Dublin: Ireland holds the rotating Council presidency, and it has also become the target of an infringement step over the EU sanctions directive. On 1 October 2026 the European Commission sent a reasoned opinion to Dublin because Ireland has not notified any measures transposing Directive (EU) 2024/1226 on the criminalisation of violations of EU restrictive measures.

The transposition deadline fell on 20 May 2025, which means Ireland is now more than 16 months late. The EU sanctions directive requires every member state to treat the violation of EU restrictive measures as a criminal offence and to set common minimum standards on offences and penalties. Until now, the sanctions imposed against Russia and other targets were EU-wide in law but enforced very differently, and some governments treated breaches as administrative matters.

The reasoned opinion is the second stage of the infringement procedure. Ireland has two months to reply and to notify the measures it has adopted, and the Commission can refer the case to the Court of Justice if the answer falls short. Late transposition of the EU sanctions directive can also bring a request for financial penalties at that stage.

The decision stands out because of the timing. Sanctions policy dominates the Union’s response to Russia’s war against Ukraine, and the Foreign Affairs Council meets again on 12 October to discuss the war. The EU sanctions directive exists precisely so that evasion becomes a crime everywhere, and a gap in one national system weakens the whole structure.

Justice files in the same package show how broad the Commission’s enforcement work is. Hungary received a reasoned opinion for incorrectly transposing Directive (EU) 2016/1919 on legal aid for suspects and accused persons in criminal proceedings. Spain was referred to the Court of Justice because it has not applied a 2022 judgment on State liability for breaches of EU law, and a draft amending law is still pending in the Spanish Parliament.

Sixteen member states also received reasoned opinions for not communicating full transposition of the Consumer Credit Directive, which had a deadline of 20 November 2025. That separate decision shows that Ireland is far from alone in missing transposition dates, although its case touches a more politically sensitive field.

For companies and banks in Ireland, a national law that implements the EU sanctions directive will bring clearer exposure to criminal liability for breaches. For the Commission, a prompt answer from Dublin would remove an awkward example during the Irish presidency. The reply is due in early December.