CENUSA: The Cyprus precedent for Ukraine, Moldova and Georgia

CENUSA: The Cyprus precedent for Ukraine, Moldova and Georgia
Cyprus joined the EU in 2004 despite the fact that the island remained divided. / Walkerssk via Pixabay
By Denis Cenusa July 4, 2023

Against the backdrop of a radical reset of the regional geopolitical context, joining the European Union (EU) is a necessity, not just a historic opportunity, for Ukraine, Moldova and Georgia in their efforts to consolidate their own statehood. In addition, embracing the European vector would make possible a future detachment from the Russian sphere of influence, provided that the reforms initiated generate order and prosperity, and depopulation is stopped.

The fate of the “frozen conflicts” and whether the Russian military threat, which could be used by future European elites to block the three countries' progress towards the eventual accession stage, matters no less significantly. 

The current European leadership admits that a situation similar to the acceptance of divided Cyprus as an EU member state may be repeated. The head of EU diplomacy, Josep Borrell, referred to the Cypriot precedent in the context of the Transnistrian conflict in Moldova. The same argument applies to Georgia, but also to Ukraine, which launched a military counter-offensive in June to liberate all of its territories from Russian occupation, including Crimea. However, the details of the Cypriot model require more nuanced analysis to determine the plausibility of using it as a precedent for the “Associated Trio” countries.

The European agenda of the “Associated Trio” — technical progress and political ambitions

Although the completion of the pre-accession requirements set by the EU in June 2022 is advancing, none of the three countries has fully complied with them. They had almost a year at their disposal, but the nature of the reforms implies systemic changes, which require time, sufficient financial resources, a functional administrative apparatus, competent human capital, political stability and adequate security ambiance (absence of war). The traditional problems for these countries refer to justice, the fight against political and high-level corruption, the reform of local public administration, etc. According to the EU mid-term evaluation, Moldova has fully implemented three out of nine conditions (33%), followed by Ukraine with two requirements out of seven (28%). Georgia has three conditions out of 12 fully met or 25%.

All three countries have similar strategies to achieve the goal of European integration, that is, to meet the technical aspects of the EU requirements. The political side depends on the subjectivity of Brussels in the face of the actions and speeches of the governing elites in Kyiv, Chisinau and Tbilisi. The EU has clear preferences for Ukraine and Moldova. A dilemma situation persists in relation to Georgia. The EU has to decide between the pro-EU sympathies of the population and the geostrategic role of the country, on the one hand, and the oligarchic political system combined with aggressive Euroscepticism of the government on the other.

Ukraine’s intention is to start accession negotiations as early as 2024, and President Volodymyr Zelenskiy is using his political weight to advance the Ukrainian cause among European leaders. The opening of negotiations is also presented as a way to boost the morale of the Ukrainian army, engaged in the fight against Russian aggression.

Moldovan political rulers are trying to send political signals to national institutions and European chancelleries regarding their determination to fulfill EU requirements. In the context of criticism that she would exert political influence on reforms in the field of justice, President Maia Sandu suggested to the Supreme Council of the Magistracy and to the members of the Pre-Vetting Commission that accession to the EU depends on the fight against corruption in the judiciary. 

Georgia is in a delicate situation. Both the EU and the majority of civil society have legitimate objections related to the quality of the political reforms, the repressive nature of the regime, and the influence of informal oligarchic actors (Bidzina Ivanishvili). However, the Georgian government considers that 11 of the 12 EU conditions are already implemented, contradicting the objectivity of the assessments made by the European institutions. Even if meeting the pre-accession conditions is the only requirement for candidate country status, non-alignment with sanctions against Russia could be an additional, but unstated, political obstacle.

The “Cypriot precedent”: the conditioning of Greece and the size of the uncontrolled area

Suggested as a precedent by Borrell, Cyprus’ accession to the EU in 2004 took place in a context of tense relations between Greece and Turkey and persistent deadlock in the island's reunification process. As an EU member state since 1981, Greece has treated Turkey's pre-accession dialogue and accession negotiations with the EU, initiated in 1999 and 2005 respectively, as ways of influencing both the settlement of the Cyprus issue and the resolution of the Turkish-Greek disputes, including territorial ones. The right of veto in the field of enlargement, which the EU member states possess, gave Greece an advantage in the process of Turkey’s accession to the EU. Subsequently, Greece extended the same lever on its relations with the EU and its enlargement policy towards Central and Eastern Europe (ex-socialist and ex-Soviet space) to promote the Cypriot candidacy, presented in 1990. Specifically, Greece conditioned the enlargement of the EU to the east, through the accession of nine states, with the inclusion of Cyprus in the same wave. This step was achieved, despite the fact that the island remained divided and with a disputed Turkish military presence in the northern region of Cyprus.

According to some estimates, the Greek Cypriot community saw added value in the EU accession process for the reintegration of the island. Thus, the Turkish minority would have received security and freedom guarantees, including in the field of free movement of people, as a result of Cyprus' accession to the European Economic Community (EEC-EU). Already in the pre-accession stage, the share of exports from the Greek part of the island to the EEC was 50% and in the Turkish part it was 64%. This trade dependence on the European market was another argument in favour of the island's accession as a whole to the EEC (EU) area.

In the 1998 EU documents, the integration of the northern part of Cyprus, controlled by the Turkish Cypriot community, with the military support of Turkey (which has had Nato membership since 1952), is considered manageable, if carried out as part of the accession of Cyprus to the EU. The EU’s openness to such a scenario was based on the territorial and population dimensions of the region controlled by the Turkish side, and the region’s potential in the field of tourism and agriculture was rated as an advantage. The only major objections raised by Brussels at the time concerned the need to align the region’s infrastructure standards with those of the rest of the Greek Cypriot-ruled island.

Yet even 19 years after Cyprus joined the EU, the island remains divided. The main reasons relate to the limited attractiveness of reunification to the EU and the deadlock in Turkey’s accession negotiations, including Turkey’s non-implementation of the Additional Protocol to the Association Agreement with the EU in relation to Cyprus. Both the Greek veto and the EU’s intention to contribute to the reunification of Cyprus served as essential factors in Cyprus’ accession. However, so that the lack of territorial integrity in the candidate country does not represent a problem for the EU, other aspects also matter.

The Cypriot example is rather sui generis, since not only is the size of the population in the breakaway region (the area controlled by the Turkish minority) negligible, but the external actor opposing reunification is an EU candidate country and Nato member: Turkey, with 40,000 soldiers stationed in Northern Cyprus in 2022. From this point of view, Cyprus could represent a kind of “semi-precedent” for the European integration of states in Eastern Europe and the South Caucasus with frozen conflicts — Moldova and Georgia — or armed conflicts (external military aggression) — Ukraine. Obviously, European integration represents an incentive for the territorial reintegration of these countries. However, unlike Cyprus, the territorial problems facing Ukraine, Moldova and Georgia stem from Russia’s aggressive stance that fuels and/or reproduces “frozen conflicts” in the ex-Soviet space, later used as a source of geopolitical influence in the region.

The Cypriot “semi-precedent” for Ukraine, Moldova and Georgia

Emerging from security realities in the countries with regions de facto controlled or occupied by Russia, the Cypriot model currently represents only a “semi-precedent” for the eventual EU membership agenda of Ukraine, Moldova and Georgia.

Firstly, the balance of forces in the separatist or temporarily occupied regions by Russian forces is constantly changing and will be marked by the results of the Ukrainian counteroffensive and the future of the war. Among the three cases, Moldova has the most influence in moving the Transnistrian conflict toward a peaceful solution. Therefore, the economic dependence on the breakaway regime of Moldova and the EU increases. At the same time, the Transnistrian region’s criminal-political elites are inclined to make concessions in order to survive politically and economically. The situation in Ukraine is currently uncertain due to the continuation of the war, and in the breakaway regions of Georgia — Abkhazia and South Ossetia — Russian political and military control is maintained and/or increased.

Secondly, Cyprus benefited from the Greek veto that forced the EU to accept the island still divided in the wave of enlargements of 2004. In the case of the “Associated Trio”, only Moldova has a degree of historical and identity kinship with another EU member state (Romania) similar to the one between Greece and Cyprus. In theory, Romania has a veto power that can be used to promote Moldova's accession to the EU. But Romania’s intra-European policy is still in the process of manifesting itself and will be partially limited by the fact that it is not yet part of the Schengen area or the Eurozone. Poland and the Baltic nations (Lithuania, Latvia and Estonia) could lobby for Ukraine. Georgia is in a more isolated situation. But if qualified majority voting materialises in the area of EU foreign policy and is eventually extended to enlargement policy, then the veto will disappear as a tool used by member states to promote or block candidate countries.

The third and last aspect refers to the size of the population and the territory of the separatist regions effectively occupied by Russia (see table below). According to the EU’s argument on the manageable size of the region not controlled by official Cyprus, formulated in 1998, Moldova and Georgia should be eligible for EU membership, having respectively 12% and 20% of their territories occupied. Similar parameters are also observed in terms of the population of the breakaway regions. In the case of Ukraine, the removal of Russian territorial occupation is currently underway.

At the same time, in addition to the EU’s ability to digest candidates with breakaway regions, the geopolitical actor that produces or feeds territorial disintegration also matters. Contrary to the negative image of Turkey, a candidate country for EU membership and a Nato member, in the case of Cyprus, Russia is perceived as a direct military threat both by the EU and by Ukraine, Moldova and Georgia.

Table. Comparison parameters between Cyprus, Ukraine, Moldova, and Ukraine: population and territory in uncontrolled regions, year of candidate status, destructive geopolitical actors






Population until accession to the EU, uncontrolled area





2,000,000 (only in the occupied Crimea)








Uncontrolled territory, % 





Candidate status, year







Pending since 2022


Qualification of the external actor that blocks the reinsertion

Tukey - EU candidate, NATO member state

Russia – aggressor state, source of threat to the EU

Russia – aggressor state, source of threat to the EU

Russia – aggressor state, source of threat to the EU

Source: Author's estimates, based on open sources. In the case of Ukraine, the percentage of the population is calculated for Crimea, within the internationally recognised borders of 1991, based on the fact that there are approximately 7mn Ukrainian refugees, of which 4mn are in EU states.


Although the Cypriot model offers some political solutions for new candidate countries with unresolved territorial issues, it is only a “semi-precedent” that requires individual approaches for Ukraine, Moldova and Georgia. Neither the Greek veto nor the Turkish factor is present in the case of the countries of the “Associated Trio” to replicate the accession of Cyprus to the EU. Instead, they are facing a violent and unpredictable geopolitical player: Russia.

The Ukrainian counter-offensive may revise the balance of forces even in areas with “frozen conflicts”. If Ukraine’s military success facilitates the substantial undermining of Russian levers of influence over decision-making processes in the breakaway regions, then the European integration of Ukraine, Moldova and Georgia may become a useful tool for territorial reintegration. In any case, if the three countries meet the conditions for the start of (pre-)accession negotiations, close the accession chapters and are accepted to join in the tangible future, then, as in the case of Cyprus, membership of the EU may be insufficient to reintegrate breakaway territories. Until then, the three countries must begin accession negotiations, for which they must produce credible, sustainable and transformative reforms in the immediate present.