Yesterday the Council of the European Union and the European Parliament reached a provisional agreement on a Regulation under the REPowerEU framework to end EU imports of Russian natural gas, covering both liquefied natural gas and pipeline gas.
The provisional agreement introduces a stepwise, legally binding prohibition: as a rule, imports of Russian liquified natural gas (LNG) and pipeline gas will be prohibited six weeks after the Regulation enters into force, while allowing wind-down periods for certain existing contracts (25 April 2026 for certain short-term LNG contracts and 1 January 2027 for long-term LNG contracts) and phase-out of long-term pipeline gas by 30 September 2027 (or 1 November 2027 if storage-filling conditions are not met).
The Regulation builds on the Commission’s 17 June 2025 Proposal, which aimed to combine an import phase-out with stronger monitoring of potential energy dependencies and amendments to the security of gas supply Regulation.
Background: REPowerEU and the Post-2022 Shift
Following Russia’s full-scale invasion of Ukraine, EU leaders committed to end dependence on Russian fossil fuels as soon as possible. Since then, EU exposure has fallen sharply in some areas: coal imports from Russia were banned by EU sanctions in 2022 and thereby reduced to zero, while crude oil imports fell from roughly 27% in 2022 to around 3% in 2025. Russian gas, however, still accounted for an estimated 13% of EU gas imports in 2025, worth over 15 billion euros annually, which policymakers consider a continued security and market vulnerability.
EU Sanctions
The upcoming Regulation is separate from the sanctions adopted by the Council of the European Union against Russia, including the 19th sanctions package adopted on 23 October 2025 that introduced a phased ban on LNG imports (not on pipeline gas).
Sanctions are coercive foreign policy measures that are meant to be temporary. They need the unanimous support of the Member States in the Council to become European law. By contrast, the REPowerEU-based Regulation is designed as a structural, long-term trade and energy measure, intended to apply beyond any lifting of sanctions against Russia. It will become law if adopted by a qualified majority of the Member States in the Council, and a simple majority in the European Parliament. The negotiations between these two EU co-legislators, under the brokerage of the Commission, are called the trilogue.
Positions before the Provisional Agreement
Ahead of the trilogue negotiations, the Council adopted its negotiating position on 20 October 2025, keeping the Commission’s then-planned 1 January 2028 full-ban date and confirming a prohibition from 1 January 2026, subject to transitional arrangements for existing contracts. In parallel, the Parliament’s committees in charge of the file (INTA-ITRE) supported a faster phase-out, including bringing forward the end date for long-term LNG contracts by around one year.
Main Elements of the Provisional Agreement
The Council and the Parliament agreed that imports of Russian pipeline gas and LNG will be prohibited six weeks after the Regulation enters into force (instead of by 1 January 2026), with temporary transition periods for certain existing contracts, as follows:
- for short term supply contracts concluded before 17 June 2025, the ban will apply from 25 April 2026 for LNG (in line with EU sanctions) and 17 June 2026 for pipeline gas;
- for long-term LNG contracts, the prohibition will apply from 1 January 2027 (in line with EU sanctions);
- for long term pipeline gas contracts, the prohibition will kick-in on 30 September 2027, provided that Member States are on track to fulfil the storage-filling targets foreseen in the gas storage regulation; otherwise, the prohibition will start applying no later than on 1 November 2027
Thus, in effect, the co-legislators agreed to push forward the phasing out of gas imports by one year, at least for LNG, with a full ban starting on 1 January 2027.
The co-legislators also adopted the prior authorization regime during the transitional phase as follows:
- for Russian gas still eligible under the transitional period, the required information for authorization (such as date of conclusion of the gas supply contract, duration of the gas supply contract, identify of the parties to the country, EORI number, the delivery points etc.) must be submitted at least one month before entry.
- for non-Russian gas, the proof must be provided at least five days before entry (and 7 days for gas imported via the Strandzha 1 interconnection point).
- Some countries can be exempted from the authorization procedure based on objective criteria (e.g., major gas-producing countries that exported more than 5bcm of natural gas to the EU in 2024 and that either prohibit or restrict imports of Russian gas, or countries without any infrastructure to import).
Contrary to the Commission’s Proposal, the co-legislators introduced provisions for effective, proportionate and dissuasive penalties for failure to comply with the measures set out in the Regulation, including a maximum threshold for penalties both for companies and private individuals.
In addition, the Council and the Parliament maintained the suspension clause allowing the Commission to temporarily suspend the measures because of sudden and significant development seriously threatening the security of energy supply of one or more Member States. However, the co-legislators tightened the conditions for the Commission to trigger the temporary lifting of the import prohibition, including reliance on a declared state of emergency and limited duration, focused on short-term contracts.
Finally, the co-legislators also required the Commission to review the implementation of the Regulation within two years, including for the prior authorization procedure. Member States must also prepare national diversification plans outlining measures for diversifying their oil and gas supplies and potential challenges in doing so.
Next Steps
The provisional agreement must still be formally adopted by the Council and Parliament and then published in the Official Journal before it enters into force.
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Please do not hesitate to get in touch with Cassidy Levy Kent’s European security team in Brussels, or your usual contact in any of Cassidy Levy Kent’s offices, with any questions.