The EU's Russian LNG cut-off lands in the middle of a thin winter

The EU's ban on Russian gas has two deadlines that matter, and they fall on different countries. The one that arrives first, on 1 January 2027, ends Russian LNG delivered under long-term contracts. Its buyers are in western Europe, not in the landlocked centre that dominates the political argument. And it arrives in mid-winter, with European storage lower for the time of year than at any point in almost two decades.

What the regulation sets

The REPowerEU gas regulation entered into force on 3 February 2026. Its calendar, as set out by the Commission when the Council and Parliament agreed the text in December 2025, is staggered by contract type. Short-term contracts concluded before 17 June 2025 lost their cover on 25 April 2026 for LNG and on 17 June 2026 for pipeline gas. Long-term LNG contracts end on 1 January 2027, matching the date already set in the 19th sanctions package. Long-term pipeline contracts may run until 30 September 2027. A member state that is struggling to meet its storage-filling obligation can have that last date pushed to 1 November 2027.

Two provisions shape how the regime behaves in practice. Contract amendments are allowed only for narrow operational purposes and may not raise volumes or prices. Imports during the transition need prior authorisation, with detailed information to show that they match historical contracts. Member states had to submit national diversification plans by 1 March 2026.

The starting point is already small. The Commission put Russia's share of EU gas imports at 13 per cent in the first half of 2025, against 45 per cent before the full-scale invasion of Ukraine, and estimated that 35bn cubic metres of Russian gas entered the EU in 2024. The size of the remainder is not in dispute. What matters is who holds it and when their deadline falls.

The January date falls on the western buyers

Russian LNG in the EU now comes almost entirely from one plant. Urgewald, a German NGO, analysed Kpler cargo data and found that EU ports received 136 of the 140 cargoes shipped from Yamal LNG in the first half of 2026: 9.97m tonnes, worth an estimated €5.96bn. That was 16 per cent more by volume than in the same period of 2025, while deliveries to Asia fell from 25 cargoes to four. France took 51 cargoes (3.74m tonnes), Belgium 37 (2.70m), Spain 34 (2.50m) and the Netherlands 12. The country where a cargo lands is not always the country where the gas is burned, but the contracts, the terminals and the replacement cargoes are all on the Atlantic side.

The pattern is what a fixed end date would be expected to produce. Holders of long-term contracts are taking their full entitlement while it lasts. The effect is that the volume the EU must replace on 1 January is at its highest just before the cut-off. The imports carry on legally until then, so the replacement has to be found in the spot LNG market in the middle of the heating season.

Storage is entering winter well short

That market is tight. Wood Mackenzie reported EU storage at 65.40 per cent full on 1 September and 67.12 per cent on 8 September, the lowest for the time of year since 2009. It expects stocks to reach about 73 per cent at the end of the injection season and to fall to 21 per cent by the end of winter, and does not see balances returning to the bottom of the five-year range before 2028. Member states have accepted 80 per cent as enough this year, below the usual 90 per cent target, and on current trends even that will be hard to reach.

The supply side explains why. Wood Mackenzie estimates that about a fifth of global LNG supply has been off the market since the conflict around the Strait of Hormuz began in late February. When the Commission's Gas Coordination Group met on 3 September, it noted that Qatari LNG production was still shut down. The group nonetheless concluded that there was no immediate risk to security of supply, pointing to higher LNG import capacity, more diverse sources and lower demand than in 2021–22, and said it saw no reason to intervene.

Both assessments can be right. The Commission is judging physical supply, and there is no sign that gas will run out. Wood Mackenzie is judging price, and a thin cushion means a cold spell or a further outage goes straight into bills. The 1 January deadline takes a known volume out of that cushion at the point in the season when it is thinnest.

The pipeline states have nine months more, and are using them

Hungary and Slovakia face a different calendar. Their Russian supply comes through TurkStream, now the only route for Russian pipeline gas into Europe. According to ENTSOG data reported by Reuters, the line carried 1.61bn cubic metres to Europe in August, a daily average of 51.9m cubic metres. From January to August it carried 11.9bn cubic metres, 3.5 per cent more than a year earlier. Flows are rising, not falling, ahead of a deadline a year away.

Slovakia is the clearest case. SPP, which supplies about two-thirds of the country's gas, said it received only a third of its 2025 supply from Russia after transit through Ukraine ended. In March it amended its Gazprom contract to comply with EU rules, and Reuters reported that it could take up to all of its needs from Russia until 2027. The regulation's ban on volume-raising amendments will be tested here. Bratislava's case is that the change is operational, since it concerns the route through Türkiye.

Hungary's position has shifted with its government. MVM's 2021 contract with Gazprom allows up to 4.5bn cubic metres a year. On 18 September Kyiv Post reported the energy minister, István Kapitány, telling Telex that Hungary would "break away from Russian gas" within a year, which fits the October 2027 deadline. That is a statement of capability, not a decision to end the contract, and the minister also said the country had enough gas stored for this winter.

Austria's exposure is through price, not contracts

Austria shows a third kind of exposure. It has had no Russian deliveries since Ukrainian transit ended in January 2025 and now imports mainly from the west, through Germany and Italy. On 1 September its storage held 66.8 TWh of a capacity of about 100 TWh (66.6 per cent), well down on the previous year. The regulator, E-Control, judged supply for 2026–27 secure "as long as the current import situation and infrastructure remain unchanged". A strategic reserve of 20 TWh has been extended to April 2029. Austria's risk is the same as Germany's or Italy's: it buys at the margin in a market that will lose Yamal volumes on 1 January.

What to watch

The emergency clause is the key variable. The regulation lets the Commission suspend the ban for a limited period if security of supply is seriously threatened, and a hard January could bring requests from LNG importers rather than from Budapest or Bratislava. ENTSOG's winter outlook and the next Gas Coordination Group meeting, both due on 8 October, will show whether the Commission still sees no reason to act. The fill level on 1 November will show whether the 80 per cent target is met. Later, the question is whether any member state claims the storage-based extension of the pipeline deadline to 1 November 2027. Hungary and Slovakia are the likeliest to do so, but low stocks this winter would give others the same grounds.

The phase-out is on schedule on paper. Its first real test will come from the weather and from Qatar, not from the landlocked states.

Sources

• European Commission — EU agrees to permanently stop Russian gas imports (IP/25/2860, 3 December 2025)
• European Commission — Gas Coordination Group: No immediate security of supply risk (3 September 2026)
• Urgewald — EU paid an estimated €5.96 billion for Russian Arctic LNG in the first 6 months of 2026 (13 July 2026)
• Pipeline & Gas Journal (Reuters) — TurkStream gas flows to Europe climb 3% in August (3 September 2026)
• Rigzone — EU faces worst gas storage position in decades, WoodMac says (10 September 2026)
• MarketScreener (Reuters) — Slovakia amends Gazprom gas contract, seeks to raise Russian imports before EU ban kicks in (6 March 2026)
• Kyiv Post — Hungary eyes break from Russian gas by next October (18 September 2026)
• The Local Austria — Is Austria's gas supply secure for the coming winter? (7 September 2026)