Reparations for conflict-related harms in Ukraine: The crucial role of businesses, July 2026

This policy report analyses potential pathways for involving businesses in reparations for conflict-related harms in Ukraine resulting from Russia's war of aggression. While principal responsibility for providing reparations for the international human rights and humanitarian law violations lies with Russia, businesses which have caused or contributed to harms in Ukraine may also owe reparations to victims. Businesses may have caused or contributed to gross human rights and humanitarian law violations, for example by supplying dual-use products to the aggressor's military or by enabling financial transactions crucial to the functioning of the Russian war economy. Ukraine has an opportunity to raise the bar in holding businesses accountable for war related harm and enhancing standards for positive business involvement in reparations efforts. With reconstruction and recovery costs assessed at almost $588 billion as of the end of 2025, and efforts to involve businesses in remediation so far limited, this policy report maps accountability-based and voluntary pathways and incentive models for securing reparations from businesses.

There are different types of business involvement in conflict-related harms and in their connection to such harms. Businesses may be liable to provide reparations if it is established that they have caused or contributed to gross human rights or international humanitarian law violations committed in Ukraine. What will constitute the most appropriate or promising pathways to reparation will depend on the form and degree of business involvement, among other factors. We identify three main accountability-based pathways for seeking reparations from businesses. First, in Ukraine, tort litigation can be a pathway to seek reparations from businesses that have caused, jointly caused or economically benefitted from the aggression. Despite the challenges in establishing causal links, Ukrainian tort law might offer sufficient flexibility for novel interpretation and evolution of secondary and joint liability in line with the expectations of the UN Guiding Principles on Business and Human Rights (UNGPs).

Second, options for home state accountability routes are outlined. A tort or civil liability claim could be brought in the home states of foreign businesses. In some European jurisdictions, such as France, human rights due diligence (HRDD) legislation might directly allow civil liability claims. HRDD legislation in other European jurisdictions, such as Norway, may indirectly enable remediation if the relevant regulator requires the business to provide reparations to remediate the harms caused in breach of the HRDD responsibilities.

Third, the OECD Responsible Business Conduct National Contact Points offer an accessible non-judicial grievance mechanism. The process may result in a mediated settlement leading to remedies for victims and may potentially reach businesses less closely linked to harms than only those ‘most responsible’...