“Exchanges” of civilians. What are the current and potential risks of existing procedures? Analytical note
The issue of returning Ukrainian civilians unlawfully detained by the Russian Federation has existed since the beginning of the armed aggression against Ukraine in 2014 and has significantly intensified following the full-scale invasion in 2022. According to the Media Initiative for Human Rights, as of November 2025, at least 2,436 Ukrainian civilians are being held by the Russian Federation.
Although civilians are a protected category under international humanitarian law and are not subject to any “exchange” procedure, Ukraine continues to face the absence of effective international mechanisms for their release.
On 25 July 2024, the “Hochu k svoim” project was publicly presented as a mechanism for returning Ukrainian civilians from Russian captivity. It is implemented by the Coordination Headquarters for the Treatment of Prisoners of War with the support of the Main Directorate of Intelligence of the Ministry of Defence of Ukraine, the Security Service of Ukraine, and the Secretariat of the Ukrainian Parliament Commissioner for Human Rights.
The project envisages the release of Ukrainian civilians through their “exchange” for Ukrainian citizens convicted of crimes (primarily against the foundations of national security), who have expressed consent to be transferred to the Russian Federation. This became the first publicly acknowledged state approach to such a mechanism for the return of civilians.
The introduction of this approach has raised a number of legal and practical concerns regarding its compliance with international humanitarian law and human rights standards, as well as the potential risks associated with its implementation.
This analytical note was prepared by experts from the Human Rights Centre ZMINA and the Ukrainian Legal Advisory Group (ULAG) to assess the project’s compliance with international humanitarian and human rights law and to examine the possible practical risks of its implementation.
The full analytical note is available in English and Ukrainian.
