Niccolo Fantin, Author at UpRights

Each year, our Annual Report is an occasion to step back from the day-to-day of the work and take stock of what it has amounted to. This year, that reflection returned us to a simple conviction: that the pursuit of justice and accountability for human rights violations and international crimes, often quiet and against significant odds, is carried forward by those closest to the harm — prosecutors, judges, civil society organisations, and national institutions that refuse to accept injustice as inevitable.

UpRights exists to support those efforts. What has grown over the past year is our understanding of where legal and technical support makes the most difference, and our conviction that working in genuine partnership with the actors closest to these issues remains the most effective way to deliver it.

Today we are publishing our 2025 Annual Report, which sets out what that support made possible across the year and what it has added up to over five years of work.

Our 2025 at a glance

200⁺

Ukrainian public servants trained on transitional justice

60⁺

Judicial authorities trained on the adjudication of international crimes

Auditors trained on business and human rights due diligence

7⁺

Research reports, practitioner guides, and policy publications produced or contributed to

4⁺

Workshops, conferences, and expert meetings convened

Formal submissions to international and regional accountability bodies

20⁺

Partners supported across civil society, research, international organisations, and national authorities

Behind each of these figures are partnerships built on shared purpose. In a landscape where resources for human rights work are increasingly constrained, we believe targeted legal support is among the most cost-effective investments available — and that our partners, from national governments navigating complex transitions to civil society organisations defending democratic futures under pressure, deserve the strongest possible foundation for their work.

The report is organised around the four areas of work that structure everything we do: ensuring those responsible for human rights violations and international crimes are held accountable; building more just and peaceful societies through transitional justice and institutional reform; holding corporations accountable for their human rights impact; and supporting civil society to protect the human rights of those most at risk. Across each, the same question guided us: how can our specialised support make a genuine difference to those who need it most?

None of this work is ours alone. We are grateful to everyone who made the past year possible — our partners, our funders, and our board — whose trust and commitment sustained us throughout.

As we look to the year ahead, that conviction carries forward. The need for this work is not diminishing, and neither is our resolve to meet it alongside the people and institutions doing it on the ground.

Read the full 2025 Annual Report below.

UpRights_Annual_Report_2025.pdf Download

UpRights’ Valérie Gabard and Asa Solway have co-authored a comprehensive report, incorporated as part of the description of the EU Integrated Approach to External Conflicts and Crises, on supporting implementation of the European Union’s Transitional Justice Framework (“Framework”). Commissioned by the Team Europe Democracy (TED) Secretariat, the report assesses how the EU and its Member States have been supporting transitional justice in partner countries and sets out concrete recommendations for more effective implementation of the Framework. More broadly, the Report was intended to support the EU’s integrated approach to conflicts by strengthening EU and Member State support to transitional justice processes in partner countries as a fundamental means of addressing legacies of past violence, preventing the recurrence of crises, and building the conditions for more peaceful and just societies. The resulting report is a practical roadmap to promote more concrete implementation of the Framework in partner countries to address legacies of past violence and build more peaceful futures.

Background

Conflict, post-conflict and authoritarian societies coming to terms with a history of mass violence face an exceptional challenge when trying to build a stable, more peaceful future. Transitional justice has long been central to how the EU and its Member States engage with partner countries navigating exactly this challenge.

Today, the need for such support is not diminishing. Across many of the countries where the EU is most deeply engaged, the legacies of past violence remain unresolved, and the risk of renewed conflict remains real. In the DRC, decades of armed conflict have produced millions of victims whose justice needs remain largely unmet, while in Ukraine, the question of how to document ongoing atrocities, pursue accountability, and eventually build a broader process of reckoning is already being actively discussed.

Addressing these challenges is at the core of UpRights’ mission. Working on transitional justice and its implementation, UpRights operates from the conviction that durable peace requires legal mechanisms that are effective, trusted, and capable of bringing all parties into genuine processes of dialogue.

Core findings at a glance

Transitional justice is a fundamental component of the EU’s approach to supporting partner countries and should be broadly integrated in human rights, security, political and economic programming to address past violence, conflict, and instability.

The EU Transitional Justice Policy Framework is a sufficient high-level policy instrument, but it requires concrete guidance to be effectively implemented as outlined in the report.

Ensuring better implementation of the Framework requires sensitisation on the relevance of transitional justice processes in the EU and Member States to better identify where and how transitional justice applies.

Transitional justice must not be seen solely as a human rights concern, but a process that is directly linked to EU and Member State security, political, and economic interests.

Overall Recommendations

The report identifies a set of interconnected opportunities to support a more effective implementation of the Framework.

The report, while noting that criminal accountability is an indispensable component of transitional justice, also underscores that an asymmetrical support to criminal justice at the expense of truth-seeking, reparations, trauma healing, institutional reform, and reconciliation risks missing both the immediate priorities of victims and the deeper structural causes of violence.

Recognizing the importance and mutually supportive nature of both government and non-government processes is also critical. While nationally owned processes are fundamental to the legitimacy of transitional justice, the report argues that the EU and its Member States should assess whether such processes are genuinely inclusive, victim-centred, and consistent with broader transitional justice objectives and EU values. Where concerns arise regarding the nature or credibility of these processes, a range of indicators should be considered in evaluating their legitimacy, including:

✓ The meaningful participation of victims and civil society

✓ A commitment to accountability rather than amnesty

✓ The independence and impartiality of institutions

✓ Alignment with international human rights standards

In the absence of these indicators, engagement should remain cautious and carefully calibrated. At the same time, support for civil society-led and informal initiatives should not be viewed as a substitute for national processes, but rather as a parallel and equally important priority, both to complement state-led efforts and, where necessary, to sustain transitional justice objectives in contexts where official mechanisms are inadequate or compromised.

Another track identified by the report is the relationship between European leaders and the Framework itself. While the Framework is often recognized as relevant, its use is limited due to a lack of concrete guidance, expertise, and of the recognition of its benefits. This is fully addressed in the next section.

The report also emphasises that early engagement in transitional justice should not wait for the establishment of formal processes or explicit expressions of interest from national authorities. Instead, it notes that documentation during conflict, support to victims’ associations, community dialogue, and mental health and psychosocial support (MHPSS) can all lay the groundwork for future transitional justice processes and can help prevent peace negotiations from foreclosing future accountability. This perspective aligns with the EU Transitional Justice Framework in underscoring that early engagement is desirable as it paves the way for future engagement.

Supporting Better Implementation

While the research underpinning these findings focused on the integration of the EU Transitional Justice Policy Framework into a range of EU responses, the best practices that emerged point to opportunities that are not unique to that context. Indeed, the conditions that enable or obstruct effective transitional justice integration recur across a range of settings and addressing them requires a series of interrelated principles that together constitute a more comprehensive approach to embedding transitional justice in policy and programming.

A foundational step is building a fuller understanding of what transitional justice is and where it applies in relevant institutions. This means moving beyond the assumption that transitional justice is only relevant where a formal national process exists and recognising instead the full range of mechanisms that can constitute a transitional justice response. It also means understanding transitional justice not as a human rights-exclusive issue but as a framework with direct relevance to strategic interests.

Transitional justice should also be embedded structurally rather than treated as a standalone concern. This means integrating it into planning cycles, crisis response tools, conflict prevention strategies, and peacebuilding instruments from the outset. It equally means drawing explicit connections to related thematic areas, like anti-corruption for instance, that are too often pursued in parallel rather than as mutually reinforcing efforts.

Further, experience suggests that transitional justice programming is more likely to be implemented effectively where actors have prior engagement with the field. More systematic efforts to build, share, and retain expertise are needed to prevent knowledge gaps from limiting implementation. Finally, coordination is essential. Bringing together policymakers, implementing actors, and civil society to align priorities, map existing programming, and share lessons learned reduces duplication, ensures coherent messaging, and strengthens the overall impact of transitional justice efforts.

Transitional Justice as a Strategic Priority

In April 2026, the TED Initiative brought together a broad audience from the EU, Member States, international organisations and civil society to discuss the findings of the report, representing both an opportunity and an urgency to evaluate what has worked, what has fallen short, and where the EU and Member States can strengthen their approach.

Running through the entire session was a broader argument: transitional justice is not a narrow post-conflict exercise, nor a luxury for societies that have already achieved stability. It is, rather, a precondition for the stable, peaceful and rights-respecting societies that the EU’s own external action is committed to building, and it is increasingly relevant in a global context marked by democratic backsliding, the proliferation of conflicts, and the erosion of international norms.

From this perspective, the webinar was more than a review of a ten-year-old policy document. It was a call to operationalise a genuine commitment, to move from framework to practice, from principle to programming, and from good intentions to measurable outcomes for victims and affected communities.

Today, TRIAL International, in collaboration with Civitas Maxima, the Center for Justice and Accountability (CJA), the European Center for Constitutional and Human Rights (ECCHR), the International Federation for Human Rights (FIDH) and REDRESS, published the latest edition of the Universal Jurisdiction Annual Review (UJAR). The UJAR 2026 compiles developments in 91 extraterritorial and universal jurisdiction cases prosecuted in 20 countries. The figures, increasing year by year, show the growing importance of universal jurisdiction in the fight against impunity worldwide.

The effectiveness of universal jurisdiction

This year’s report demonstrates once again that universal and other forms of extraterritorial jurisdiction remain effective tools for pursuing accountability for international crimes. Between January and December 2025, 34 new cases were opened or made public, and 23 convictions were secured. This underscores the unique impact of universal jurisdiction within the international criminal justice ecosystem, both in the number of cases and perpetrators held accountable, and in the concrete access to justice it provides for victims.

In 2025, authorities in four new States – Kosovo, Peru, Poland and Türkiye – took steps to exercise universal and other forms of extraterritorial jurisdiction for the first time. Several cases also set important precedents: the first conviction for crimes committed in the context of the 2014 war in Eastern Ukraine; the first conviction for genocide through the transfer of children to another group; the first trial concerning the war crime of starvation; and the first conviction for crimes committed during the Second Congo War (1998-2003).

International justice at a crossroads

2025 was also marked by unprecedented attacks on international criminal justice. US-sanctions targeting the International Criminal Court (ICC) and other actors in relation to the situation in Palestine constitute direct attempts to shield the US and its allies, specifically Israel, from accountability, and risk depriving many people of what might be their last resort for justice.

A broader erosion of States’ commitment to universal accountability norms is also evident in the 2025 announcementsby five States of their intention to withdraw from the ICC. This decline is also evident in the failure by certain States Parties to cooperate with the Court, specifically in executing ICC arrest warrants against individuals present on their territories.

The importance of synergies and of overcoming challenges

These developments risk entrenching double standards and eroding the credibility of international criminal justice. At a time where accountability mechanisms are strained, coordination and cooperation between different actors becomes more crucial than ever. This year’s UJAR demonstrates that, where such synergies exist, they can deliver concrete results.

At the same time, universal and other forms of extraterritorial jurisdiction’s effectiveness face limitations. Their effectiveness is shaped by power dynamics and depends on specialised units and adequate resources. Strengthening legal frameworks and capacities remains essential to closing widening accountability gaps.

Throughout 2025, a lack of prioritisation and coordination remained evident in the context of the Israeli military operation in Gaza. However, a few States took some initial steps, and civil society continued to be central in driving efforts to seek accountability.

Many contexts where international crimes continue to be committed on a mass scale remain largely absent in universal and extraterritorial jurisdiction practice. As pressure grows, States committed to the international rule of law must strengthen their capacity to act.

About the UJAR 2026

The UJAR 2026 was researched and written by UpRights. It is produced as part of the “Global Initiative against Impunity for International Crimes and Serious Human Rights Violations: Making Justice Work” (GIAI). The GIAI is a global civil society-led programme, co-funded by the European Union, that promotes inclusive, integrated, comprehensive justice and accountability for serious human rights violations worldwide.

The UJAR 2026 has been produced with the financial support of the City of Geneva, the European Union, Oak Foundation and the Taiwan Foundation for Democracy. The contents of this publication are the sole responsibility of TRIAL International and can under no circumstances be regarded as reflecting the positions of the above-mentioned donors.

The artwork featured on the cover is part of a series of court sketches created by Augustin Guichot for TRIAL International during the trial of former Congolese rebel leader Roger Lumbala, which took place in Paris from 12 November to 19 December 2025.

Read and download the UJAR 2026:

UJAR_2026_digital Download

On 19 March 2026, the Team Europe Democracy (TED) Initiative published Supporting Implementation of the 2015 EU Transitional Justice Policy Framework drafted by UpRights’ Co-Directors Valerie Gabard and Asa Solway. Commissioned by the TED Secretariat in view of the 10th anniversary of the adoption of the framework, the report assesses how the EU and its Member States have supported transitional justice processes in partner countries, drawing on six case studies across Sub-Saharan Africa, as well as a comprehensive literature review and interviews with EU staff, Member State representatives, civil society organisations and transitional justice experts.

The framework sets out well-recognized transitional justice principles including calls for nationally owned, participatory, victim-centred and gender-sensitive approaches. While on paper this broad language provides a foundation to support transitional justice processes in partner countries, the report finds that implementation has been hindered by a lack of concrete guidance and a need to sensitise the UE and Member States on the ultimate goals and applicability of transitional justice.

As such, the Report sets out concrete recommendations to ensure better implementation of the framework, including accurately assessing and promoting nationally and locally owned transitional justice processes, ensuring their legitimacy and genuineness and a commitment to meaningful participation of victims;

Ensuring support to non-governmental, informal processes, particularly those led by civil society and victim-driven initiatives;

While recognising the importance of criminal justice, avoiding an over-emphasis on such processes at the expense of a balanced approach that incorporates trauma healing, truth seeking, memorialization, reconciliation, reparations, security sector reform and disarmament, demobilization and reintegration;

Ensuring both early, and long-term, engagement regardless of whether national authorities have initiated formal processes;

Placing victims and affected communities – with particular attention to traditionally excluded and marginalised groups – at the centre of design and implementation of transitional justice processes;

Integrating mental health and psychosocial support to victims and affected communities, and gender transformative approaches, in programming to address the root causes of violence;

The report recognizes that transitional justice remains a critical means for the EU and its Member States to address a global rise in instability, democratic backsliding and the proliferation of internal and external conflicts across the globe that present a significant challenge to fundamental EU values.

Fundamentally, the report affirms that transitional justice is not a luxury for post-conflict societies but a precondition for stable, peaceful and rights-respecting societies that the EU’s own external action is committed to building.

TJ_Final_Public_Report Download

Turin / The Hague / Rome / Brussels, 19 March 2026. For the second time in just over a year, UpRights and StraLi – this time together with Médecins Sans Frontières (MSF) and Pro Iura – have obtained urgent interim measures from the United Nations Human Rights Committee against Malta for its failure to rescue people in distress in the Central Mediterranean Sea. The Committee’s decision, issued today, requires Malta to immediately coordinate a search and rescue (SAR) operation for more than 100 people, including women and children, who have been stranded on the Miskar gas platform and a nearby boat in the Maltese SAR region since 15 March 2026. This is also the third time in less than twelve months that the UN Human Rights Committee has granted such interim measures in a case of distress at sea in the Central Mediterranean.

On 14 March 2026, the emergency hotline Alarm Phone was alerted of two rubber boats in distress that had departed from Zuwara, Libya, earlier that morning carrying a total of estimated 118 people, including women and children. Although Alarm Phone relayed the alerts, among others, to the Maltese and Italian authorities, none of the authorities took over coordination of the search and rescue operation.

Contact with the boats was lost on the night of 14 March. On 16 March, it was confirmed by Miskar platform personnel that the two boats had approached the platform on 15 March and that the people on board had climbed onto it. Most people were now stranded on the industrial structure but a small number of them were still on a vessel attached to the platform, with no food, water, and exposed to severe weather conditions. With no SAR operation being coordinated, and the lives of so many people at imminent and serious risk, UpRights, StraLi, MSF and Pro Iura filed an urgent request for interim measures with the UN Human Rights Committee on 17 March 2026, urging Malta to take all measures necessary to coordinate a SAR operation and ensure that the people in distress at sea are disembarked as soon as possible in the closest place of safety.

“The consistent failure of states to fulfill their obligations under the law of the sea is one of the main factors contributing to the alarmingly high mortality in the Central Mediterranean”, says Juan Matias Gil from MSF. “In the absence of proactive state-led search and rescue mechanism, NGOs are stepping in to fill the void and we call on coastal states to assume their SAR duties as a matter of urgency”.

As noted above, the people had departed from Zuwara, Libya, on two unseaworthy rubber boats before becoming stranded on the Miskar gas platform – located in the Gulf of Gabès, in international waters within the overlap of the Maltese and Tunisian search and rescue regions. “The people stranded on the platform had been at sea for a long time and on the Miskar platform already since 15th March,” explains a representative of Alarm Phone. “The platform provided basic food and water, but people were forced to sleep on the floor in harsh weather conditions. The platform’s doctor informed us that among those stranded, 14 were suffering from flu, one person had sustained chemical burns from fuel contact, and one woman was pregnant. Among the group were also one child of 10 years old and two babies of 2 years old.” On 19 March 2026, the rescue vessel Ocean Viking, operated by SOS Mediterranee, finally rescued the persons.

The submission to the UN Human Rights Committee was made on behalf of those hundred or so persons in distress, urging the Committee to issue interim measures requiring Malta to prevent imminent and irreparable harm to the right to life and the prohibition of torture and other forms of ill-treatment (Articles 6 and 7) enshrined in the International Covenant on Civil and Political Rights (ICCPR).

Today, 19 March 2026 at 10:32 (CET), the UN Human Rights Committee granted the request and ordered Malta to coordinate a SAR operation to rescue the persons in distress and “to ensure that they are not disembarked in a place where they will be at risk of torture and other forms of ill-treatment or risk to their life”. The decision by the Committee is legally binding and also requests Malta to inform them about the measures taken.

“Interim measures issued by the UN Human Rights Committee represent one of the last available and urgent instrument to prompt States to coordinate SAR missions and save lives at sea, where people risk death or other forms of ill-treatment”, say Chiara Amitrano and Benedetta Perego from StraLi. “In this critical historical moment, they are essential to pressure States into upholding their international law obligations,” added UpRights’ Co-Director Valérie Gabard.

Nonetheless, the present case is not an isolated incident. It is part of a well-documented, systematic pattern of non-assistance by European states that has been documented by numerous international and civil society organisations over many years.

In March 2025, UpRights and StraLi, together with SOS Humanity, had already obtained the very first interim measures ever issued by the UN Human Rights Committee in a case of distress at sea. On that similar occasion, the Committee instructed Malta to coordinate the rescue of 32 people who had been stranded for four days near the same Miskar platform. Malta did not respond to any communication and took no action, despite the Committee’s legally binding order. The individuals were ultimately rescued by Aurora, the rescue vessel of Sea-Watch. In September 2025, the Committee granted a further set of interim measures – this time in a case filed by Sea-Watch – requiring both Malta and Italy to coordinate the rescue of 41 survivors stranded on a gas platform supply vessel for seven days. The present case now brings the total number of Committee decisions to three in under twelve months, all concerning the same stretch of sea, the same legal obligations, and the same pattern of alleged State inaction.

Press contacts:

Miriam Corgiat info@strali.org, StraLi

Valérie Gabard, info@uprights.eu, UpRights

Mohamad Cheblak, SAR-FCC@oca.msf.org, MSF

Daria Sartori, info@proiura.org, Pro Iura ASBL

Alarm Phone Media Team, apmedia@autistici.org

Yesterday, March 5, 2026, the Database Center for North Korean Human Rights (NKDB) hosted a seminar in Seoul to present the findings of its latest investigative report, “The Machinery Behind the Forced Repatriation of North Koreans in China.” The report examines the system of forced repatriation of North Korean escapees carried out by North Korean and Chinese authorities, and proposes concrete pathways for accountability, including potential sanctions against responsible actors.

UpRights provided comprehensive legal analyses examining China’s forced repatriation practices from three perspectives: international criminal law, international refugee law, and international human rights law.

Our team assessed whether China’s forced repatriation practices may constitute crimes against humanity under Article 7 of the ICC Rome Statute. Crucially, the analysis also examined whether the involvement of Chinese officials and agencies – from arrest and detention in China through to the handover and subsequent treatment of escapees in the DPRK – may amount to complicity in the DPRK’s own crimes against humanity under international criminal law. This analysis drew from a detailed study of bilateral treaties between the respective states, the organisational structures of multiple state agencies involved, patterns of interagency coordination and cooperation, and documented post-repatriation human rights violations.

UpRights also assessed China’s binding obligations as a State Party to the Torture Convention and Refugee Convention, identifying China’s failure to provide asylum where warranted, its failure to undertake refugee status determination, and violations of the principle of non-refoulement – all despite its obligations under the Refugee Convention and international human rights law.

Recognising that effective domestic remedies within China are essentially unavailable, UpRights evaluated the viability of different pathways, identifying three key potential accountability avenues:

Third-state proceedings under universal or extraterritorial jurisdiction
Targeted human rights sanctions, including Magnitsky-style sanctions and the EU Global Human Rights Sanctions Regime
UN mechanisms

At the Seoul seminar, NKDB’s human rights analysts shared the legal findings with senior international figures, including Special Rapporteur Elizabeth Salmon, acting Deputy Assistant Secretary of State Julie Turner, and former ROK Ambassador Shinhwa Lee.

UpRights is committed to contributing rigorous legal analysis in support of accountability for serious human rights violations and crimes under international law. We thank NKDB for their leadership in amplifying victims’ voices and pursuing accountability until forced repatriations are fully halted.

The full report is available in English and Korean on the NKDB website: https://en.nkdb.org/researchreport/?q=YToxOntzOjEyOiJrZXl3b3JkX3R5cGUiO3M6MzoiYWxsIjt9&bmode=view&idx=170265783&t=board

Amid the deadliest nationwide protests in Iran since the revolution in 1979, the need to acknowledge suffering by victims and ensure their right to hold perpetrators accountable has never been more critical. In 2025, HRA, with legal support from UpRights, published the “Practitioner’s Guide to Addressing Alleged Serious Human Rights Violations and International Crimes Committed by the IRGC in Iran and Abroad”. Building on the Pasdaran Documentation Project (PDP), the Guide transforms structured documentation into a tool practitioners can actively use in navigating complex accountability landscapes concerning Iran.

Instead of functioning as an overly technical manual, the Guide is designed as a pragmatic roadmap to support victims, lawyers, investigators, civil society and other actors seeking practical ways to pursue accountability for alleged Islamic Revolutionary Guard Corps (IRGC)-linked violations and international crimes. In the absence of effective domestic remedies in Iran, the Guide realistically maps judicial, quasi-judicial and non-judicial pathways available outside Iran, including the limitations and challenges of each pathway. The Guide was presented by Valérie Gabard, Co-Director of UpRights during Asser Institute’s Panel Discussion, “Islamic Revolutionary Guard Corps: human rights violations and international crimes in Iran and beyond” on 5^th February 2026.

This blogpost explores the Guide’s role as a practical tool to challenge impunity where domestic remedies are absent or ineffective. It examines the methodological approach used to identify feasible accountability pathways during the development of the Guide and highlights key considerations for practitioners seeking to apply this approach across different contexts.

The PDP, built by HRA with legal support from UpRights, was created with future accountability efforts in mind. The database systematically maps the IRGC’s structure, units, chains of command from its inception to the present day, and links those to documented incidents of serious human rights violations and potential international crimes, including repression within Iran and operations connected to IRGC structures abroad. Today, the PDP Database houses profiles of more than 4,800 IRGC members and 84,700 IRGC units, providing practitioners with solid foundations to advance accountability while also serving as an enduring public record of an institution notorious for its widespread abuses.

Developing an Accountability Strategy

Recognising that accountability could be pursued on multiple fronts, the Guide provides practitioners across the world with a concrete and clear methodology to identify pathways to accountability, gain practical insights and plan effective international strategies as there are no viable domestic remedies in Iran. It adopts a victim-centred and broad approach to accountability encompassing judicial, quasi-judicial and non-judicial pathways, including transitional justice mechanisms, and sets out to assess the viability of different pathways.

Developing an accountability strategy like the one outlined in the guide starts with the documentation and assessment of the human rights violations and/or international crimes committed and the perpetrators that are alleged to be responsible for these acts. Since its establishment in 1979, the IRGC – a parallel military institution created in 1979 to protect the Iranian revolution and who respond directly to Iran’s Supreme Leader – has been allegedly responsible for a wide range of serious human rights violations and international crimes committed both within Iran and abroad. Outside of Iran, allegations of human rights violations or crimes involving IRGC’s members have been reported all over the world for decades and are an integral part of the IRGC modus operandi. These incidents mostly target dissidents or interests of foreign enemies to the Iranian regime such as the 1994 AMIA bombing in Argentina.

In Iran, the IRGC’s involvement in violations or crimes relates inter alia to the targeting of political dissidents, journalists, activists, and any perceived enemy of the regime, including by kidnapping dissidents abroad and running unofficial detention centres across the country. Over the years, the IRGC has been involved in the violent repression of most, if not all, the protests challenging the Iranian Government. Most recent crackdowns like the repression of 2022-2023 “Woman, Life, Freedom”movement, and incidents such as the 2022 “Bloody Friday” in Zahedan not only constitute serious human rights violations but also amount to crimes against humanity, including political and gender persecution, as shown in our submission to the UN Independent International Fact-Finding Mission on Iran (FFMI) from 2023.

The IRGC also appears to bear primary responsibility for the deadly crackdown on protesters between 8 to 10 January 2026. Based on publicly available information to date, the acts committed by the IRGC in this context similarly may meet the threshold of crimes against humanity in light of the verified scale of killings and injured, number of protesters arrested and detained, forced confessions already broadcast, nationwide geographic distribution, and deliberate deployment of military-grade weapons against civilians, as documented in HRA’s latest report.

Based on the human rights violations and/or international crimes documented, the second step is to map the full range of accountability pathways understood broadly as including judicial, quasi-judicial and non-judicial available at the international level. While Iran is the primary duty-bearer for its citizens’ human rights, there are no viable domestic remedies within Iran which makes accountability avenues outside Iran essential for victims seeking justice or redress.

In this context, human rights violations generally refer to violations attributable to the State – thereby engaging State responsibility. International crimes, by contrast, concern individual criminal responsibility under international law. The Guide underscores that accountability pathways for serious human rights violations and international crimes at the international level are fragmented and rarely offer fully satisfactory answers or comprehensive solutions for victims and affected communities.

As a result, the mapping contained in the Guide emphasises the strategic use of combined/mixed pathways such as criminal prosecution in third States under universal or extraterritorial jurisdiction, targeted sanctions under Magnitsky-style and global human rights sanctions regimes, and engagement with relevant UN mechanisms. Rather than presenting any single pathway as a solution, the Guide highlights the need for a coordinated, long-term strategy as well as the importance to have realistic expectations about each pathway’s viability and potential outcomes.

The mapping of accountability pathways is often undertaken in a theoretical manner – this fails to provide direct support to practitioners. Accordingly, the Guide incorporates a feasibility analysis. For each pathway, consideration is taken to outline in concrete and accessible terms:

its legal requirements;

the evidentiary thresholds needed;

Iran’s limited treaty ratification, reservation or declaration;

current contextual risks, challenges and political constrains; and

lessons from past Iran-related or other comparable efforts.

Because the alleged violations may amount to crimes against humanity and therefore attract criminal responsibility under international law, the Guide evaluates accountability options for both States responsibility and individual criminal liability. For example, it examines potential pathways at the International Criminal Court (ICC), International Court of Justice (ICJ), and third States proceedings under universal or extraterritorial jurisdiction and their feasibility.

For instance, because Iran is not a State Party to the ICC, the ICC’s ability to exercise jurisdiction over crimes committed in Iran or by Iranian nationals, such as IRGC members, is extremely limited and currently unrealistic. The ICJ also has its own legal and political obstacles which make this pathway particularly challenging in the context of Iran. Recognising these limitations, the Guide places greater emphasis on feasible domestic forums outside Iran, notably third States proceedings under universal or extraterritorial jurisdiction, as the more realistic pathway to advancing criminal accountability,

In addition, States’ responsibility for human rights violations can be pursued in parallel through different forums, including strategic engagement with relevant UN mechanisms such as the FFMI, and using Magnitsky-style and EU sanctions regimes. While these tools have their limitations, including the lack of formal victim participation in the sanction’s designation process, they still serve as an important accountability tool especially when available avenues are otherwise limited. The Guide also recommends that any strategy on accountability related to Iran be framed under broader transitional justice principles to ensure on the long term that Iranian society can come to terms with its legacy of States’ abuses.

Key Considerations for Practitioners Applying This Approach Across Different Contexts

The approach underpinning the Guide offers a structured framework that practitioners can adapt across different contexts to pursue accountability, including incorporating transitional justice principles and pursuing non-judicial pathways for serious human rights violations and international crimes.

First, an effective accountability strategy begins with clearly identifying the types of violations, the scale of harm and the individuals or entities responsible. Tools like the PDP Database are especially valuable as they enable practitioners to transform fragmented information into connected, verifiable patterns of violation backed by structured, evidence-based documentation.

Second, practitioners must have clear objectives related to the accountability efforts they wish to pursue. Different accountability pathways serve different purposes. Practitioners need to decide whether they want to pursue short-term outcomes such as engaging with UN mechanisms or securing sanctions designations, or longer-term goals such as third States universal jurisdiction, or support to potential transitional justice initiatives. Each pathway comes with its own legal and jurisdictional requirements, evidentiary standards, risks, challenges and limitations. Clearly defining the objectives pursued is what can make accountability efforts move from abstract goals to actionable, effective strategies.

Third, context specificity is crucial in understanding different nuances and shaping accountability strategies. A pathway that worked in one country or case may not be viable in another. Effective strategies must therefore be tailored to the specific jurisdictional and legal requirements, evidentiary standards, political willingness and situational realities of each context. By conducting careful legal and contextual analysis together with a rigorous feasibility assessment, practitioners will be able to determine which pathways are most realistic and effective given the context.

Fourth, practitioners must keep in mind that accountability efforts can expose victims, witnesses, their families, and organisations involved in documentation or advocacy, to reprisals, intimidation or legal risks. Aiming to pursue accountability can also easily create unrealistic expectations for victims and communities that should be properly understood and managed from inception. This is why risk assessment must sit at the centre of planning and practitioners must always prioritise a “Do No Harm” approach.

Conclusion

Judicial, quasi-judicial and non-judicial pathways together form a broader accountability ecosystem and when used strategically, each pathway can reinforce and strengthen one another. The most effective approach at the international level is rarely a single, isolated effort but mixed, long-term accountability strategies that combines multiple pathways conducted by one or several actors. For practitioners facing difficulties in navigating complex international accountability landscapes, the Guide serves as a practical tool in helping to map viable pathways, set realistic expectations, and design both advocacy and accountability strategies that can best deliver tangible results for victims pursuing recognition and some form of redress for their suffering.

27 January, 2026: Lawyers for Justice in Libya (LFJL), The Nuhanovic Foundation and UpRights welcome today’s verdict from the District Court of Zwolle in the Netherlands convicting Eritrean national Tewelde Goitom, also known as Walid, to 20 years imprisonment.

The Court recognised the jurisdiction of the Dutch courts over all charges, with the sole exception of acts relating to two witnesses, due to the absence of a sufficient territorial nexus with the Netherlands in those two specific cases.

Crucially, the Court affirmed that under Article 2 of the Dutch Penal Code, Dutch jurisdiction applies where criminal conduct is committed at least in part in the Netherlands or where the consequences of the crimes occur on Dutch territory, regardless of where the acts originated. In this case, acts of extortion were partially committed in the Netherlands, and the offence of human trafficking was completed through its effects, as many victims ultimately reached the Netherlands or became irregularly present there as a direct result of the defendant’s actions.

The Court found all charges proven beyond reasonable doubt, recognised the credibility of the victims’ testimonies, and confirmed Walid’s leadership role. Walid faced multiple charges under the Dutch penal code, including leading a criminal organisation, human smuggling, extortion, violent acts, and sexual offences committed primarily against vulnerable migrants and asylum seekers attempting to reach Europe between 2014 and 2018. Walid was convicted for leading a criminal network operating detention camps, mainly in Bani Walid in Libya, where people were held and tortured until families abroad paid ransoms amounting to thousands of US dollars. Walid was also convicted for arranging the illegal transport of migrants from Libya to Europe, primarily by sea. The victims were mostly Eritrean and other East African nationals. The verdict rendered today set a critical precedent in a case which has been truly unique and remarkable in many respects. The trial that took place between the 3rd and the 26th of November 2025 in Zwolle is one of – if not the – largest human smuggling cases in Dutch history and one of the very rare cases in Europe that attempt to address crimes committed against migrants and refugees in Libya.

For the first time, a Dutch criminal court examined in detail how abuses committed in Libya were embedded within a broader transnational migration trajectory, including events occurring in countries of origin, transit, and destination.

LFJL, The Nuhanovic Foundation, and UpRights commend the proactivity and perseverance of the Dutch Prosecutor to pursue such a complex case, as well as the measures taken by the District Court of Zwolle to ensure transparency and accessibility to affected communities and wider public, including livestreaming the proceedings and providing interpretation and broadcasts in Dutch, English, and Tigrinya.

Walid’s conviction represents an important first step for migrants and refugees who are routinely subjected to serious international crimes in Libya, whose voices are rarely heard in Europe, and for whom access to justice remains unattainable. However, the Dutch prosecutors narrowed the scope of the case to human smuggling and related domestic offences, thereby failing to fully capture the exploitative, systematic and widespread nature of the crimes committed against migrants in Libya. LFJL filed a criminal complaint to the

Dutch international crimes unit in an effort to prompt additional investigations that reflect the full gravity of the crimes committed by Walid, including details of alleged conduct that may amount to human trafficking, slave trading, and crimes against humanity. The Nuhanovic Foundation has conducted an analysis highlighting the key implications for victims’ rights in cases of human smuggling versus cases of human trafficking, which can be found here. The Pearce case is closely linked to proceedings against another Eritrean national named Zekarias Habtemariam Kidane. Alleged to be part of the same criminal network, Kidane was arrested in Sudan and was held in the United Arab Emirates (UAE) since January 2023 after escaping Ethiopian justice, where he had been convicted in absentia. He was finally transferred to the Netherlands to face charges before Dutch courts in late December 2025.

His case, scheduled to be heard in April 2026, offers the Dutch prosecution and the District Court of Zwolle an opportunity to build on today’s precedent and to reconsider their legal approach, with a view to addressing the full range of harms suffered by victims and ensuring accountability that reflects the true nature of the crimes committed.

On 11 December 2025, the Council of Europe convened prosecutors from the Office of the Prosecutor General of Ukraine (OPG) and regional offices to address the recruitment of children to commit acts that threaten national security in Ukraine. The increasing number of cases – often involving minors recruited online to carry out sabotage or attacks on infrastructure – has raised urgent questions about responsibility, accountability, and the rights of children exploited by foreign actors.

UpRights was invited to contribute to the session, with Co-Director Valérie Gabard and Legal Advisor Ciara Laverty sharing the results of research commissioned by the Council of Europe and the OPG. A central focus of UpRights’intervention was the amendment to Article 438 of the Criminal Code of Ukraine, which criminalizes the “recruitment or use of a child for participation in an armed conflict, military (combat) operations.” Their presentation focused on how Ukrainian law interacts with international standards on the recruitment and use of children in armed conflict, and how these legal frameworks can guide prosecutorial strategies in Ukraine.

UpRights also stressed that children coerced or manipulated into such acts must be viewed primarily as victims. Although international law does not prohibit prosecuting minors for crimes they commit, prevailing standards require states to prioritize alternatives to judicial proceedings, limit the use of detention, and ensure rehabilitation and reintegration.

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UpRights remains committed to supporting Ukrainian prosecutors and judges in navigating these complex issues – combining comparative expertise, international standards, and practical approaches to accountability that reflect the realities of the armed conflict and the vulnerabilities of the children affected.

This work forms part of the Council of Europe project “Fostering Human Rights in the Criminal Justice System in Ukraine – Phase II,” under the Action Plan for Ukraine “Resilience, Recovery and Reconstruction” (2023–2026).

Throughout June UpRights delivered a training programme on auditing GOTS human rights due diligence (HRDD). The training was funded, in part, through an Impulse Grant from ISEAL Innovations Fund in partnership with the Global Standard.

The training was delivered to 30 auditors from 17 different GOTS-approved Certification Bodies across the world, in Germany, the United Kingdom, France, Portugal, Poland, Italy, Turkey, India, Bangladesh, China, and Indonesia.

Participating auditors learned to effectively audit GOTS Certified Entities in line with GOTS criteria, including particularly GOTS due diligence requirements as modelled on the OECD six steps of due diligence, and in line with fast-moving HRDD developments.

The training structure comprised four, full-day modules: Module 1, as a microcosm of the overall programme, covered GOTS due diligence and auditing techniques to verify that due diligence. Module 2 expanded on the theoretical foundations in the first module by covering other legal frameworks applying alongside GOTS, particularly the EU Corporate Sustainability Due Diligence Directive and select national HRDD legislation. Module 3 expanded on the practical foundations in the first module by way of a large-scale exercise, with small break-out groups undertaking a simulated facility walkthrough, interviews with workers, management and stakeholders, and document review and analysis. Module 4 covered pivotal cross-cutting issues, namely gender- and diversity-responsive HRDD auditing, cultural sensitivity, and enterprise pressures.

Methodologically, the training involved presentations, lively Q&A, open discussions, case studies, and the break-out group work. The training was presented by UpRights and Global Standard personnel, as well as guest presentations by specialists in certain subject matters including from the OECD, academia, and legal practitioners.

This was the culmination of a long journey. An UpRights-Global Standard consortium started a long-term needs assessment in 2023, including interviews with GOTS auditors. The consortium heard auditors’ unequivocal voices about the need for support, notedly in the form of training, to deal with the introduction of GOTS due diligence requirements, and the fluid, rapid developments in the HRDD legislative and regulatory landscape at the international, regional and national levels. This was followed by analysis and mapping out high-level purpose, objectives, and possible parameters for the form and content of the training. The needs assessment culminated in a research paper, a draft continuous learning policy, and the draft curriculum for the training programme, which comprised the first phase of this project.

UpRights and the Global Standard also jointly applied for an Impulse Grant from the ISEAL Innovations Fund, in late 2024, financed by the Swiss State Secretariat for Economic Affairs (SECO) and UK International Development from the UK government. This grant was successfully awarded to the consortium in early 2025, enabling the development of the modules. This included training materials, and pre- and post-course assessments, as well as the delivery of the four training sessions, which comprised the second phase of the project.

Initial feedback on the course from participating auditors includes:

“[A] dynamic and professional training […] I appreciated these sessions very much.”

“Thank you [for] this meaningful and eye-opening training. I truly learned how to see beyond documents and better understand the real human rights risks in factories.”

“One thing I really appreciated about this module was how it clearly explained the latest updates in human rights due diligence laws. The way it connected the EU CSDDD with national laws and global frameworks made a complex topic much easier to understand. It really helped me see the bigger picture and how everything fits together in the real world of compliance and auditing.”

[On the Module 3 simulation exercise:] “The realistic audit flow was excellent. Going through desk review, walkthroughs, interviews, and document checks made it feel like we were in an actual audit. It really helped connect theory with practice […] Overall, a really engaging session—looking forward to more exercises like this!”

UpRights is very pleased to have had the opportunity to execute this project. UpRights looks forward to enhancing the training programme, scaling it up, extending and diversifying it, as well as keeping it up to date with future HRDD developments including for example the European Commission’s Omnibus Simplification Package and sector-/subsector-specific developments. This with a view to further contributing to strengthening the Global Standard and the wider system of voluntary sustainability standards in the textiles industry, to drive positive change in business and human rights.

(This project was possible thanks to an Impulse Grant from ISEAL Innovations Fund, with funding from the Swiss State Secretariat for Economic Affairs (SECO) and UK International Development from the UK government.