Insights

EU Moves to End Russian Natural Gas Imports and Prepare Oil Ban

The European Union has adopted a regulation that establishes a stepwise prohibition on (pipeline) imports of Russian natural gas and LNG, and sets in motion plans for the full phase-out of Russian oil.

In line with the European Commission's Communication of 6 May 2025 on the Roadmap towards ending Russian energy imports ("REPowerEU Roadmap"), on 26 January 2026, the EU adopted Regulation (EU) 2026/261 (the "Regulation") to effectuate ending Russian energy imports, with clear deadlines underlying an authorization framework. The Regulation reflects policy objectives concerning the diversification of the EU's energy supply sources. The Regulation entered into force on 3 February 2026.

The Regulation introduces an EU-wide, legally binding framework for the phase out of direct and indirect imports of natural gas, originating in or exported from Russia, covering both pipeline gas and liquefied natural gas ("LNG"), including Russian gas contained in mixed LNG cargoes. The phase out timeline varies depending on the type and timing of the contract, with full application by 30 September 2027, subject to certain transitional and implementation conditions.

As a general rule, the Regulation imposes a prohibition to import natural gas under new contracts (i.e., contracts concluded or "materially" amended after 17 June 2025). For pre-17 June 2025 contracts, the Regulation provides for transitional periods. Short-term contracts benefit from transitional periods extending into 2026, while long-term contracts may benefit from longer transition periods, in some cases extending to 2027, and including specific provisions for landlocked Member States facing supply route constraints.

To support enforcement and prevent circumvention, the Regulation establishes a prior authorization regime for in-scope contracts that are subject to the relevant transitional periods. This authorization regime takes effect as of 18 February 2026, and imposes extensive administration obligations on importers. In some cases, the import of natural gas from production countries other than the Russian Federation would also require prior authorization, with some exceptions. The Regulation further grants enhanced powers to EU Member State enforcement and customs authorities to prevent circumvention, including in relation to transit.

Obligations are also placed on EU Member States. These include the obligation to submit, by 1 March 2026, national diversification plans outlining measures to replace Russian gas and oil supplies. In parallel, EU Member States are required to establish penalties for breaches of the Regulation, subject to pre-defined maximum thresholds.

In conclusion, the Regulation significantly tightens controls on Russian gas imports into the EU and signals a shift from policy-driven reduction of Russian energy dependence to a legally binding phase out. EU gas importers, traders, and related operators should assess their exposure and adopt compliance measures in light of the new rules.

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