© Marco Fieber via Flickr
Key Takeaways
Introduction
Passports are the gateway to opportunities abroad. Whether in search of employment, study or a better life, presenting a well-identified passport opens doors, not only for entry into another country, but to a wide range of opportunities. But what happens when your passport is considered one of the “most useless in the world” [1]? The case of Transnistria is not new, however, there has been a renewal of the Kremlin’s intentions to grant Russian passports to nationals of this de facto country.
The History of the Passportation Law
The phenomenon of passportation studied here involves a process of mass granting of passports to republics that are not internationally recognised but orbit the post-Soviet space. Russian policies aimed at this aspect have a confirmed beginning from the 1990s, immediately after the fall of the Soviet Union. Russia’s passportation policies are usually conditioned by three independent variables: access to territory, which can be diplomatic or military; the capacity of another government to reclaim that territory in the event of Russia’s loss of control over it; and Russia’s concerns regarding its own territorial integrity [2].
This can be seen in the historical periods when passportation was most implemented by Russia. Before the collapse of the Soviet Union, the Russian Soviet Republic passed the 1991 Federal Law on Citizenship, which entered into force in February 1992 [3]. This legislation defined the Russian nation extremely broadly: all former Soviet citizens, regardless of the post-Soviet state in which they resided, had the right to apply for Russian citizenship through a simplified procedure [4]. Permanent residents of the Russian Federation received citizenship automatically [5].
The law involved a concept of nation known as Rossiiskaya, as a great ethnic appreciation based on language and loyalty to the Russian State, which ended up having imperial traits: the law ignored the international borders of the new states that were forming with the Soviet Union’s dissolution [6]. The result of this law was an enormous influx of applications, with an estimated number of 400,000 to 500,000 applicants per year, of multiple ethnicities, which generated pressure on Russian State resources and provoked a xenophobic reaction from public opinion [7].
The outcome, however, was less satisfactory: with this large influx and the two Chechen Wars (1994–1996 and 1999–2009), various xenophobic discourses emerged targeting minorities of Caucasian and Muslim origin [8]. This pressure made the open-door policy unsustainable. This situation led to the second historical moment of passportation policies, the 2002 Citizenship Law. Back in April 2001 [9], the newly inaugurated President Putin presented a reform proposal that significantly restricted access to simplified citizenship, requiring that only former Soviet citizens born in the region of the Russian Federation be eligible [10]. Anyone else would be classified as an ordinary foreigner, which was considered extremely controversial, as it was seen as a recession in favour of the xenophobic discourses that had emerged.
There were weeks of debate until the final version, retreating to international standards, requiring permanent residence of at least five years, economic independence and command of Russian for naturalisation [11]. However, it maintained loopholes for simplified procedures applied in de facto territories. The 2002 Law officially expanded the simplified procedure to former Soviet citizens whose parents were born in the Russian Federation, and stateless persons residing in territories separated from former Soviet republics, that is, inhabitants of de facto states such as Abkhazia, South Ossetia and Transnistria [12].
In addition to this loophole in the 2002 Law, the Loophole Mechanism (Clause 1 of Article 14) also opened an exception for people who had Soviet citizenship and lived in countries that were part of the USSR, but who had not obtained the citizenship of these new countries, remaining effectively stateless [13]. These mechanisms in the 2002 Law, even though it was considered a rigorous legal provision, allowed a wider opening for the inhabitants of these de facto states to obtain citizenship.
In 2019, this topic arose again when President Putin signed a decree offering citizenship through a simplified procedure to all Ukrainians who lived in the Donbas region before 2014 and to current residents of Donetsk and Luhansk. [14].
The Process of Passportation in De Facto Republics
The passportation policy was not applied uniformly to the unrecognised republics of the post-Soviet space, varying significantly according to the Kremlin’s objectives and the particular conditions of each territory [15]. Some regions were more affected by this phenomenon over the decades, with various theoretical interpretations regarding the differences in treatment between the republics.
The de facto republic of Abkhazia is an example. It declared its independence from Georgia in 1992 with an armed conflict that lasted over a year. The granting of Russian citizenship was presented as a “guarantee of security and independence” [16]. Passportation was intense and deliberate. Russia passportised Abkhazia starting from June 2002, coinciding with tensions over the Chechen War and the Georgian refusal to allow Russian military operations in its territory. In just one month, 150,000 passports were distributed [17]. The process was intensified after the Rose Revolution in Georgia, with almost the entire population having acquired Russian citizenship by 2008. A legal particularity that helped in this process is the 2005 Abkhazian Citizenship Law, which grants citizenship automatically to all ethnic Abkhazians, regardless of residence or previous citizenship. For others, dual citizenship is permitted exclusively in combination with Russian citizenship, which created practical exclusivity in favour of Moscow [18]. Furthermore, after the Russo-Georgian War of August 2008, Russia formally recognised the independence of Abkhazia and signed military cooperation agreements for 49 years, renewable.
Another emblematic case involves South Ossetia. The region has faced tensions since 1989, which escalated until the conflict with Georgia was frozen in 1992. The situation remained this way until the Rose Revolution, when Georgia, under Saakashvili, began to present peace proposals and created an alternative Ossetian administration. In response, Russia intensified the process of granting citizenship to Ossetians, resulting in almost 97% of the population holding a Russian passport [19]. Ossetia ended up with a similar result to Abkhazia, with the recognition of the region by the Russians and the establishment of military bases in the republic.
In the republics of Donetsk (DPR) and Luhansk (LPR), known as Donbas, there was no formal granting of Russian citizenship; instead, both republics began to issue their own travel documents, recognised by Russia [20]. The Ukrainian constitution prohibits dual citizenship but lacks ways to track or prevent this practice, a situation that worsened with the war in Ukraine [21]. Thus, part of the population acquired Russian citizenship without giving up Ukrainian citizenship.
The Case of Transnistria
The case of Transnistria is somewhat different regarding mass granting, having received less attention than South Ossetia and Abkhazia, for instance. Less than 40% of the population holds Russian citizenship, and Moldova has liberalised rules so that Transnistrians can maintain their Moldovan citizenship as well [22]. However, just as occurs with the former Georgian regions, the “appeal” of Russian citizenship is based on granting security to the Russian people and the pretext of a claim over its citizens. Russian troops even remain in the region to this day.
The Pridnestrovian Moldavian Republic (PMR), better known as Transnistria, declared sovereignty on 23 June 1990 and full independence on 2 September of the same year [23], but ended up being dragged into a civil war from 1991 to 1992, which ended with a ceasefire guaranteed by Russian, Moldovan and PMR forces themselves [24]. After the end of the conflict, there was a need for autonomous documentary systems, since cross-border mobility and identity verification became contentious. [25]
During this beginning, residents still used Soviet documents, complemented by endorsements or stamps. The formal issuance of passports by the PMR began on 1 October 2001, based on Presidential Decree No. 227 of 11 May 2001, which established the legal framework for the “Passport of the Citizen of the PMR.” However, no sovereign state recognises the Transnistrian passport as a valid travel document [26], considering that the international community observes the territorial integrity of Moldova and the latter explicitly rejects Transnistrian passports for official purposes. [27]
Even Russia, despite its military presence and distribution of citizenship in Transnistria, does not officially validate the local passport for its own borders, promoting instead Russian passports through simplified naturalisation processes [28]. This practice is often viewed as a way to reinforce dependence and influence without a formal annexation of the territory. [29]
However, since Russia’s full-scale invasion of Ukraine in 2022, Russian access to the region has decreased significantly [30]. The border with Ukraine is closed, which isolates Transnistria geographically, since it does not directly border Russia or Russian-controlled territories. Furthermore, the economic model that allowed Russia to sustain the region through energy subsidies (such as the supply of free gas) was destabilised and effectively reduced [31]. Financial assistance and political support from Moscow also weakened under the pressure of the war in Ukraine [32], which once again weakened the granting of Russian passports to Transnistria.
After the last few years of conflict, on 15 May 2026, President Vladimir Putin signed a decree that simplifies access to Russian citizenship for adult residents of Transnistria [33]. The measure allows residents to bypass common requirements, such as proof of knowledge of the Russian language, history or the country’s legislation. This strategy is being considered as an attempt to create an “extraterritorial legal community” within Moldova [34]. By expanding the number of Russian citizens, the Kremlin can claim the sovereign right to “protect its compatriots” against what it calls pressures from Moldova, Ukraine or the West. This new effort is described as “passportation under pressure”. [35]
The Problem of Passportation in International Law
Nationality can be understood as the legal and political bond connecting a State to an individual, having as a basis a social fact of attachment and should reflect the genuine link between the state and a person; otherwise, it can be non-recognised by others [36]. The extension of Russian citizenship by Moscow to residents of these de facto ex-Soviet republics is termed a humanitarian policy for the protection of citizens [37]. However, the act of giving citizenship en masse to others can be viewed as a violation of the principle of non-intervention into domestic affairs, as the Russian State wants to claim the sovereign right of protection. [38]
Historically, in passportation cases such as Georgia (2008) and Ukraine (2014/2019), Russia used the presence of these citizens to legitimise military interventions under the justification of “humanitarian protection” [39]. This use of citizenship to justify the use of force is a Russian interpretation that collides with the international community’s view on territorial integrity. Transnistria is described as a “de facto State” that is not recognised by the international community. Because of this, the mass granting of Russian citizenship serves to fill a legal vacuum and offer residents a sense of security and mobility that the region’s unrecognised status does not provide. [40]
The issue of passportation is not an uncontested subject within international law, having various nuances discussed to this day. Although there were discussions, from previous cases, whether attacks on nationals could activate the right to self-defence (Art. 51 of the UN Charter), this is considered a breach of international law and can be considered a potential abuse of the doctrine when the State “manufactures” nationals in someone else’s territory.[41] According to Oliveira:
“A mass conferral of nationality to residents of a third State may serve as a pretext for the use of force in their defense. While the traditional rules on forcible action to guarantee the protection of nationals abroad have been largely replaced by Articles 2(4) and 51 of the UN Charter, current discussions are centered on the possible emergence of customary law to that effect in the post-1945 period. The idea behind the protection of nationals abroad is usually framed as an iteration of the right to self-defense, meaning that nationals of a State would be covered as targets of an armed attack in the sense of Article 51 of the UN Charter. Naturally, the doctrine is controversial and has a propensity for misuse, as any hostile State could implant or fabricate nationals in a third State with a view to legitimizing intervention, incurring in an archetypal abuse of rights situation.”[42]
However, stating that there is a deliberate manufacturing of nationals by Russia is a dangerous assertion, and must be evaluated against the historical context and the real links of the population, case by case.
One of the mechanisms for analysing international law in these cases involves the concept of “personal annexation” [43], which describes the mechanism by which passportation operates as an instrument for the discursive extension of Russian sovereignty over foreign territories. If nationality symbolises an individual’s formal belonging to a nation-state, it also materialises the relations between population, political community and territory [44]. By issuing passports to individuals residing abroad, Russia symbolically extends its sovereignty to the soil where these individuals dwell.
Passportation can thus play a decisive role in the discursive production of territory constituting the object of the dispute [45]. Possessing a Russian passport in contested territories reinforces the idea that the holder is located in a space, both ideal and physical, that belongs to the Russian Federation. In this way, by conferring mass nationality, Russia would like to discursively extend its sovereignty into the territories of other States [46].
However, there is still no single understanding on this matter, because there is also no single understanding regarding Russia’s actual intentions. What is observed under international law is that passportation practices remain on a threshold between what is correct and what is disputable or even clearly illegal in international law.
In the post-Soviet space, this policy could be a way to bring back the Rossiiskaya, in a way apart from the European influence. It is necessary to be careful with the analysis of cases involving Russian policy and how it might come to affect other countries in the long term.
Conclusion
Russian passportation policies in Transnistria, resumed by the decree of May 2026, expose how the strategic use of nationality can transcend mere bureaucracy to consolidate itself as a tool for power projection and “personal annexation”. By relaxing legal requirements and symbolically extending its sovereignty over the citizens of that de facto region, the Kremlin could compensate for its geographical isolation and the weakening of its traditional subsidies, creating a discursive pretext of humanitarian protection that challenges the internationally recognised borders of Moldova. Although the phenomenon inhabits a grey area of international law, oscillating between the protection of minorities and the abuse of sovereign prerogatives, the Transnistrian case demonstrates that the passport, in the post-Soviet space, remains an active vector of geopolitical dispute.
Policy Recommendations
[1] ‘World’s Most Useless Passport?’ (Young Pioneer Tours) [https://www.youngpioneertours.com/worlds-most-useless-passport/]accessed 23 June 2026.
[2] Lukáš Dravecký, ‘Russia’s Passportisation Policies in the Context of Post-Soviet De Facto Republics’ (PhD thesis, Central European University 2020).
[3] Ibid.
[4] Ibid.
[5] Ibid.
[6] Ibid.
[7] Ibid.
[8] Human Rights Watch, ‘The Rise of Xenophobia in Russia’ (1998) [https://www.hrw.org/legacy/reports98/russia/srusstest-03.htm] accessed 23 June 2026.
[9] Oxana Shevel, ‘The Politics of Citizenship Policy in Post-Soviet Russia’ (2012) 28(1) Post-Soviet Affairs 111.
[10] Thomas Hoffmann and Archil Chochia, ‘The Institution of Citizenship and Practices of Passportization in Russia’s European Neighbourhood Policies’ in Russia and the EU: Spaces of Interaction* (Routledge 2012) 223.
[11] ‘Russian Citizenship’ (General Consulate of Russian Federation in Rio de Janeiro) [https://consrio.mid.ru/pt/consular-services/grazhdanstvo/] accessed 23 June 2026.
[12] Dravecký (n 2).
[13] Toru Nagashima, ‘Russia’s Passportization Policy Toward Unrecognized Republics: Abkhazia, South Ossetia, and Transnistria’ (2019) 66(3) Problems of Post-Communism 186.
[14] ‘Passportisation Under Pressure: Why Russia is Expanding Citizenship in Transnistria’ (German Marshall Fund, 2024) [https://www.gmfus.org/news/passportisation-under-pressure-why-russia-expanding-citizenship-transnistria] accessed 23 June 2026.
[15] Nagashima (n 13).
[16] Hoffmann and Chochia (n 10) 223.
[17] Ibid.
[18] Ibid.
[19] Louise Grönsund, ‘Passportisation—the New Geopolitical Strategy? A Comparative Analysis of Russia’s Passportisation Policy and its Effects on Brain Drain in the Eastern Neighbourhood’ (Master’s thesis, 2020).
[20] Grönsund (n 19).
[21] Hoffmann and Chochia (n 10) 223.
[22] Ibid.
[23] Grönsund (n 19).
[24] Ibid.
[25] ‘Transnistrian Passport’ (Grokipedia) [https://grokipedia.com/page/Transnistrian_passport] accessed 23 June 2026.
[26] ‘World’s Most Useless Passport?’ (n 1).
[27] Grönsund (n 19).
[28] Ibid.
[29] Victor Santos Mariottini de Oliveira, ‘Russia’s “Passportization” and the Pitfalls of “Personal Annexation” in the Post-Soviet Space: Recasting the Limits of Nationality Attribution in International Law?’ (2024).
[30] ‘Passportisation Under Pressure’ (n 14).
[31] Ibid.
[32] ‘What’s Behind Transnistria’s Call for Russian ‘Protection’?’ (Deutsche Welle, 2024) [https://www.dw.com/en/whats-behind-transnistrias-call-for-russian-protection/a-68410601] accessed 23 June 2026.
[33] ‘Putin Eases Path to Russian Citizenship for Residents of Transnistria’ (Meduza, 16 May 2026) [https://meduza.io/en/news/2026/05/16/putin-eases-path-to-russian-citizenship-for-residents-of-moldovan-breakaway-republic-transnistria accessed 23 June 2026.
[34] ‘Putin Eases Path to Russian Citizenship’ (n 33).
[35] ‘Passportisation Under Pressure’ (n 14).
[36] Nottebohm Case (Liechtenstein v Guatemala) (Second Phase) [1955] ICJ Rep 4, 23.
[37] Ramesh Ganohariti, ‘Dual Citizenship in De Facto States: Comparative Case Study of Abkhazia and Transnistria’ (2020) 48(1) Nationalities Papers 175.
[38] Santos Mariottini de Oliveira (n 29).
[39] Ibid.
[40] Ibid.
[41] Ibid.
[42] Ibid.
[43] Ibid.
[44] Ibid.
[45] Vincent M Artman, ‘Documenting Territory: Passportisation, Territory, and Exception in Abkhazia and South Ossetia’ (2013) 18 Geopolitics 682, 683–684.
[46] Artman (n 44) 683–684.
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