International Register of Damage: a key mechanism for recording material losses caused by the Russian Federation

Are reparations and the International Register of Damage the same thing?

Reparations are a legal obligation of the aggressor state to compensate for damage caused by war—to individuals, the state, and infrastructure. In the case of Ukraine, this means that the Russian Federation must compensate for the full extent of losses caused by its aggression. However, in practice, obtaining reparations is difficult, as Russia blocks international decisions, particularly through its veto power in the UN.

This is precisely why the International Register of Damage is being established — as a tool for recording losses, which constitutes the first step toward future reparations and their legal enforcement.

What is the International Register of Damage for Ukraine?

The International Register of Damage for Ukraine is a specially established international mechanism for recording damage caused as a result of the armed aggression of the Russian Federation. Its creation is the result of joint efforts by states supporting Ukraine, under the auspices of the Council of Europe.

The purpose of this register is to document all losses in order to form a legal basis for future reparations. In other words, it is the first stage of a broader international compensation mechanism.

What role does the International Register of Damage play in the mechanism of future compensation?

The International Register of Damage is only one element of the future system for compensating Ukraine’s losses. It is expected that the overall mechanism will consist of three components:

• the Register of Damage;
• a compensation commission;
• a compensation fund.

At present, the Register is being formed. The next step is to establish a compensation commission that will review claims, and subsequently — a compensation fund from which payments will be made.

How does the approach of the International Register of Damage differ from other compensation programs?

One of the key features of the International Register of Damage is its simplified approach to recording the circumstances of damage. Unlike national compensation mechanisms, where it is necessary to prove a clear legal title to property (e.g., ownership rights), the international register applies a more flexible approach to evidence.

Which laws regulate the submission of claims to the International Register of Damage?

The procedure for submitting claims is governed by international documents as well as national regulatory acts of Ukraine. An important role is played by Resolution No. 365 of the Cabinet of Ministers of Ukraine dated March 29, 2024, which details the procedure for submitting claims to the Register.

In addition, the official website of the International Register of Damage provides submission rules for each category. These documents specify what evidence, data, and supporting materials must be provided to record losses in each specific category.

Who can submit applications to the International Register of Damage?

The Register system provides for several main categories of claimants:

• individuals affected by the war;
• legal entities and businesses;
• the State of Ukraine and territorial communities.

Currently, the category of individuals is actively operational, while other categories are being gradually introduced, undergoing testing and preparation for full-scale launch.

When will full submission to the International Register of Damage start?

Full-scale opening of all categories for submitting claims to the International Register of Damage is expected in 2026. After the launch, the system will gradually expand access to different categories of applicants.

How will applications be submitted to the Register of Damage?

At the initial stage, applications will be submitted exclusively in electronic form through the “Diia” application. For territorial communities and state authorities, an electronic submission format is also foreseen, using designated digital tools.

At the level of each community, an authorized person must be appointed who will be responsible for preparing and submitting documents to the Register. This person will be granted the necessary access rights and digital keys.

Detailed representation rules and technical submission procedures are already set out on the official website of the International Register of Damage in the relevant section.

How to prepare for submitting claims to the International Register of Damage?

The key recommendation is to start systematic preparation now: conduct an inventory of property, collect available documents, organize technical and title documentation, and record all available evidence of damage or destruction of assets.

Special attention should be paid to critical and non-critical infrastructure objects. Their classification is determined by specific regulatory acts, in particular Cabinet of Ministers Resolution No. 365 dated March 29, 2024, which details the procedure for submitting claims to the Register.

What should communities do if property ownership is not registered?

The International Register of Damage provides a special approach for cases where objects of municipal or state ownership physically exist, but ownership rights have not been entered into modern state registers.

This is a fairly common situation for social infrastructure or public facilities that have been on the balance sheets of communities since Soviet times.

In such cases, the Register offers a practical procedure:

• the community should collect all available documents related to the asset;
• apply to the state registrar for official registration of ownership rights;
• obtain a written refusal of registration.

This official refusal can be used as evidence in a claim submitted to the International Register of Damage. It confirms the factual existence of the asset and the community’s rights to it within the meaning of the Register, even if formal ownership registration is absent.