Part I — Situation overview

On 18 August 2026 the German campaign organisation Urgewald published its analysis built on the Kpler shipping database, which for the first time quantifies how much traffic a single actor handles on the EU route of Russian Arctic liquefied natural gas. According to the data, ships linked to the Greek company Dynagas took 53 consignments into EU ports between January and July 2026, with an estimated value of 2.35 billion euros. Out of the Yamal plant’s 162 consignments this year 149 set off for Europe — that is 92.1 per cent of the exports, roughly 6.64 billion euros in total. The route, navigable with ice-breaking, Arc7-class tankers, is dominated by three companies: the Greek Dynagas, the British-based Seapeak, owned by the New York-based Stonepeak, and the Japanese Mitsui OSK Lines; of these Dynagas is the only EU operator, and out of the 149 European consignments it carried 57.

The procedural story behind the figures is the essential thing. In July Greece blocked the twenty-first sanctions package until the member states took out of it the transport ban planned for liquefied natural gas and put an exception in its place. On this basis EU operators may, even after the entry into force of next year’s import ban, ship Russian liquefied natural gas to buyers outside the Union — typically Asian ones — on the basis of contracts concluded before February 2022. According to the analysis of CREA (Centre for Research on Energy and Clean Air, an independent energy research centre), 96 per cent of this trade was handled last year by a single carrier, Dynagas. According to the reports the Greek ambassador argued before the other permanent representatives that a total ban would ruin the company. The exception runs until 25 July 2027, after which it renews automatically every year unless the member states vote to terminate it. Meanwhile Kaja Kallas, the EU High Representative for Foreign Affairs and Security Policy, announced in an interview presented in Die Welt on 17 August that in the autumn she will put forward the most extensive listing proposal since the beginning of the war, which if adopted would increase the number of sanctioned Russian entities by a third. According to the European Commission’s data there are currently some 3,000 persons and entities on the lists in force.

According to MIAK’s reading this story is not about Greece, and not about Dynagas either — the behaviour described in the analyses is legal under the present rules, and MIAK does not characterise it as a breach of law. What is at stake is the decision-making procedure, in which Hungary is just as much an actor as Athens. The legal form of sanctions listing is a Council regulation and decision adopted unanimously: this rule gives everybody a right to stop, but in return it exposes everybody to the others’ making use of it as well. EUobserver’s report draws the Hungarian parallel in a single sentence: in 2022 Hungary and Slovakia obtained a similar exception for Russian crude oil arriving through the Friendship pipeline, and without a time limit at that, and this arrangement is still in force after four years. Criticism of the technique of exceptions is therefore credible only if Hungary applies the yardstick to itself first.

Part II — Foundations in the literature

The phenomenon that the Greek exception exemplifies is older than EU sanctions policy. Adam Smith (Scottish philosopher and economist, the founder of modern economics) formulated in his 1776 work The Wealth of Nations the warning that regulation proposed by the order of merchants must always be received with particular suspicion, because the interest of this order never coincides exactly with the public interest. For narrowing the market always serves the good of the one asking for the regulation, and always goes to the harm of the others. The volume Diplomatic Theory from Machiavelli to Kissinger by G. R. Berridge and his co-authors points out that negotiating credibility is a value in itself: the actor that proves unreliable comes to an agreement with more difficulty later, and a concession too is worth giving from a strong, not a weak position. In his open-access study published in the pages of the Journal of Contemporary European Research, the Danish researcher Kristian L. Nielsen describes the recurring weakness of EU foreign policy with the concept of the “capability-expectations gap” originating from Christopher Hill: the announced ambition is regularly greater than the result actually attainable, and this difference produces disappointment, not authority. The detailed treatment of the literature — author by author, with quotations — can be found in the 6.4 Literature in detail section.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures. None of them is about Hungary giving up the protection of its own energy-security interests — under the KP4 principled pragmatism doctrine, protecting the national interest and consistency of principle are not mutually exclusive choices. The proposals are about the protection being stated, quantified and limited in time.

3.1 A duty of public reasoning for every Hungarian request for an exception (from the next sanctions item on the Council agenda)

In every case in which the Hungarian government asks for an exception, exemption or transitional rule for the adoption of an EU sanctions legal act, it should prepare an internal impact assessment summary in accordance with the methodology of the G20 economic policy impact assessment system, and publish the non-confidential part of it within sixty days after the decision is taken. The document should contain the estimated annual value of the exception requested, the circle of companies and consumers affected, the cost of the alternatives, and the time horizon for which it considers the exception necessary. This is not the abandonment of the negotiating position: during the negotiation the document remains confidential, publicity sets in after the decision. The KP3 transparent foreign policy programme point describes exactly this logic, and the present case adds the most credible reason for it — the member state that publicly accounts for its own exception can credibly ask the same of the others.

3.2 A Hungarian initiative for an EU register of requests for exceptions in the Council (on the Council agenda within 90 days)

Hungary should put forward a proposal that member-state requests for exceptions made in the Council’s sanctions negotiations be compulsorily registered and published after the adoption of the legal act: which member state asked for an exemption, in what subject matter, with what economic reasoning, for what estimated value and for which circle of companies. This proposal carries over the “legislative footprint” principle of the A4 lobby register to Council decision-making, and fits into the framework of the A14 participation in and accountability of international institutions and of the KP19 position on international institutional reform. It is worth recording whose interest this is: the data from which the whole Greek story can be reconstructed was compiled by a civil organisation from commercial shipping data, it was not published by an EU institution. For a smaller member state publicity is the only cheap instrument for limiting the overuse of the unanimity procedure — and this is why Hungary would do well to take a supportive, not a defensive position on this question. The framework of coalition building is the KP17 issue-based coalition building in the EU: the natural allies of the proposal are export-exposed member states of similar size.

3.3 An expiry date and an annual public assessment for the Hungarian crude oil exception (by the first half of 2027)

The Hungarian exemption for Russian crude oil arriving through the Friendship pipeline has been in force since 2022 without a time limit. MIAK’s proposal is not its termination but that the government should initiate the supplementing of the exemption with an expiry date — that is, with a point in time fixed in advance at which the exemption ceases without a separate decision. Alongside this the government should undertake to publish once a year a public, quantified assessment of it: how large the quantity concerned was, how much the alternative of replacement cost, where the expansion of feed-in capacity from Croatia and other directions stands, and under what conditions the exemption could be dispensed with. This is the calendar side of the K7 energy market shock resilience and the K2 energy transition plan programme points. The expiry date in itself forces nothing — but it forces planning, because alongside an exemption without a date replacement can always be postponed.

The three proposals are bound together by a single principle: the exception is not the shame, the absence of a register is. A member state may legitimately protect its own security of supply; what it cannot do without consequences is to leave the extent, the beneficiary and the duration of the protection in obscurity. The negotiating-technique proposition of Berridge and his co-authors can be applied directly here (see 6.4.2): credibility is the capital that can be spent on a single occasion, but takes years to reproduce.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Foreign policy The Hungarian negotiating position becomes more predictable and more defensible; the request for an exception turns into a reasoned request instead of blocking In the short term it narrows the room for manoeuvre: it is harder to depart in the next round from a publicly stated reasoning
Economy Energy procurement exposure appears quantified, with a plannable calendar; market actors can calculate in advance Publishing the value of the exception may touch sensitive business data; aggregated publication is needed
Transparency Council bargains become reconstructable afterwards, not by way of civil-organisation investigation The register may divert the coordination to informal channels if the formal route is disproportionately burdensome

The most important question of judgement in the package is the relation between negotiating room and publicity. There is a reading according to which a member state weakens itself if it commits in advance to accounting afterwards: the negotiating partner will know that the position has to be defended later, and this makes one inflexible. This counter-argument is serious, and partly true as well — which is why MIAK proposes subsequent, not prior publicity, and aggregated, not company-level publication of data where business secrecy is justified. The proposal tips over to the risk side if publicity is introduced in such a way that the substantive yardstick is not fixed: a formal reasoning without figures is worse than nothing, because it creates the appearance of accountability. And the EU-level fate of proposal 3.2 does not depend on the Hungarian government — the introduction of such a register requires the support of a majority of member states, and the interest of the larger member states that make use of more exceptions is limited. The value of the proposal is therefore partly independent of that: if Hungary fulfils points 3.1 and 3.3 unilaterally, its own credibility grows even so.

Part V — Measurability and summary

5.1 What is worth following? (proposed KPIs)

MIAK proposes the public following of the following performance indicators (KPIs — Key Performance Indicator):

  • The proportion of Hungarian requests for exceptions closed with a public reasoning compared with all requests for exceptions — proposed target value: 100 per cent from 2027, within sixty days of the decision.
  • The proportion of Hungarian energy exemptions that have an expiry date — proposed target value: by mid-2027 every exemption in force gets an expiry date or a public review day.
  • The share of Russian crude oil arriving through the Friendship pipeline in Hungarian crude oil imports, in annual breakdown — proposed target value: an annually declining path, with a published, month-by-month plan on the replacement capacities.
  • The number of supporters of the proposal for a Council register of exceptions — proposed target value: at least five member-state co-sponsors by the first half of 2027.

These are proposed indicators, not government commitments; MIAK as a shadow government considers these worth following.

5.2 Summary

MIAK’s key message in a single sentence: the price of an exception fought out in the unanimity procedure is communal, its benefit national — the exception therefore needs a reasoning and an expiry date, not a prohibition. MIAK asks the decision-maker to publish the non-confidential reasoning of the Hungarian position after the next sanctions vote in the Council, to initiate an EU register of Council requests for exceptions, and to give an expiry date to the crude oil exemption that has been operating without a deadline for four years. And it asks of the public that it should not judge the question according to which member state has just asked for an exception.

Two MIAK foundational values are in play here. Transparency, because the one lesson of the Greek story that can certainly be generalised is this: the information on the basis of which the decision can be judged afterwards was not issued by the institutions but put together by a civil organisation from commercial data — this situation is not sustainable. And universal representation, because in the unanimity procedure the interest of the smaller member states is the rule and publicity, not the separate bargain: whoever strengthens the logic of the separate bargain weakens their own bargaining position in the long run, because in the next round they will be dependent not on the rule but on the goodwill of the other party.

Part VI — Reasoning and further sources

6.1 The press framing by spectrum

This topic ran in the international press, so the framing is worth reading according to the European papers monitored.

EUobserver — which published the Urgewald analysis first — framed the story as a matter of procedure and accountability: it put at the centre not the moral question of Russian gas imports but how the blocking by a single member state transformed an adopted legal act, and who is served by the exception that took its place. The article closes by mentioning the Hungarian and Slovak crude oil exemptions as a parallel — that is, the source itself reads the case as a general pattern, not as a Greek peculiarity.

Euractiv showed the same structure from the other end: it carried the Kallas interview about the autumn listing package, and recorded in it that the package adopted in the summer went through in a “watered-down” version because of Greek resistance. In this frame today’s data is not a closing but a forecast: if the list expands by a third, what is at stake in the technique of exceptions also grows.

In the Hungarian press this thread did not run as an independent topic on this day; the domestic papers carried the news of the possible sanctioning of the Russian nuclear main contractor, which is the other branch of the same decision-making procedure. MIAK considers this indicative: the way the unanimity procedure works usually comes up in Hungary when it affects a direct Hungarian interest, and more rarely on its own, as an institutional question.

6.2 Facts and data

Datum Value
EU consignments of ships linked to Dynagas, January–July 2026 53
Their estimated value 2.35 billion euros
All consignments of the Yamal plant this year 162
Of these, set off for Europe 149 (92.1%)
Estimated value of the whole European traffic 6.64 billion euros
Of the 149 European consignments, carried by Dynagas 57
Dynagas’s share last year in the trade affected by the exception (CREA) 96%
Number of companies dominating the route 3 (Dynagas, Seapeak, Mitsui OSK Lines)
Of these, EU operators 1
Period of the exception until 25 July 2027, then renewed annually unless the member states vote against it
Entry into force of the British services ban January 2027
EU sanctions packages adopted since 2022 21
Persons and entities on the lists in force approx. 3,000
Extent of the planned autumn expansion of listings +1/3

Two rows of the table belong closely to the Hungarian proposal. One is the renewal mechanism of the exception: automatic annual extension means that nothing has to be done to maintain it, whereas an active member-state vote is needed to terminate it — this structure tips towards survival. The other is the January entry into force of the British ban: the structure of the market will be rearranged over the next twelve months, and this affects the pricing of the Hungarian procurement portfolio too, irrespective of what position the Hungarian government takes on the listing questions.

6.3 Policy dimensions

  • Foreign policy (programme points) — the unanimity rule of EU decision-making, the delimitation of requesting an exception from a veto, issue-based coalition building; this is the centre of gravity of the topic.
  • Transparency and anti-corruption policy (programme points) — the legislative-footprint principle in Council decision-making, the accountability of participation in international institutions.
  • Environment and climate (programme points) — the calendar of energy market shock resilience and the scheduling of the energy transition.
  • Economy (programme points) — the impact assessment methodology and the transparency of economic decision-making.

6.4 Literature in detail

6.4.1 Adam Smith: The Wealth of Nations

In the closing chapter of the work’s first book Smith writes that the interest of the order of merchants is to widen the market and to narrow the competition — the former can turn to the public good as well, the latter never:

“The proposal of any new law or regulation of commerce which comes from this order, ought always to be listened to with great precaution, and ought never to be adopted till after having been long and carefully examined, not only with the most scrupulous, but with the most suspicious attention. It comes from an order of men, whose interest is never exactly the same with that of the publick.”

In today’s matter this proposition can be used not as an accusation but as a yardstick of procedure. Smith does not say that the merchant is in bad faith; he says that the merchant’s interest is structurally different, and that therefore a separate examination procedure is needed for a regulatory proposal coming from that quarter. This is precisely what today’s case lacks: the request aimed at the exception did not go through any public examination, and we learn its effect afterwards only from a civil organisation’s analysis. Proposal 3.2 — the registering and subsequent publication of requests for exceptions — is today’s equivalent of this Smithian examination procedure. And since the yardstick relates to the source of the regulation, not to the country, it is to be applied to the Hungarian crude oil exemption in the same way.

📖 Source: Adam Smith: The Wealth of Nations (An Inquiry into the Nature and Causes of the Wealth of Nations, 1776)

6.4.2 Berridge and co-authors: Diplomatic Theory from Machiavelli to Kissinger

The volume’s chapter dealing with Machiavelli unfolds two propositions that can be applied directly to today’s question. The first is the intrinsic value of credibility: according to the authors’ argument even the least scrupulous prince had to keep the majority of his agreements, because he had no other way of acquiring a reputation for reliability — and without a reputation for reliability nobody concluded an agreement with him. The second is the position-dependence of concessions: a concession is worth giving from a strong, not a weak position, because a concession made out of weakness unsettles the allies and increases the appetite of the other party.

Translated to the EU sanctions negotiations: the member state that extracts an exception by blocking a whole package wins in the short term, but in the next round it is already received with suspicion — and the qualitative difference between requesting an exception and blocking is visible precisely here. The former is a reasoned, delimited demand, limited in time, which is part of the negotiation; the latter is taking the decision hostage, which burdens the actor’s later credit. The Hungarian proposal therefore does not give up requesting an exception, but is about its form: let the government state what it is asking for and until when.

📖 Source: G. R. Berridge – Maurice Keens-Soper – T. G. Otte: Diplomatic Theory from Machiavelli to Kissinger

6.4.3 Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap

Nielsen’s study starts from Christopher Hill’s concept of 1993, which describes the recurring structural weakness of EU foreign policy: the actors — from the outside and from the inside alike — expect more of the Union than it can deliver with the instruments at its disposal. In Hill’s description the sources of the gap are the difficulty of forming a common position, scarce resources and the lack of instruments. Nielsen’s main proposition adds to this that soft power — the attractiveness of values — does not narrow but widens this gap, because it further increases expectations while changing nothing in the capacity to deliver; and the consequence is “a disproportionate degree of disillusionment and resentment” when the hopes are not fulfilled.

The data on the Yamal route is a textbook case of this mechanism. The Union adopted twenty-one packages, announced an effect of more than a thousand billion euros, and meanwhile one branch of shipping ran 92 per cent into European ports, under the protection of a negotiating exception. The problem is not that the sanctions are not perfect — it is that the difference between the announced and the delivered action is unexplained. MIAK’s proposals are therefore not aimed at increasing severity but at stating the difference: a registered exception, reasoned and provided with an expiry date, pulls the gap narrower than one that is not stated.

📖 Source: Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap (Journal of Contemporary European Research, 2013)

6.5 International comparison

There are two established patterns in international practice for handling the technique of exceptions, and neither of them is prohibition. One is the sunset clause: the exemption ceases to be in force at a specified point in time, and an active, reasoned decision is needed to maintain it — that is, inertia leads towards cessation, not towards survival. Today’s Greek exception is exactly the reverse: it renews automatically unless the member states vote against it. The Hungarian and Slovak crude oil exemptions go even further than this, because they do not even contain a time limit.

The other pattern is the system of trade policy safeguard measures, where under world trade rules the introduction of a safeguard measure comes with an investigation, public reasoning and a time limit, and its extension with a new investigation. The principle there too is not that protection is prohibited; it is that protection is the subject of a procedure. MIAK’s proposal transplants this principle into the world of sanctions exceptions: if a member state asks for an exemption, let it give an account of it, and let it say until when it is asking for it.

Foreign policy

  • KP3 — Transparent foreign policy
  • KP4 — Principled pragmatism doctrine
  • KP17 — Issue-based coalition building in the EU
  • KP19 — Position on international institutional reform

Transparency and anti-corruption policy

  • A4 — Lobby register
  • A14 — Participation in and accountability of international institutions

Environment and climate

  • K2 — Energy transition plan
  • K7 — Energy market shock resilience

Economy

  • G5 — Competition policy and anti-monopoly
  • G19 — Radical transparency in economic decision-making
  • G20 — Economic policy impact assessment system

Proposed new programme point: Sanctions exception protocol — public reasoning and a compulsory expiry date — for the Foreign policy area.

6.7 List of sources

Press sources (MIAK foreign press monitor, 18 August 2026 — topic 2):

Knowledge base references (literature):

  • 📖 Adam Smith: The Wealth of Nations
  • 📖 G. R. Berridge – Maurice Keens-Soper – T. G. Otte: Diplomatic Theory from Machiavelli to Kissinger
  • 📖 Kristian L. Nielsen: EU Soft Power and the Capability-Expectations Gap

MIAK internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point ID: KP4, KP17)
  • MIAK policy area: Transparency and anti-corruption policy (programme points; programme point ID: A4)
  • MIAK policy area: Environment and climate (programme points; programme point ID: K7)
  • MIAK foreign press monitor, 18 August 2026 — topic 2, score: 90/100

Supplementary public data sources:

  • Urgewald and CREA (Centre for Research on Energy and Clean Air) — analyses of the trade in Russian liquefied natural gas
  • Kpler — shipping database
  • EU Sanctions Map and the consolidated text of the twenty-first sanctions package
  • Eurostat — energy import statistics
  • ENTSOG / AGSI+ — storage-level and transit data

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