Brussels, 1st December 2025
What’s happening:
The EU has now entered the final stage of negotiations on the proposed Regulation to ban imports of Russian gas. The last open-ended trilogue will take place on Tuesday, 2 December, where negotiators from the European Parliament and Council are expected to reach a political compromise. If an agreement is found, the Danish Presidency will be able to put the text to a final vote in the Council on 15 December, in parallel with a plenary vote in the European Parliament, during the week of 15 December.
However, negotiations remain difficult: the Parliament has adopted a significantly more ambitious position than the Council, which risks watering down the ambition and impact of the final agreed text.
Why it matters:
The Regulation is a key step to:
- reduce Russia’s war revenues, which continue to finance the full scale, unjustified, invasion of Ukraine, soon entering its fourth year;
- end Europe’s dangerous dependence on Russian fossil fuels, while strengthening the EU’s democracy, energy security and preventing future geopolitical and energy price crises.
Delays or weakened rules would undermine EU energy security, prolong the war in Ukraine, and leave open channels for continued political pressure – especially from those countries, which have consistently blocked and delayed more ambitious EU measures and sanctions against Russia for years.
A new research documents Russia’s extensive influence across Europe and how they are organising political and corporate resistance against the phasing out of Russian fossil fuels.The research indicates that several major EU political far right parties received Russian energy sector financing including Austria’s FPÖ (cooperation agreement with United Russia, 2016), France’s National Rally (€9.4 million loan, 2014), and Germany’s AfD (financial connections promoting Russian gas dependency), undermining thereby democracy in the Union. On top of this, Europe has historically been Russia’s main customer for gas exports, re-exports and transshipments. Yamal LNG’s European contracts (with TotalEnergies, SEFE, Naturgy, and Fluxys) between 2022 and 2024 generated around $5.2 billion to Russian tax revenues.
Over the last weeks of negotiations, over 30 civil society organisations called on the EU to adopt the European Parliament’s more ambitious position to finally put an end to the EU’s dependence on Russian gas. The timeline is particularly important: the Parliament proposes banning all Russian fossil gas imports by 1 January 2027, while the Council’s approach would allow Russia to continue receiving revenues from European fossil fuel exports for another year, until 1 January 2028. The differences between the positions of the European Parliament and the Council of the EU are very significant when measured in monetary terms. According to Razom We Stand’s estimates, the EU could deprive Putin’s military machine of an additional €29 billion between 2026 and 2028.
“This Regulation will set an important precedent for the EU and it cannot be built on loopholes and exemptions. Weakening the text now would leave open backdoors for indirect Russian gas flows. Postponing a ban on Russian gas imports until 2028 would not only continue to fuel Putin’s war economy by €29 billion, but also enable the Kremlin to sustain its dangerous influence over EU democracy, including by funnelling resources, directly or indirectly, into major far-right parties such as Austria’s FPÖ, France’s Rassemblement National, and Germany’s AfD. This alarming reality underscores the urgency of cutting all remaining ties with Russian fossil fuels, but also rejecting new dependencies on unreliable countries, and fast-tracking the full phase-out of fossil gas.” said Flora Witkowski, Gas Policy Coordinator at Climate Action Network (CAN) Europe
Beyond the timeline, a credible Regulation must close loopholes, strengthen enforcement, prevent indirect imports, and ensure consistent application across all Member States. The European Parliament’s mandate is much stronger in this sense, as it does not create any exemption for landlocked countries, rejecting the Council’s call for “regional flexibility” and extended transition periods. It also extends the scope of the regulation to cover Russian oil and petrochemical imports by 1 January 2027. These elements unfortunately very likely will not survive the Member States’ divided approach on the issue.
Other key points under negotiations at stake:
As several issues still need to be discussed in the upcoming trilogue, four points will require particular vigilance:
- Strengthening the prior-autorisation system for fossil gas not directly originated from Russia
Both the European Parliament and the Council agreed to add a specific pre-autorisation system for imports of gas produced in countries other than Russia, strengthening overall the regulation with a traceability and ex-post monitoring system that protects the EU from buying Russian gas through intermediaries. But the two positions are significantly diverging on crucial issues.
The EP’s version of article 7.2.a proposes a one-month verification period, giving operators and custom authorities enough time to submit all relevant documentation, and to assess, analyse and verify the compliance and integrity of the information provided, before granting authorisation to enter the EU market. It creates a real barrier to circumvention, unifies the mechanism, includes OLAF, guarantees transparency, and provides for a risk-based approach, minimising opportunities for corruption. The Council’s mandate, on the other hand, foresees 5 days for the reporting and control of the origin verification. Checking the movement of LNG tankers alone takes between 3 to 6 days just to obtain the data and confirm it with the port authorities and a few more days to check the loading documents. This is already more than 5 days. The Council’s position might be convenient for business, but it doesn’t allow for real monitoring and therefore does not protect the EU from indirect Russian gas imports.
On top of this, the Council, under strong pressure from fossil fuel industries and supported by Italy and Spain, is pushing to grant Qatar, Nigeria and Algeria an exemption from this already simplified pre-authorisation system, despite the fact that none of these countries have a strict legal ban or tracing system for Russian gas flows (negotiations around article 7.2b.). The European Parliament mandate must also be maintained in the final agreed text, to ensure that only countries with an explicit legal ban on Russian gas can benefit from an exemption of the pre-autorisation system (limiting the list of “trusted countries” to the US, UK and Norway). The Council’s extended list of trusted countries is creating a real threat in terms of energy security: Qatar’s recent threats to cut LNG supplies in response to EU legislation, Algeria’s track record of using gas as political leverage and its deepening energy cooperation with Russia, and Nigeria’s continued openness to Russian energy ties, show that these suppliers cannot be treated as inherently reliable.
- Preserving the European Parliament’s penalty article (Article 10a), including the 5% minimum threshold for the administrative fine
Without an article on penalties, the entire implementation of this Regulation is jeopardised. While the European Parliament was so far successful to maintain a firm position on this article, there is concern that a potential compromise could align the wording of this with the penalty regime set up under the EU Methate Regulation, that sets out the general principles of effectiveness, proportionality and dissuasiveness of penalties, but does not establish a strict minimum threshold for the fines.
Relying solely on these principles is insufficient, as it does not guarantee harmonized penalties across the EU Member States.
Without the 5% minimum administrative fine threshold that the European Parliament included in its mandate, penalties risk becoming symbolic, uneven across Member States, and easily absorbed as a cost of doing business by large companies. The 5% threshold is essential to create real deterrence and to make the Regulation enforceable in practice. It is also essential to ensure that the sanctions are genuinely dissuasive and that we have an even level playing field without creating a “patchwork of penalty regimes” across EU Member States.
- Deleting completely Article 15 (the “security of supply” suspension clause), without compromise
The European Parliament is calling for a complete deletion of Article 15, because it fundamentally undermines the purpose and legal integrity of the Russian Gas Ban Regulation by permitting a temporary return to Russian gas, based on an undemocratic, unilateral and uncontrolled assessment made by the European Commission alone, and potentially reopening the door for blackmailing from EU Member States, especially Hungary and Slovakia.
Unfortunately, a complete removal of this article is a red line for some member states such as Germany, Spain and landlocked countries. We hope that the European Parliament will stay strong during the last night of negotiations and win in securing the complete removal of this article. Any other version of this clause, even with added safeguards, or added layers of controls to the Commission’s unilateral powers to apply the exemption, would keep alive the very vulnerability that fuelled the 2022 energy crisis and would continue to threaten EU security of supply, instead of supporting it.
- Maintaining and strengthening National Diversification Plans, ensuring they will be public
The diversification plans are a central piece of the implementation of this regulation, to avoid supply disruptions and ensure a coordinated phase out of Russian fossil fuels across the EU. Yet, EU Member States have largely dismissed them on the grounds of “administrative burden”. The European Parliament’s mandate is stronger, and introduces concrete milestones and legally binding timelines.
Negotiations might lead to a situation where only Member States directly concerned by the imports of Russian oil and gas through their national borders will have to realise these plans. This would de facto exclude most of EU Member States from doing these plans, even if some of them are directly re-importing the same gas (e.g. Germany through Belgium, or Luxembourg sharing a joint grid system with Belgium). At a minimum negotiators must ensure transparency requirements and make all plans public to guarantee scrutiny and consistency with REPowerEU. It is crucial to keep these plans to ensure transparency, accountability, and coordinated phase-out efforts across the EU.
This is particularly important for the phase out plans on oil, as the European Parliament will most certainly not obtain an extension of the gas ban to oil imports. Robust, transparent and legally time-bound national diversification plans for oil in each member state would ensure a concrete phase-out rather than relying on political declarations.
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Notes to the Editor:
Read and download the full media advisory here: https://caneurope.org/content/uploads/2025/12/Media-advisory-on-last-Trilogue.pdf
Joint Letter: https://caneurope.org/content/uploads/2025/11/CSO-joint-letter.pdf
Joint NGO detailed recommendations for the trilogue negotiations
Contact:
Flora Witkowski, Gas Policy Coordinator – flora.witkowski@caneurope.org
Marianna Plomariti, Communications Coordinator – marianna.plomariti@caneurope.org