“Prove that you are under occupation”: How the 2026 admission campaign put applicants from TOT at risk

Ukraine’s 2026 university admission campaign has effectively come to an end, but it has left behind a precedent that human rights activists describe as dangerous. For the first time in the years since the introduction of a simplified admission procedure for applicants from temporarily occupied territories (TOTs), some higher education institutions began requiring them to provide documents issued by occupation authorities or specially created digital evidence of their presence under occupation — photographs with geolocation data taken in the central squares of cities and villages, selfies with local newspapers, and, in some cases, even with occupation symbols.

Human rights organizations consider this practice dangerous for applicants and their families, as the digital materials they create may be discovered during checks and filtration procedures when leaving occupied territories. At the same time, questions remain about the specific legal grounds on which educational institutions required such evidence and whether it was provided for in the regulations governing university admissions.

OstroV contacted the Ministry of Education and Science with a request for information about this practice. In its response, the ministry referred to the Procedure for Admission to Higher Education Institutions but did not specifically explain on what grounds applicants were required to provide documents issued by occupation authorities or digital materials to confirm their presence in TOTs.

An imperfect system

“Since 2016, special admission conditions under the so-called Quota 2 have been introduced for applicants from temporarily occupied territories. The quota took into account the fact that a person lives in a temporarily occupied territory and may not have Ukrainian-standard education documents. Quota 2 provided for simplified admission without a school-leaving certificate: applicants could take the required exams under a specific program at their chosen higher education institution, become students, and compete for state-funded places”, - Violeta Artemchuk, chief coordinator of the Donbas SOS NGO, tells OstroV.

After the start of the full-scale war, the possibility of participating in the admission campaign remotely became particularly important, as leaving temporarily occupied territories had become significantly more difficult.

According to Violeta Artemchuk, human rights activists had advocated for the possibility of applying online even before 2022. After the full-scale invasion, it effectively became one of the few realistic options for young people who remained under occupation: applicants could take interviews and submit documents remotely, and travel to territory controlled by Ukraine later.

Before this year’s admission campaign, confirming the fact of residence in a TOT was relatively easy. Since applicants often do not have Ukrainian passports, it was sufficient to provide, for example, a parent’s passport showing the relevant registered address or place of residence.

“Applicants often do not have Ukrainian passports because they are unable to take their documents with them. Therefore, they could, for example, provide their parents’ passports, which indicate their place of residence or registration in a temporarily occupied territory. This confirmed that the applicant lived in a temporarily occupied territory and was applying online. That was how things worked until this year”, - the human rights activist explains.

However, this year, according to her, it became clear during the admission campaign that information about parents’ registration was no longer sufficient.

“Somehow, it was necessary to confirm that the applicant was actually in a temporarily occupied territory. In other words, they had to prove that they were not, say, abroad at the time, that they had not left for Vienna, for example, and were not applying online from there using a VPN under the simplified procedure to a Ukrainian higher education institution. The assumption is that the parents’ registered address is not sufficient proof that the applicant themselves is actually in a temporarily occupied territory”, - the coordinator explains.

The problem is that this requirement had neither been agreed upon in advance nor even announced. Back in April, when civil society organizations held their annual series of webinars for admissions officers at admission centers, with representatives of the Ministry of Education and Science participating, there was no mention of the need for additional evidence.

Complaints about the new requirement began coming in during the admission campaign itself — and the electronic applicant registration system technically would not allow an application to be submitted without attaching the relevant document.

What exactly constituted proper evidence remained unclear for a long time. One of the suggested benchmarks was a certificate issued by an occupation-run school in the current year.

“In other words, the state does not recognize occupation-issued documents — this is explicitly stated — but at the same time, applicants are required to submit them in order to gain the right to apply. And this creates a rather serious contradiction”, - Violeta Artemchuk notes.

The very logic behind the choice of evidence suggested to applicants is also telling. A certificate from an occupation-run school is a document whose legal validity is not recognized in Ukraine at all: decisions issued by so-called occupation administrations are not part of the Ukrainian legal system, and diplomas or certificates issued by them are not automatically converted into Ukrainian ones.

At the same time, this very document was de facto required as a “pass” for admission. The requirement for photographic evidence goes even further: a state that officially does not recognize any administrative procedures in TOTs is asking applicants to prove their presence there in a way that has no legal status whatsoever — but could have very real consequences if it falls into the hands of occupation security forces.

“The problem is that we are dealing with a situation in which applicants did not graduate from school this year. They finish school at 16, but do not immediately enroll in a Ukrainian higher education institution. They wait until they turn 18, when they can leave for territory controlled by Ukraine after enrolling, without their parents’ permission. In other words, we have an entire group of applicants who have already turned 18 and graduated from school two years ago. Their school certificate is, say, from the year before last. And it is no longer accepted as proof of residence in temporarily occupied territory”, - explains Violeta Artemchuk.

It was at this point, according to the coordinator, during consultations with the Ministry of Education and Science and representatives of admissions committees, that recommendations were made which subsequently sparked outrage among human rights activists: take a photograph with geolocation enabled in the central square of one’s city, or buy a local newspaper and take a photograph with it showing the current date.

OstroV contacted the Ministry of Education and Science with a request for clarification regarding the requirement to provide documents issued by occupation authorities or digital evidence of residence in temporarily occupied territory.

The Ministry’s response, signed by Deputy Minister Mykola Trofymenko (No. 1/20142-26, dated September 18, 2026), does not provide a specific explanation of this practice. The Ministry referred to general provisions on the right to education and to special admission conditions for residents of temporarily occupied territories, established by the Admission Procedure approved by Ministry of Education and Science Order No. 271 of March 1, 2021, as amended by Order No. 813 of May 20, 2026.

At the same time, the response does not explain on what specific grounds applicants could have been required to provide documents issued by occupation authorities or digital materials created by them.

According to information provided by human rights activists, the relevant Admission Procedure allows applicants to confirm their place of residence using registration documents, including their parents’ documents. Therefore, the question of how exactly the additional requirement to confirm an applicant’s physical presence in temporarily occupied territory arose, and which regulatory provisions justified it, remains open.

“We know how strict filtration can be”

To an outsider, the advice to take a selfie with a newspaper may seem like a minor issue. But for those who work with residents living under occupation and know how filtration works when people leave occupied territories, it looks very different.

Violeta Artemchuk explains that simplified admission has never meant that a person would study online permanently. Sooner or later, applicants still have to leave for territory controlled by Ukraine, in particular to take exams or submit original documents. And it is precisely at this stage that the digital traces left during the admission process become dangerous.

“If online admission is generally allowed, that does not mean you can study online the entire time. At some point, you still have to leave, travel to territory controlled by Ukraine, and submit your documents. And we simply know how difficult it is to leave, what kind of filtration people undergo there, and what they can be detained for”, - she says.

According to her, partner organizations systematically prepare people for departure: they help “clean” their phones of any traces of pro-Ukrainian activity and provide safety recommendations. However, no amount of preparation guarantees a 100% success rate — it is difficult to predict exactly what will attract attention during an inspection. Violeta Artemchuk gives an example: a young man carefully cleaned his phone before leaving but forgot to delete a sticker reaction he had created himself in Telegram, depicting the Ukrainian flag — and it was precisely because of this that he failed to pass filtration.

“And here there will be photographs from the central squares of cities”, - she concludes, referring to the fact that the Ministry of Education and Science’s requirement effectively obliges applicants to create potentially incriminating digital evidence themselves, which they will then have to store somewhere — and risk having it become the very reason for their detention when leaving.

That this is not a matter of isolated instances of overreach at the local level, but rather a systematic policy, is confirmed by the Ministry of Education and Science’s letter No. 1/15004-26 of July 10, 2026, “On the Specifics of Exercising the Right to Special Conditions for Participation in the Competitive Selection Process by Persons Whose Place of Residence Is Registered in Temporarily Occupied Territories/Temporarily Occupied Territories of the Autonomous Republic of Crimea and the City of Sevastopol”. The document, a copy of which was obtained by the NGO Donbas SOS, was also sent to the heads of higher and pre-higher professional education institutions and the state-owned enterprise Inforesurs — that is, to the bodies directly administering the admission campaign.

In an appeal to the Minister of Education and Science, nine civil society organizations present two systemic arguments in support of their position that the requirement poses a real threat to the lives and health of applicants and their families.

First, russia systematically monitors the online activity of children and young people in occupied territories, viewing Ukraine as a source of “extremism”. The authors of the appeal cite data from the State Committee for Youth Policy of the Republic of Crimea, according to which more than 500,000 accounts were monitored on the peninsula in the first half of 2024 alone. This resulted in criminal cases and administrative proceedings being initiated over the distribution of materials demonstrating a connection to or interest in Ukraine.

Second, a systematic practice has been documented in temporarily occupied territories whereby security forces inspect and confiscate phones and other devices belonging to young people and their parents — during targeted searches, as well as random checks on the street or even in schools. The contents of these devices are analyzed for pro-Ukrainian content, installed applications (Ukrainian banks, Diia, Rezerv+), subscriptions to Ukrainian media outlets and Telegram channels, and correspondence with people in territory controlled by Ukraine. Any material found can become grounds for detention, fines, and criminal prosecution, and, according to human rights reports cited by the authors of the appeal, even torture.

In this context, the requirement to independently create “proof” of being in occupied territory — a photograph with geolocation or a selfie with printed materials — appears to directly contradict the “do no harm” principle, the authors of the appeal emphasize. The state’s public interest in verifying and confirming an applicant’s presence in temporarily occupied territory is effectively being placed above its obligation to ensure the child’s safety — whereas it is precisely the state that should be guaranteeing that safety.

Another aspect of the problem is legal and logical, and this is precisely what Violeta Artemchuk focuses on. In effect, the burden of proving one’s own safety and legitimacy has been shifted onto applicants: instead of the state having to prove its suspicions of fraud, applicants themselves must prove in advance that they are not trying to circumvent the system.

According to her, cases of actual fraud, in which a person has in fact left for territory controlled by Ukraine but claims to be a resident of temporarily occupied territory in order to take advantage of preferential admission conditions, are theoretically possible. However, such cases should be addressed selectively, examining each individual situation after the fact, rather than introducing a blanket requirement that affects all applicants at once — including those who are genuinely living under occupation and face real risks.

In response to the civil society organizations’ appeal regarding this requirement, the Ministry of Education and Science sent a letter which, according to Violeta Artemchuk, stated that a person is already in danger while in temporarily occupied territory, that leaving also poses a danger, and therefore the additional requirement supposedly does not create any new risks for them. The coordinator says there was no further communication with the Ministry after that letter: “I don’t know how to communicate with them further. As of now, we don’t know”.

Consequences

Even human rights activists themselves find it difficult to assess the exact scale of the problem in figures. The Ministry of Education and Science publishes general statistics on applicants in preferential categories — internally displaced persons, residents of frontline areas, and residents of occupied territories — without breaking them down further. Therefore, it is impossible to determine how many applicants come specifically from occupied territories.

“We believe that the share of applicants coming directly from occupied territories is getting smaller and smaller. But overall, the number of applicants eligible for simplified admission, including internally displaced persons and residents of frontline areas, is growing”, - says Violeta Artemchuk.

The human rights activist warns that if the new requirements remain in place in the future, this could become an additional barrier that would critically reduce the number of applicants from occupied territories, as well as the number of young people and families with children who ultimately decide to leave for territory controlled by Ukraine.

For many residents of occupied territories, higher education is one of the few legal and safe reasons to leave.

“I believe that there are more and more obstacles to admission. This is precisely where a contradiction arises against the backdrop of what is being declared: ‘We are waiting for you’. Leaving is becoming more difficult, and admission is becoming more difficult”, - she emphasizes.

In their appeal to the Ministry of Education and Science, civil society organizations demand the immediate cancellation of the requirement for applicants who are in temporarily occupied territories of Ukraine to provide educational institutions with documents issued by occupation authorities to confirm their presence under occupation, or to create any digital materials for this purpose. Instead, they call for the development of a safe, clear, and comprehensive mechanism for confirming the relevant circumstances, based exclusively on documents and information obtained from Ukrainian state registers and other safe sources.

The 2026 admission campaign has effectively already ended, so it is formally too late to change the rules for current applicants — Violeta Artemchuk herself says this directly: “We will not change the situation this year. But it needs to be changed for the future.”

The key question now is whether the Ministry of Education and Science will have time to reconsider its approach for the next admission campaign, and whether human rights organizations will receive a substantive response to their appeal beyond the July letter already received outlining the Ministry’s position. For now, according to the coordinator of Donbas SOS, filtration when leaving occupied territories is only becoming stricter, meaning that every new digital trace applicants are forced to leave in order to have the right to receive Ukrainian higher education increases, rather than reduces, the risk to them personally and to their families.

By Vladyslav Bulatchik, OstroV