In international relations, citizenship is often seen as a key symbol of belonging, representing identity, protection and political influence.
However, history shows that documents intended to empower can equally be used to restrict, exclude and erase. The experience of South Africa, especially the tragic legacy of the so-called “homelands” during apartheid, offers important lessons. At that time, administrative boundaries and artificial citizenship were employed not to promote self-determination, but to reinforce division and deny fundamental rights.
From Crimea annexation to full-scale invasion – using legal identity as a weapon
With the current situation in the temporarily occupied territories of Ukraine, as it faces the challenge of resisting unprovoked aggression and defending its sovereignty, echoes of the past resurface with unsettling clarity.
In March 2025, decree No 159, signed by Russian President Vladimir Putin, introduced a new legal measure as part of Russia’s ongoing effort to annex Ukraine’s temporarily occupied territories and erase Ukrainian national identity. The decree requires residents of these regions —who held Ukrainian citizenship – to either obtain Russian citizenship or leave the area by 10 September 2025. Although presented as a form of “legal regularisation”, the policy essentially issues an ultimatum: accept an imposed nationality or be expelled from their homes.
This model is not without precedent. After Russia’s attempted annexation and temporary occupation of Crimea in 2014, Russian authorities adopted a similar policy of forced naturalisation.
Residents were automatically granted Russian citizenship unless they formally refused within a short and poorly publicised period. Those who kept their Ukrainian citizenship faced systemic discrimination – being denied access to employment, healthcare, property rights and public services. Ukrainian documents were invalidated and residents were gradually pushed into legal and economic submission.
Since the start of the full-scale invasion, at least 44,500 Crimean residents have been conscripted into the Russian armed forces – a clear violation of International Humanitarian Law. Crimea has become a testing ground for tactics of legal erasure and forced assimilation, now being used in newly temporarily occupied Ukrainian territories.
These policies constitute serious violations of International Humanitarian and Human Rights law – including articles 31 and 49 of the Fourth Geneva Convention (1949), article 45 of the Hague Regulations (1907), the Rome Statute of the International Criminal Court (2002) and UN General Assembly Resolution A/RES/76/179 (2021).
By linking access to rights and residency with acceptance of imposed citizenship, the occupying power uses legal status as a weapon to enforce loyalty, suppress dissent and maintain de facto control. This is not integration. It is a form of coercive assimilation, carried out in defiance of international legal standards.
Bureaucracy as a tool for coercion and demographic engineering
The Kremlin’s tactic of redefining legal identity to consolidate control mirrors the logic of the Bantustan system.
Just as apartheid authorities used fabricated citizenship to exclude black South Africans from the political system, Russia aims to erase Ukrainian national identity by forcing civilians to adopt the identity of the occupying force. In both cases, administrative tools – such as passports, records and territorial boundaries – are used not to reflect the will of the people, but to manipulate consent, fragment societies, and suppress resistance. What may seem like bureaucratic procedures on the surface are, in fact, a form of political displacement meant to facilitate territorial annexation.
Moreover, this strategy bears the hallmarks of ethnic cleansing. By pressuring or forcibly removing Ukrainians who resist assimilation – those deemed “undesirable” – and massively replacing them with loyal Russian citizens relocated from other regions, the occupying power seeks to reshape the demographic composition of the temporarily occupied territories.
Through mass administrative deportations, the denial of essential services and aggressive passportisation campaigns, Russia is systematically attempting to erase Ukrainian identity from these regions and install a population more amenable to permanent annexation.
Today, millions of residents in the temporarily occupied regions of Donetsk, Luhansk, Zaporizhzhia and Kherson face a coercive dilemma with severe consequences on both sides. Those who refuse Russian citizenship are subjected to escalating discrimination, bureaucratic harassment and exclusion from basic services – and, under the March 2025 decree, risk being forcibly removed after September.
Meanwhile, those who accept the imposed citizenship may be “legally” conscripted into the armed forces of the occupying power – in direct violation of Article 51 of the Fourth Geneva Convention. The population is thus trapped between two types of coercion: displacement or militarisation, with no genuine choice and no effective remedy under the conditions of occupation.
The stakes for international order
The Kremlin’s approach did not emerge in a vacuum – it draws inspiration from past regimes, such as the apartheid-era government in South Africa, which entrenched its power by manipulating identity, excluding “undesirable” populations and dismantling the foundations of national belonging.
These policies were not merely bureaucratic or administrative; they were part of broader systems of domination that aimed to suppress resistance, erase culture and reengineer societies through coercion and fear.
Today, we are witnessing a disturbing revival of these tactics in the temporarily occupied territories of Ukraine. Under the pretext of “legal regularisation”, Russia is implementing a model of coercion – stripping people of their rightful citizenship, denying fundamental rights and enforcing an identity they did not choose. Such actions violate not only international legal norms, but also the very principles of human dignity and self-determination upon which the modern international order is founded.
The international community, especially nations that have experienced colonialism, occupation or systemic exclusion, cannot stay silent. A clear, coordinated, and principled response is necessary: one that upholds the legal doctrine of non-recognition of unlawful territorial changes, defends the inalienable rights of Ukrainian citizens and holds accountable those responsible for violations.
Russia’s actions in Ukraine are not only a grave breach of law – they are a warning.
If the forced erasure of identity, the weaponisation of citizenship and the demographic manipulation of occupied populations are allowed to proceed unchecked, they will set a dangerous precedent for the world legal order. Restoring a just peace for Ukraine is a test of the resilience, credibility and moral authority of the entire international rules-based system. DM