This report is the result of dedicated collective work, but it would not have been possible without the courage of those who agreed to speak to us. Sharing their statements required extraordinary determination and effort. We are sincerely grateful to everyone who entrusted us with their stories.
In preparing this report, we faced a difficult choice—which of the numerous crimes to focus on and which to leave outside the scope of this study. Ultimately, we decided that this report should primarily be a study of the occupation itself, of both the city and the plant, of cases of torture of civilians, and of the threats posed to nuclear safety and security. At the same time, we considered it important to focus on an enabler of the reported crimes and breaches.
Executive Summary
Russia’s seizure of the city of Enerhodar and the Zaporizhzhia Nuclear Power Plant (ZNPP) in March 2022 marked an unprecedented event in modern history: the first military occupation of a functioning commercial nuclear power plant. This occupation, now into its fourth year, has seen a convergence of human rights abuses, breaches of international law, and acute nuclear safety and security risks, with profound national and global consequences.
This report examines the occupying forces’ physical and administrative takeover of Enerhodar and the ZNPP, the systematic torture and persecution of civilians, including plant personnel, and the deep integration of Russia’s state nuclear corporation, the Rosatom State Atomic Energy Corporation (hereafter, Rosatom), into the governance of occupied Enerhodar and the crimes themselves. Based on months of investigative research, the report reveals how Rosatom’s corporate, administrative, and financial structures have been weaponized in the service of military control and led to the suppression of resistance, the commission of serious crimes, and the compromising of nuclear safety and security. The findings underscore the urgent need for coordinated international action to halt ongoing violations, protect nuclear safety and security, and hold perpetrators accountable.
When Russian forces captured Enerhodar on March 4, 2022, less than two weeks after the full-scale invasion of Ukraine began, they took control of the ZNPP, the largest nuclear power plant in Europe. Russian troops held critical infrastructure in Enerhodar, but Ukrainian municipal authorities continued to try to function, organizing evacuations, maintaining public services, and sustaining citizen morale. Civilian resistance led to thousands demonstrating against the occupation. This fragile arrangement collapsed in late March and early April, when Russian forces dismantled Ukrainian governance systems, replacing them by force with parallel administrative bodies. Repression and violence quickly became systematic, targeting territorial defense volunteers, pro-Ukrainian activists, and ZNPP staff who refused to collaborate, among others.
Russian forces established at least seven detention sites in Enerhodar and the surrounding area, including two smaller-scale facilities. Truth Hounds has documented how the Russian occupation unlawfully detained at least 226 Enerhodar residents and ZNPP employees, most of them in severely overcrowded facilities where detainees were subjected to physical and psychological torture to extract information, force confessions, punish dissent, intimidate, and coerce collaboration. Russian forces deprived detainees of food, water, and medical care, contrary to the provisions of international law. Torture, including beatings, electrocution, sexual violence, mock executions, and threats to family members of detainees, became routine.
Interrogations often sought intelligence on resistance activities, weapons, and Ukrainian military ties. Some detainees were compelled to sign cooperation agreements or contracts with Rosatom and many were filmed making false statements praising Russian forces or discrediting Ukraine for propaganda purposes.
Truth Hounds research indicates that such abuses were widespread and systematic acts directed against civilians that constitute war crimes and crimes against humanity under international law. Furthermore, licensed plant personnel and specialists with unique technical skills critical to reactor safety were deliberately targeted, compromising the safe operation of the facility and heightening the risk of a nuclear accident.
By Fall 2022, Russia had consolidated its control through a staged referendum, decrees transferring the ZNPP to Russian jurisdiction, and the disconnection of the Plant from Ukraine’s energy grid. Enerhodar’s population fell from 50,000 before the occupation to roughly 10,000 by March 2025. Rosatom played a central role in this consolidation. Municipal budgets became dependent on subsidies and grants channelled through the corporation, with key positions in the occupying administration filled by individuals with Rosatom or nuclear-sector backgrounds, replicating governance models from Russia’s “atomic cities”. Rosatom representatives or those acting on their behalf coerced ZNPP staff into signing contracts and pledging compliance with the occupation. The corporation’s status as a “state corporation” under Russian law, which combines commercial activity with state functions, enables it to serve both as an economic actor and an implementer of occupational policy. Its continued presence in global nuclear markets provides resources and expertise to sustain the occupation itself.
The conduct of Russian forces and occupying authorities in Enerhodar and at the ZNPP amounts to serious breaches of international humanitarian law (IHL) as war crimes and to crimes against humanity. The unlawful confinement, torture, and inhumane treatment of civilians violate the Rome Statute and the Geneva Conventions, while the targeting of civilian nuclear facilities contravenes Additional Protocol I (AP(I)). Rosatom’s active role in coercive practices may give rise to state responsibility and corporate liability under international law. Furthermore, the integration of a state-owned corporation into the machinery of occupation and repression is a troubling and dangerous reality that warrants greater international action to hold corporate actors to account for their role in the commission of these crimes.
The risks of nuclear disaster at the ZNPP remain real and demonstrate Russia’s fundamental disregard for well-established international norms on nuclear safety and security. The occupation’s coercive recruitment of plant personnel and the broader climate of fear in and around the ZNPP violate the International Atomic Energy Agency’s (IAEA) “Seven Indispensable Pillars of Nuclear Safety and Security”, especially the principle that staff must operate free from undue pressure. Intimidation, loss of qualified staff, and severed ties to Ukraine’s regulatory systems have eroded the Plant’s safety culture, creating nuclear risks with international implications. As of September 2025, the ZNPP remains under de facto Russian control. The six reactors at the Plant have been in shutdown since September 2022, but, in May 2025, Rosatom chief Alexey Likhachev announced approval of a plan to restore the Plant’s full generating capacity, including the replacement of the power grid. There is evidence of new power lines connecting the Plant to the Russian grid. The major nuclear hazards that currently exist at the ZNPP would become severe in the event of Rosatom restarting one or more reactors, with the potential for very large releases of radioactivity into the environment of Ukraine and Europe.
These crimes and nuclear safety and security risks are taking place against a backdrop of renewed diplomatic discussions about ending hostilities. The ZNPP’s fate was among the issues raised in these talks, with Russia declaring it will never transfer control and the Ukrainian government insisting that full Ukrainian control is the only way to restore safety. International actors have proposed international oversight of the Plant, but lack any meaningful agreement.
This report is based on 39 in-depth interviews with survivors and witnesses—including 20 ZNPP staff members—conducted in Ukrainian and Russian, anonymized for security, and gathered in line with ethical field research standards, as well as an additional testimony from 17 former Enerhodar residents provided by the Association of Relatives of Political Prisoners of the Kremlin. Truth Hounds also monitored and analyzed open-source information from media outlets, local Telegram channels, official social media channels, leaked databases, and other open-source material to document administrative changes, civilian restrictions, social dynamics, and military presence in and around Enerhodar. The research incorporated an analysis of Rosatom’s governance, operations, and global activities, drawing on official Russian sources, corporate reports, and other specialized sources. To assess nuclear safety and security risks, the team consulted a Greenpeace Ukraine nuclear expert and interviewed former ZNPP nuclear professionals. Legal experts reviewed evidence to evaluate potential violations of IHL and international criminal law (ICL), with cross-verified findings through both witness testimony and open-source data to generate a comprehensive analysis of the occupation’s impact.
The implications of recent events in Enerhodar and at the ZNPP are not confined to Ukraine. The operational degradation of the ZNPP, its proximity to active hostilities, and the erosion of safety culture threaten nuclear security across Europe and potentially beyond. A severe incident could disperse radioactive materials over vast areas, with grave humanitarian, environmental, and economic consequences.
Truth Hounds and Greenpeace Ukraine call for immediate and decisive international action. Criminal justice actors in relevant jurisdictions should initiate investigations and legal proceedings against individuals and entities responsible for war crimes, crimes against humanity, and nuclear safety violations in Enerhodar and at the ZNPP. Key stakeholders should urgently impose expanded sanctions on Rosatom and its subsidiaries, targeting the financial flows that sustain the occupation. The IAEA’s on-site inspection team must be granted full and unimpeded access to the Plant’s staff and all relevant areas of the ZNPP. Independent monitoring of human rights conditions in Enerhodar and any detention facilities is essential, with priority given to protecting plant personnel. The United Nations (UN) bodies should also do more to publicly condemn the situation at the ZNPP and ensure systematic monitoring and reporting of human rights abuses, violations of international law, and risks to nuclear safety. In any ongoing negotiations, priority should be given to restoring the ZNPP to Ukrainian control.
The occupation of Enerhodar and the ZNPP is a uniquely dangerous convergence of systematic repression, breaches of international law, and risk of nuclear catastrophe. With Russia signaling its intent to restart the Plant under unsafe conditions, the dangers are accelerating. Inaction will not only abandon the survivors of abuses in Enerhodar, but also expose the world to the possibility of a nuclear disaster. The international community must treat the ZNPP crisis as a global security priority, acting to restore safety, uphold the rule of law, and prevent the establishment of a precedent of the militarization of civilian nuclear facilities, such as the ZNPP.
Truth Hounds compiled this report with the support of donors:
We wish to acknowledge the generous support of the Howard G. Buffett Foundation. Its commitment to this work and PEJ’s and Truth Hounds’ project «Restraining a Doubt Machine: Truth-Telling about Atrocity Crimes in Ukraine through Strategic Litigation and Advocacy Campaigns» ensures that the world will learn of the full scope and scale of Russia’s acts and that the Ukrainian people will ultimately obtain justice. We are grateful for their belief in our work and dedication to the cause of justice for Ukraine.
This publication was produced with the financial support of the European Union. Its contents are the sole responsibility of Truth Hounds and do not necessarily reflect the views of the European Union.
This report draws on the technological resources of the I-DOC database developed by Case Matrix Network, and made available with the support of our partner, the Norwegian Helsinki Committee, a Norway-based international human rights organization committed to the promotion and protection of human rights, democratic values, and the rule of law.
Recommendations
To foreign governments and criminal justice authorities:
Investigate crimes under universal jurisdiction, including:
- Investigations into torture and other serious violations of IHL in Enerhodar, including Rosatom’s potential complicity; and
- Investigate these abuses as crimes against humanity, given their widespread and systematic nature and hold both individual perpetrators and corporate enablers, including Rosatom, accountable.
End cooperation with Rosatom, including by:
- Suspending or terminating existing contracts with Rosatom and its subsidiaries due to their involvement in serious IHL violations;
- Not entering into new partnerships with Rosatom, given its legal, ethical, and reputational risks; and
- Banning Rosatom-linked entities from public procurement and energy sector partnerships.
Impose expanded targeted sanctions by:
- Broadening and imposing punitive sanctions against Rosatom, especially in the EU and other states yet to act, including:
- Bans on new contracts and existing nuclear cooperation;
- Restrictions on equipment, services, and technology exports;
- Financial sanctions—asset freezes and transaction bans;
- Export/import controls on nuclear materials, especially enriched uranium; and
- Sanctions on Rosatom subsidiaries tied to military procurement and nuclear weapons development; and
Call on Russia to release all unlawfully detained Ukrainian civilians, including Enerhodar residents and ZNPP employees.
To the bodies of the UN:
1. The UN Secretary General:
- Appoint a Special Envoy for the Protection of Civilian Infrastructure and Nuclear Safety in Armed Conflict who is mandated to:
- Coordinate international efforts to ensure the demilitarization of the ZNPP and the protection of nuclear facilities in Ukraine;
- Engage directly with all relevant parties, including the Russian Federation, to secure the immediate withdrawal of military personnel and equipment from the plant;
- Serve as a dedicated focal point for monitoring threats to nuclear facilities in conflict zones or areas at risk of political instability, including nuclear power plants in regions with rising tensions and report regularly to the UN Security Council and General Assembly on the status of the ZNPP and other critical civilian infrastructure;
- Facilitate cooperation with the IAEA and the Office of the High Commissioner for Human Rights (OHCHR) to ensure independent monitoring, risk assessment, and accountability for IHL violations; and
- Reinforce international norms under IHL and human rights law regarding the protection of nuclear infrastructure, advocate adherence to the IAEA’s Seven Indispensable Pillars of Nuclear Safety and Security and to the Five Concrete Principles in all conflict-affected areas, and push for the inclusion of nuclear safety protections in UN Security Council resolutions, peacekeeping mandates, and ceasefire agreements.
2. OHCHR:
- Increasing monitoring and public condemnation by:
- Incorporating findings on systematic detention and torture in Enerhodar into OHCHR reports and deploying investigative teams; and
- Publicly calling for the immediate release of unlawfully detained civilians, including Enerhodar residents and ZNPP staff.
3. UN Global Compact:
- Assess Rosatom’s compliance with UN Global Compact principles. If violations are confirmed, immediately suspend its membership to uphold the Compact’s integrity.
To the IAEA:
- Publicly document and attribute safety violations by:
- Moving beyond generic safety updates to specifically document instances where occupational practices violate both the IAEA’s Seven Indispensable Pillars and the Five Concrete Principles, naming the responsible party when evidence is clear;
- Publishing frequent and detailed public reports, with annexes containing factual incident logs, timelines, and photographic or sensor evidence; and
- Briefing the UN Security Council and General Assembly with clear language on violations, highlighting both immediate risks and structural threats caused by military control and staff coercion; and
Demand Rosatom’s full compliance with both the Seven Pillars of Nuclear Safety and Security and the Five Concrete Principles at the ZNPP and work to prevent any restarting of the plant under military occupation without independent oversight.
To the Council of Europe Commissioner for Human Rights:
Conduct a thematic investigation and public reporting, including by:
- Launching a special thematic report on human rights violations against ZNPP personnel and Enerhodar residents, documenting arbitrary detention, torture, coercion, and restrictions on freedom of movement, highlighting the direct connection between these abuses and compromised nuclear safety culture;
- Including ZNPP-related findings in annual or ad hoc reports to the Committee of Ministers and Parliamentary Assembly of the Council of Europe;
- Issuing formal public statements naming Russia’s treatment of ZNPP staff and Enerhodar civilians as violations of the European Convention on Human Rights and IHL; and
- Organizing public hearings or expert panels focused on “Human Rights in Occupied Nuclear Facilities”, using the ZNPP as the primary case study to highlight the connections between the nuclear safety threat and the grave human rights emergency in and around the ZNPP.
To Ukrainian State institutions:
1. The Ministry of Foreign Affairs:
- Integrate report findings into diplomatic efforts, international statements, and submissions to global bodies.
2. Enerhoatom (Ukraine’s state-owned nuclear power generation company):
- Use these report findings in public communications and international engagement with nuclear institutions.
3. The Office of the Prosecutor General:
- Include evidence from this report in ongoing investigations of IHL violations in Enerhodar, addressing both individual and institutional accountability, including Rosatom; and
4. Law enforcement:
- Ensure legal assessments of ZNPP personnel and civilians under occupation reflect the coercive environment, including torture and threats, limiting voluntary agency.
To nuclear sector businesses:
- Cease all direct and indirect ties with Rosatom due to its role in grave human rights violations and nuclear safety breaches.
To international trade unions:
- Publicly condemn Rosatom’s involvement in human rights abuses, war crimes and crimes against humanity; and
- Mobilize members to demand governments cut ties with Rosatom and support persecuted Ukrainian energy workers.
To civil society organizations, environmental activists, and the academic and scientific communities:
- Publicly recognize the ZNPP as a high-risk environmental and public health issue;
- Raise awareness of the situation at the ZNPP and demand justice by engaging governments, supporting justice and accountability for torture survivors and detainees, and conducting further research to further elucidate the issues detailed in this report;
- Advocate for full compliance with international safety standards, oppose any plant restart under occupation and push for the site’s demilitarization;
- Further engage with ways in which survivors of repression and their families can be assisted in terms of psychological, legal, and humanitarian support; and
- Call on Russia to release all unlawfully detained Ukrainian civilians, including Enerhodar residents and ZNPP employees.
This list of recommendations and addressees is not exhaustive. Institutions, organizations, and individuals with the capacity and mandate to advance the objectives outlined above are also encouraged to take appropriate action to prevent further safety, security, and human rights breaches and to ensure accountability for the violations examined in this report.
Truth Hounds compiled this report with the support of donors:
We wish to acknowledge the generous support of the Howard G. Buffett Foundation. Its commitment to this work and PEJ’s and Truth Hounds’ project «Restraining a Doubt Machine: Truth-Telling about Atrocity Crimes in Ukraine through Strategic Litigation and Advocacy Campaigns» ensures that the world will learn of the full scope and scale of Russia’s acts and that the Ukrainian people will ultimately obtain justice. We are grateful for their belief in our work and dedication to the cause of justice for Ukraine.
This publication was produced with the financial support of the European Union. Its contents are the sole responsibility of Truth Hounds and do not necessarily reflect the views of the European Union.
This report draws on the technological resources of the I-DOC database developed by Case Matrix Network, and made available with the support of our partner, the Norwegian Helsinki Committee, a Norway-based international human rights organization committed to the promotion and protection of human rights, democratic values, and the rule of law.