a. Freedom of Expression, Including for Members of the Press and Other Media
The law provides for freedom of expression, including for the press, but government respect for this right remained poor. Intimidation, harassment, political pressure, and threats, including death threats, against journalists and media outlets, continued during the year. While threats and pressure against journalists persisted, BH Journalists, a professional association, noted an increase in the number of cases resolved in favor of journalists whose rights were violated. To advance efficiency and standards, the Sarajevo Canton Prosecutors Office improved the process of documenting cases of violations of the rights of journalists and appointed a prosecutor to facilitate communication between relevant institutions and journalist associations. Numerous restrictive measures introduced to deal with the COVID-19 pandemic continued to limit access to information and limit the presence of journalists at events otherwise open for media coverage. Media coverage was increasingly dominated by nationalist rhetoric and ethnic and political bias, often encouraging intolerance and sometimes hatred, especially prior to the October elections. The absence of transparency in media ownership remained a problem. Ownership of online media remained opaque in many instances. For many broadcast and print outlets, only information concerning nominal ownership was available.
Freedom of Expression: The country’s laws provide for a high level of freedom of expression, but the implementation and application of the law seriously undermined press freedoms. The law prohibits expression that provokes racial, ethnic, or other forms of intolerance, including “hate speech,” but authorities enforced these restrictions only occasionally and never for online media. In 2021, the high representative for BiH amended the criminal code of the country to sanction genocide denial, the glorification of war crimes, and the incitement of racial, religious, or ethnic hatred, and violence, but as of November no persons had been indicted or prosecuted for these acts. According to the Srebrenica Memorial Center, denial of genocide decreased by nearly 80 percent as of July since the legislation was amended.
Violence and Harassment: Intimidation, violence, politically motivated litigation, and threats against journalists were recorded during the year. As of July, the Free Media Help Line (FMHL) recorded 40 cases reported by media outlets involving alleged violations of journalists’ rights and freedoms, including five death threats and one physical assault. On October 26, Zoran Cegar, head of the Federation Uniformed Police Sector, threatened a journalist from the Center for Investigative Journalism (CIN) from Sarajevo. A CIN journalist was working on a story on Cegar’s acquisition of multimillion-dollar properties in BiH and Croatia and contacted him to request an interview. Cegar refused and threatened and cursed at the journalist over the phone, saying “Don’t even think of calling me again, so that I don’t come to you from where you’re calling me,” and calling the journalist a “Chetnik,” a term referring to Serbian nationalist fighters which is often used as a derogatory term for Serbs in general. The following day, a CIN journalist asked Cegar for comment in front of the Dubrovnik Municipal Court in Croatia, where Cegar’s trial for fraud began. Cegar reacted violently and threatened “Don’t make me rip your throat out!” On November 3, at the request of the FBiH Minister of Interior, Aljosa Campara, deputy Director of the Federation Police Administration Ensad Korman suspended Cegar from his position.
During the election campaign, SNSD president and then Serb member of BiH Presidency Milorad Dodik often made negative comments regarding the Bijeljina-based television station, BNTV. At a SNSD rally in Banja Luka in September, two attendees physically attacked a BNTV cameraman because he refused to stop filming their improperly parked truck with SNSD signs. BH Journalists condemned the incident.
In October following the general elections but before results were announced, Dodik’s daughter Gorica tweeted a photo of High Representative Christian Schmidt and BNTV owner Vladimir Trisic, captioned “Hitler and his servant.” In response, BH Journalists called on BiH institutions to appropriately prosecute threats and hate speech against journalists via social networks. The largest Bosniak ethno-nationalist party, the SDA, continued to malign Sarajevo-based Face TV owner Senad Hadzifejzovic and his family. SDA member Faruk Kapidzic wrote on Facebook that Hadzifejzovic was a “sick journalist,” a “blackmailed coward,” and a “thief.” These insults were a reaction to a satirical piece aired on Face TV that included compromising photos of SDA officials picked up from social media. There were numerous similar abuses across the country.
In May a well-known blogger and columnist from Banja Luka, Srdjan Puhalo, faced online harassment, including death threats, after he published a commentary on Analiziraj.ba, questioning the often-cited number of children killed in Sarajevo during the war and offering a cash reward to anyone who could prove the claimed figure was correct. Critics challenged Puhalos’s reputation and alleged he was involved in the war. Very few outlets stood by Puhalo, advocated for his right to ask a question, or condemned hate speech and threats he faced. Jasmila Zbanic, a film director from Sarajevo whose movies regarding the 1990s war and most recently concerning the Srebrenica genocide have been internationally recognized, strongly supported Puhalo. BH Journalists and the regional Safe Journalists Network defended Puhalo’s freedom of expression, asking police and judiciary authorities to investigate and sanction the propagators of hate speech and all those who endanger Puhalo’s the personal and professional rights of Puhalo.
The number of verbal attacks against journalists increased during the year. Attacks on journalists’ professional integrity and freedom of the press continued throughout the reporting period. Disrespect toward journalists and journalism continued, becoming a dominant behavior of politicians across the country. When asked questions they disliked, BiH politicians often reacted with insults based on gender, age, ethnic or political affiliation, trying to discredit journalists, categorizing them as incompetent or as political puppets. In March then Serb member of the BiH Presidency and the leader of the ethno-nationalist SNSD Milorad Dodik showed his middle finger to a group of camera crews as he passed by on his way to a hearing at the BiH Prosecutors Office. On his way back, Dodik repeated the gesture. When criticized for his actions, he apologized and claimed that he had aimed his finger only at the crews of BNTV and Avaz, not the entire journalist community. BH Journalists called on the media community to boycott Dodik’s press events until he apologized to all journalists, which he did not do. In April President of the Social Democratic Party Nermin Niksic stopped N1 journalist Suncica Sehic, grabbed her by her hand, and called her “pathetic.” Sarajevo Canton Prime Minister Edin Forto in a TVSA television program shouted at a journalist, attempting to discredit her questions. The BH Journalists Steering Board issued a press release, protesting the disrespectful behavior of politicians toward women journalists.
BH Journalists noted that gender-based attacks and pressure against journalists increased during the year. According to the FMHL, the number of threats against women journalists has rapidly grown over the last three years with almost 70 registered cases. Approximately 50 percent of these threats came from politicians and other elected officials.
In April the Sarajevo Canton Prosecutor’s Office, supported by the Organization for Security and Cooperation in Europe (OSCE) Mission to Bosnia and Herzegovina, appointed a prosecutor in charge of communicating and coordinating with the journalists’ associations and law enforcement agencies in cases of criminal acts against persons who perform tasks of public importance in the field of information. Sarajevo-based commentators considered this a positive initiative for the protection of journalists, which remains to be tested and could be expanded.
Censorship or Content Restrictions for Members of the Press and Other Media, Including Online Media: The Communications Regulatory Agency received six complaints related to hate speech but did not determine any case as in the broadcast media constituted hate speech. The Press Council, which operates as a self-regulatory membership-based body for both online and printed media outlets across the country, registered 110 complaints related to hate speech, out of which eight complaints were related to articles published in online media. As of September, 81 complaints had been resolved through the media outlets publishing retractions, providing corrections to the text in dispute, or removing the comments in question, depending on what the Press Council asked them to do to resolve the dispute.
Political and financial pressure on media outlets to influence editorial policies and content continued. According to information provided by media outlets, tax authorities used tax audits to punish critical media, conducting the audits without justification. These authorities, assumed to be acting under the direction of ruling political parties, used audits and allegations of tax evasion to intimidate and censor outlets. A broader economic downturn also continued to erode the financial stability of media across the country, often forcing them to scale back their operations and making them more vulnerable to outside pressure.
Public officials obstructed the work of journalists. This period was marked by attempts to restrict access to information in several areas. Restrictions imposed during the pandemic remained in place. Institutions continued selectively closing events to media coverage by using the pandemic as an excuse. In February the Tuzla Cantonal Assembly held a session discussing a vote of no confidence for the government and closed it to the press because of “pandemic restrictions,” despite having allowed media presence previously when COVID-19 cases were more numerous. BiH Journalists note that similar practices were registered throughout the country.
The practice of pressuring journalists to censor their reporting continued during the year. Reaction to investigative stories focusing on the corruption of high-level judicial officials and their lack of accountability continued generating pressure on journalists. Additionally, reports that challenged official narratives provoked pressure and threats. In August, Franjo Sarcevic, editor in chief of the Sarajevo-based web portal Prometej.ba, his editorial team, and family members were threatened with violence, first by the Stav political magazine, closely associated with Bosniak ethno-nationalist SDA, and later by a wider social network community. These threats came after his web portal presented opinions different from SDA’s regarding the High Representative’s proposed changes to the BiH election law and FBiH constitution as well as corresponding protests in front of the Office of High Representative in Sarajevo in August. BH Journalists reacted by strongly condemning hate speech and the campaign against Sarcevic. At the beginning of August, Oslobodjenje Editor in Chief Vildana Selimbegovic published and tweeted out an op-ed on possible changes to the election law. This provoked harsh social media reactions against Selimbegovic. In addition to misogynous and insulting comments, one of the replies was a threat, saying if the legislation was adopted, “she would be looking into a pit.”
In January BH Journalists Secretary General Borka Rudic and UNA TV journalist Sladjan Tomic received threats via Facebook from Jasmin Mulahusic, a Luxembourg resident, who was reported to police. Mulahusic, arrested in BiH in 2011 for fanning hatred, national and racial intolerance, also threatened Selma Fukelj, a Media Center journalist and Editor in Chief of Inforadar.ba, and journalist Almedin Sisic. Sisic also received threats from Semir Fruska from Travnik, who said that a group would visit him “to test his courage.” All these incidents were reported to police. The BiH Prosecutor’s Office is in the process of investigating Mulahusic, who continued to use his social media accounts to target journalist and media outlets throughout the country.
Authorities continued to exert pressure on media outlets to discourage some forms of expression, and party and governmental control over some news outlets narrowed the range of opinions represented in both entities. Public broadcasters at the state (BHRT) and entity level (RTV FBiH and RTRS) continued to operate without stable and sustainable income that would enable independent editorial policy. They remained exposed to political influence, especially through politically controlled steering boards, because existing legal solutions failed to provide mechanisms that protect editorial independence. Independent analysts stated that limiting the competencies of entity parliaments in the process of the appointment of the steering boards of public broadcasters remained crucial for their editorial independence.
RTV FBiH continued to demonstrate a selective approach to news. The RS government continued to increase its direct control of RTRS, which strongly amplified the positions and narratives of the ruling coalition in the RS entity. Failure to implement the state-level Law on Public Broadcasting and to implement the established system of subscription fee collection has led BHRT to the brink of bankruptcy, forcing it to downscale operations. Entity broadcasters were in charge of collecting subscription fees and sharing a portion of them with BHRT, but they failed to do so. State-level parliament’s failure to adopt systematic solutions to ensure BHRT sustainability continue to threaten the future of this state-level broadcaster. Authorities remained subject to competing political interests and failed to establish a public broadcasting service corporation to oversee the operations of all three public broadcasters in the country as envisioned by the law.
The Communications Regulatory Agency, which regulates the audiovisual media market, lacked full financial and political independence. The mandate for its Council expired at the end of 2017, but the parliamentary commission for the appointment of the council had not decided on its mandate renewal by the end of the year. The agency repeatedly warned that a major delay in switching from analogue to digital broadcasting could have dangerous consequences on media plurality in the country.
Multiple political parties and entity-level institutions attempted to influence editorial policies and media content through legal and financial measures and through political pressure. As a result, some media outlets practiced self-censorship. Government institutions restricted access to information concerning ongoing corruption cases and the improper use of public funds and foreign investments. For example, Transparency International BiH (TI BiH) filed a case with a district court against RS Ministry of Traffic in 2021 for restricting access to information on details about a potentially problematic contract on the concession for the Banja Luka-Prijedor highway. The court ruled in favor of TI BiH and ordered the ministry to provide the requested information to TI BiH. TI BiH also turned to the Human Rights Ombudsman, which requested that the ministry provide the information sought by TI BiH. The court ruling and the Ombudsman’s recommendation, however, were not implemented by year’s end. Cases of allowing only selected media representatives to cover events were noted. In some instances, media sources reported that officials threatened outlets with loss of advertising or limited their access to official information. Prevailing practices reflected close connections between some major advertisers and political circles and resulted in biased distribution of advertising time. Public companies, most of which were under the control of political parties, remained the key advertisers. Outlets critical of ruling parties claimed they faced difficulties in obtaining advertising. Numerous restrictions related to the pandemic continued to have a direct negative impact on the finances of media in the country, making them more vulnerable to economic and political pressure.
Reacting to unfavorable media reports about him, Elmedin Konakovic, president of the Narod i Pravda political party, labeled online news portals in question as “regime affiliated” and “liars,” accusing them of campaigning against him.
Libel/Slander Laws: While the country has decriminalized defamation, many complaints continued to be brought before courts against journalists, often resulting in extremely high fines. The Press Council of BiH noted that public figures, politicians, judicial officials, and directors of public companies were predominantly the ones filing complaints. Professional organizations noted that the practice of demanding extremely high compensations continued.
A first instance court ordered online media outlet Zurnal, known for its investigative reporting, to pay more than 170,000 KM ($102,000) in a 2021 defamation case. Zurnal appealed the ruling, but no ruling on the appeal was made as of year’s end. BH Journalists expressed deep concern that such high fines and penalties could seriously jeopardize the work and business operations of media outlets, noting the need for balance between economic sustainability of media, public interest, and individual right to compensation.
Defamation cases continued to be used to exert both financial and political and financial pressure on media and journalists, jeopardizing the right to freedom of expression. Data from the FMHL and the Press Council indicated that the number of defamation cases against journalists and editors remained high. Courts continued to fail to differentiate between different media formats (e.g., news versus commentary), while long court procedures and legal and financial battles were financially exhausting to journalists and outlets. Data available from FHML indicated that 80 percent of defamation cases were initiated by government officials or politicians. Professional organizations note that courts impose enormously high damage compensation claims with increased frequency.
According to Amnesty International, two environmental activists faced baseless defamation charges in a Sarajevo court from BUK, a hydropower company in BiH owned by Belgian company Green Invest. BUK pursued defamation cases against the activists after they expressed concerns over the potential environmental impact of the company’s hydropower plants on the Kasindolska River. Amnesty International claims that this lawsuit fits into a broader pattern of corporations using strategic lawsuits for public participation to stifle activists.
Restrictions on Academic Freedom and Cultural Events
The government did not restrict or disrupt access to the internet or censor online content, and there were no credible reports that it monitored private online communications without appropriate legal authority.
Restrictions on Academic Freedom and Cultural Events
There were some government restrictions on academic freedom. The cantons of Tuzla and Sarajevo have laws that could restrict the independence and academic freedom of universities within their jurisdictions by allowing elected municipal authorities to hire and fire university personnel, including academics, at their discretion. Staff at these faculties reported, however, that while the laws have not changed, the situation improved and there were no reports of restrictions being enforced.
The country’s eight public universities remained ethnically segregated, including their curricula, diplomas, and relevant school activities. Professors reportedly on occasion used prejudicial language in their lectures, while the selection of textbooks and school materials reinforced discrimination and prejudice.
b. Freedoms of Peaceful Assembly and Association
The laws provide for the freedoms of peaceful assembly and association, but there were cases when the government limited such freedoms.
Freedom of Peaceful Assembly
The law provides for freedom of peaceful assembly, and the government generally respected this right. Leaders of the informal group Justice for David, however, reported harassment by RS police in Banja Luka.
The Justice for David movement emerged in response to the 2018 killing of David Dragicevic, age 21, which remains unsolved. Dragicevic’s family mobilized thousands of citizens in support of their search for the facts of the killing and demand for justice. The RS entity government justified its decision to ban all public gatherings of the group, including protests, claiming the movement failed to fully respect the law during previous rallies. Some journalists and protesters alleged that during the arrests police used excessive force on Justice for David protesters and produced photographs that appeared to support their claims.
Justice for David gatherings in Banja Luka have taken place without major incidents. A large rally for David Dragicevic was held in Sarajevo in 2021. After allegations of a cover-up and failure by RS entity authorities to adequately investigate the circumstances of Dragicevic’s death, the BiH State Prosecutor’s Office took over the case in April 2021. After the Banja Luka court acquit two members of the Banja Luka Police Administration of tampering with evidence in January, Davor Dragicevic, David’s father, set up a tent in front of the BiH State Prosecutor’s Office in March, where he remained for two months.
There are 12 laws governing the right to free assembly in different parts of the country, many of which were generally assessed to be overly restrictive. Examples include the prohibition of public assembly in front of numerous public institutions in the RS entity, while some cantonal laws in the Federation (e.g., in Central Bosnia Canton) prescribe criminal liability for failing to fulfill administrative procedures for holding a peaceful assembly. The lesbian, gay, bisexual, transgender, queer, and intersex (LGBTQI+) community has also had problems with freedom of assembly (discussed further in section 6). The only law that is entirely in conformity with applicable international human rights standards is the Brcko District Law on Public Assembly. Due to opposition from the ruling coalition member conservative Narod i Pravda (NiP) party, the Sarajevo Canton government failed to adopt an improved freedom of assembly law and instead produced a draft that further limited spontaneous gatherings and did not comply with the international human rights standards, according to OSCE.
Freedom of Association
The law provides for freedom of association, and the government generally respected this right. Cooperation between the government and civil society organizations at the state and entity levels remained weak, while government support for civil society organizations remained nontransparent, particularly regarding the allocation of funds. Independent NGOs complained that the government distributed funding to NGOs connected to ruling political parties.
In the RS entity, organizations and individuals who publicly criticized Russia’s aggression against Ukraine following the February 24 full-scale invasion, often received threats to personal safety; buildings were graffitied with pro-Russian and pro-war markings and personally owned vehicles or businesses were damaged. RS authorities did not investigate or prosecute such cases, sanction perpetrators, or condemn these practices, which NGOs reported were ongoing as of year’s end.
e. Protection of Refugees
The government cooperated with the Office of the High Commissioner for Refugees and other humanitarian organizations in providing protection and assistance to refugees, returning refugees, or asylum seekers, as well as other persons of concern.
Access to Asylum: The law provides for the granting of asylum (refugee or subsidiary protection status), and the government has established a system for providing protection to refugees. Asylum seekers with pending claims have a right to accommodation at the asylum center until the Ministry of Security makes a final and binding decision on their claims, although in practice only asylum-seeking families were accommodated, resulting in single men and unaccompanied children being accommodated in a limited number of TRCs, limiting their access to asylum. In addition, the two centers specifically designated to accommodate asylum seekers – Delijas Asylum Center and Salakovac Refugee Reception Center – remained underutilized, and Salakovac had no residents as of September. Accommodation in either is not based on asylum status or intention but instead on the capacity of the Usivak TRC where referrals are made and approved by the Ministry for Security, resulting in most families staying for brief periods before pursuing onward movement.
The overwhelming majority of refugees and migrants arriving in the country were issued an attestation on expressed intention to seek asylum, although very few intended to apply for asylum in the country. Accommodation in any of the reception centers was contingent on possession of this attestation document. This created a severe backlog in the asylum system, which has no mechanisms for identifying and prioritizing those with protection needs and a willingness to pursue international protection in the country over those pursuing onward movement. As a result, there were extreme delays for persons wishing to register an asylum claim. For asylum claims registered, the average wait time between issuance of an attestation and registration with the Sector for Asylum was 182 days, and this was only for those who managed to register. Processing times for those who were registered were also excessive, averaging 422 days between registration and the issuance of a decision during the year, meaning that on average the asylum process can take up to two years from initial issuance of an attestation to a decision.
To register a claim, individuals must be invited by the Sector for Asylum. Asylum authorities prioritized unaccompanied children and families accommodated in Usivak TRC and persons in private accommodation. While UNHCR observed that during the year the Sector for Asylum began to invite individuals legally represented by its free legal aid partner, Vasa Prava, for registration, this leaves those without access to legal representation essentially unable to access the asylum process. For single men in Blazuy, the country’s largest temporary reception center, asylum authorities continue to maintain their position that they would not invite them for registration, essentially leaving the majority of adult male asylum seekers unable to apply for asylum. At the Delijas Asylum Center, authorities conducted two registration visits in 2021, involving three families, while 66 families were accommodated in the center without being registered, staying on average 21 days before leaving. For the Salakovac Refugee Reception Center, no registrations were conducted over the year for the 20 families accommodated there who stayed an average of 54 days. Highly restrictive access to the asylum process combined with the lengthy and inefficient procedure for those registered resulted in many abandoning their asylum request, and authorities suspending most cases prior to issuing an initial decision (184 suspensions compared to 82 decisions in 2021 or 69 percent of cases being suspended).
Authorities also maintained a restrictive approach to assessing asylum claims, granting refugee status in just five cases since the start of the mixed movement surge in 2018. They instead granted subsidiary protection in cases when refugee status would likely be more appropriate, such as cases involving Afghan, Syrian, and Turkish citizens. Asylum seekers have the right to appeal a negative decision before the Court of BiH, although the court lacked specific expertise on asylum and often upheld the initial decision issued by asylum authorities, while only intervening on issues related to the process rather than the content or quality of the decision. When appeals were upheld, they were returned to the Sector for Asylum for reexamination, rather than issuing a decision on the merits of the claim, and most often the subsequent decisions issued by asylum authorities remained unchanged. In one high-profile case, authorities repeatedly rejected a claim despite it being returned to the Sector for Asylum on appeal four times. In the final decision, authorities rejected the claim for asylum while paradoxically acknowledging a risk of refoulement, and the individual was subsequently issued a removal order and temporary residence permit on humanitarian grounds.
In reception centers, international organizations, NGOs, and volunteers provided services which varied depending on the facility. There were two government-run centers (Delijas and Salakovac) which remained underutilized, while most asylum seekers and migrants resided in four temporary reception centers operated by the Service for Foreigners’ Affairs in Sarajevo (Usivak and Blazuj) and Una-Sana Cantons (Borici and Lipa). In November 2021, the IFS-EMMAUS Center for Children and Youth in Doboj Istok stopped receiving unaccompanied asylum-seeking and migrant children after the protocol, signed with the Ministry of Security in December 2020, expired in August 2021. Unaccompanied children are thus accommodated in the country’s two mixed-use TRCs (Usivak and Borici) leaving BiH without dedicated accommodation for children. There remained an acute lack of protection-sensitive accommodation for other vulnerable categories or persons with specific needs, including those with physical and mental disabilities, families with children, survivors of gender-based or domestic violence, persons with diverse sexual orientations and gender identities, elderly persons, and victims of human trafficking.
As a result of the mass influx from 2018, authorities largely stopped the previous practice of detaining irregular migrants in the Immigration Center in Lukavica, mainly due to its limited capacity. NGOs including free legal aid providers continued to have limited access to the immigration detention and asylum centers, on the grounds of COVID-19 mitigation measures. Access to information, free legal aid, and asylum remained a concern for those detained in Lukavica, especially given the risk of return and refoulement for those detained.
Certain provisions of the laws on extradition give authorities the possibility of extraditing a person who has expressed the intention to seek asylum if the request was made after the country had received an extradition request. While access to the territory is largely respected for those arriving by land, there were cases where persons arriving at the airport were not admitted to the country and were de facto denied access to the asylum procedure despite an expressed fear of return to their country of origin, placing them at serious risk of refoulement. In one case, the European Court of Human Rights granted an interim measure under Rule 39 preventing the removal of two persons from the territory of BiH due to a well-founded fear or persecution in their country of origin, but the injunction was delivered after they had already been placed on a return flight.
Durable Solutions: The legal framework provides a program for integration and return of refugees and displaced persons. The country was party to a regional housing program funded by international donors and facilitated in part by UNHCR and the OSCE to provide durable solutions for up to 74,000 refugees and displaced persons from four countries in the region, including 14,000 of the most vulnerable refugees, returnees, and internally displaced persons (IDPs) from the country. The process of selecting program beneficiaries was protracted due to capacity and management problems that resulted in extended delays in the reconstruction of homes. Fragmented institutional arrangements added administrative delays to the process, as did the political imperative to select beneficiaries proportionally from among the country’s constituent communities, while COVID-19 and supply-chain issues led to the extension of the program for an additional year beyond the June 2022 closure date due to the failure to reach the implementation targets. As of year’s end, more than 1,900 housing units were delivered in BiH with 1,000 in progress. UNHCR and OSCE, however, expressed concern that 83 vulnerable Bosniak families who were already selected for inclusion in the program to return to their prewar home in RS may remain without housing after the June 2023 closing date.
Temporary Protection: The government provided subsidiary protection status to individuals who qualified as refugees, including Afghan and Turkish citizens with strong individual claims.
For refugees fleeing Ukraine, BiH authorities failed to establish a Temporary Protection plan in line with the European Union. Instead, most Ukrainians applied for temporary stay on humanitarian grounds, which does not afford them any rights, including employment, healthcare, or education, and takes up to two months to be confirmed. This left many vulnerable refugees who were unable to return to Ukraine in legal limbo. While the regular asylum system is in theory open to Ukrainians, the extremely lengthy processing times (up to two years) renders the procedure inappropriate for this specific demographic requiring immediate international protection.