Belaruskali v Council (Appeal - Restrictive measures taken in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine - Judgment) [2026] EUECJ C-816/24P (18 June 2026)

Executive summary

The Court of Justice heard appeals by Belaruskali AAT, Ivan Ivanovich Golovaty, and Belarusian Potash Company AAT against General Court judgments that had dismissed their challenges to EU restrictive measures adopted in 2022 and 2023 in view of the situation in Belarus and Belarus’s involvement in the Russian aggression against Ukraine. The source text identifies the measures at issue as listings under the EU freezing regime and related Belarus-sector restrictions, framed around the definitions of the “Lukashenko regime,” persons benefiting from or supporting that regime, and the obligation to state reasons, legal certainty, and proportionality.

Key points

• Appellants: Belaruskali AAT, Ivan Ivanovich Golovaty, and Belarusian Potash Company AAT; defendant: Council of the EU, supported by Lithuania and with Belgium/Latvia intervening below.
• They sought annulment of Council Implementing Decision (CFSP) 2022/881 and Implementing Regulation (EU) 2022/876, and later Decision (CFSP) 2023/421 and Implementing Regulation (EU) 2023/419, insofar as those acts concerned them.
• The General Court had dismissed their annulment actions; this judgment is the Court of Justice appeal judgment on those dismissals.
• The sanctions framework in the text covers freezing of funds and economic resources for listed persons/entities, including those responsible for serious human-rights violations or repression, and those benefiting from or supporting the Lukashenko regime.
• The text also notes Belarus-related financial restrictions, including bans on certain transferable securities and on making new loans or credit over 90 days to Belarusian public bodies and related entities.
• The appeal is explicitly tied to issues of reason-giving, legal certainty, and proportionality in EU restrictive-measures listings.

Why it matters

This is directly relevant to Belarus sanctions enforcement because it concerns the legality of EU listings and related restrictive measures against named Belarusian industrial and financial actors. It also shows the EU’s post-2022 pivot from Belarus human-rights sanctions to measures linked to Belarus’s role in Russia’s war against Ukraine.

Implications

For compliance teams, the case signals that the Council’s listing methodology for Belarus-linked entities is being tested against due-process standards, but the source text shows the appeals arose after the General Court had already upheld the measures. For litigation strategy, the operative issues are the scope of the “Lukashenko regime” and “benefiting from or supporting” criteria, plus whether the Council adequately explained why each appellant was listed under the EU freezing regime.