Attached below is the mark-up of the current FAQs published by the European Commission (version as of 2026.01.23) against the last version of the FAQs (version as of 2025.11.21).
The mark-up is substantial, but most of changes are related to the improvement of FAQs’ drafting.
As to substance, the relevant points are:
- New FAQs on the provision of the tourist services in Russia which we covered in our earlier video. As we expected, the restriction is given very broad meaning. A clear distinction, however, is drawn between tourist travel services (prohibited) and business / personal travel services (permitted).
- Another helpful clarification is that travel information in the form of public web-sites and books is not considered a “service” and, accordingly, is not subject to the prohibition. To be considered a prohibited service – the activity shall be provided in “active, consultative capacity, on a fee or contract basis” (See FAQ 44, Section 8 (Provision of Services)). The clarification is useful both for tourist services and any other Article 5n prohibited services (where it may be applied by analogy), as, for example, it makes clear that the publication of legal up-dates on the websites of legal service providers (even if accessible in Russia) shall not be treated as the legal advisory services prohibited under Article 5n.
- Nord Stream / Nord Stream 2 section, largely, clarifies that: (i) except as falling under a closed list of derogations (see, Article 5af(2)-3)) or set out in (ii), all services to these two pipelines by the EU operators shall be prohibited; (ii) services unrelated to the functionality of the pipelines are not prohibited (see FAQ 2 of this section); and (iii) the prohibition relates to the infrastructure itself and not to the companies which own these pipelines (see FAQ 3 of this section).
- New Oil Price Cap of USD44,1 per barrel will come into effect on 1 February 2026. The grace period for existing contracts (where the Oil Price Cap is USD47,6 per barrel) will end on 16 April 2026. The Price Caps for the petroleum products which trade at premium to crude (USD100 per barrel) and at discount to crude (USD45 per barrel) remain unamended.