EU Commission unveils proposals to use the frozen funds of the Russian Central Bank

On 3 December 2025, the EU Commission published several proposals for regulations outlining two possible mechanisms to support Ukraine's financial needs.

These proposals will be discussed during the next European Council on 18-19 December 2025 which aims at a clear commitment on the way forward.

These proposals include a number of safeguards designed to protect Member States and financial institutions holding the frozen assets of the Russian Central Bank.

These two proposed solutions are :

• the use of the UE budget to underpin a loan to Ukraine; and

• the creation of a “reparation loan” allowing the EU Commission to borrow cash balances from EU financial institutions holding immobilised assets or reserves of the Russian Central Bank, or assets held for its benefit (or for the benefit of any legal person, entity or body acting on behalf of, or at the direction of the Russian Central Bank, such as the Russian National Wealth Fund).  This proposal does not concern, other frozen funds.

There is no legal basis allowing the use of Russian frozen funds belonging to other Russian entities or individuals.

Sources :

• Commission unveils two solutions to support Ukraine's financing needs in 2026-2027

• Proposal for a Regulation establishing the Reparations Loan to Ukraine and amending Regulation (EU) 2024/792

• Proposal for a Council Regulation on emergency measures addressing the serious economic difficulties caused by Russia's actions in the context of the war in Ukraine

• Proposal for a Council Regulation on amending Council Regulation 2020/2093 laying down the MFF for the years 2021-2027

For more information, please contact :

Bruno Lebrun – Partner – b.lebrun@janson.be

Cédric Alter – Partner – c.alter@janson.be