EU’s largest Russia sanctions listings: implications for India

On 12 October 2026, the Council of the European Union (the “EU Council”) adopted sanctions against 1,569 individuals and entities in Russia’s military-industrial complex. [1]  The EU Council has described these measures as the single largest set of listings that the European Union (the “EU”) has ever agreed. The High Representative of the EU for Foreign Affairs and Security Policy, Ms Kaja Kallas, has called them the single largest expansion of the EU sanctions list since the war in Ukraine began. [2]

These new measures name only Russian companies and individuals. However, since February 2024, the EU Council has regularly named entities outside the EU and Russia, including entities in India, in its sanctions packages against Russia. Given this practice, we expect that the EU Council could name third-country entities again in its next round of measures.

This article explains the new measures, the legal framework behind them, the recent practice of listing third-country and Indian entities, and what this means for Indian businesses. Indian businesses must note that sanctions exposure no longer comes from the United States of America (the “U.S.”) alone.

The new measures list 826 Russian companies and 743 individuals who are the chief executive officers of those companies. The EU Council describes the companies as mid-level suppliers that form the core of Russia’s military industry. Together, they are reported to have an annual turnover of at least EUR 20 billion and employ more than 250,000 people. These listed companies are reported to supply components for missiles, unmanned aerial vehicles and aircraft, and their products include electronics, communication equipment, satellite and missile systems, explosives, ammunition, and optics and navigation systems.

The EU has frozen the assets of the listed persons, and no person in the EU may make funds or economic resources available to them. The listed individuals also face a ban on travel to the EU. The EU has published the legal acts of the listing in the Official Journal of the European Union. [3]  With these additions, the EU Council has now listed close to 4,600 persons in connection with the war in Ukraine.

Unlike the 20th package of 23 April 2026 and the 21st package of 23 July 2026, the new measures do not introduce new sectoral restrictions on the energy, financial or trade sectors. They consist of financial sanctions alone, which is a distinction that the legal framework described below makes important.

A “Russia sanctions package” is not a legal instrument. It is a set of legal acts that the EU Council adopts on the same day to amend two regulations that have been in force since 2014, in furtherance of the foreign policy of the EU towards Russia on account of its involvement in the war in Ukraine. [4]  The effect of a listing depends on which regulation and which annex to that regulation contains the name.

3.1 Regulation 269/2014: asset freezes

Council Regulation (EU) No 269/2014 (“Regulation 269/2014”) provides for financial sanctions. [5]  The EU freezes all funds and economic resources of a person listed in Annex I to Regulation 269/2014, and no person in the EU may make funds or economic resources available to a listed person, directly or indirectly. Listed individuals also face a travel ban. The new measures are listings under Regulation 269/2014. A listing under Regulation 269/2014 is similar to a designation on the Specially Designated Nationals list of the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”). 

3.2 Regulation 833/2014: sectoral sanctions

Council Regulation (EU) No 833/2014 (“Regulation 833/2014”) contains the sectoral sanctions, which restrict trade, energy, finance and transport. [6]  Two of its lists matter most to third-country entities. The first is Annex IV to Regulation 833/2014 (“Annex IV”), which lists entities to which persons in the EU may not supply dual-use goods and advanced technology items. A listing in Annex IV is therefore an export restriction and not an asset freeze. The second is Annex XLV to Regulation 833/2014 (“Annex XLV”), which lists entities outside the EU with which persons in the EU may not enter into any transaction. [7]

3.3 Reach of the regulations

Regulation 269/2014 and Regulation 833/2014 apply within the EU, to nationals of the EU member states, to entities incorporated in the EU, and to business done wholly or partly in the EU. [8]  They do not directly bind an Indian company that trades entirely outside the EU. They do, however, bind every bank, insurer, supplier, customer and group company in the EU that deals with the Indian company, and every EU member state must treat a breach of EU sanctions as a criminal offence. [9]  EU sanctions, therefore, reach India through these relationships.

While the new measures name Russian companies and individuals alone, the recent practice of the EU Council shows how measures against Russia’s military-industrial complex come to affect entities in third countries, including India.

4.1 How the practice began

For the first two years of the war in Ukraine, the EU Council directed its listings almost entirely at persons in Russia and Belarus. This changed with the 11th package of 23 June 2023, which introduced an anti-circumvention tool aimed at third countries through which sanctioned goods were reaching Russia. [10]  The EU Council named the first Indian company eight months later, when the 13th package of 23 February 2024 added one company registered in India to Annex IV, along with companies registered in China, Kazakhstan, Serbia, Sri Lanka, Thailand and Türkiye. [11]

4.2 Indian listings since February 2024

Since then, Indian names have appeared in seven of the nine packages from the 13th to the 21st. The 14th package of June 2024 and the 15th package of December 2024 each added one Indian company to Annex IV, the 16th package of February 2025 added two, and the 19th package of October 2025 added three. [12]  Only the 17th package of May 2025 and the 20th package of April 2026 named no Indian entity.

The measures have also become more severe. The 18th package of 18 July 2025 imposed the first asset freezes under Regulation 269/2014 on companies based in India, including Nayara Energy Limited (“Nayara”), which Rosneft of Russia reportedly partly owns. [13]  The 21st package of 23 July 2026 then used all three forms of listing against India-linked persons at once. It added two Indian companies to Annex IV, froze the assets of a maritime services company and an individual based in India, and added ‘Sberbank India’ and ‘India VTB’, the Indian operations of sanctioned Russian banks, to Annex XLV from 13 August 2026. [14]

In total, since February 2024, the EU Council has taken 14 listing measures against companies and individuals based in India, of which 10 are listings in Annex IV and 4 are asset freezes under Regulation 269/2014. The two transaction bans under Annex XLV are in addition. 

Figure 1 below shows the position, including the new measures of 12 October 2026, which named no Indian entity.

Figure 1: India-linked listings in EU sanctions packages against Russia, from the 13th package to the new measures of 12 October 2026

4.3 A wider practice

The EU Council has not singled out India. Of the 60 entities that the 20th package added to Annex IV, 28 were in third countries such as China (including Hong Kong), Türkiye, the United Arab Emirates and Thailand, and the 51 entities that the 21st package added included entities in China, India, Kazakhstan, Kyrgyzstan, Türkiye and the United Arab Emirates. [15]  The EU Council has also extended asset freezes to third-country actors. The first such listings of Chinese actors came in the 15th package of December 2024, [16]  and asset freezes on entities based in India followed in the 18th and 21st packages, as noted above.

The listing of third-country entities is now an established feature of the EU sanctions packages against Russia. The new measures targeted Russian companies and individuals alone. While Indian businesses can take comfort from the absence of third-country names on this occasion, we expect that the EU Council may return to this practice in its next round of measures.

4.4 Basis of listings

The EU Council does not seem to publish the material on which it bases a listing in Annex IV. The position is not entirely clear, but the EU Council appears to rely, at least in part, on export and import data that commercial trade data aggregators unofficially publish. No authority verifies this data and a company may therefore find itself listed on the basis of records that it has had no chance to examine or correct.

4.5 Recourse available to a listed entity

This makes the available recourse all the more relevant. A listing by the EU Council is open to challenge. A listed entity may ask the EU Council to reconsider its listing, and the EU Council appears to have removed third-country entities from its lists in the past, including after it reportedly received commitments about their future (change in) conduct. [17]  A listed entity may also bring an action for annulment before the General Court of the European Union, subject to a strict time limit. [18]  The right course in each case depends on the regulation and annex that contain the listing, the reasons that the EU Council gives, and the evidence available to rebut those reasons. Since the remedies are time-bound, a listed entity must act promptly.

Awareness of sanctions, and compliance with them, is not yet widespread in Indian industry. Where Indian businesses do have sanctions compliance in place, it appears to be built around the U.S. alone, with a focus on the lists that OFAC maintains, the risk of secondary sanctions and access to the U.S. dollar. That focus remains necessary, but it is no longer sufficient. As set out above, the EU Council has named Indian entities in most of its packages since February 2024, and the measures that it has used against them have grown from export restrictions to asset freezes and transaction bans.

Against this background, the new measures matter directly to Indian businesses. No bank, insurer, supplier or customer in the EU may now deal with any of the 826 newly listed companies, and Indian businesses that continue to transact with these companies may find that their own EU relationships suffer. Indian companies that transact with the listed entities can also expect close scrutiny of those dealings, both from their banks and counterparties in the EU and from the EU Council when it identifies entities for future listings. This is significant because the EU Council has, in its earlier packages, listed third-country entities, including Indian entities, for allegedly supplying goods to Russia’s military-industrial complex.

EU law also places duties on the EU counterparties of Indian businesses. Exporters in the EU must contractually prohibit their buyers outside the EU from re-exporting sensitive goods to Russia, and parent companies in the EU must make their best efforts to ensure that their subsidiaries outside the EU do not undermine the sanctions. [19]  Indian businesses will therefore encounter EU sanctions in their contracts and in the conduct of their EU counterparties, even where they have no dealings with Russia.

The experience of Nayara shows how quickly an EU listing affects a business in India, and how EU sanctions can come into conflict with Indian law. The EU Council listed Nayara under Regulation 269/2014 on 18 July 2025. On 24 July 2025, SAP India Private Limited (“SAP India”), the Indian subsidiary of the German software company SAP SE, suspended the software support services that it provided to Nayara, and its export control team declared business with Nayara to be prohibited because of the EU listing. [20]

Nayara filed a suit against SAP India before the Hon’ble Delhi High Court, with an interim application seeking directions from the Hon’ble Court to restore services. SAP India argued that the services were economic resources that Regulation 269/2014 required it to withhold, and that its German parent, which performed the services, faced criminal liability under German law if they continued. It contended that the contracts had therefore become void or impossible to perform under Sections 32 and 56 of the Indian Contract Act, 1872.

The Hon’ble Delhi High Court, however, did not accept this defence at the interim stage. J. Mahajan held that Indian law governed the agreements, which expressly gave Indian law priority over any conflicting foreign rule. It was further held that an Indian court cannot take judicial notice of an EU regulation, and that a party relying on foreign law must prove it as a fact through expert evidence at trial. Since SAP India had not yet done so, it could not rely on the EU regulations at the interim stage to avoid its obligations under contracts governed by Indian law. The Hon’ble Court directed SAP India to resume the services and to restore the position as it stood before 24 July 2025, noting that Nayara meets about 8% of the energy needs of India and that uninterrupted technical support was essential for infrastructure of this kind.

While the findings are interim and the order has been appealed by SAP India before a division bench at the Hon’ble Delhi High Court, such a ruling may provide much needed relief to Indian companies for their business-continuity concerns in light of the extraterritorial effect of foreign sanctions.

The new measures are the largest that the EU has adopted against Russia, and the direction of EU sanctions policy is clear. The EU Council now looks beyond Russia to the entities that supply and trade with its military-industrial complex. Indian businesses that deal with Russia, directly or through intermediaries in third countries, should therefore review those dealings, their counterparties and their supply chains for exposure under EU sanctions, and should screen counterparties against the updated EU lists as well as the OFAC lists. This is particularly important now, because the next round of measures may name third-country entities and dealings with the newly listed Russian companies are likely to attract scrutiny.

More broadly, Indian businesses should re-examine whether their compliance frameworks, export controls and contractual protections address EU sanctions as well as U.S. sanctions. Businesses that do this before a listing, and not after it, will be better placed to protect their access to the EU market, their banking relationships and their reputation.