The EU Council has adopted a corrigendum to its sanctions regime against Russia, correcting an error in the Danish and Estonian language versions of Regulation (EU) 2025/2033. The correction clarifies that the prohibition applies to maintaining any existing capital interest in entities within Russian special economic zones listed in Annex LII, Part A, rather than the previously stated 'new or expanded' interests. This technical adjustment ensures the legal text accurately reflects the intended scope of the restrictive measures under the EU's Common Foreign and Security Policy (CFSP), aimed at countering Russia's actions destabilising Ukraine.
Document details
The corrigendum, published on 2 September 2026, amends Council Regulation (EU) No 833/2014, which forms the backbone of EU sanctions against Russia. The error was limited to the Danish and Estonian versions, meaning the substantive obligations for other member states remain unchanged. The correction is classified as a legislative act and is binding in its entirety.
Policy orientation and trade-offs
The corrigendum does not introduce new policy but ensures consistency across language versions. By clarifying that the prohibition covers all existing capital interests, the EU closes a potential loophole that could have allowed continued investment in Russian special economic zones. This strengthens the sanctions' effectiveness but imposes a stricter compliance burden on entities that may have interpreted the earlier wording as permitting existing holdings.
Impact on stakeholders
- EU businesses and investors: Those with existing capital interests in Russian special economic zones must now divest or face penalties. The correction eliminates any ambiguity about grandfathering existing investments.
- National authorities of EU member states: Danish and Estonian enforcement agencies must update their guidance and ensure compliance with the corrected text. Other member states are unaffected.
- Russian entities in special economic zones: The correction reduces their access to EU capital, potentially hampering their operations and investment.
- EU regulatory bodies: The Council and Commission must ensure that future sanctions texts undergo rigorous linguistic review to prevent similar errors.
Institutional follow-up
The corrigendum takes effect upon publication in the Official Journal of the European Union. No further institutional action is required, as the correction is purely technical. However, the European Commission may issue guidance to assist stakeholders in complying with the clarified prohibition.