MEP Marc Botenga (The Left) has submitted a parliamentary question challenging the European Commission to explain an apparent contradiction in its account of how it suspended payments to Russian entities under Horizon Europe following the invasion of Ukraine. The question, filed on 26 June 2026, targets the legal basis and factual accuracy of the Commission's actions between March and April 2022, and could affect the credibility of EU sanctions enforcement and the rights of research partners.
Botenga points to the Commission's public announcement on 4 March 2022 of a 'general suspension' of payments and cooperation with Russian entities under Horizon Europe. On 8 April 2022, the Commission further announced that with the fifth sanctions package, participation of all Russian public bodies in ongoing projects would be terminated. However, in February 2026, the Commission stated that both measures had been carried out on a 'case-by-case assessment'. The MEP asks how these two accounts can be reconciled, and whether the initial suspension had any legal basis before the fifth sanctions package entered into force.
first, an explanation of the contradiction; second, the legal basis for a general suspension if one existed; third, the number of individual decisions taken between 4 March and 8 April 2022 if the measures were case-by-case. The Commission is expected to reply within approximately six weeks, and its answer will signal whether it maintains the 2026 interpretation or acknowledges a broader initial suspension.
The question reflects a tension between swift executive action in crisis and the requirement for a clear legal mandate. A general suspension without explicit sanctions would imply the Commission acted beyond its delegated powers, while a case-by-case approach would require evidence of individual assessments. The outcome could influence future EU crisis management procedures and the transparency of sanctions implementation.
EU research institutions and Horizon Europe beneficiaries face uncertainty over the legal validity of past decisions; Russian entities affected by the suspension may seek legal recourse if the legal basis is found lacking; the European Commission risks reputational damage if it cannot justify its actions; and EU member states may see implications for the balance between swift sanctions and rule-of-law constraints.