Bulgaria eyes veto on 21st Russia sanctions

The EU's 21st sanctions package against Russia is taking shape. Diplomats are targeting the shadow oil fleet, Russian banks, and the Russian Orthodox Church (Hromadske, S&P Global). In Sofia, political figures are clashing over whether Bulgaria should block parts of the package to protect Patriarch Kirill and Lukoil-linked interests. The dispute matters because one country's objection can hold up sanctions for all 27.

The treaties built that vulnerability in.

How one government stops the rest

EU sanctions belong to the Common Foreign and Security Policy, the treaty area where member states kept foreign policy under national control rather than handing it to Brussels. Article 31 of the Treaty on European Union makes unanimity the default. Every government must agree, or no decision passes (Council sanctions explainer).

The process works in two steps. Governments first agree a political decision naming who gets sanctioned and why (under Article 29 TEU). Then a separate regulation (under Article 215 TFEU) turns that into binding economic restrictions that banks and companies across the single market must obey (Verfassungsblog). The veto sits at step one. If a single capital refuses the political decision, the economic machinery cannot start. The other 26 cannot outvote the holdout the way they can on most internal-market laws.

One government with a concentrated domestic interest can force the rest to choose: accommodate the objection or lose the package.

Hungary proved it works

Budapest demonstrated the tactic in 2022. Hungary demanded that Russian Orthodox Patriarch Kirill be removed from the EU's sixth sanctions package. The EU complied, dropping Kirill to preserve the wider deal (Reuters, Politico). Hungary did not need to persuade anyone that Kirill deserved protection. It only needed to make the cost of keeping his name higher than the cost of removing it.

The lesson travelled. Bulgaria's president threatened in 2023 to veto sanctions on the Russian nuclear sector (Reuters). Now Bulgarian political actors are seeking removals from the 21st package tied to Kirill and to Lukoil, which operates Bulgaria's largest refinery in Burgas (S&P Global). That refinery anchors Bulgaria's fuel supply, giving Sofia leverage that goes well beyond religious symbolism.

No public evidence shows Hungary coordinating Bulgaria's current position (Council Russia sanctions page). The structural point is sharper: no coordination is needed. Once one government proves that a single-name objection can reshape a sanctions package, every capital with a domestic sensitivity understands how the tool works.

The reasons differ — energy dependency, refinery exposure, religious ties. The leverage is the same. Hungary and Slovakia secured pipeline exceptions during the sixth package by invoking landlocked energy supply (Council sixth package). They delayed the 20th package earlier this year over a dispute with Ukraine before lifting their vetoes in April (The Geopost). No bloc is needed. The unanimity rule itself supplies the leverage.

What remains unclear

The biggest gap is the formal status of Bulgaria's demand. The treaty mechanics and the Hungary precedent are well established. What no public Council document confirms is whether Sofia has formally requested removals from the 21st package's draft annex. The Bulgarian political clash is reported in domestic media; Council negotiations remain closed. Whether this becomes a real blockage or a pre-negotiation signal depends on what Sofia actually does when diplomats present the final text.

Twenty sanctions packages in (Council Russia sanctions page), the EU has built formidable economic pressure against Russia. Each new round still passes through the same unanimity lock. That reflects a deliberate treaty choice to keep foreign policy under national control. But the cost accumulates. Every time the other 26 accommodate a narrow objection to save a package, the next capital learns the tactic is available, and that the EU will likely pay the price rather than lose the deal.