What is the current state of universal jurisdiction?
On 21 April 2026, a new edition of the Annual Report on Universal Jurisdiction (UJAR 2026) was published, produced by TRIAL International in collaboration with various organisations specialising in international justice. The report covers the main developments in 2025 regarding universal jurisdiction and other forms of extraterritorial jurisdiction, confirming its growing importance as a key tool in the fight against impunity.
In Latin America, Argentina continued to establish itself as one of the most active jurisdictions in the application of this principle. During 2025, significant progress was made in the case of the genocide against the Rohingya people in Myanmar, where the Federal Court ordered the issuance of arrest warrants against 25 senior officials. Likewise, in the case concerning crimes against humanity in Venezuela, international arrest warrants remained in force whilst hearings on jurisdiction progressed. In parallel, the reopening of the investigation into the Uighur people in China reinforced Argentina’s role as a key jurisdiction, highlighting both the dynamism and the tensions inherent in this type of process.
In 2025, Peru joined the South American country, adopting the principle of universal jurisdiction for the first time by opening an investigation into Adi Karni, an alleged member of the Israeli army’s Combat Engineering Corps, for possible crimes committed in Gaza. The complaint, filed on behalf of the Hind Rajab Foundation, is based on his alleged involvement in the destruction of civilian infrastructure during the Israeli military offensive between 2023 and 2024. In June, the Attorney General’s Office referred the case to its Specialised Human Rights Unit, setting a significant precedent in the region.
In Europe, activity was particularly significant. Austria made progress in the prosecution of crimes committed in Syria with the indictment of Khaled H. and Musab A. R., former intelligence officials accused of torture and other serious offences. In Belgium, universal jurisdiction continued to develop with progress on multiple fronts: the conclusion of the investigation against Martina Johnson and its referral to the Indictment Division; the opening of new cases relating to the Rwandan genocide; the confirmation of Emmanuel Nkunduwimye’s 25-year prison sentence; the pending trial of Ernest Gakwaya; and the referral to the International Criminal Court of an investigation into alleged crimes committed in Gaza.
In Finland, one of the most significant rulings of the year was handed down with the sentencing of Yan Petrovsky to life imprisonment for war crimes committed in Ukraine, in a judgement considered a key precedent for accountability in this conflict. In France, progress was made alongside the closure of certain cases: notable developments include the sentencing of Roger Lumbala Tshitenga to 30 years’ imprisonment for crimes against humanity in the Democratic Republic of the Congo; progress in the investigation against Saturday T., with on-the-ground missions to gather evidence; and the conclusion of the investigation against Amesys for complicity in torture in Libya, pending a decision on a possible trial. At the same time, cases such as that of Ahmed Hamdane El Aswadi (Iraq) were closed, and the investigation against Agathe Habyarimana was dismissed, a decision currently under appeal.
Germany continued to establish itself as a key jurisdiction in this field. In 2025, significant arrests took place, such as that of Anwar S., and indictments were issued, such as that of Fahad A., in connection with crimes committed in Syria. Among the most notable decisions were the life sentences handed down to the doctor Alaa M. and Ammar A. for crimes against humanity and war crimes. Furthermore, the trial began against Jihad A., Mahmoud A., Sameer S., Wael S. and Mazhar J., in a case involving charges of using starvation as a method of warfare. At the same time, numerous proceedings against former ISIS members continued, resulting in convictions, partial acquittals and retrials, reflecting the breadth of application of this principle.
In Lithuania, a case linked to war crimes in Ukraine progressed – for the first time – following the extradition of a Russian military officer, who is currently in custody whilst his alleged involvement in torture and ill-treatment is investigated. In the Netherlands, several significant decisions were consolidated: the final conviction of Abu Khuder; progress in the cases of Ahmad al-Y. and Mustafa A., including the award of compensation to victims; and the continuation of investigations, including a landmark case regarding sexual violence as a crime against humanity.
Meanwhile, in Portugal, the Court of Appeal upheld the convictions of Ammar Ameen and Yaser Ameen for crimes linked to ISIS, in a case now before the Supreme Court. Furthermore, in Sweden, the trial of Ian Lundin and Alexander Schneiter for complicity in war crimes in Sudan continued, a landmark case regarding corporate liability for international crimes.
Likewise, in Switzerland, it is worth noting the confirmation of the conviction of former Gambian minister Ousman Sonko for crimes against humanity, whilst investigations into the Rwandan genocide continued. The case against Rifaat al-Assad – accused of the Hama massacre – was, meanwhile, suspended due to his health and will conclude following his death in 2026. Meanwhile, Turkey invoked universal jurisdiction by issuing arrest warrants against Benjamin Netanyahu and 36 other senior Israeli officials for alleged crimes committed in Gaza.
These developments reflect the key role of national jurisdictions in ensuring accountability for international crimes, particularly when victims cannot find justice in their countries of origin. The report also highlights the inclusion of new states and the expansion of the geographical scope of these mechanisms, alongside significant developments in case law.
However, these advances coexist with significant challenges. In contrast to the progress mentioned above, the United Kingdom closed an investigation into crimes in Zimbabwe due to lack of evidence.
Furthermore, the report notes that 2025 saw unprecedented attacks against the International Criminal Court (ICC), as well as a growing lack of state cooperation and risks of double standards in the application of international law.
In this context, it was emphasised that the effectiveness of universal jurisdiction is largely limited by issues of political will, a lack of available resources, and the complexity of investigating powerful actors. In this regard, the report underlines the importance of strengthening cooperation between states, international mechanisms and civil society, whose role has been decisive in documenting crimes and initiating judicial proceedings.
In short, the report confirms that, against a backdrop of weakening international mechanisms, universal jurisdiction is establishing itself as an essential tool for closing gaps in impunity. Its future effectiveness will depend on the capacity of states to apply it in a consistent, equitable and sustained manner, reaffirming that justice must not be limited by borders.
Federica Carnevale, Project Manager at FIBGAR
