Action Plan for Implementing the Strategy for the Deoccupation and Reintegration of Crimea. What has changed?

On April 4, 2023, the Cabinet of Ministers of Ukraine (CMU) approved Order No. 288-r, which amended the Action Plan for Implementing the Strategy for the Deoccupation and Reintegration of the Temporarily Occupied Territory of the Autonomous Republic of Crimea and the City of Sevastopol approved by CMU Order No. 1171 dated September 29, 2021. The Ukrainian Helsinki Human Rights Union went over the amendments to the Action Plan and submitted its recommendations, some of which were reflected in the new text.

Vladyslav Miroshnychenko, analyst UHHRU

The Action Plan’s approval was an important event in 2021, signifying major changes in state policy on Crimea’s deoccupation and reintegration. The first version of the Action Plan was clearly based on a diplomatic approach to Crimea’s deoccupation, which was prevailing at the time. The key elements of the Deoccupation and Reintegration Strategy included: maintaining constant ties with the residents of the occupied Crimea in all possible areas; encouraging young people from the occupied peninsula to move to, and study in, the government-controlled areas of Ukraine; disrupting the monopoly of Russian propaganda in the peninsula’s information sphere; keeping up international diplomatic and sanctions pressure on the aggressor state. The Action Plan was aimed at the implementation of these main vectors of state policy.

Since the beginning of Russia’s full-scale military aggression, the Action Plan developed in 2021 has partially lost its relevance. This is because the state’s approach to restoring control over Crimea has shifted overall from a political-diplomatic to a military-political one, as evidenced by numerous statements made by Ukrainian leaders and politicians. Under these circumstances, and given the rapidly changing conditions of the armed conflict, it is necessary to start preparing right away for Crimea’s reintegration after deoccupation, which may be carried out, in particular, by military means.

What has changed?

According to the Ministry for Reintegration of the Temporarily Occupied Territories of Ukraine, the finalized reintegration and deoccupation plan concerns the following areas: protection of the rights of Ukrainian citizens and legal entities whose legitimate interests were violated as a result of military aggression; social and humanitarian policy; international cooperation; economic policy; defense and security component, etc.[1]

In terms of quantitative changes to the Action Plan, the previous text contained 158 measures, while the new one has 127. The difference is due to the following reasons:

–        measures that have already been implemented were excluded, for instance: “Establish a specialized state institution “Ukrainian National Peacebuilding Center” to collect evidence of rights violations related to the temporary occupation and military aggression of the Russian Federation;”

–        measures that are impossible to implement during the full-scale war, or that are lower priority, were excluded, such as measures involving the opening of checkpoints on the administrative border with the temporarily occupied territory of the ARC and Sevastopol and the launch of transport (bus) connection between the checkpoints and the main transport hubs in Kherson Oblast;

–        some measures that were similar in nature have been merged.

Nevertheless, most of the Action Plan has not been changed. While the wording was changed in places, the essence of the measures remains the same. Instead, at least 15 qualitatively new tasks appeared in the updated Action Plan, the most important of which are detailed below.

Measure 24: “Develop and implement comprehensive methodologies for overcoming the consequences of education militarization and re-education of children and youth in the deoccupied territory of the Autonomous Republic of Crimea and the city of Sevastopol.” This point is among the most significant. Its inclusion in the Action Plan is extremely important as the militarization of education and youth in the occupied Crimea, which is aimed at destroying Ukrainian identity, will be a major challenge for reintegration. More information about this issue can be found in the materials of the Center for Civic Education “Almenda,” for instance: “How Russia is destroying the identity of Ukrainian children in the occupied territories and why it can be considered indoctrination.”

Measure 27: “Develop and submit to the Cabinet of Ministers of Ukraine a bill on overcoming the consequences of the occupation.” In the Action Plan, the expected result of implementing this measure reads as “procedure established for recognizing as valid certain transactions involving property that took place in the temporarily occupied territory; recognition/verification of information contained in the documents issued in the TOT by Russian occupation administrations (according to the Namibia exception principle); issue addressed regarding the restoration of notaries, the bar, and courts in the TOT after deoccupation.” This bill can be expected to determine the way of addressing key issues of reintegration: property rights, obtaining/restoring documents, restoring the bar and judiciary, etc.

Measure 30: “Develop legislation on prosecution for criminal offenses committed under conditions of temporary occupation.” Given the description of the expected result from implementing this measure, its main goal is to establish clear criteria for bringing collaborators to justice. No less important is defining categories of persons who, although involved in collaborationism, did not cause serious violations of human rights and thus are eligible for amnesty. Another important issue that must be addressed is reviewing the decisions of the so-called “courts” issued in the occupied territories since 2014. This is an enormous undertaking, and reviewing all these decisions will likely be impossible. In light of this, it would be prudent to outline specific criteria that would necessitate a review, e.g. when a decision has resulted in serious violations of human rights.

Measure 31: “Create a personnel reserve for staffing, in particular, of judicial, law enforcement, and state bodies, security and defense sector, as well as local self-government bodies that will be restored in the deoccupied territory of the Autonomous Republic of Crimea and the city of Sevastopol, taking into account the results of lustration procedures and the principles of international humanitarian law and international law in the field of human rights and non-discrimination on the basis of gender.”

Measure 116: “Submit recommendations on the creation of military administrations in the territory of the Autonomous Republic of Crimea and the city of Sevastopol.”

Measure 124: “Develop and submit to the Cabinet of Ministers of Ukraine a bill on restoring state authorities in the Autonomous Republic of Crimea and the city of Sevastopol.”

These three measures (31, 116 and 124) determine the general framework for restoring and staffing state authorities after deoccupation. Establishing military administrations will undoubtedly be the only practical solution at the initial stage after deoccupation, although there may be some difficulties in this regard, which will be discussed in more detail at the end of this material.

Measure 127: “Develop and submit to the Cabinet of Ministers of Ukraine a bill on determining criteria for assessing the feasibility of holding elections in the deoccupied territory as well as forming local self-government bodies and representative authorities.” This measure is directly related to the previous ones, which concern restoration of state authorities in the deoccupied territory. It is important to acknowledge the obvious fact that it will be impossible to form local self-government bodies in the deoccupied Crimea until reintegration is completed. Introducing criteria is one way to determine how much time it will take to restore local self-government and close down military administrations in Crimea. However, so far there is no clear vision of what exactly these criteria should be and to which areas they would apply.

Conclusions and recommendations

To summarize, the updated Action Plan introduces important positive changes in regards to state policy on Crimea’s reintegration, as well as defines the framework for further work. However, many of the new measures are too general and do not offer specific solutions for major problematic issues of reintegration. The future content of bills on prosecution for criminal offenses committed under conditions of temporary occupation, on overcoming the consequences of occupation, and on restoring state authorities in the ARC and Sevastopol, all of which are mentioned in the document, remains uncertain. At the same time, some other issues were left out altogether.

It is worth recalling that on December 30, 2022, CMU approved the Action Plan for Executive Bodies on Rebuilding Deoccupied Areas of Territorial Communities, which is an important organizational and administrative document for the initial period after the end of the armed conflict as well as for overcoming the conflict’s direct consequences and rebuilding the life of deoccupied areas and their residents. See more on this in UHHRU’s analytical material “Did the government take into account transitional justice elements in the plan for rebuilding deoccupied territories? Analytics.” According to this document, military administrations will be established by the President of Ukraine in liberated settlements unless an extraordinary session of the appropriate village, town, or city council is convened, or councils and/or their executive bodies and/or village, town, or city mayor resume work, or in other cases provided for by the Law of Ukraine “On the Legal Regime of Martial Law.” Since there are currently no legitimate local self-government bodies in the occupied Crimea, military administrations will be established in all villages, towns, and cities, of which there are about 1,000 on the peninsula. This means creating about 1,000 military administrations, which is unrealistic given the current shortage of personnel.

This is why Ukraine should carry out a reform of local self-government at the community level in Crimea right away. This will involve, in particular, amending the procedure of voluntary unification of territorial communities for the creation of united territorial communities in the ARC and Sevastopol with a CMU order until full control over the territory is restored. A similar administrative divisions reform was already carried out at the level of raions in 2020 when new raions were formed in the ARC and Sevastopol by Ukrainian Parliament Resolution No. 807-IX dated July 17, 2020, which will enter into force after deoccupation.

Moreover, the Action Plan does not mention the need to develop a special procedure for expelling illegal migrants, which concerns the majority of Russian citizens living in Crimea, “How to decolonize Crimea. The procedure for expelling illegal migrants,” and “How to decolonize Crimea. The international legal aspect of restoring the demographic composition of the population.”

In conclusion, it is worth paying attention to another aspect, namely interdepartmental interaction in developing state policy regarding Crimea. According to the Mission of the President of Ukraine in the ARC, the Secretariat of the National Security and Defense Council of Ukraine has started collecting proposals from state agencies regarding amendments to the Strategy for the Deoccupation and Reintegration of Crimea. This brings the question whether it was appropriate to  change the Action Plan now, given that the Strategy itself is going to be changed in the near future, which will require the Action Plan to be updated once again.


Author: analyst UHHRU Vladyslav Miroshnychenko


USAID is the world’s premier international development agency and a catalytic actor driving development results. USAID’s work demonstrates American generosity, and promotes a path to recipient self-reliance and resilience, and advances U.S. national security and economic prosperity. USAID has partnered with Ukraine since 1992, providing more than $3 billion in assistance. USAID’s current strategic priorities include strengthening democracy and good governance, promoting economic development and energy security, improving health care systems, and mitigating the effects of the conflict in the east. 

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