ZMINA and partners prepared three submissions for the UN Universal Periodic Review of Ukraine
The Human Rights Centre ZMINA submitted its own submission for the fourth cycle of the UN Human Rights Council’s Universal Periodic Review (UPR) and co-authored two further coalition submissions with its partners. Across the three documents, human rights defenders assessed Ukraine’s implementation of 42 of the 190 recommendations made by other states during the previous UPR cycle in 2017.
The UN Human Rights Council, Geneva, Switzerland. Photo credit: AFPUkraine is currently undergoing the fourth cycle of the Universal Periodic Review, which assesses how it fulfils its human rights obligations. The submissions cover the development of civil society, media freedom, the functioning of human rights institutions and protection mechanisms, the rights of people affected by Russian aggression, the prevention of torture, conditions in places of detention and international justice.
Civil society, media and human rights institutions
The submission by the Human Rights Centre ZMINA focuses on the implementation of recommendations concerning the work of civil society, media freedom, the protection of human rights defenders, the functioning of the Ombudsman institution, the implementation of the National Human Rights Strategy, compliance with international humanitarian law and the harmonisation of domestic legislation with international criminal law.
Of the 25 recommendations assessed, only two were found to have been fully implemented. These were recommendations made by France and Czechia to abolish the requirement for representatives of anti-corruption NGOs to submit financial declarations (electronic asset declarations for activists) and to ensure that legislation on asset declarations by NGOs does not undermine the work of civil society.
Most of the other recommendations are either being implemented or have seen only limited progress. In several cases, however, limited implementation is directly linked to Russia’s ongoing armed aggression against Ukraine and the challenges arising from martial law.
Civil society remains highly active even in wartime but continues to face a number of challenges. In particular, the United News telethon limits media pluralism, while regulatory mechanisms for blocking online media raise concerns about freedom of expression. Legislative changes, including Law No. 4576-IX, adopted in 2025, weaken mechanisms for public oversight and investigative journalism, while restrictions on access to state registers undermine anti-corruption tools. Further risks arise from initiatives to update the Civil Code, which could restrict access to information and make investigations more difficult. Cases of pressure on journalists and anti-corruption activists also continue to be documented, while investigations into them remain insufficiently effective. Moreover, criminal law still does not allow hate crimes to be properly classified.
As regards the Ukrainian Parliament Commissioner for Human Rights, the appointment procedure remains a key concern, as it does not provide for a transparent, open and competitive selection process with adequate civil society participation. Regarding the National Human Rights Strategy, human rights defenders note that Ukraine has begun developing a new strategy. However, the limited consideration given to civil society proposals and insufficient attention to discrimination and human rights in wartime are hindering its effective implementation.
The analysis points to institutional progress and some positive practices in documenting and investigating international crimes and strengthening international cooperation. However, the effectiveness of these efforts is significantly constrained by limited resources, excessive workloads within law enforcement agencies and the absence of fully independent monitoring mechanisms, particularly regarding compliance with international humanitarian law. The document also emphasises that, despite the establishment of an extensive system for investigating war crimes and cooperating with international institutions, the scale of documented violations and staffing constraints make it considerably more difficult to ensure accountability and combat impunity.
The full submission by the Human Rights Centre ZMINA is available here.
Protecting the rights of people affected by Russian aggression
The second submission was prepared by the Coalition of organisations dealing with the protection of the rights of victims of armed aggression against Ukraine. The Coalition comprises nine organisations: the Human Rights Centre ZMINA, NGO Donbas SOS, NGO CrimeaSOS, Charitable Foundation Right to Protection, Charitable Foundation East SOS, NGO Civil Holding GROUP OF INFLUENCE, Charitable Foundation Stabilization Support Services, the Crimean Human Rights Group and NGO Crisis Insight.
The submission assesses Ukraine’s implementation of recommendations concerning the protection of the rights of people affected by Russia’s armed aggression. Its authors note that, despite some positive developments, state policy concerning those affected remains fragmented, while some of the recommendations made to Ukraine in 2017 have yet to be implemented.
In particular, human rights defenders highlight the absence of a single body responsible for developing policy for people affected by the war. In their view, dividing responsibilities among different ministries has undermined inter-agency coordination and left some functions, including those relating to transitional justice and the protection of the rights of residents of temporarily occupied territories, without clear institutional ownership.
The submission also examines problems concerning compensation for damage. The current national mechanism covers only certain categories of residential property damaged or destroyed after 24 February 2022. People whose property was destroyed before the full-scale invasion or remains in territories occupied before 2022 are not eligible for compensation. Moreover, the statutory system for recording non-pecuniary damage has yet to become operational.
Human rights defenders also documented numerous barriers faced by residents of the temporarily occupied territories. These include the need to apply to a court to register births or deaths, the lack of a legal framework governing the use of documents issued under occupation, difficulties faced by citizens seeking to return without Ukrainian documents and children’s limited access to Ukrainian education.
Regarding internally displaced persons, the Coalition identified the adoption of a revised version of the Law on Ensuring the Rights and Freedoms of Internally Displaced Persons as an important step towards developing a comprehensive policy. At the same time, the authors highlight the persistence of discriminatory practices in pension provision for people who have left the temporarily occupied territories, as well as the need to strengthen the participation of IDP councils in shaping state policy.
Of the 10 recommendations assessed, only one was found to have been fully implemented: France’s recommendation to provide medical assistance to displaced persons. The remaining recommendations are either being implemented or have seen only limited progress.
The Coalition recommends that Ukraine designate a single body responsible for policy concerning people affected by the war, establish a comprehensive support system for them, introduce a fully operational system for recording non-pecuniary damage, ensure an effective compensation mechanism, simplify access to administrative services for residents of the temporarily occupied territories and eliminate discriminatory practices affecting internally displaced persons and pensioners.
The full submission by the Coalition of organisations dealing with the protection of the rights of victims of armed aggression against Ukraine is available in Ukrainian and English.
Prevention of torture and conditions in places of detention
ZMINA prepared another submission jointly with the World Organisation Against Torture (OMCT). It assesses seven recommendations concerning the prevention of torture and other forms of ill-treatment.
The analysis covers the alignment of criminal legislation with the Convention against Torture, the effectiveness of torture investigations conducted by the State Bureau of Investigation, adequate funding and independence for the National Preventive Mechanism (NPM), improvements to conditions in places of detention, and the protection of the rights of minors and persons with disabilities held in such facilities.
The assessment found that all seven recommendations had been only partially implemented. This indicates that, despite some positive developments, systemic problems persist.
The submission notes that Ukraine has taken a number of important steps, including improving criminal legislation governing liability for torture, establishing a specialisation in torture investigations within the State Bureau of Investigation, continuing to reform the penitentiary system and ensuring that the National Preventive Mechanism has unhindered access to places of detention. At the same time, the experts highlighted several unresolved problems: the definition of torture is still not fully aligned with the UN Convention against Torture; the NPM remains underfunded; detention conditions remain inadequate, particularly in pre-trial detention centres (SIZOs); medical staff are in short supply; and the integration of prison healthcare into the unified medical space has been delayed.
The full submission by ZMINA and OMCT is available here.
For reference
The Universal Periodic Review (UPR) is a mechanism of the UN Human Rights Council under which each of the 193 UN member states is required to report on its observance of human rights and freedoms and have its record scrutinised by other states. Each state undergoes the Universal Periodic Review once every four and a half years. In 2026, Ukraine is undergoing the review for the fourth time.
The previous review of Ukraine took place in 2017, when the country received 190 recommendations from 47 states. Ukraine accepted 163 of the recommendations and rejected 27. At the time, ZMINA prepared the report “Implementation of the recommendations of the Universal Periodic Review (2017–2020)” and a mid-term report on Ukraine’s implementation of recommendations with regard to protecting the rights of victims of armed conflict.
