority of the Russian Federation, it is not in itself sufficient evidence of a relinquishment of North Korean authority. The Geneva Academy believes, based on publicly available information, that North Korea is itself directly involved in armed confrontations with Ukraine, that its acts amount to use of ‘armed force’ against Ukraine, and that it is therefore a party to an international conflict with Ukraine, fighting as co-belligerent alongside Russia. This conclusion is buttressed by the acknowledgment by Russia and North Korea of the sending of its troops to assist Russia, on 28 April 2025.¹⁶

1
Article 42 of the Hague Regulations annexed to the Hague Convention of 1907 respecting the Laws and Customs of War on Land.
2
Федеральный конституционный закон от 04.10.2022 № 5-ФКЗ (ред. от 26.12.2024) « О принятии в Российскую Федерацию Донецкой Народной Республики и образовании в составе Российской Федерации нового субъекта – Донецкой Народной Республики », Статья 7.
3
Article 91 AP I; see also Ukraine and the Netherlands v. Russian Federation, Judgment (Grand Chamber), 9 July 2025, paras 363–4.
4
Article 42 of the Hague Regulations annexed to the Hague Convention of 1907 respecting the Laws and Customs of War on Land.
5
Ukraine and the Netherlands v. Russian Federation, Judgment (Grand Chamber), 9 July 2025, paras 337–38.
6
Article 47 Convention (IV) relative to the Protection of Civilian Persons in Time of War. Geneva, 12 August 1949; United Nations General Assembly Resolution 68/262. Territorial integrity of Ukraine, 27 March 2014, p 2, para 5; United Nations General Assembly Resolution 71/205. Situation of human rights in the Autonomous Republic of Crimea and the city of Sevastopol (Ukraine), 1 February 2017, p 1.
7
See eg International Criminal Court, Office of the Prosecutor, Report on Preliminary Examination Activities (2020), 14 December 2020, p 70, para 279; European Court of Human Rights, Ukraine v. Russian Federation (Crimea), Judgment (Grand Chamber), 25 June 2024, para 918.
8
United Nations General Assembly Resolution ES-11/4. Territorial integrity of Ukraine: defending the principles of the Charter of the United Nations, 12 October 2022, para 3.
9
ICTY, Prosecutor v. Mladen Naletilić and Vinko Martinović (Judgment) IT-98-34-T, T Ch (31 March 2003) p 74, para 217.
10
O. Kovalenko and K. Kobernyk, ‘“Ukraine cannot prosecute Russians in Russia for espionage in favor of Russia — that is their right.” Humanitarian law expert Marko Milanovic talks about what Ukraine should do in the Kursk region’, Babel.ua, 16 August 2024. But see for the contrary view that Ukraine could not be seen as an occupying power due to ongoing hostilities in the region, M. W. Meier, ‘Ukraine Symposium – Is Ukraine Occupying Territory in Russia?’, Articles of War, Lieber Institute West Point, 26 August 2024; B. Padrón Salinas, ‘Kursk Operation: Legal Perspectives of a Counter Offensive’, FINABEL – The European Land Force Commanders Organisation, Info Flash, October 2024, p 6.
11
ICTY, Prosecutor v. Mladen Naletilić and Vinko Martinović, Judgment, (IT-98-34-T), Trial Chamber, 31 March 2003, para 218; see also ICTY, Prosecutor v. Duško Tadić, Judgment (IT-94-1-T), Trial Chamber, 7 May 1997, para 580.
12
‘What we know about North Korean troops fighting Russia’s war’, BBC, 24 December 2024.
13
L. Yoon, ‘North Korean Soldiers in Ukraine Spotlight Rights Crisis’, Human Rights Watch, 14 January 2025.
14
‘DPRK-Russia Treaty on Comprehensive Strategic Partnership’, KCNA, 20 June 2024.
15
‘Statement by the President of the Russian Federation’, President of Russia, 28 April 2025. See also United Nations, Security Council, 9908^th meeting, Tuesday, 29 April 2025, 4 p.m., UN Doc S/PV.9908, p 19 (Russian Federation, Mr. Nebenzia.
16
N. Pasko, ‘Why Did Pyongyang and Moscow Finally Admit North Koreans Are Fighting in the Russia-Ukraine War?’, The Diplomat, 8 May 2025.

State Parties

Russian Federation
Ukraine
Democratic People’s Republic of Korea (North Korea)

1
Office of the United Nations High Commissioner for Human Rights, Accountability for killings in Ukraine from January 2014 to May 2016, Geneva, 2016, p 9, para 20.
2
K. Lally, ‘Putin’s Remarks Raise Fears of Future Moves Against Ukraine’, Washington Post, 17 April 2014.
3
Common Article 2(2) of the 1949 Geneva Conventions.
4
‘Ukraine Crisis: President Vows to Fight Pro-Russia Forces’, BBC, 14 April 2014; ‘Ukraine Says Donetsk “Anti-Terror Operation” Under Way’, BBC, 16 April 2014.
5
Letter dated 24 February 2015 from the Permanent Representative of Ukraine to the United Nations addressed to the President of the Security Council (25 February 2015) UN Doc S/2015/135 and annexes
6
United Nations, Security Council, Resolution 2202 (2015) (17 February 2015) UN Doc S/RES/2202 (2015) and annexes
7
See eg Office of the United Nations High Commissioner for Human Rights, Accountability for killings in Ukraine from January 2014 to May 2016, Geneva, 2016, p 5, para 1 and pp 10–11, para 29; International Criminal Court, Office of the Prosecutor, Report on Preliminary Examination Activities 2016, The Hague, 14 November 2016, p 37, para 168; and M. Hrnjaz and M. Radončić, ‘Geneva, We Have a Problem: Internationalisation of Armed Conflicts through Indirect Intervention Remains a Dead Letter’, Israel Law Review, Vol 57, No 1 (2024) 116–20.
8
See eg Putin. War: An Independent Expert Report Based on Materials from Boris Nemtsov, Free Russia Foundation, Washington DC, May 2015; Bellingcat, Origin of Artillery Attacks on Ukrainian Military Positions in Eastern Ukraine between 14 July 2014 and 8 August 2014, 15 January 2015; S. Case, Putin’s Undeclared War: Summer 2014 – Russian Artillery Strikes Against Ukraine, Bellingcat, 21 December 2016; S. Frizell, ‘US: Satellite Imagery Shows Russian Shelling Easter Ukraine’, Time, 27 July 2014.
9
W. Benedek, V. Bílková and M. Sassòli, Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022, OSCE, Office for Democratic Institutions and Human Rights, Vienna, 12 April 2022, Annex: Comments by Ukraine to the Report of the Mission of Experts, established to address the violations of international humanitarian and human rights law, war crimes and crimes against humanity committed during Russia’s war of aggression against Ukraine, p 2, paras 1–2.
10
International Criminal Court, Office of the Prosecutor, Report on Preliminary Examination Activities 2016, The Hague, 14 November 2016, p 37, para 169
11
International Criminal Court, Office of the Prosecutor, Report on Preliminary Examination Activities (2019), The Hague, p 71, para 277.
12
Hague District Court, Case number 09/748007-19, Judgment of 17 November 2022, para 40.
13
W. Benedek, V. Bílková and M. Sassòli, ‘Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022’, Report, Office for Democratic Institutions and Human Rights, OSCE, Vienna, 12 April 2022, p 51. See further, on this issue, ‘International Law and Defining Russia’s Involvement in Crimea and Donbas’, Global Rights Compliance, The Hague, 13 February 2022.
14
European Court of Human Rights, Ukraine and the Netherlands v. Russian Federation, Admissibility Decision (Grand Chamber), 30 November 2022, paras 576–706.
15
ibid., para 693
16
ibid., para 695
17
Ukraine and the Netherlands v. Russian Federation, Judgment, (Grand Chamber), 9 July 2025, para 331.
18
L. Ragozin, ‘Russia-US escalation: How did we get here?’, Al Jazeera, 21 December 2021; ‘Timeline: How did the recent Ukraine-Russia crisis start?’, Al Jazeera, 13 February 2022; I. Khurshudyan and D. L. Stern, ‘Why Ukraine’s Turkish-made drone became a flash point in tensions with Russia’, The Washington Post, 15 January 2022.
19
‘Address by the President of the Russian Federation’, President of Russia, 21 February 2022.
20
Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation; 32 States intervening), Preliminary Objections, Judgment of 2 February 2024, para 31
21
Address by the President of the Russian Federation, Annex to the letter dated 24 February 2022 from the Permanent Representative of the Russian Federation to the United Nations addressed to the Secretary-General, 24 February 2022, UN Doc S/2022/154.
22
Указ Президента Российской Федерации от 29.09.2022 № 686 “О признании Херсонской области”
23
Указ Президента Российской Федерации от 29.09.2022 № 685 “О признании Запорожской области”
24
‘Signing of treaties on accession of Donetsk and Lugansk people’s republics and Zaporozhye and Kherson regions to Russia’, President of Russia, 30 September 2022.
25
‘Photos illustrate the intensity of Russia’s battle for Soledar and Bakhmut’, CNN, 12 January 2023; ‘Russia’s Wagner group fighting ‘heavy, bloody battles’ for control of Soledar’, The Guardian, 10 January 2023.
26
‘Ukraine tried to assassinate Putin by drone, Kremlin says’, Reuters, 3 May 2023; ‘Russia accuses Ukraine of attempt to kill Putin with drones’, Al Jazeera, 3 May 2023; ‘Drone attacks hit Moscow, sparking fury at the Kremlin’, Al Jazeera, 30 May 2023.
27
A. Bland, ‘Why Hasn’t Ukraine Held Elections since the War Began?’ The Guardian, 20 February 2025.
28
ICTY, Prosecutor v. Duško Tadić (Decision on the Defence Motion for Interlocutory Appeal on Jurisdiction) IT-94-1-A, A Ch (2 October 1995), para 70.
29
W. Benedek, V. Bílková and M. Sassòli, Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022, OSCE, Office for Democratic Institutions and Human Rights, Vienna, 12 April 2022, Annex: Comments by Ukraine to the Report of the Mission of Experts, established to address the violations of international humanitarian and human rights law, war crimes and crimes against humanity committed during Russia’s war of aggression against Ukraine, p 3, para 4.
30
R. Stepanovych, ‘Belarus Participated in the Invasion of Ukraine as “Little Green Men.” Zaborona Investigation’, Zaborona, 22 March 2023.
31
B. Cole, ‘Belarus Joins Russia in Invading Ukraine as Video Shows Tanks Cross Border’, Newsweek, 24 February 2022.
32
‘Belarusian troops could be used in operation against Ukraine if needed, Lukashenko says’, Reuters, 24 February 2022.
33
See, eg, ‘Belarus Not Party to Ukraine Conflict, Lukashenko Says’, TASS, 3 July 2025.
34
W. Benedek, V. Bílková and M. Sassòli, Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022, Office for Democratic Institutions and Human Rights, OSCE, Vienna, 12 April 2022, p 5.
35
W. Benedek, V. Bílková and M. Sassòli, Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022, Office for Democratic Institutions and Human Rights, OSCE, Vienna, 12 April 2022, Annex: Comments by Ukraine to the Report of the Mission of Experts, established to address the violations of international humanitarian and human rights law, war crimes and crimes against humanity committed during Russia’s war of aggression against Ukraine, p 3, para 3.
36
ibid.
37
Ibid.; United Nations General Assembly Resolution 3314 (XXIX): ‘Definition of Aggression’, 14 December 1974, Annex: Definition, Article 3(f); see, for discussion, A. Wentker, M. Jackson and L. Hill-Cawthorne, ‘Identifying Co-Parties to Armed Conflict in International Law: How States, International Organizations and Armed Groups Become Parties to War’, Chatham House, March 2024, p 16; A. Wentker, Party Status to Armed Conflict in International Law, Oxford University Press, 2024, pp 199–202.
38
Russian forces fire barrage of missiles at northern Ukraine from Belarus’, The Guardian, 28 July 2022; H. Chen, W. Chang, J. Hallam, R. Gigova, ‘Belarus claims to have shot down Ukrainian missiles’, CNN, 3 July 2022.
39
‘Evidence of complicity of the Lukashenko regime in Russia’s military aggression against Ukraine’, Belarusian Hajun Project, 24 September 2023.
40
See eg A. Wentker, ‘At War: When Do States Supporting Ukraine or Russia become Parties to the Conflict and What Would that Mean?’, EJIL Talk!, 4 March 2022; J. Grignon, ‘“Co-belligerency” or when does a State become a party to an armed conflict?’, Institut de recherche stratégique de l’École militaire, Strategy Brief, No 39, 6 May 2022, p 2.
41
W. Benedek, V. Bílková and M. Sassòli, Report on Violations of International Humanitarian and Human Rights Law, War Crimes and Crimes against Humanity committed in Ukraine since 24 February 2022, OSCE, Office for Democratic Institutions and Human Rights, Vienna, 12 April 2022, p 5; J. Grignon, ‘“Co-belligerency” or when does a State become a party to an armed conflict?’, Institut de recherche stratégique de l’École militaire, Strategy Brief, No 39, 6 May 2022, p 2; but see, more cautiously, M.N. Schmitt, ‘Ukraine Symposium – Are We at War?’, Articles of War, 3 February 2022.
42
O. Harmash and T. Balmforth, ‘Ukraine opens military office in occupied Kursk region, says it is still advancing’, Reuters, 15 August 2024.
43
‘Meeting with Chief of the General Staff of the Russian Armed Forces Valery Gerasimov’, President of Russia, 26 April 2025.
44
See eg ‘Russia to deploy 10,000 North Korean troops against Ukraine within “weeks”, Pentagon says’, The Guardian, 29 October 2024.
45
AFP, ‘Ukraine Captured North Korean Soldier Fighting Alongside Russia, South Korea Says’, The Moscow Times, 27 December 2024; ‘What we know about North Korean troops fighting Russia’s war’, BBC, 24 December 2024.
46
‘Meeting with Chief of the General Staff of the Russian Armed Forces Valery Gerasimov’, President of Russia, 26 April 2025.
47
N. Pasko, ‘Why Did Pyongyang and Moscow Finally Admit North Koreans Are Fighting in the Russia-Ukraine War?’, The Diplomat, 8 May 2025.
48
Article 42 of the Hague Regulations annexed to the Hague Convention of 1907 respecting the Laws and Customs of War on Land.

Ukraine

Reporting period: July 2023 - June 2025

why a disclaimer ?

International armed conflict between the Russian Federation and Ukraine

International armed conflict between the Russian Federation and Ukraine

Belligerent occupation of parts of the territory of Ukraine

Belligerent occupation of part of the Kursk region by Ukraine

Involvement of North Korea in the international armed conflict between Russia and Ukraine

State Parties

Ukraine

Reporting period: July 2023 - June 2025

why a disclaimer ?

Overview

Historical background

Key developments (2023-2024)

International Armed Conflict

International armed conflict between the Russian Federation and Ukraine

Belligerent occupation of parts of the territory of Ukraine

Belligerent occupation of part of the Kursk region by Ukraine

Involvement of North Korea in the international armed conflict between Russia and Ukraine

Parties to the Conflict

State Parties