On 16 October 2019, President Vladimir Putin signed an executive order[9] and submitted a State Duma bill to revoke the statement accompanying Russia's ratification of the Protocol I, accepting the competence of the Article 90(2) International Fact-Finding Commission.

[10][11][12] The bill was supplied with the following warning:[10][12] Exceptional circumstances affect the interests of the Russian Federation and require urgent action. ...

In the current international environment, the risks of abuse of the commission's powers for political purposes by unscrupulous states who act in bad faith have increased significantly.Article 1(4) says: The situations referred to in the preceding paragraph include armed conflicts in which peoples are fighting against colonial domination and alien occupation and against racist regimes in the exercise of their right of self-determination.Jan Arno Hessbruegge, who works at the New York Office of the United Nations High Commissioner for Human Rights, examined the three categories listed in his book Human Rights and Personal Self-defense in International Law:[13] Legal scholar Waldemar A. Solf opined that Article 1(4) was largely symbolic and gave party states "a plausible basis for denying its application to their situation", while the states which the article most applied to (e.g., Israel, and apartheid-era South Africa) would not sign the agreement at all.

[14] The Reagan administration declared that Article 1(4) would "grant terrorists a psychological and legal victory",[15] as it appears to grant combatant status to non-state actors, many of which (such as the Palestine Liberation Organization) have been designated as terrorist groups by the United States and other countries.

By contrast, an article in the International Review of the Red Cross argues that this article, in fact, strengthens the fight against terrorism, by applying the laws of war (including all its prohibitions and obligations) to national wars of liberation.