The action comes as a result of evidence produced by World Anti-Doping Agency investigator Richard McLaren, who released his latest report on December 9th.
McLaren has accused Russia of "state sponsored" doping; using the intelligence services to organise the swapping of samples at Sochi.
“The IOC is initiating disciplinary cases against all 28 athletes for whom there is evidence of manipulation of one or more of their urine samples that were collected at the Olympic Winter Games Sochi 2014,” an IOC statement said.
McLaren found that 28 of the 95 samples his team studied had signs of "manipulation".
Those samples are now being re-analysed at the Lausanne Anti-Doping Laboratory. The Olympic body said the cases are not yet doping failures but that the tampering alone could lead to sanctions.
The Russian government has denied any official involvement in the doping.