Why the EU should take custody of the immobilised Russian accounts

By Annegret Kramp-Karrenbauer, Nathalie Loiseau and Hugo Dixon

August 28, 2026

In December 2025, the European Council invited the Commission to work on the technical

and legal aspects of using the immobilised Russian assets. This paper sets out how the first

step should be to transfer custody to a new European Union instrument. It explains how this

would operate and annexes a draft regulation giving it legal form.

The European Union has stood shoulder-to-shoulder with Ukraine since Russia’s illegal

invasion. It is the biggest source of funding, including most recently via its €90 billion Ukraine

Support Loan. Unfortunately, Kyiv will run out of cash well before the end of 2027. The

government is estimating a funding hole of $78 billion for next year – made up of a $45 billion defence deficit and a further $33 billion uncovered ordinary budget deficit.

Without new funding, Ukraine's capacity to sustain its defence would be gravely impaired.

This would undermine the EU’s own security, as Ukraine is its first line of defence against

Russian aggression. The Union must find a solution to fill the funding gap. While other allies

must do their bit, the EU will have to take the lead.

In theory, one option would be more common borrowing. In practice, this will be virtually

impossible because the headroom in the EU budget is nearly exhausted and there will be

resistance to common borrowing in some Member States.

The fair and natural solution is to deploy the €210 billion of immobilised Russian sovereign

assets to help Ukraine. Moscow has an obligation under international law to pay

compensation for its illegal invasion. Using these funds to help Ukraine defend itself would

not only be just; it would be more acceptable to EU voters than raising taxes or further

borrowing.

But the EU must first allay Belgium’s legitimate concern that it should not face alone any risk

from mobilising the Russian assets. The bulk of the funds, €185 billion, are sitting at

Euroclear, the Belgian clearing house. The solution is to transfer custody of all the

immobilised accounts in the Union, both in Belgium and elsewhere, to a new EU instrument,

so taking Belgium out of the line of fire.This would not be confiscation as the Central Bank of Russia would remain the owner of the accounts after the transfer of custody. There is a precedent: after the fall of Saddam Hussein, the Iraqi sovereign assets outside Iraq were moved to a new account at the Federal Reserve Bank of New York.

“The Russian Transfer” answers the key concerns raised by Belgian Prime Minister Bart De

Wever and more recently Belgian Foreign Minister Maxime Prévot. There is a detailed

proposal here illustrating how this could be done under Article 122(1) TFEU, (QMV). The key

elements are:

• The EU would mandate the transfer of the immobilised Russian accounts to a new

Union instrument, which would act as custodian for the Russian accounts.

• The liabilities would be transferred along with the assets, so Euroclear and other

institutions would no longer have an obligation to the Central Bank of Russia.

• The EU would indemnify Member States and financial institutions in respect of any

losses in connection with the transfer of the accounts. Member States themselves

would not need to provide any guarantee.

• Non-EU countries with immobilised Russian assets would be invited to move these

accounts to the new facility.

Simply moving the accounts would be a powerful signal that would strengthen Ukraine’s

negotiating position, whether the war continues or peace talks begin. Once the accounts are

transferred, the EU would have flexibility to use the funds to help Ukraine in a time and

manner of its choice following a separate decision – abiding of course always by EU and

international law.

Annegret Kramp-Karrenbauer is Chair of the Konrad Adenauer Foundation. She served as

Germany’s Minister of Defence from 2019 to 2021 and as Leader of the Christian

Democratic Union (CDU) from 2018 to 2021.

Nathalie Loiseau is Chair, Special Committee on the European Democracy Shield,

European Parliament. She is a member of the European Parliament. She served as the

French Minister for European Affairs from 2017 to 2019.

Hugo Dixon is Commentator-at-Large at Reuters. He is a journalist, political entrepreneur

and philosopher.