The European Union has triggered Article 122 to indefinitely...
Jorge Liboreiro@JorgeLiboreiro
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Dec 12, 2025
~3 min read
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The European Union has triggered Article 122 to indefinitely immobilise the assets of the Russian Central Bank, worth a whopping €210 billion.
I explain what just happened and why this is such a big deal for Europeans.
🧵 Long thread.
I explain what just happened and why this is such a big deal for Europeans.
🧵 Long thread.
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In the early days of Russia's war, the EU, in close coordination with G7 allies, agreed to immobilise the assets of the Russian Central Bank.
This was done under traditional EU sanctions, which depend on unanimity. Since then, the sanctions have been renewed every 6 months.
This was done under traditional EU sanctions, which depend on unanimity. Since then, the sanctions have been renewed every 6 months.
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In the months that followed, the EU debated several ways to use those assets and "make Russia pay", as leaders repeatedly said.
In 2024, they decided to capture the windfall profits, estimated at €2.5-3 billion annually, to support Ukraine but without touching the assets.
In 2024, they decided to capture the windfall profits, estimated at €2.5-3 billion annually, to support Ukraine but without touching the assets.
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But after Trump returned to the White House and cut off all assistance to Ukraine, Europeans were suddenly forced to assume the full responsibility.
Ukraine's financial and military needs for 2026 and 2027 are estimated at a staggering €135 billion. How can the EU pay for this?
Ukraine's financial and military needs for 2026 and 2027 are estimated at a staggering €135 billion. How can the EU pay for this?
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This led Ursula von der Leyen to come up with a bold proposal: to channel the immobilised Russian assets into a zero-interest reparations loan to Ukraine. The assets are now mature and therefore liquid.
Kyiv would only repay the loan if Moscow paid for war reparations.
Kyiv would only repay the loan if Moscow paid for war reparations.
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In other words, the EU would not pay out of pocket, neither the principal nor the interest. The money would come directly from Russia's sovereing assets.
A taboo was broken.
euronews.com/my-europe/2025…
A taboo was broken.
euronews.com/my-europe/2025…
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The reparations loan was quickly embraced by Germany, Poland, the Nordics and the Baltics, but it was met with the opposition of Belgium, which holds the bulk of the assets (€185 billion) at Euroclear.
Belgium asked for sweeping guarantees in return.
euronews.com/my-europe/2025…
Belgium asked for sweeping guarantees in return.
euronews.com/my-europe/2025…
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Then, in the middle of the debate, a bombshell dropped: the 28-point peace plan secretly drafted by US and Russian officials.
Point 14 proposed using the Russian assets for the commercial benefit of both the US and Russia. Europeans were horrified and quickly said "no way".
Point 14 proposed using the Russian assets for the commercial benefit of both the US and Russia. Europeans were horrified and quickly said "no way".
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The Belgian concerns and the US plan pushed the Commission to an experimental last resort: Article 122, which is designed for economic emergencies.
Article 122 was previously used in the context of the COVID-19 pandemic, the energy crisis and defence.
Article 122 was previously used in the context of the COVID-19 pandemic, the energy crisis and defence.
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Article 122 comes with a double advantage: it bypasses the European Parliament and only requires a qualified majority, so it helps the EU act fast.
The Commission proposed using Article 122 to prohibit the return of sovereing assets to Russia.
In practice, an indefinite ban.
The Commission proposed using Article 122 to prohibit the return of sovereing assets to Russia.
In practice, an indefinite ban.
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In a novel interpretation, the Commission argued the shockwaves unleashed by Russia's war constituted an economic emergency for the EU as a whole.
"Preventing that funds are transferred to Russia is urgently required to limit the damage to the Union's economy," the text said.
"Preventing that funds are transferred to Russia is urgently required to limit the damage to the Union's economy," the text said.
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The release will only happen when Russia 1) ceases its aggression, including hybrid attacks against EU countries, and 2) pays for war reparations.
It's a high bar that Moscow will most likely never meet. So the assets will be locked in for good.
It's a high bar that Moscow will most likely never meet. So the assets will be locked in for good.
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Moreover, the eventual release of the assets will be subject to a qualified majority and therefore protected against undesirable vetoes.
This means that, even if Hungary or somebody else blocks the renewal of the sanctions, the assets will remain immobilised under Article 122.
This means that, even if Hungary or somebody else blocks the renewal of the sanctions, the assets will remain immobilised under Article 122.
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These safeguards drastically strengthen the European hand at the negotiating table. The US and Russia won't be able to decide the fate of the assets without the Europeans. Even if they convince somebody to veto the sanctions, it won't work.
A European consensus will be needed.
A European consensus will be needed.
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Regardless of what happens to the reparations loan, which is still under intense negotiations, the Russian assets will be protected from undue interference.
It's a bold decision and an act of defiance. The Europeans are finally playing their cards.
euronews.com/my-europe/2025…
It's a bold decision and an act of defiance. The Europeans are finally playing their cards.
euronews.com/my-europe/2025…