On 22 April 2026, the Arbitral Tribunal constituted under Annex VII to the 1982 United Nations Convention on the Law of the Sea (UNCLOS) rendered its Award on the merits in the case brought by Ukraine against the Russian Federation concerning coastal State rights in the Black Sea, Sea of Azov, and Kerch Strait.
The proceedings were initiated by Ukraine on 14 September 2016 in response to the Russian Federation’s violations of its obligations under the UNCLOS in the maritime areas adjacent to the coast of Crimea in the Black Sea, the Sea of Azov, and the Kerch Strait since 2014.
In its final Award, the Arbitral Tribunal did not find that the Sea of Azov and the Kerch Strait constitute a so-called “Russian lake”. Instead, it confirmed their status as internal waters of two States – Ukraine and the Russian Federation.
Ukraine remains a coastal State in the Black Sea, the Sea of Azov, and the Kerch Strait and retains all sovereign rights vested in it under international law. No unlawful unilateral actions taken by Russia after 2022 have altered this legal reality.
The Arbitral Tribunal further found that the Russian Federation breached its obligations under the UNCLOS by failing to conduct an adequate environmental impact assessment in connection with the construction of the so called “bridge”, the laying of the power cables, and the gas pipeline and by failing to ensure proper notification and publication of the results of such assessment. These omissions constitute breaches of Russia’s obligations of due diligence and cooperation in the protection and preservation of the marine environment.
The Arbitral Tribunal’s Award is yet another confirmation that the Russian Federation systematically disregards the rules of international law and that its attempts to impose the consequences of its war of aggression on the world as a “new reality” have no international legal effect and will never receive international legal recognition.