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A Bureaucracy of Erasure : The "municipalization" of housing in Russian-occupied territories

ABOUT THE CASE

Using mapping to visualise lists of dwellings declared “ownerless” in the occupied areas of Ukraine, the case shows how administrative records can reveal patterns of dispossession. By mapping fragmented datasets (such as in Mariupol, where about 11% of surviving housing appears to have been "municipalised") it exposes how a technical process functions as a territorial strategy for reassigning property while obscuring how buildings are labeled “abandoned.”

Since 2014 in Crimea and the self-proclaimed "Republics of Donetsk and Luhansk", and since 2022 in the four annexed regions of southeastern Ukraine (Donetsk, Luhansk, Zaporizhzhia and Kherson), the Russian occupying administration has implemented a legal framework to govern various aspects of social, political, and economic life. This concerns all sectors, from those the most obviously linked to the State-building (such as the distribution of citizenship through the “passportization” policy) to more localized issues, such as water and electricity management.

One of the dimensions of Russian occupation administration concerns the management of dwellings abandoned by people fleeing the war and the occupation, or whose inhabitants were killed during the war. During the first months of occupation, many example of informal occupations were reported. Month after month, local authorities began to take charge of the question and created the first lists of properties "showing signs of ownerlessness". However, there was still no legal framework for the newly annexed regions. Some municipal lists referred—notably in Mariupol—to decrees adopted before the official (yet illegal under international law) annexation of the region, specifically a decree adopted in 2021 in the so-called DNR.

In the spring 2024, local authorities have since implemented a legal framework to “municipalize” or “regionalize” dwellings considered “ownerless” in a far more systematic way, with regional legal texts that closely resemble one another (see diagram). They outline a similar procedure: identifying potential dwellings, and if no objection is raised within 30 days, registering them as ownerless property, followed by submitting the case to a court to initiate municipalization. In every municipality or region, new lists of dwellings “showing signs of ownerlessness” are now published almost on a daily basis. Across all occupied territories, this involves tens of thousands of properties. Through the adoption of a legal framework at various levels (from the federal to the local), the Russian administration regulates and rationalizes the seizure of dwellings.  A bureaucracy of erasure emerges.

In December 2025, a Russian federal law was adopted to standardize, accelerate, and organize the transfer of property at different levels (municipalization, regionalization, and nationalization) in the occupied regions of Ukraine.

Lists and Laws: How Russia Visibilizes its Administration of dispossession 

For the occupying authorities, producing this legal framework and issuing lists that refer to it functions as a tool of legitimation. By generating laws, they act as though the state were capable of governing and resolving an “issue,” while obscuring the fact that they created it themselves: the regulatory texts make no mention of the causes of these “empty” homes, namely war and occupation. The lists and legal texts thus serve as evidence of the occupying authorities’ activities. Moreover, these laws allow the development of a strategy widely observed in Russia: giving the appearance of possible resistance or opposition that is almost impossible to realize in practice but aims at legitimating the actions of the public authorities. 

Explore the map below to learn more about specific laws and decrees.

Ukraine

The “municipalization” process also generates extensive administrative activity. A significant share of the official communication from local occupying authorities concerns the identification of “ownerless” dwellings. In this way, the occupying administration performs and displays its power through the bureaucratic work of dispossession.

 

Screenshots of regional laws and decrees (cover pages).

This process also enables other dimensions of Russification, such as changes in toponymy (dwellings are often listed using street or avenue names introduced by the Russian administration), the restructuring of administrative boundaries, and passportization (a Russian passport is required to prove property ownership). Besides, it remains unclear to whom these properties will be redistributed—some sources mention veterans or civil servants—but it is already evident that recipients will need to obtain Russian citizenship, as is now required of all people living under Russian occupation. Both the municipalization and the redistribution contribute to making the state function.
The Russian occupiers therefore make this confiscation of property rights visible: these laws and documents are accessible, and the process appears transparent and contestable. In a context where access to information is extremely restricted, and were expressing a reality different from that portrayed by the Russian authorities is dangerous, these administrative traces play an even more significant role in shaping the narrative of erasure.

From 'signs of ownerlessness' to municipalization

All these laws adopted in the spring of 2024 by regional parliaments are very similar in the procedures they regulate. They all first provide a common definition of what would constitute ‘signs of ownerlessness,’ namely:

  • non-payment of communal services for more than one year (Zaporizhzhia, Donetsk, and Luhansk regions) or six months (Kherson region),
  • the absence of any information on property rights in the cadastre register,
  • lack of use of a dwelling showing signs of potentially dangerous deterioration (no further details are provided beyond these broad categories).


    Next, they follow similar stages: 
     

The laws, describing this stage though in a rather vague manner, read that individuals or legal entities can report dwellings exhibiting ‘signs of an ownerless property’ to the local Ministry of Property and Land Relations. This Ministry then forwards the information to the federal and regional services responsible for property and cadastral matters. Within ten days, the addresses of dwellings showing ‘signs of ownerlessness’ must be published on the local administration’s websites and in an ‘accessible place’ near the entrance of the dwelling.

The dwelling is added to the list of ‘ownerless properties’ if no one claims the property and/or occupancy rights within 30 days after the publication of its address. Claims require, in addition to proof of occupancy and/or property titles, identity documents recognized by the Russian administration, and must be submitted to the Ministry of Property and Land Relations.

Following a series of procedures outlined in these decrees, including filing a petition with the court by local housing authorities, the Ministry can transfer the property into the municipal housing stock.

Mapping to unpack the visibilize occupation practices

The sources provided by the Russian administration are abundant: to demonstrate that it rules over the territory, it documents its own crimes—borrowing the expression of historian JD1 regarding the lists of heritage monuments seized by Russia in occupied Ukraine. In a context where access to other sources is largely limited, these official lists also allow the foundations of an alternative narrative to be laid. In other words, they make it possible to challenge the dominant narrative by using data provided by the authorities:
 

  • First, by making the phenomenon visible. The lists of buildings subject to municipalization are numerous, provide evidence, and confer legitimacy, but they are not centralized, appear through various journalistic investigations, and in inconsistent formats. Whether this is part of a deliberate strategy or a form of improvisation, it makes it difficult to measure the scale of the phenomenon and thus to objectify it. Early journalistic work has shown the effectiveness of centralizing all lists at the regional level. This can be seen, for example, in the city of Mariupol [cf. map], where it was found that this represents about 11% of the residential stock (among housing that is not completely destroyed).

     

Map by Guénola Inizan, 2025.

 

  • Secondly, by revealing spatial patterns in the implementation of municipalization. Neither the laws nor the address lists indicate how the identification of housing is carried out in practice and they hide micro-scale practices and logics (reports of absence, conversations, individual interests at stake...). Without fully resolving these questions, mapping nonetheless allows some phenomena to be observed: the areas most affected, the spatial distribution of municipalization, etc. For example, in Mariupol, on certain days, the distribution of dwelling lists appears scattered, which may suggest a largely ad hoc process carried out by individuals or at least, quite spontaneous or bottom-up practices (Fig 2, list of potential "ownerless" dwellings published on 30/01/2024). In contrast, at other times (Fig 3, list of potential "ownerless" dwellings published 22/10/2024), the listed housing is highly concentrated, seemingly indicating a more systematic procedure. This provides a foundation for further analysis when combined with OSINT data or personal accounts, while broader access to firsthand information remains pending.

     

ABOUT THE AUTHOR

Guénola Inizan is a postdoctoral researcher. After defending her PhD in Geography and Planning on the “Renovation" programme in Moscow at Lumière Lyon 2 University (2024), she worked on housing and urban policies in occupied Ukraine at the Leibniz Institute for Regional Geography (Germany), the Department of Geography at the University of Łódź (Poland), and the Lviv Center for Urban History (Ukraine). She is a member of the project "Occupied and Erased: Stories of Ukraine’s Lost Homes”