EU Regulation banning imports of Russian natural gas expected in early 2026
The European Commission is expected to approve a Regulation to phase out imports of Russian natural gas for both pipeline gas and liquefied natural gas (LNG), which was proposed on 17 June 2025, as part of EU’s broader energy security and sanctions policy.
On 2 December 2025, the Council of the European Union and the European Parliament reached a provisional agreement on the Regulation, agreeing to a full ban on Russian gas imports, subject to transitional arrangements for existing contracts.
On 17 December 2025, the European Parliament adopted the Regulation’s text at first reading and transmitted it to the Council for approval and publication in the Official Journal. The Council’s Permanent Representatives Committee has confirmed that the Council will approve the Regulation subject to legal-linguistic review.
Final approval is expected in early 2026.
The Regulation establishes a prohibition on imports of Russian pipeline gas and LNG, applicable six weeks after entry into force, with transitional arrangements for certain existing contracts.
Specifically, for short-term supply contracts concluded before 17 June 2025:
- LNG: the ban will apply from 25 April 2026;
- Pipeline gas: the ban will apply from 17 June 2026.
For long-term contracts:
- LNG: the ban will apply from 1 January 2027;
- Pipeline gas: the ban will apply from 30 September 2027 with a possible extension to 1 November 2027 for EU member states at risk of meeting the 2027 gas storage filling target. The Commission will confirm such extensions through implementing decisions made no later than 15 September 2027.
Amendments to existing contracts are permitted only for narrowly defined operational purposes. These amendments cannot increase volumes, and deliveries under exemptions must not exceed the originally contracted quantities.
The Regulation introduces a prior authorisation requirement for imports of both LNG and pipeline gas, applicable from six weeks minus one month after entry into force.
- For Russian gas and imports subject to transitional arrangements, authorisation information must be submitted at least one month prior to entry.
- For non-Russian gas, proof must be provided:
- at least five working days before entry; or
- seven working days before entry where gas is imported via the Strandzha 1 interconnection point.
To limit administrative burdens, no prior authorisation is required where gas is imported from a country that:
- produced gas and exported more than 5 bcm of natural gas to the EU in 2024; and
- either has prohibited Russian gas or imposed other restrictive measures concerning Russian gas, or has no infrastructure enabling imports of LNG or pipeline gas.
The Regulation imposes several reporting and planning obligations on EU member states:
- By 1 March 2026, member states must submit national diversification plans identifying measures and challenges to ending imports of Russian gas in line with the Regulation’s deadlines.
- Within four weeks after entry into force, member states must provide the Commission with import contract information relating to Russian gas under the amended security of supply framework.
- Member states continuing to import Russian oil must submit oil diversification plans setting out how those imports will be discontinued by the end of 2027.
The final text of the Regulation has strengthened enforcement in comparison to the Commission’s initial proposal. The final Regulation requires member states to introduce effective, proportionate and dissuasive penalties for non‑compliance, including maximum penalty thresholds for companies and private individuals.
For more information on the ban of Russian natural gas into the EU, contact your CMS client partner or the CMS experts who contributed to this article.
