Space and sanctions: another lens to observe international cooperation in this decade (and those to follow)
João Nuno Frazão
§1. On December 2, 2025, the Faculty of Law, Economics, and Finance at the University of Luxembourg held a conference called “The Next Phase of Sanctions: New Challenges in the War Between Russia and Ukraine” [1], to which I had the honor to attend[2]. The conference explored “the multifaceted impact of sanctions arising from the Russia–Ukraine war, focusing on the most recent measures adopted by the EU and Russia’s responses across different fields”. In other words, the backdrop was international sanctions, a complex concept riddled with legal challenges, intertwining political, economic, and international relations spheres. Although somewhat polysemic – the terms “sanctions,” “economic sanctions,” or “international sanctions” are used – the concept broadly suggests that sanctions “are defined as the withdrawal of customary trade and financial relations for foreign and security policy purposes (…); may be comprehensive, prohibiting commercial activity with regard to an entire country (…), or they may be targeted, blocking transactions by and with particular businesses, groups, or individuals”[3]. Given the increasing use of these instruments, which are both political and legal in nature, particularly over the last decade, above all by the EU and the US, and even more so because this is a subject that requires further scrutiny, it prompted the collection of contributions to the first encyclopedia on international sanctions, published a couple of days earlier and discussed at this event[4].
§2. The proceedings lasted all day and focused on three panels, on Criminal Law, dispute resolution, and Space Law, with the aim of highlighting “the varied dimensions of sanctions and the new challenges these measures pose amid the ongoing conflict”[5]. About the first two, the debate encompassed, among others, matters related to money laundering[6], as well as several specific issues surrounding bilateral investment treaties (BITs)[7], respectively. Finally, the third panel, entitled “Outer Space Governance in the Context of Sanctions and War”, covered important and undoubtedly timely topics of Space Law, such as space security, International Humanitarian Law, and the use of force, featuring presentations by Almudena Azcárate Ortega (UNIDIR – United Nations Institute for Disarmament Research), Professor Setsuko Aoki (Keio University Law School), and Marko Höyhtyä (VTT Technical Research Centre of Finland Ltd); and moderation by Professor Mahulena Hofmann (SES Chair in Satellite Communication and Media Law, University of Luxembourg). I had the opportunity to join this panel, and I was asked to speak on the following topic for approximately twelve minutes: “Sanctions, war, and the future of international space cooperation.” A preliminary remark: neither I nor my fellow colleagues are experts in sanctions, either in the broader field of International Law nor in the specific field of Space Law, precisely because this is still a relatively new subject, with a (still) limited number of contributions within the legal doctrine on space[8].
Having opened the discussion, and given the relatively broad scope of the topic, my contribution focused on three points: (i) the recent, current, and future context of international cooperation in space, with a focus on Europe; (ii) direct and indirect sanctions within the EU, that is, on the one hand, those resulting from the sanctions packages against Russia, with an emphasis on the most recent (“19th package”), approved at the end of October 2025; and, on the other hand, other restrictive measures within the EU which, although indirect in nature, are relevant to the space sector; and, finally, (iii) related to point (i), the consequences of sanctions for cooperation, considering the EU and the European Space Agency (ESA). Therefore, the following paragraphs reflect research and analysis conducted prior to the conference, as well as insights drawn from other debates, as well as additional readings after the conference.
§3. It is well known that space activities began on October 4, 1957, with the launch of the first space object, Sputnik 1, by the Soviet Union, which in 1961 was also responsible for sending into orbit the first human being, Yuri Gagarin. Since then, scientific and technological developments, on the one hand, and subsequent global geopolitical and economic transformations, on the other, have shaped space activities and international cooperation in space. It is not possible to identify the exact moments when these transformations occurred, but we can group them into three major periods: (i) in the first, beginning in the late 1950s and lasting until the mid-1980s, space activities were almost exclusively led by States, but in limited numbers, restricted to those with space capabilities, also involving space cooperation; (ii) in the second period, which lasts roughly until the early 2000s, the presence of States persisted and expanded, with many adopting political, strategic, and legal tools alongside international organizations, and with the increasing participation of private entities that, in addition to other activities, became involved in the provision of launch services; and (iii) in a third period, in which space and space activities consolidated as a strategic domain, with the emerging and consolidated presence of private entities and the commercialization of this sector. At present, we may be experiencing a fourth chapter, with many different players and diverse interests, both in terms of numbers and activities. Widespread access to space and the exponential increase in the number of space objects have brought considerable benefits, but also new and complex challenges, including the proliferation of space debris and the risk of congestion in Earth’s orbits, with serious implications for the sustainability of space activities, along with growing threats to space infrastructure, both in orbit and terrestrial, with regard to the increasingly important dimension of security and defense. In other words, international cooperation has gone hand in hand with space activities since the beginning, however, given the variety of interests and the profound transformations that have taken place over nearly six decades, it is reflected in different contexts, forms, and purposes.
Space cooperation, at the universal, regional, and bilateral levels, is essential and unavoidable, both to meet the challenges of space and space activities and to promote the “space blocks”[9], consisting of groups of States that cooperate and compete. In this context, the recent past, present, and future emphasize and anticipate the intensification of both regional and bilateral cooperation. The most prominent and successful model of regional cooperation, but one that is also highly complex both politically and legally, is that of Europe, embodied by the ESA, the EU and all Member States. A coordinated response at European level is therefore understandable, given the competences of the ESA and the EU: the Russian invasion of Ukraine almost immediately affected international cooperation[10].
§4. Within ESA, this was particularly evident in the ExoMars program, an unmanned ESA mission to explore Mars, whose partner at the time was the Russian Space Agency (Roscosmos) – a program that was formally resumed in April 2024[11] – or at the level of the International Space Station (ISS), which is expected to be decommissioned by 2031[12]. In the months that followed, much was written about the impact of the invasion of Ukraine on space cooperation, notably the economic sanctions imposed by the United States (US) on the Russian Central Bank but also affecting the aerospace industry and other relevant technologies[13]. In turn, also in February 2022, Russia suspended launches of the Soyuz capsule from the Guiana Space Centre (Kourou, French Guiana)[14], in response to European sanctions imposed on the country that same month[15]. The events of 2022 abruptly changed access to space, which affected, and continues to do so, Europe’s launch capability, here including the triangular model comprising ESA, the EU, and all Member States. In fact, until recently, space launches were carried out using three different launchers: Ariane 5, in operation since 1996-1998; Vega, in operation since 2012; and the above-mentioned Soyuz capsule, in operation since 2002. Following the invasion of Ukraine and the subsequent unavailability of Soyuz, anomalies were also reported with the new Vega model, Vega-C, in June 2023, resuming its activity only in December 2024. With the decommissioning of Ariane 5 in July 2023, this combination of events left Europe without any launch vehicles available for over a year, an unprecedented scenario that impacted, and continues to impact, European programs. The first successful test of the new model, Ariane 6, took place in July 2024, and the first commercial flight only in March 2025[16], with its fifth successful launch taking place in December 2025. Nevertheless, when compared to third-country operators, the pace, flexibility, and competitiveness of Europe’s access to space remain significantly lower. It should also be noted that, throughout the first half of 2022, sanctions targeting Russia and its legal entities and individuals were progressively imposed by both the US and the EU[17].
§5. At the EU level, beyond ESA’s programmatic and technological perspective, given its intergovernmental nature, the EU is empowered to adopt “restrictive measures.” Under article 29 of the Treaty on European Union (TEU), the Council may “adopt decisions which shall define the approach of the Union to a particular matter of a geographical or thematic nature”, whereas “Member States shall ensure that their national policies conform to the Union positions”. The Council’s decisions are adopted within the framework of the Common Foreign and Security Policy (CFSP), which means that they do not take the form of legislative acts – and therefore do not follow the legislative procedure – and require further implementation, in this case under article 215 of the Treaty on the Functioning of the European Union (TFEU). With the Treaty of Lisbon, the provisions concerning the CFSP – Title V of the TEU – remained largely structured at the intergovernmental level, i.e., article 40 of the TEU follows the logic prior to 2009, “based on the distinction between the CFSP, retains the exclusive competence to pursue political objectives, and the TFEU EU policies, which are to pursue the substantive objectives respectively assigned to them”[18]. Under the CFSP, the jurisdiction of the Court of Justice of the European Union (CJEU) is limited, meaning that such matters remain largely within the sphere of the Member States (articles 4(2) and 42(3) of the TEU, without prejudice to article 275(2) of the TFEU). In this context, the adoption of restrictive measures, in line with Article 215 TFEU, “constitutes the only EU policy that explicitly straddles the foreign policy competence and the substantive competences of the EU”[19]. Thus, the exercise of such competence “entails a sequence of acts based on different and perhaps irreconcilable decision-making procedures: a CFSP decision to be taken through intergovernmental mechanisms determines the conditions for the adoption of restrictive measures to be taken through the procedure laid down by article 215 TFEU”[20]; whereby the purpose of article 215 TFEU “is precisely to establish a link – the only one expressly provided for on the legal plan – between the political and the substantive dimensions of the EU”[21].
§5.1. The complexity surrounding the adoption of restrictive measures remains, leaving several legal questions unresolved. In any case, and as anticipated, the EU has not only adopted restrictive measures but has also strengthened this dynamic, given that, since February 2022, subsequent packages of sanctions have broadened the scope of application with regard to the prohibitions imposed. In relation to space, we can distinguish between direct and indirect sanctions. To be precise, the starting date to be considered is not 2022, but 2014, following the annexation of Crimea by Russia, leading to the adoption, in March, of Decision 2014/145/CFSP[22]and Regulation (EU) No. 269/2014[23]; and, in July, Decision 2014/512/CFSP[24] and Regulation (EU) No. 833/2014[25] – the legal basis invoked for each type of legal act was that of articles 29 TEU and 215 TFEU. For the purposes of this post, we shall focus on the latter set of acts. Looking back at the timeline, neither Decision 2014/512/CFSP nor Regulation (EU) No. 833/2014, in their original wording, targeted the aerospace sector; quite the contrary. In 2014, a ban was introduced on the sale the sale, supply, transfer, or export, directly or indirectly, of “dual-use goods and technology (…) to any natural or legal person, entity or body in Russia or for use in Russia (…),” if those were intended “for military use or for a military end-user” – prohibition that, however, did not affect “the exports of dual-use goods and technology, including for aeronautics and for the space industry, for non-military use or for a non-military end-user”[26].
§5.2. In 2022, three days after the invasion of Ukraine, Decision (CFSP) 2022/327[27] and Regulation (EU) 2022/328[28] were adopted, each amending the aforementioned legal acts. The EU raised the bar by imposing a total restriction on dual-use goods and technologies, regardless of their civilian or military use[29]. It also did so in relation to aviation and space by introducing a prohibition on the export of goods and technologies suitable for use in the aviation and space industries, eliminating the 2014 exception[30]. Despite this, the prohibition “to sell, supply, transfer or export, directly or indirectly, goods and technology which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector”, the possibility of a derogation remained, including in the case of “intergovernmental cooperation in space programmes”[31]. At the same time, the EU strengthened prohibitions in other sectors relevant to the space sector, such as electronics and semiconductors, as well as the provision of technical assistance and other related services – a move that gained further momentum in 2023 and 2024, particularly with the adoption of the “11th package”[32] the “13th package”[33] of sanctions against Russia. In the first couple of years after the invasion of Ukraine, the EU’s approach to restrictive measures was scalable and incremental, which, step by step, albeit somewhat indirectly, became evident in relation to space.
§5.3. In late October 2025, the “19th package” of sanctions against Russia was adopted[34], with new provisions concerning space. Decision (CFSP) 2025/2032, which amended Decision 2014/512/CFSP, extended the scope of the prohibitions, particularly with regard to the provision of services[35]. The Council considered “pertinent to impose further restrictions on the provision, to the Government of Russia or to legal persons, entities or bodies established in Russia, of services that contribute to enhancing Russia’s technological capabilities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services” (recital 24). Hence, article 1k, added in 2022, now provides, in its subparagraph f), the following: “1. It shall be prohibited to provide, directly or indirectly, the following services to the Government of Russia or to legal persons, entities or bodies established in Russia: (…) f) commercial space-based services consisting of Earth observation or satellite navigation”. Similarly, Regulation (EU) 2025/2033, which amended Regulation (EU) No. 833/2014[36], took the same approach in terms of the context (recital 22) and substance (Article 5-N(f)). This prohibition applies as of 25 November 2025[37]. There is, however, the option of derogation: “the competent authorities may authorise the provision of services (…), under such conditions as they deem appropriate, after having determined that such services are necessary for intergovernmental cooperation in space programmes”[38].
There are at least two major effects. First, the normative “double layer” binds Member States politically (through Decision 2014/512/CFSP, as currently worded) and is legally binding and directly applicable to all economic operators (through Regulation (EU) No. 833/2014, as currently worded), that is, any natural or legal person providing “commercial space-based services,” whether Earth observation or satellite navigation services – but also other types of services, including “artificial intelligence services consisting of access to models or to platforms for their training, fine-tuning and inference”, or “high-performance computing, including access to graphic processing unit-accelerated computing, or quantum computing services”[39]. Second, and following on from this last point, the territorial and personal scope of Regulation (EU) No. 833/2014, as currently in force, is broad, since it applies: (i) within the territory of the EU; (ii) on board any aircraft or any vessel under the jurisdiction of a Member State; (iii) to any person inside or outside the territory of the EU who is a national of a Member State; (iv) to any legal person, entity or body, inside or outside the territory of the EU, which is incorporated or constituted under the law of a Member State; and (v) to any legal person, entity or body in respect of any business done in whole or in part within the EU (article 13) – given that the prohibition covers the provision of services, whether “directly or indirectly” (which was already provided for in article 1k), it seems to follow from the latest case that it covers intermediaries or other third parties outside the EU. Furthermore, as highlighted, the material scope of service provision is (once again) expanded with the 19th package of sanctions. By including highly technological and specialized services, the EU’s restrictive measures target not only so-called “classic” services, including legal advice, accounting, or construction and engineering[40], but now also directly target the space sector, more specifically, the provision of commercial space-based services.
§5.4. A question that came up was whether there would be consequences for the EU Space Program[41]. The impacts are difficult to assess, not least because the most recent prohibitions have been in force for a little over a month. Even so, on a global level, the EU’s restrictive measures, besides seeking to weaken the Russian economy, are intended, on the one hand, to affect its space capabilities, and on the other, to strengthen European space capabilities, contributing to the much-discussed strategic autonomy. Two brief remarks. Access to and use of the Galileo[42] open service, like Copernicus[43], by Russia, remains technically possible and legally acceptable. There appear to be no obstacles to the use of such data, nor has the EU to date signaled any intention to limit or restrict its access. A different aspect is the Galileo public regulated service, which is restricted to authorized users and intended for sensitive applications which require a high level of service continuity, including in the area of security and defense, to which Russia has never had access, since no agreement with the EU has been concluded to date. A second point to emphasize is that in the recent past, at present, and in the coming years, the path forward is to strengthen space infrastructure and systems, moving towards full dual use, particularly with regard to the Galileo[44] and Copernicus components – in addition to the future IRIS²[45] – as well as the acknowledgement that investing in more and better national space capabilities, notably in the field of security and defense, indeed complements and strengthens European programs, including the EU Space Program[46].
§6. Space cooperation is the last bulwark of international cooperation. Space is crucial from a scientific and technological point of view, as well as in economic and geopolitical terms, which explains why the ISS has so far preserved cooperation between Western astronauts and Russian cosmonauts, or why the EU has only decided at the end of 2025 to prohibit the provision of commercial space services to Russia. EU-Russia relations have been steadily deteriorating, particularly since February 2022, with Europe gradually taking a harder line. As the conditions for dialogue and cooperation fade, so too does the door to space cooperation, which in theory has always remained open. The current situation, marked by growing tensions at both global and regional levels, should (must!) make us rethink the role of Europe and its independence more than ever. When looking East, Europe is confronted with Russia and its expansionist drive, and when looking West, it faces the US, an old and important ally, but one whose political leadership oscillations dictate inconsistencies when it comes to supporting the European bloc, and this applies to space: it is no longer the final frontier, and Europe is (or must be) aware of this.
[1] “The Next Phase of Sanctions: New Challenges from the Russia–Ukraine War”, available at https://www.uni.lu/fdef-en/events/the-next-phase-of-sanctions-new-challenges-from-the-russia-ukraine-war/ (consulted on 30.12.2025).
[2] With gratitude to Javier García Olmedo (PhD, Research Scientist, University of Luxembourg).
[3] “What Are Economic Sanctions?”, 24.06.2024, available at https://www.cfr.org/backgrounder/what-are-economic-sanctions (consulted on 30.12.2025).
[4] AAVV., Elgar Encyclopedia of International Sanctions (ed. Clara Portela, Andrea Charron e Mirko Sossai), Edward Elgar Publishing, 2025, available at https://www.e-elgar.com/shop/gbp/elgar-encyclopedia-of-international-sanctions-9781035339525.html?srsltid=AfmBOoqboJJKzxtpnXvlthR0kgCqgYIveb6_xyWKKRk4L0-Q-7gXdpsQ (consulted on 30.12.2025). Highlights included a dinner discussion with Professor Clara Portela (University of Valencia), Michael de Boeck (Managing Partner, BOEX Law), and Marita Gorgiladze (PhD candidate in Law, Ghent University).
[5] Supra, note 1.
[6] Within the scope of Directive (EU) 2024/1226 of the European Parliament and the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673, OJEU, L Series, 29.04.2024.
[7] For more details on the main features of investment treaty arbitration in Portugal, “Investment Treaty Arbitration Know-How – Portugal”, 19.12.2025,available at https://globalarbitrationreview.com/insight/know-how/investment-treaty-arbitration/report/portugal (consulted on 30.12.2025).
[8] ŽUKAUSKAITĖ, Liepa e VALKIŪNAITĖ, Kristina, “Sanctions Without Weight: How Sanctions Affect Russia’s Power in Space?” in Vilnius University Open Series, 2025, pp. 280-295.
[9] “Space Blocs: The future of international cooperation in space is splitting along lines of power on Earth”, 21.04.2022, available at https://theconversation.com/space-blocs-the-future-of-international-cooperation-in-space-is-splitting-along-lines-of-power-on-earth-180221 (consulted on 30.12.2025).
[10] As written in another SPARC blog post, “The conflict in Ukraine and space: legal aspects and the consequences for international cooperation”, 29.03.2022, available at https://sparc.cedis.fd.unl.pt/the-conflict-in-ukraine-and-space-legal-aspects-and-the-consequences-for-international-cooperation/ (consulted on 30.12.2025).
[11] Based on the agreement between ESA and Thales Alenia Space for the design and construction of the Rosalind Franklin rover, “ESA awards contract to Thales Alenia Space to restart ExoMars”, 10.04.2024, available at https://spacenews.com/esa-awards-contract-to-thales-alenia-space-to-restart-exomars/(consulted on 30.12.2025).
[12] “It’s Nearly Time to Say Goodbye to the International Space Station. What Happens Next?”, 31.10.2025, available at https://www.scientificamerican.com/article/the-end-of-the-international-space-station-will-begin-a-new-era-of/ (consulted on 30.12.2025).
[13] “The Future of Western-Russian Civil-Space Cooperation”, 26.05.2022, available at https://warontherocks.com/2022/05/the-future-of-western-russian-civil-space-cooperation/ (consulted on 30.12.2025).
[14] “Russia halts Soyuz rocket launches from French Guiana over European sanctions on Ukraine invasion”, 26.02.2022, available at https://www.space.com/russia-halts-soyuz-launches-french-guiana (consulted on 30.12.2025).
[15] “Timeline – Packages of sanctions against Russia since February 2022” available at https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-packages-sanctions-since-february-2022/ (consulted on 30.12.2025).
[16] “Europe hopes to end ‘launcher crisis’ with planned Ariane 6 takeoff”, 09.07.2024, available at https://www.euronews.com/my-europe/2024/07/09/europe-hopes-to-end-launcher-crisis-with-planned-ariane-6-takeoff?utm_source (consulted on 30.12.2025) and “Ariane 6 takes flight for the second time”, 06.03.2025, available at https://www.esa.int/Enabling_Support/Space_Transportation/Ariane/Ariane_6_takes_flight_for_the_second_time (consulted on 30.12.2025).
[17] “Sanctions and Satellites: The Space Industry After the Russo-Ukrainian War”, 10.06.2022, available at https://warontherocks.com/2022/06/sanctions-and-satellites-the-space-industry-after-the-russo-ukrainian-war/ (consulted on 30.12.2025).
[18] BARTOLINI, Maria Eugenia, “’Restrictive Measures’ Under Art. 215 TFEU: Towards a Unitary Legal Regime? Brief Reflections on the Bank RefahJudgment” in European Papers, Vol. 5, n.º 3, 2021, p. 1360.
[19] Ibid. “(…) Art. 75 TFEU also provides a legal basis for the adoption of restrictive measures. Unlike Art. 215 TFEU, which is based on a combination of CFSP and material policies acts, Art. 75 TFEU is fully drawn up within the substantive competences”. In other words, article 75 TFEU is included in Title V (“Area of freedom, security, and justice”), one of the competences falling within the shared competences, in accordance with article 4(2)(j) TFEU.
[20] Ibid.
[21] Ibid.
[22] Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJEU L 78/16, 17.03.2014.
[23] Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJEU L 78/6, 17.03.2014.
[24] Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L 229/13, 31.07.2014.
[25] Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L 229/1, 31.07.2014.
[26] Recital 3 and article 2(1) of Regulation (EU) No. 833/2014, and Recital 11 of Decision 2014/512/CFSP.
[27] Council Decision (CFSP) 2022/327 of 25 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L 48/1, 25.02.2022.
[28] Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L 49/1, 25.02.2022.
[29] Articles 3(4)(b) and 2(1), as amended by Decision (CFSP) 2022/327 and Regulation (EU) 2022/328, respectively.
[30] Recital 14 and article 4d, as amended by Decision (CFSP) 2022/327, and article 3c, as amended by Regulation (EU) 2022/328.
[31] Article 2a(4)(b), as amended by Regulation (EU) 2022/328.
[32] Council Regulation (EU) 2023/1214 of 23 June 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L 159 I/1, 23.06.2023. It expanded the list of goods and technologies that “might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector” (recital 5), expanding the categories of advanced technological goods listed in Annex VII to Regulation (EU) No. 833/2014, including, for example, electronic components and integrated circuits (essential for processing, control, communications, and other systems).
[33] Council Regulation (EU) 2024/745 of 23 February 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L Series, 23.02.2024. Among other things, it added semiconductor devices to Annex VII of Regulation (EU) No. 833/2014.
[34] “19th package of sanctions against Russia: EU targets Russian energy, third-country banks and crypto providers”, 23.10.2025, available at https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/ (consulted on 30.12.2025).
[35] Council Decision (CFSP) 2025/2032 of 23 October 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L Series, 23.10.2025.
[36] Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJEU L Series, 23.10.2025.
[37] In accordance with Article 1k(8b) of Decision 2014/512/CFSP and Article 5n(8b) of Regulation (EU) No 833/2014, as consolidated and in force.
[38] In accordance with Article 1k(9d) of Decision 2014/512/CFSP and Article 5n(9d) of Regulation (EU) No 833/2014, as consolidated and in force.
[39] In accordance with paragraphs (g) and (h) of Article 1k of Decision 2014/512/CFSP and paragraphs (g) and (h) of Article 5n of Regulation (EU) No. 833/2014, in their consolidated versions and in force.
[40] As stated, respectively, in paragraphs a) and b) of article 1k of Decision 2014/512/CFSP and in paragraphs a) and b) of article 5n of Regulation (EU) No. 833/2014, in their consolidated versions currently in force.
[41] Regulation (EU) 2021/696 of the Europan Parliament and the Council of 28 April 2021 establishing the Union Space Programme and the European Union Agency for the Space Programme and repealing Regulations (EU) No 912/2010, (EU) No 1285/2013 and (EU) No 377/2014 and Decision No 541/2014/EU, OJEU, L 170/69, 12.05.2021.
[42] Galileo is the main satellite navigation and positioning component of the EU Space Program (articles 3(1)(a) and 45(1)(a) of Regulation (EU) 2021/696).
[43] Copernicus is the operational, autonomous, user-driven, civil Earth observation system under civil control, based on existing national and European capabilities, which provides geoinformation data and services. As a rule, it follows a free, full and open data policy (articles 3(1)(c) and 49(2) of Regulation (EU) 2021/696).
[44] Galileo is to be complemented and strengthened by the “Celeste” constellation, an ESA program consisting of a constellation of ten LEO-PNT satellites (Low Earth Orbit – Positioning Navigation and Timing) satellites, as recognized and accepted by the EU, with the first two scheduled for launch in 2026, “ESA’s LEO-PNT satellites set to launch by end of year”, 25.06.2025, available at https://www.esa.int/Applications/Satellite_navigation/Celeste/ESA_s_LEO-PNT_satellites_set_to_launch_by_end_of_year (consulted on 30.12.2025).
[45] Regulation (EU) 2023/588 of the European Parliament and the Council of 15 March 2023 establishing the Union Secure Connectivity Programme for the period 2023-2027, OJEU L79/1, 17.03.2023.
[46] It is worth mentioning the “Atlantic Constellation” (“Constelação do Atlântico”) a partnership between Portugal and Spain, consisting of a network of very high-resolution Earth observation satellites. On the Portuguese side, two SAR (Synthetic Aperture Radar) satellites were purchased in 2025, with launches scheduled for 2026 – totaling four this year – and the constellation is expected to have at least 26 satellites. The implementation phase is progressing at a good pace and benefits from the crucial contribution from the Portuguese Air Force (Força Aérea Portuguesa) and CTI Aeroespacial (Centro de Tecnologia e Inovação (CTI) Aeroespacial), “Projeto da Força Aérea em destaque no Estado da União da União Europeia”, 11.09.2025, available at https://www.emfa.pt/noticia-5303-projeto-da-forca-aerea-em-destaque-no-estado-uniao-europeia (consulted on 30.12.2025).