Bulgaria Holds Up 21st Russia Sanctions

The EU's 21st sanctions package against Russia is being assembled in the usual way: painstakingly, capital by capital. Diplomats are looking at the shadow oil fleet, Russian banks and the Russian Orthodox Church (Hromadske, S&P Global).

The difficulty is in Sofia. Bulgarian political figures are arguing over whether their government should block parts of the package to protect Patriarch Kirill and interests linked to Lukoil. That matters because EU sanctions do not pass by majority vote. If a single government digs in, all 27 are stuck.

The treaties made it that way.

How one government stops the rest

EU sanctions sit inside the Common Foreign and Security Policy, the part of the treaties where member states kept foreign policy largely in national hands. Article 31 of the Treaty on European Union makes unanimity the default. Every government has to agree, or the decision fails (Council sanctions explainer).

The machinery works in two stages. First, governments agree a political decision naming the people, companies or sectors to be sanctioned and setting out the reasons, under Article 29 TEU. Then a separate regulation, under Article 215 TFEU, turns that political decision into binding economic rules for banks and companies across the single market (Verfassungsblog).

The veto sits at the first stage. If a single capital refuses the political decision, the economic regulation cannot follow. The other 26 cannot simply outvote the holdout, as they can on most internal-market law.

That gives any government with a concentrated domestic interest a hard lever: accept its objection, or risk losing the package.

Hungary proved it works

Budapest showed how effective the tactic could be in 2022. Hungary demanded that Russian Orthodox Patriarch Kirill be removed from the EU's sixth sanctions package. The EU gave way, dropping Kirill to save the wider deal (Reuters, Politico).

Hungary did not have to convince the rest of Europe that Kirill merited protection. It only had to make the price of keeping his name on the list higher than the price of taking it off.

The lesson travelled. Bulgaria's president threatened in 2023 to veto sanctions on the Russian nuclear sector (Reuters). Bulgarian political actors are now seeking removals from the 21st package connected to Kirill and to Lukoil, which operates Bulgaria's largest refinery in Burgas (S&P Global).

That refinery is not a symbolic asset. It sits at the centre of Bulgaria's fuel supply, giving Sofia leverage that reaches well beyond church politics.

There is no public evidence that Hungary is coordinating Bulgaria's current position (Council Russia sanctions page). The point is sharper than that. Coordination is not required. Once one government shows that a narrow objection can reshape a sanctions package, every capital with a domestic pressure point understands the method.

The reasons vary: energy dependency, refinery exposure, religious ties. The leverage is the same. Hungary and Slovakia won pipeline exceptions during the sixth package by pointing to their 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 organised bloc is needed. The unanimity rule does the work.

What remains unclear

The key unknown is the formal status of Bulgaria's demand. The treaty mechanics are clear. The Hungary precedent is clear. What no public Council document confirms is whether Sofia has formally asked for names or interests to be removed from the 21st package's draft annex.

The Bulgarian argument is being reported in domestic media. Council negotiations, as usual, are closed. Whether this becomes a genuine blockage or stays as a pre-negotiation warning depends on what Sofia does when diplomats put the final text on the table.

Twenty sanctions packages in (Council Russia sanctions page), the EU has built serious economic pressure against Russia. Each new round still has to pass through the same unanimity lock.

That is not an accident. It reflects a treaty choice to keep foreign policy under national control, a principle smaller member states have often valued. But the cost is mounting. Every time the other 26 accept a narrow objection to save a package, the next capital learns that the tactic is available, and that the EU will probably pay rather than let the deal collapse.