Key data
| Regulation | Council Implementing Regulation (EU) 2026/2313 of 13 October 2026 |
|---|---|
| Legal basis | Regulation (EC) No 765/2006 relating to the situation in Belarus and its participation in Russian aggression against Ukraine |
| Publication | 14 October 2026 |
| Entry into force | 13 October 2026 |
| Affected parties | Companies, financial entities and persons with commercial or financial ties to Belarus |
| Category | European Regulation |
| Effect | Direct in all EU Member States, without national transposition |
From 13 October 2026, Implementing Regulation (EU) 2026/2313 expands the EU's restrictive measures against Belarus, updating the list of natural and legal persons subject to asset freezing and prohibition of entry into EU territory. The regulation has direct effect in Spain and all Member States without need for transposition: it is binding from day one.
The reference legal framework is Regulation (EC) No 765/2006, which has been the central instrument of European sanctions against the Lukashenko regime for years and, since 2022, also for its participation in Russian aggression against Ukraine.
What does this regulation establish?
Regulation 2026/2313 updates the list of designated persons subject to restrictive measures under Regulation (EC) 765/2006. The two main measures applied to subjects included in the list are:
- Asset freezing: all funds and economic resources belonging to or under the control of the designated persons must be blocked. No European company or financial entity may make funds available to them.
- Prohibition of entry: natural persons included in the list cannot enter or transit through the territory of the European Union.
This type of implementing regulation does not create new sanctions from scratch: it modifies and expands the list of designated persons already existing under Regulation (EC) 765/2006, adding new natural and legal persons. Companies that already had control procedures must update their screening databases with the new subjects included.
As it is an implementing regulation of the EU, it does not require national transposition: it is directly applicable in Spain from the date of entry into force, 13 October 2026.
Economic and operational impact
The impact is not only regulatory: it has direct economic and operational consequences for any company with exposure to Belarus.
| Area of impact | Concrete consequence |
|---|---|
| Commercial relations with designated persons | Immediate prohibition on operating. Ongoing contracts must be suspended if the counterparty appears in the updated list. |
| Accounts and assets of designated persons | Obligation to freeze funds and notify competent authorities. |
| Non-compliance | Administrative and criminal sanctions in Member States, the severity of which depends on applicable national legislation. |
| Compliance systems | Need to immediately update screening lists with new designated persons. |
| Due diligence in new operations | Mandatory verification before any new commercial or financial relationship with Belarusian counterparties. |
The operational cost of not acting can be much higher than adapting systems: non-compliance with EU restrictive measures can result in criminal sanctions for managers and disqualification from operating in certain markets.
Who does it affect?
- Export and import companies with commercial activity in Belarus or with Belarusian counterparties.
- Banking and financial entities that manage accounts, transfers or financing linked to Belarusian persons or companies.
- Transport and logistics companies with routes or clients in Belarus.
- Advisors, consultancies and law firms that provide services to clients with Belarusian ties.
- Companies with subsidiaries or partners in Belarus or in third countries acting as intermediaries.
- Capital market operators with positions in assets linked to Belarusian entities.
Practical example
A Spanish industrial machinery company maintains a supply contract with a Belarusian company with which it has been operating for three years. On 13 October 2026, Regulation 2026/2313 enters into force, adding that Belarusian company to the list of sanctioned entities.
From that moment, the Spanish company has the legal obligation to suspend the contract and make no pending payments or deliveries. If the Spanish company's bank detects a transfer to that already designated entity and does not block it, both the company and the financial entity may breach EU restrictive measures, with the resulting administrative and criminal sanctions provided for in Spanish legislation.
Proactive review of the updated list, before executing any pending operations, is the only way to avoid this situation.
What should companies do now?
- Immediately update compliance screening lists with the new designated persons included in Regulation 2026/2313. Do not wait for the next periodic review cycle.
- Review all active contracts and commercial relationships with Belarusian counterparties to verify if any appear in the updated list.
- Block any pending payments or transfers to entities or persons appearing in the list, until confirming they are not designated.
- Notify competent authorities if you detect that any client or counterparty is included in the list and you hold assets or funds linked to them under management.
- Review the supply chain and intermediaries: it is not enough that the direct counterparty is not designated; you must also verify whether it acts on behalf of a designated person.
- Document all checks performed to demonstrate due diligence in case of inspection or request from authorities.
Frequently asked questions
Where can I consult the updated list of persons and entities sanctioned by the EU in relation to Belarus?
The consolidated list of designated persons under Regulation (EC) 765/2006, updated by Regulation 2026/2313, is published in the EU Official Journal. Additionally, the European Commission maintains a consolidated sanctions search tool on its official portal.
What happens if my company operates with a Belarusian entity that has just been added to the list?
From the entry into force of Regulation 2026/2313 (13 October 2026), any operation with that entity is prohibited. You must suspend the contract, block pending payments and, if you manage assets or funds linked to that entity, notify competent authorities. Non-compliance can result in administrative and criminal sanctions under Spanish legislation.
Does Spain need to transpose this regulation for it to be applicable?
No. As it is an EU Implementing Regulation, it has direct effect in all Member States, including Spain, without need for any national transposition or regulatory development. It is applicable from 13 October 2026.
What specific measures apply to subjects included in the list?
The two main measures are: (1) asset freezing, that is, blocking all funds and economic resources belonging to or controlled by the designated persons; and (2) prohibition of entry and transit in the territory of the European Union for natural persons included.
How frequently is the list of sanctioned persons linked to Belarus updated?
The list is updated through successive Implementing Regulations of the EU Council, with no fixed periodicity. Regulation 2026/2313 is the latest published update, dated 14 October 2026. Companies must monitor the EU Official Journal or use regulatory alert tools to detect each new update.
Official source
Consult full regulation at official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R2313
