Regulation (EU) 2025/2600: what changes and what effects it will produce
Regulation (EU) 2025/2600 of the Council, adopted on 12 December 2025, introduces a new approach to the European Union’s restrictive measures, marking a significant step forward compared with previous sanction packages.
Main novelties
- Default immobilisation of sovereign assets: the regulation establishes a mechanism that makes the freezing of assets considered to be Russian sovereign property structural, moving away from the six‑monthly renewal practice typical of the Common Foreign and Security Policy (CFSP).
- Legal basis and decision‑making procedure: the measure is based on Article 122 of the TFEU (Treaty on the Functioning of the European Union), which allows the Council to adopt urgent measures in the event of serious supply difficulties or in exceptional circumstances; this enables decisions by qualified majority, overcoming the impasse caused by unanimity and potential vetoes by Member States.
Entities affected
- Assets and reserves of the Central Bank of the Russian Federation (CBR): any transfer, direct or indirect, of such funds is prohibited.
- Related entities: the restriction also extends to legal persons and bodies acting on behalf of, or under the direction of, the CBR, including the Russian National Wealth Fund.
Duration and conditions for lifting the measures
Assets will remain immobilised until three cumulative conditions are met:
- Cessation of military aggression against Ukraine.
- Payment of war reparations sufficient to cover the damage.
- Formal and verifiable guarantees of non‑repetition.
Practical consequences
- The regulation effectively blocks enforcement of Russian court decisions seeking the return of sovereign assets.
- The immobilised assets are intended to serve as collateral for a €90 billion loan agreed at G7/EU level; the interest generated will be used for debt service and for Ukraine’s reconstruction.
- For financial operators, managing these funds becomes a long‑term restriction, with very stringent compliance requirements.
Legal and constitutional issues
The regulation raises significant questions of international law and EU law, in particular regarding state immunity and protection of property:
- Russia may challenge the measure as a breach of the customary principle of sovereign immunity of state assets.
- Although the measure is presented as a “freezing” (reversible) and not as a definitive confiscation, its near‑permanent character raises proportionality concerns in light of the EU Charter of Fundamental Rights.
Political and economic impact
With this regulation, sanctions evolve from an instrument of diplomatic pressure to an element of macroeconomic stability and recompense. Operationally, banks and financial institutions will need to treat these funds as immobilised in the long term and adopt appropriate compliance procedures.
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