Prisoners and Convicts in Ukraine in 2025. Statistical Overview

1. In the places of detention of the penitentiary system of Ukraine that are controlled by the Ukrainian authorities—that is, excluding the facilities in Crimea and the occupied parts of other regions—according to data provided to the “Donetsk Memorial” by the Department for the Execution of Criminal Penalties of the Ministry of Justice of Ukraine, there were 34,925 persons held as of 01.01.2026 (letter from the Department No. 34/33-pi/5.4.3/14-26/3/1/24.1-26 dated 03.02.2026; hereinafter in parentheses—as of 01.01.2025—37,119 persons).

2. As of 01.01.2026, 86 institutions held convicts, persons in custody, and prisoners of war, with the latter being held in five camps for prisoners of war, just as they were a year ago. In the Annual Report of the Commissioner on the State of Observance and Protection of Human and Civil Rights and Freedoms in Ukraine in 2025 (hereinafter—the Commissioner’s Report), this data is presented in more detail:

“As of 31 December 2025, 24 pre-trial detention centres (remand prisons), 52 correctional colonies, 5 camps for holding prisoners of war, 4 correctional centres, and 1 educational colony are operating within the system of the Ministry of Justice of Ukraine, holding 34,925 persons.”

A year ago, there were also 86 operating penal institutions within the State Penitentiary Service, but excluding the five camps for prisoners of war—25 pre-trial detention centres (penal institutions), 56 correctional colonies, four correctional centres, and one educational colony.

3. The dynamics of the number of persons in penitentiary system institutions over the last seven years are shown in the following Table 1 (excluding persons held in camps for prisoners of war),

Table 1

4. It is currently impossible to realistically calculate the prison population rate per 100,000 population for Ukraine for several reasons. While the number of prisoners is known, the country’s population—especially since the beginning of Russia’s aggression—cannot be determined. It is unclear whether the millions of people who are currently forced to live outside the country should be included in the country’s actual population. Furthermore, the number of residents in the occupied territories is known only very approximately. Therefore, this year, as in previous years, it would be most fair to abandon the calculation of this indicator. In 2021, it stood at 117.

5. As of 01.01.2026, 12,624 persons (12,948 persons) were held in custody in pre-trial detention centres and penal institutions with remand functions, including 838 women (804 women). The number of minors in pre-trial detention centres was 102 (98). Thus, over the year, the number of all persons held in custody decreased by 324 (a year earlier, it decreased by 452), or by -2.50% (-3.37%).

6. In 2025, 11,147 persons were released from pre-trial detention centres and did not enter penal institutions (last year, 9,861 persons). Among the main reasons for which persons were released from pre-trial detention centres during 2025 were: in connection with a change in the preventive measure—8,304 persons (3,042); in connection with the expiry of the sentence (including parole)—506 persons (1,036 persons); in connection with the courts’ application of non-custodial sentences—866 persons (338 persons); in connection with the termination of cases by courts and acquittal verdicts—949 persons (8 persons).

On the other hand, it is not possible to obtain information regarding the number of persons released from pre-trial detention centres in connection with the termination of cases by investigation and inquiry bodies, as the collection and summarisation of such data is not provided for by the analytical information of the State Penitentiary Service of Ukraine.

Statistical data regarding the reasons for the release of persons from pre-trial detention centres in recent years are shown in Table 2.

Table 2

7. It is obvious that the named reasons do not exhaust the grounds for release from pre-trial detention centres. While in some previous years they accounted for 94% to 99.7% of all releases, in 2024 it was less than 45%. This jump is perhaps related to another very significant reason for release, which is mentioned in the State Penitentiary Service's response to the question about the grounds for release from pre-trial detention centres:

“The collection and summarisation of data on the number of persons released from pre-trial detention centres in connection with the termination of cases by investigation and inquiry bodies is not provided for by the analytical information of the State Penitentiary Service of Ukraine.”

8. The number of convicted persons decreased from 24,171 to 22,301 (during 2024, it decreased from 30,624 to 24,171), i.e., by 1,870 persons (last year by 6,453 persons), or by -7.74% (-21.07%).

9. There are 71 persons serving sentences in educational colonies for minors (50 persons), of whom 39 are under 18 years of age (22 persons). After many years of a constant decrease in the number of convicted minors, there was an increase in their number in 2025.

10. The number of convicted women serving sentences in penal institutions was 1,681 (1,417 women).

11. The number of life-sentenced persons as of 1 January 2026 was 1,573 (a year ago—1,579), including 30 women (30 women). Over the year, the number of life-sentenced prisoners decreased by 6 (last year—by 12). At the same time, 30 life-sentenced persons died in 2025.

12. Miracles are happening with the statistical data regarding persons released during 2025 from all institutions of the penitentiary system (colonies, correctional centres, pre-trial detention centres). Their number cannot be determined because the information provided by the State Penitentiary Service is too contradictory.

Logically, this number should consist of the number of convicted persons released from State Penitentiary Service institutions, including those released on parole, and persons released from pre-trial detention centres, among whom are also those released upon the expiry of their sentence and those released on parole. It is also worth adding to this number the persons who died during the year in the system’s institutions.

The State Penitentiary Service's response indicates that the number of persons released from penal institutions is 11,591. At the same time, 11,147 persons were released from pre-trial detention centres. Since it is obvious that the total number of persons released from the system’s institutions cannot consist almost entirely of persons released from pre-trial detention centres, then (for the State Penitentiary Service) these are different categories of facility residents.

If this is the case, then the total number of persons who left all State Penitentiary Service institutions in 2025 cannot exceed the total number of these two categories of persons, i.e., 11,591 + 11,147 = 22,738, to which it is logical to add the number of persons who died during the year in the institutions—306.

In total, this makes 23,044 persons. However, it is absolutely unclear how the number of new arrivals who entered penal institutions in 2025 can be 32,324.

13. A year ago, it was already noted that “such a large number of newly arrived persons can only be explained if persons transported from institution to institution are considered a new arrival every time and counted several times (cl. 13 of the 2024 Report).”

We note that when the “Donetsk Memorial” sent an information request to the State Penitentiary Service, it was emphasised:

“We draw special attention to the fact that we are requesting the number of persons who entered the service’s institutions during the year, excluding statistics on the transfer of persons from institution to institution, i.e., not the number of prisoners counted several times when transferred from one institution to another. Unfortunately, we have recently been constantly receiving completely different information to what we are asking for on this issue.”

Despite this, for several years in a row, the State Penitentiary Service has stubbornly provided such strange statistical data without in any way explaining their absurdity. It is noteworthy that 10–15 years ago, the State Penitentiary Service provided perfectly adequate and understandable information about the number of persons who left the system’s institutions during the year and who entered them during that time.

14. In 2025, 6,967 persons were released on parole (a year ago—9,236, eight years ago—9,244) out of a total number of 8,217 persons who formally qualified for parole (a year ago—11,474). This amounts to 84.78% (80.5%) of the number of persons who formally qualified for parole. It is worth paying attention to the specific dynamics of this indicator. Two years ago, it stood at 34.34%; seven years ago—37.8%; nine years ago—41.15%; eleven years ago—53.5%. It is unknown for what reasons this indicator suddenly reached 80.5% in 2024 and 84.78% in 2025.

15. A person can be released before the court-ordered deadline not only by obtaining parole, but also in the case of a pardon. The relevant statistics testify to the chance of being pardoned. According to information provided by the Department for Citizen Appeals of the Office of the President of Ukraine, during 2025, pardon petitions for 232 convicted persons were received by the Pardon Directorate of the Department for Citizenship, Pardons, and State Awards of the Office of the President of Ukraine (a year ago—227 convicted persons).

In 2025, the Commission on Pardons under the President of Ukraine held three meetings (the previous year—two), at which pardon petitions for 138 persons were submitted and considered (the previous year—105 persons). In 2025, the President of Ukraine issued two decrees pardoning 7 persons.

For comparison: in 2023–24, pardon acts were not issued at all; in 2022, four decrees were issued pardoning 363 persons.

16. An important element of the President of Ukraine’s activity on the issue of pardons is informing society about its results. Regarding the question of whether “briefings or press conferences were held with the participation of members of the Commission on Pardons under the President of Ukraine during 2025, at which the work of the President of Ukraine and the Commission in the field of pardons was presented”, as well as “whether the publication of materials about pardons in the media was initiated by the Pardon Directorate or members of the Commission on Pardons under the President of Ukraine in 2025”, the Department for Citizen Appeals of the Office of the President of Ukraine reported that “briefings and press conferences were not held by the Commission in 2025. Information regarding the publication of materials about pardons in the media is absent.”

It is worth noting that during 2021–24, no press conferences or briefings regarding pardon issues were held, nor were press releases issued. No publications on pardon issues in the media were initiated during these years. Meanwhile, in 2015–2018, briefings on the results of activities in the field of convict pardons were usually held every six months.

In 2016–18, a significant number of persons were pardoned, who were then involved in prisoner exchange procedures with the Russian Federation. When asked about the number of persons pardoned in 2025 in connection with prisoner exchange agreements, it was stated that the Pardon Directorate is not the administrator of information related to prisoner exchanges (letter No. 22/1-09/455 dated 04.02.2026).

17. With the start of Russia’s full-scale invasion, a new category of detained persons appeared in State Penitentiary Service institutions—prisoners of war. They are held in separate special camps, the results of visits to which by NPM (National Preventive Mechanism) groups are reported in the Commissioner’s Report:

“Throughout the year, visits were conducted to all camps for holding prisoners of war, as well as to some detention sections for prisoners of war present in penal institutions. During the visits, representatives of NPM groups were provided with unhindered access to places of detention and the opportunity to conduct confidential communication with prisoners of war. It was established that all detained persons have the status of prisoners of war in accordance with Article 4 of the Geneva Convention relative to the Treatment of Prisoners of War of 12 August 1949.

During confidential conversations with prisoners of war, as a rule, there were no complaints of ill-treatment. Most of those interviewed noted that the general atmosphere in the camps is stable and acceptable, the camp staff maintain a correct, polite, and balanced attitude, and do not apply physical or psychological pressure. In general, proper living and sanitary-hygienic conditions have been created in the camps; no cases of overcrowding or shortages of clothing, footwear, or bed linen have been recorded. Prisoners of war are provided with access to food of proper quality, medical care, the possibility of correspondence, receiving parcels, satisfying religious needs, physical exercise, and leisure.”

18. The number of able-bodied persons in penal institutions as of 01.01.2026 was 15,275 (a year ago—20,776), or 68.49% of the number of all convicted persons (a year ago 85.95%), of whom 8,562 persons were provided with work (a year ago—8,620). This accounts for 56.05% of the number of able-bodied persons (as of 01.01.2025—41.49%) and 38.39% of the total number of convicts (a year ago—35.66%).

In 2025, the average monthly salary of working convicts was 5,033 UAH; a year ago—3,503.02 UAH. In 2022, it was 2,306.50 UAH per month.

19. Regarding the violation of the rights of prisoners and convicts to work, the Commissioner’s Report states:

“During visits to penitentiary institutions by NPM groups, it was once again recorded that the problem of observing the labour rights of convicts and prisoners remains unresolved and is of a systemic nature. Involvement in production work continues, in the vast majority of cases, to be carried out without proper documentation; the duration of working hours continues to systematically exceed the norms established by legislation; the payment of remuneration for work often does not correspond to the actual volumes performed; and working conditions remain non-compliant with occupational health and safety requirements.”

20. A certain indicator of the complexity of problems in the medical sphere and the provision of medical services is the level of morbidity, mortality, and the number of suicide cases in the department’s institutions.

According to data from the Health Protection Centre of the State Penitentiary Service of Ukraine, during 2025, 306 persons (368 persons) died in penal institutions of the State Penitentiary Service of Ukraine in territories controlled by the Government of Ukraine, including 30 persons sentenced to life imprisonment. Out of the total number of deceased, 131 persons (129 persons) died in pre-trial detention centres and penal institutions. The number of suicide cases while persons were in all deprivation-of-liberty institutions in 2025 was 25 (37), of which 7 cases (15 cases) occurred in pre-trial detention centres and penal institutions (letter No. 198-TSA-26 dated 03.02.2026). At the same time, the State Penitentiary Service reported 27 suicide cases in the service’s institutions in 2025, of which 9 were in pre-trial detention centres.

The mortality rate of prisoners in 2025 decreased slightly—from 9.91 cases per one thousand prisoners to 8.76 (two years ago it was 8.47). The suicide rate decreased from 1.00 to 0.72 cases per one thousand prisoners. In contrast, the suicide rate in 2022 was 0.49.

The number of prisoners with tuberculosis at the end of 2025 in State Penitentiary Service institutions of Ukraine in territories controlled by the Ukrainian government was 378 (415 persons), including 74 persons (129 persons) in pre-trial detention centres and penal institutions. Calculated per 1,000 prisoners, the number of such patients decreased slightly in 2025—from 11.18 to 10.82, which is significantly lower than the “pre-war” 2021 indicator of 16.60.

The number of people living with HIV who are registered with the health facilities of the Health Protection Centre of the State Penitentiary Service of Ukraine in territories controlled by the Ukrainian government as of 01.01.2026 was 2,835 persons (3,150 persons), of whom 676 persons (1,096 persons) were in pre-trial detention centres and penal institutions. The rate of patients per 1,000 prisoners decreased slightly from 84.86 to 81.17.

The dynamics of these indicators in recent years are shown in Table 3

Table 3

Morbidity and mortality in Department institutions in 2003, 2012, and in 2021–2025

21. Certain statistical data regarding medical problems are presented in the Commissioner’s Report:

“In 2025, an increase was recorded in the number of persons who were in State Penitentiary Service institutions with suspected hepatitis C—from 4,249 in 2024 to 6,577 in 2025, as well as an increase in the number of persons with a confirmed diagnosis of hepatitis C by the polymerase chain reaction method (from 1,194 to 1,340 persons, respectively). Despite this, the number of patients receiving antiviral treatment for HCV in 2025 decreased significantly—from 1,850 persons in 2024 to 758 persons, which indicates limited access to treatment and the risks of therapy interruption.”

22. The proper recording of bodily injuries of prisoners remains a problem. The violation of recording requirements is mentioned in the Commissioner’s Report:

“The entries in the registration logs (of injuries) lack information about notifying the prosecutor and law enforcement agencies, and the form of primary accounting documentation is not attached by medical staff to information about bodily injuries. The NPM group recorded cases where photographic materials are not attached to certificates of bodily injury registration, which is a violation of established requirements and reduces both the effectiveness of documenting possible facts of violence and the effectiveness of investigating each case.

The lack of properly documented bodily injuries does not comply with paragraph 60 of the CPT recommendations (CPT/Inf(93)12-part), according to which medical services in places of detention must systematically register bodily injuries and, if necessary, inform the competent authorities.”

23. NPM groups visited 13 medical facilities of the Health Protection Centre of the State Penitentiary Service of Ukraine. Based on the results of these visits, the Commissioner evaluated the situation with the provision of medical care to convicts and persons in custody as follows: “NPM recommendations remain unfulfilled, which leads to the persistence of systemic violations of patients' rights in medical units and hospitals at penitentiary institutions. Thus, during 2025, there was a decrease in the number of hospitalisations from State Penitentiary Service institutions to the inpatient wards of medical units and hospitals of the Health Protection Centre of the State Penitentiary Service of Ukraine from 9,527 persons in 2024 to 6,754 persons in 2025, as well as a slight decrease in the number of hospitalisations to public or private healthcare facilities (from 1,047 to 921 persons, respectively). The trend towards a significant increase in hospitalisations to psychiatric care facilities due to the exacerbation of symptoms of mental disorders—from 162 cases in 2024 to 315 in 2025—is alarming, which indicates a deterioration in the mental state of persons in conditions of deprivation of liberty and the insufficiency of preventive and rehabilitation measures.”

It is noteworthy that in this matter, the Report provides numerical indicators. Thus, both the scale of the phenomenon and the trends are quite concrete and measurable.

24. As of 1 January 2025, 1,213 persons with disabilities were being held in penal institutions of the State Penitentiary Service of Ukraine (a year earlier—1,069 persons). The Health Protection Centre does not report how many of them are specifically in pre-trial detention centres and penal institutions. Instead, it notes that there are 43 persons with Group I disabilities (37 persons), 263 persons with Group II disabilities (315 persons), and 720 persons with Group III disabilities (861 persons).

25. According to the Probation Centre, as of 01.01.2026, 61,671 persons sentenced to non-custodial sentences and released from serving a sentence with probation were registered with authorised probation bodies (a year earlier—63,336 persons), of whom 423 were minors (a year earlier—309 persons) (letter No. 17/19-ZPI/1/KV-26 dated 04.02.2026).

It is worth noting that the number of minors registered with authorised probation bodies grew by almost 37% over the year, whereas the total number of persons on the register decreased over the year.

As noted above (cl. 9 of this review), there is a similar situation with the number of convicted minors.

26. There are also prisoners in some other departments.

As of 01.01.2026, the territorial bodies of the National Police have 91 temporary detention facilities (a year ago—95, two years ago—117, three years ago—125). The operation of 19 temporary detention facilities is temporarily suspended (National Police letter No. 15065-2026 dated 03.02.2026).

For comparison: according to the Human Rights Commissioner, in 2024, “out of all temporary detention facilities, 68 are functioning, and the operation of the other 27 is temporarily suspended due to reconstruction or repair, hostilities, partial destruction.”

In addition, the Commissioner’s Report states that the National Police of Ukraine also has “571 detention rooms in police bodies and units, where 2,419 persons were held; 406 specialised vehicles for transporting detainees and persons in custody; 1 reception-distributor for children. In 2025, NPM groups visited 125 places of detention subordinate to the National Police of Ukraine, of which: 93—territorial police units, 29—temporary detention facilities, and 3 specialised vehicles.”

The total capacity of temporary detention facilities is 1,873 places (2.2 thousand places). As of 1 January 2026, 32 persons were held in them (94 persons). In total, during 2025, 32.5 thousand persons (32.3 thousand persons) were held in temporary detention facilities.

During 2025, while being held in temporary detention facilities, two persons died as a result of acute heart failure, and one person committed suicide by hanging while being held in a detention room of a territorial police unit.

27. The Commissioner’s Report provides a list of the main problems regarding the observance of the rights of persons who were in places of detention of the National Police:

“Despite the systematic submission of response acts by the Commissioner during 2024–2025 and the provision of detailed recommendations in annual and special reports, the leadership of the National Police does not take effective measures for their implementation. Instead of ensuring an independent investigation into the facts of the use of physical force, a subjective departmental assessment of subordinates' actions has been practised in certain police units for years. Such a practice of substituting procedural actions with internal official inspections directly contradicts the requirements of the Criminal Procedure Code of Ukraine, negates the principle of objectivity, and indicates a failure to fulfil Ukraine’s positive obligations regarding the investigation of all facts of alleged torture in compliance with the criteria for investigation effectiveness. Specifically, in 2025, it was confirmed again that the heads of certain territorial police units on the ground deliberately avoid informing the State Bureau of Investigation and do not register the relevant information in the Unified Register of Pre-trial Investigations, trying to conceal crimes through formal official inspections. Such a circle of mutual protection and ignoring of long-standing remarks by the Commissioner only stimulate impunity.”

The above findings are important and serious; however, the Report does not contain any numerical indicators of the violations detected by NPM groups, so it is impossible to assess either the scale of these violations or the trends in their changing numbers.

Particular attention during the visits of NPM groups was paid to a new specific aspect of detaining persons in temporary detention facilities:

“As a result of NPM monitoring visits, systemic problems were identified regarding the provision of the right to life of persons held in temporary detention facilities under the conditions of the armed aggression of the Russian Federation against Ukraine. The vast majority of visited temporary detention facilities do not have shelters for detained persons and staff due to the absence of built-in civil defence structures (bunkers, shelters).

In temporary detention facilities where there are no basic shelters, staff who are not involved in the daily duty shift, when an ‘Air Raid Alert’ signal is announced, can use the protective structures located in the territorial police units. At the same time, detained persons remain in camera premises, and the temporary detention facility staff who are on the daily duty shift are forced to remain at their workplaces without access to protective structures. The removal of detained persons from camera premises during the announcement of an ‘Air Raid Alert’ signal is not carried out due to an insufficient number of temporary detention facility staff required to ensure their safe accompaniment (escort) to the shelter, the absence of clear algorithms of action in such cases, and the absence of specially equipped places for detained persons to stay in shelters located in territorial police units.

In view of the detected violations and the recommendations of the European Committee, the Commissioner sent a submission (No. 21055.2/25/39.1 dated 12.12.2025) to the Ministry of Internal Affairs of Ukraine to eliminate systemic shortcomings in the regulatory framework and practical activities of temporary detention facilities, as well as to prevent the onset of severe consequences of war threats.”

28. The Security Service of Ukraine (SBU) operates one temporary detention facility in Kyiv—for holding persons suspected of preparing or conducting intelligence-subversive or terrorist activities, and committing other crimes, the investigation of which is under the competence of SBU bodies. The capacity of the facility is 48 persons. As of 01.01.2026, 12 persons were held in it, and in total, 124 persons were held during 2025 (during 2024—207 persons). There were no cases of death of detained persons in SBU temporary detention facilities in 2025 (letter from the SBU No. 23/71 dated 04.02.2026).

29. This year, no request was sent to the Ministry of Defence of Ukraine regarding the number of persons who were in the disciplinary battalion and guardhouses, based on the position of the department expressed two years ago. It is that during martial law, “exclusively in the interests of national security, the requested information cannot be provided at this time.”

At the same time, the Commissioner’s Report for 2024 reports that, in total, 39 rooms for temporarily detained military personnel, 12 guardhouses, and three disciplinary battalions operate in places of detention of the Ministry of Defence of Ukraine system, in which 14,521 persons were held during 2024.

30. Children who committed criminal offences under the age of 14 are sent to schools and vocational schools of social rehabilitation. These institutions, of which there were four until recently, are under the subordination of the Ministry of Education and Science of Ukraine.

As of 01 January 2026, there is one vocational education institution under the subordination of the Ministry of Education and Science of Ukraine—the Central Ukrainian Vocational School of Social Rehabilitation, in which three persons (boys) are studying (letter No. 5/577-26 dated 26.01.2026).

31. The level of compliance with the rule of law during the detention of prisoners is indicated by the number of violations by facility staff. The true number of such cases cannot be estimated, but the statistical data obtained from the Office of the Prosecutor General provide some idea of the scale of the phenomenon.

The Office of the Prosecutor General provided statistical information on the number of illegally detained persons released on the prosecutor’s initiative, the number of prosecutor’s response documents considered, the number of persons held to disciplinary, administrative, or material account, as well as acts cancelled or brought into compliance, and the number of entries made into the Unified Register of Pre-trial Investigations for the period of 2025 (in parentheses—for 2024), which are shown in Table 4.

Table 4

* including not only penitentiary institutions, but also psychiatric hospitals, military units, and some others.

At the same time, the reporting of the Prosecutor’s Office bodies of Ukraine does not provide for the accounting of statistical data specifically on the number of employees of penal institutions held to account.

In connection with the above, the requested information in this part was not provided by the Office of the Prosecutor General (letter No. 30/3-123vych-26 dated 04.02.2026).

32. A significant element of detecting torture and ill-treatment is the collection of information about such cases, and primarily it is provided by the persons who suffer from such treatment. They do this, in particular, by sending complaints. Therefore, important indicators of the level of torture and ill-treatment are the number of complaints received regarding such human rights violations. Important indicators are also the number of complaints recognised as well-founded and the number of upheld complaints.

Regarding the request about prisoners’ complaints, the Ministry of Justice of Ukraine reported that “according to data from the ‘ASKOD’ electronic document management system in the Ministry of Justice of Ukraine for 2025, 315 (276) complaints from convicts were registered. It is not possible to provide more detailed information about the number of upheld complaints or those recognised as well-founded in connection with the absence of appropriate document search parameters in the ‘ASKOD’ electronic document management system” (Ministry of Justice letter No. 16279/PI-YUR-503/27 dated 05.02.2026).

It is worth emphasising that a year earlier, regarding a similar question about the number of complaints received from prisoners, the Ministry of Justice reported:

“the search for documents for the specified period was carried out using the search parameters ‘social status’ ‘person deprived of liberty; person whose liberty is restricted’, therefore the obtained value may not be final.

Additionally, we note that it is not possible to provide more detailed information about the number of upheld complaints or those recognised as well-founded in connection with the absence of appropriate document search parameters in the ‘ASKOD’ electronic document management system of the Ministry of Justice of Ukraine. The accounting of incoming correspondence of the Ministry of Justice of Ukraine is not kept in terms of the requested information.” (Ministry of Justice letter No. 14085/PI-YUR-267/7 dated 30.01.2025) (cl. 25 of the 2024 Report)

The same explanations were provided by the Ministry of Justice regarding the accounting of complaints from prisoners in 2025 as well.

Thus, by these remarks, the department admits that the complaint accounting system does not provide for analytical work with them, the recording of the number of upheld complaints or those recognised as well-founded, including complaints about the use of torture and ill-treatment. But without such accounting, it is impossible to analyse the causes, prerequisites, and circumstances that cause complaints; it is impossible to fight the causes that generate them, including ill-treatment.

The issue of holding accountable the persons whose actions cause a complaint also remains outside the Ministry of Justice’s attention, which contributes to the impunity of human rights violators. So it turns out that all the department does with complaints is simply count them.

Perhaps that is why the Commissioner’s conclusions seem perfectly logical: “the systematic recording by NPM groups of human rights violations in reports based on the results of visits to penitentiary institutions confirms the persistence of the systemic nature of such violations and the lack of proper management reaction on the part of the Ministry of Justice of Ukraine.”

33. One of the few institutions in the country that has the authority to verify compliance with human rights by state bodies and to promote the ensuring of human rights is the Ukrainian Parliament Commissioner for Human Rights (hereinafter—the Commissioner). Since 1 July 2022, this is Dmytro Valeriiovych Lubinets. The role of the Commissioner is especially significant for prisoners, because the law obliges the administrations of penal institutions to unhinderedly send prisoners’ complaints to the Ombudsman. Moreover, in accordance with Article 19-1 of the Law of Ukraine “On the Ukrainian Parliament Commissioner for Human Rights”, the Commissioner is entrusted with the functions of the National Preventive Mechanism (hereinafter—NPM) in accordance with the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment.

“Donetsk Memorial” sent information requests to the Commissioner asking for information on certain results of activity in 2025. The responses from the Commissioner’s Secretariat contained only part of the requested information. A significant amount of information had to be taken from other sources, often—from the Commissioner’s annual Report. It is worth emphasising that this Report often lacks many important, concrete details, instead of which general expressions figure, which do not allow for an adequate idea of the true scale and prevalence of certain violations, problems, and shortcomings, as well as the steps taken by the Commissioner to restore violated human rights and the effectiveness of these steps.

34. As reported by the Commissioner’s Secretariat, to perform NPM functions in 2025, NPM groups together with representatives of non-governmental organisations conducted 626 visits to places of detention (in 2024—543). Which part of these places belongs to the penitentiary system (to the sphere of management of the Ministry of Justice of Ukraine), the Secretariat did not report.

At the same time, the 2025 Report provides a breakdown of visited institutions by management sphere: “67 visits were made to places of detention of the Ministry of Justice of Ukraine (the previous year—64); Ministry of Education and Science of Ukraine—10 (13); National Police of Ukraine—125 (129); Ministry of Defence of Ukraine—13 (11); Security Service of Ukraine—2 (2).”

It is worth noting that in the terminology adopted in the State Penitentiary Service, institutions where both persons in custody are held (i.e., the institution performs the functions of a pre-trial detention centre) and convicted persons serving sentences (i.e., the functions of a correctional colony are performed) are referred to as penal institutions. Usually, penal institutions are facilities that were previously pre-trial detention centres, and now have also been added the functions of a correctional colony. Unlike penal institutions, only convicted persons are held in correctional colonies. That is why the assertion in the Report that “during 2025, NPM groups visited 45 pre-trial detention centres and penal institutions” seems unclear, while there are only 24 pre-trial detention centres and penal institutions in total in the system. And it is obvious that the Report is talking not about 45 visits to 24 pre-trial detention centres and penal institutions, but precisely about 45 institutions. Information is missing in the Report about how many of the 67 visits to places of detention under the management of the Ministry of Justice were carried out specifically to correctional colonies, as well as, possibly, to correctional centres and the educational colony.

Meanwhile, the 2024 Report provides such information and separately states the number of visited pre-trial detention centres, correctional colonies, and camps for holding prisoners of war (cl. 26 of the 2024 Report). Unfortunately, the Commissioner’s 2025 Report contains some other examples of a lack of thoroughness in providing information.

35. The Commissioner’s Report declares that “cooperation with civil society is an integral part of the NPM’s activity.” Regarding the number of representatives of non-governmental organisations involved in monitoring visits, who must receive appropriate instructions from the Commissioner to participate in the visits, the Secretariat reported that during 2025, the Commissioner issued 156 written authorisations regarding the participation of representatives of non-governmental organisations in visits to places of detention (183 authorisations in the previous 2024). The recipients of these 156 authorisations were allegedly participating in all 626 visits throughout the year, and therefore also in all 67 visits to institutions under the Ministry of Justice’s management.

But regarding this information, there is a certain ambiguity.

Thus, the Report states that 626 monitoring visits (field and non-field) were carried out during the year.

As far as is known, during non-field visits, monitoring is carried out remotely, without a physical trip to the facility being checked. Instead, it is unclear why a representative of a non-governmental organisation needs permission from the Commissioner to visit institutions during a non-field visit? In general, do representatives of non-governmental organisations participate in such visits? What is their role? These questions remain unanswered.

The Report states that four specialists (experts) were involved in the visits. Although in the response to the “Donetsk Memorial’s” request, the Secretariat reported the involvement of only two specialists during the year. In how many visits the involved experts participated and to which institutions is not reported.

36. In the “Donetsk Memorial’s” request to the Commissioner, there was a request to “report the number of proposals submitted in 2025 to state authorities... (importantly—not any, but specifically) regarding the prevention of torture and other cruel, inhuman or degrading treatment or punishment.” No response to this question was provided by the Secretariat.

In the response to the request, the Secretariat reported that during 2025, the Commissioner submitted 62 (70) representations to state authorities, other bodies, and organisations, and their officials regarding the elimination of detected human rights violations in places of detention. It is unknown how many of these representations concerned penitentiary service institutions, and whether there were specifically instances of torture among the recorded human rights violations in places of detention.

At the same time, the Report notes that “based on the results of visits in 2025, NPM groups did not record cases of torture in penal institutions and pre-trial detention centres. During confidential conversations with convicts and prisoners, no reports of the use of physical violence by staff were received.” The statement formulated in the Report thus allows one to assume that in correctional colonies, cases of torture or ill-treatment could have been detected. Especially since the Report later states:

“systemic violations of human and civil rights and freedoms were detected in places of detention, in particular the right to protection from torture, cruel or degrading treatment or punishment.”

37. A characteristic example of the state’s real attitude towards improving the conditions of prisoner detention and the effectiveness of its efforts (as, in particular, in countering torture and ill-treatment) is the following finding of the Commissioner:

“In 2025, the Commissioner received 295 reports regarding inappropriate conditions of detention in places of deprivation of liberty of the Ministry of Justice of Ukraine, as a result of the response to which, the prosecutor’s offices issued mandatory instructions.

The leadership of the Ministry of Justice of Ukraine did not take the necessary measures to bring the living space standards in cells into compliance with national and European standards. In accordance with Part 2 of Article 11 of the Law of Ukraine ‘On Pre-trial Detention’, the space standard in a cell for one person taken into custody cannot be less than 2.5 m². At the same time, starting from the first visit to Ukraine in 1998, the CPT has recommended increasing the standard of living space per person taken into custody to 4 m². This recommendation is repeated in subsequent reports in 2000, 2005, 2009, 2013, 2017 and 2023.”

It seems that the Commissioner does not believe that such a long (over 20 years!!!) non-compliance with the recommendations of both national and international institutions also involves the responsibility of the Commissioner as an institution, namely the inability and, to some extent, the unwillingness to take decisive, real, and effective measures to resolve these complex problems in the observance of human rights.

38. The Report contains an assessment of the situation with human rights violations in the penitentiary system institutions.

“The results of visits by NPM groups to places of detention under the management of the Ministry of Justice of Ukraine in 2025 indicate “the actual inaction of the Ministry of Justice of Ukraine regarding the elimination of systemic human rights violations in institutions subordinate to the Department for the Execution of Criminal Penalties. Despite numerous response acts by the Commissioner and repeated recommendations from international organisations, throughout 2025, the Ministry of Justice of Ukraine did not ensure any tangible changes in the sphere of observing the rights of prisoners and convicts. Systemic problems remain unresolved, which indicates the lack of proper institutional reaction and effective management decisions on the part of the responsible body. Systematic recording by NPM groups of human rights violations in reports based on the results of visits to penitentiary institutions, published on the official website of the Commissioner, confirms the persistence of the systemic nature of such violations and the lack of proper management reaction from the Ministry of Justice of Ukraine.”

The above assessment in the Report of the situation with violations and the agency’s response to them is rather an impression of the authors of the Report, and not facts, because the results of the visits indicate such a state only for the Commissioner, but not for the readers of the Report, precisely because of the absence of numerical indicators of human rights violations. Without them, an objective assessment of possible changes—be it an improvement or a deterioration of the situation—is impossible.

39. It is even more difficult to imagine the real state of affairs in these matters if one compares the Commissioner’s presented conclusions with the Ministry of Justice’s vision of the situation regarding human rights violations in penitentiary institutions. The agency is implementing the Strategy for Reforming the Penitentiary System for the period up to 2026. The Ministry of Justice’s Report on the implementation of the Strategy in 2024 (see cl. 47 of the 2024 Report) states:

“47. The authors of the Report highly evaluate the progress achieved and consider it significant, in particular, emphasising that

● conditions of detention of convicts and persons taken into custody have been improved—in compliance with international standards in penal institutions;

● the fight against torture and ill-treatment has been strengthened—a part of the recommendations of international organisations regarding the observance of human rights in penal institutions has been fulfilled;

The operational plan has been implemented by 75%, and 81% of the values of the indicators of expected results of the Strategy’s implementation have been achieved. Such results are a solid foundation for further steps in 2025–2026.”

It is very significant that the Ministry of Justice’s Report on the implementation of the Strategy does not clearly define the mechanism for measuring the effectiveness of its measures.

This Report does not provide quantitative indicators of torture cases. The Strategy lacks important parameters for measuring the effectiveness of measures, in particular, information about how many persons who committed torture and ill-treatment were held accountable (cl. 42 of the 2023 Report).

40. Recommendations and proposals regarding the elimination of detected human rights violations, provided as a result of NPM monitoring visits, are usually contained in visit reports and in submissions, but their number is not counted by the Secretariat, limiting itself in the Report to a list only:

“To state authorities, enterprises, institutions, and organisations regardless of the form of ownership, the Commissioner submits:

proposals regarding the prevention of torture and other cruel, inhuman or degrading treatment or punishment;

letters on initiating disciplinary proceedings, proceedings on administrative offence cases,

notifications of criminal offences;

submissions regarding the elimination of detected violations of human and civil rights and freedoms.”

In this aspect of the Commissioner’s activity, unfortunately, there are also no indicators that would allow one to assess the appropriateness of certain recommendations, as well as their effectiveness. What part of them concerns specifically penitentiary institutions, the Secretariat traditionally does not report, usually referring to the fact that such a separation of recommendations regarding institutions of separate agencies is not provided for by statistical reporting.

41. It is very important that the Report often does not contain any signs that any measures of accountability have been applied to human rights violators to whom the Commissioner’s recommendations were sent and who did not implement them. Such measures do not necessarily have to be applied by the Commissioner, but he could initiate them.

It seems that such a feedback mechanism of control is absent from the Commissioner, and the Secretariat staff are also convinced that they are not obliged to control (verify) the implementation of their recommendations in any way.

In fact, the procedure prescribed by law for the Commissioner to control the observance of human rights is transformed into the appearance of control. It is unknown whether such parliamentary control satisfies People’s Deputies.

However, the Commissioner’s remark regarding these human rights violations in a broader context is important:

“It should be noted that within the framework of European integration processes, the state continues to implement roadmaps in the areas of the rule of law, public administration reform, and the functioning of democratic institutions, which are prerequisites for membership negotiations. Chapter 23 “Judiciary and Fundamental Rights” of the European Commission’s report on Ukraine for 2025 provides for the implementation of an effective system for preventing and countering torture and ill-treatment, improving conditions of detention in pre-trial detention centres and penal institutions, and fulfilling CPT recommendations. Failure to implement these measures will create risks for Ukraine’s fastest possible accession to the EU.”

42. Monitoring of the state of observance of human rights in places of detention is carried out by the Commissioner not only within the framework of fulfilling the functions of the national preventive mechanism, but also through the analysis and processing of appeals from persons deprived of liberty, as well as appeals filed in their interests. Based on the results of work with appeals, the Commissioner detects human rights violations and makes appropriate response acts aimed at restoring the rights of persons held in places of detention.

Based on the results of such measures, not only are violations of fundamental guarantees of protection against torture and ill-treatment detected, but also individual facts that contain signs of criminal offences.

The total number of appeals (applications and complaints) received by the Commissioner in 2025 about human rights violations is 995.

Number of opened proceedings is 28.

Number of rights restored based on appeals (individual and collective) is 81.

Number of response acts of the Commissioner is 7.

Number of criminal proceedings initiated as a result of checks initiated by the Commissioner is 7.

Number of instructions issued by prosecutor’s offices regarding the elimination of human rights violations in places of detention as a result of checks initiated by the Commissioner is 64.

For comparison—the Commissioner received 4,286 reports of violated rights during 2024, opened 29 proceedings, completed 25 proceedings, sent 1,713 requests and initiative letters, and 11 response acts of the Commissioner (see cl. 29 of the 2024 Report). Attention is drawn to the fact that if the number of opened proceedings and the Commissioner’s response acts do not differ significantly, the total number of appeals became more than four times smaller, and such an indicator as the number of sent requests and initiative letters in the 2025 Report is for some reason completely absent.

According to the Commissioner’s report, law enforcement agencies entered information into the Unified Register of Pre-trial Investigations and initiated 10 criminal proceedings.

43. Regarding the violation of the right of access to public information, in the response to the “Donetsk Memorial’s” request, the Secretariat reported that in 2025, 5,438 appeals with reports of violations of this right were received by the Commissioner (in 2024—4,717, in 2023—3,957). During 2025, representatives of the Commissioner and authorised persons of the Secretariat drew up 12 protocols on administrative offences under Article 212-3 of the Code of Ukraine on Administrative Offences regarding the violation of the right of access to public information (letter No. 01.36/251.14/259.13/26/ZI dated 04.02.2026). This amounts to 0.22% of the total number of appeals about violations of the right to information (0.66% in 2024, 1.11% in 2023, 1.52% in 2022).

We must note that the indicated information about the number of received appeals differs noticeably from the data presented in the annual Report, where it is reported that “the Commissioner received 6,574 appeals regarding violations of the right of access to public information”.

It is worth noting that with such a number of received appeals, the percentage of appeals for which protocols on administrative offences were drawn up amounts to only 0.18% in total. It is obvious that in the remaining cases of violation of the right of access to public information, i.e., in 99.82% of cases, the matter did not reach the stage where the Commissioner’s representatives drew up protocols on administrative offences, and therefore, did not reach the point of holding law violators at least administratively accountable.

44. It should also be noted that it is not known what decisions were made by the courts regarding the 12 protocols drawn up. For example, the 2024 Report states that out of 31 protocols drawn up that year, only in 10 cases did courts make decisions to impose an administrative penalty in the form of a fine on the guilty officials (see cl. 30 of the 2024 Report). In 2023, following the consideration of drawn-up protocols, 7 resolutions were issued on imposing penalties in the form of a fine on officials (see cl. 31 of the 2023 Report).

However, such data for 2025 are not reported. Meanwhile, the “Donetsk Memorial’s” request contained a clear request to report the number of persons held accountable for violating the right of access to public information during 2025. As the data for 2024 show, their number can differ several times from the number of protocols drawn up during the year.

The Secretariat answered the “Donetsk Memorial’s” request as follows:

“Regarding the provision of information about the number of persons held accountable, we note that in accordance with Clause 1 of Part One of Article 22 of the Law of Ukraine “On Access to Public Information” (hereinafter—the Law), an information administrator has the right to refuse to satisfy a request in the event that the information administrator does not possess and is not obliged, in accordance with their competence provided for by legislation, to possess the information requested.

In view of the above, we inform you that such information is not separately created and systematised by the Commissioner’s Secretariat, and therefore the Commissioner’s Secretariat does not possess and is not obliged, in accordance with its competence, to possess the information requested.” Thus, the actual holding to account of law violators does not seem to interest the Commissioner at all. It is telling that in previous years, such information was available in the Secretariat (“was separately created and systematised”). So it is very likely that out of 5,438 cases of probable violations of the right of access to information (or perhaps out of 6,574 cases), practically almost none of the violators (mainly thanks to the Commissioner’s position) were punished.

The reasons for suddenly not creating and not systematising it in 2025 are unknown. Taking into account that the violators of the right of access to public information are employees of state bodies, i.e., officials, the Commissioner actually acts as their defender, saving them from responsibility for violating the law. But it is common knowledge that the lack of responsibility for violations only contributes to new violations.

45. The “Donetsk Memorial’s” request also contained a request to report the number of response acts sent by the Commissioner, in particular, submissions sent to state authorities regarding violations of the laws of Ukraine “On Access to Public Information” and “On Citizens’ Appeals”. The Secretariat refused to satisfy this request as well, i.e., to provide the requested information, providing the following response:

“Based on the results of the analysis of the content of this part of your information request, and the criteria of the requested information stated therein, we inform you that the collection of the requested information to satisfy it requires the Commissioner’s Secretariat to conduct an additional meaningful analysis of an undefined number of the Commissioner’s response acts (in particular, submissions). The aforementioned does not make it possible to perform a reasonable search for information according to the criteria specified in the request; collecting and providing it requires significant intellectual efforts from the Commissioner’s Secretariat and, therefore, is not public information within the meaning of the Law. In view of the above, we ask you to clarify the period for which the information needs to be provided.”

Obviously, this is a virtuoso form of refusal to provide information, in fact—a violation of the right of access to information by the Secretariat. A year earlier, to the exact same request, the Secretariat did not refuse, but reported that during 2024, 2 submissions (in 2023—6) were made by the Commissioner regarding violations of the laws of Ukraine “On Access to Public Information” and “On Citizens’ Appeals”. However, in 2025, the Secretariat’s position evolved somewhat.

46. The provided examples of the Secretariat’s refusal to provide specific information about the effectiveness of the Commissioner’s activity in the sphere of access to information indicate that in 2025, the peculiarity of the Commissioner’s reporting is the avoidance of specifics. Thus, for example, regarding the content of official websites of state authorities with information, the Report states:

“2025 witnessed a slight improvement in the content of official websites of state authorities and local self-government bodies with information, the obligation to publish which is defined by the Law of Ukraine “On Access to Public Information”, the Law of Ukraine “On Local Self-Government”,”

It is unknown how the “improvement” was determined and why it is considered “slight”.

The description of the Commissioner’s activity in responding to violations is marked by the same meaninglessness:

“During 2025, the Commissioner opened proceedings within the framework of which letters were sent to administrators and submissions were made regarding strict adherence to the requirements of the Law of Ukraine “On Access to Public Information” when restricting access to public information in order to restore the violated right to information.”

The actual number of letters and submissions remains secret, as does the number of positive reactions to them.

Thus, in 2025, the Secretariat demonstrates ingenuity in the motives for refusing to provide information about violations of the right of access to information. Therefore, one cannot disagree with such a statement presented in the Report:

“Such violations negatively affect the functioning of the public administration system and the level of citizens’ trust in authorities.” . It would not be an exaggeration to add: including trust in the Commissioner for Human Rights.

* * *

The authors of this Statistical Overview are grateful to the agencies that provided information to the “Donetsk Memorial’s” requests regarding persons deprived of liberty who are in the agency’s institutions, or to whom the agency has a connection. We are grateful to the Department for the Execution of Criminal Penalties of the Ministry of Justice of Ukraine, the Health Protection Centre of the State Penitentiary Service of Ukraine, the Probation Centre, the National Police of Ukraine, the Security Service of Ukraine, the Ministry of Education and Science of Ukraine, the Office of the Prosecutor General of Ukraine, and the Office of the President of Ukraine.

The information provided by them was used in the preparation of this Overview. The data and information presented in the Overview may be clarified and supplemented if corresponding additional information is received.

⬇ Prisoners and Convicts in Ukraine in 2025. Statistical Overview (PDF-file, Ukr.)