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A person on an EU sanctions list can ask the General Court of the European Union to annul the listing (see how to challenge a listing). How many succeed? No official statistic says. The figures available nonetheless give a fair picture, and explain why an annulment does not always mean leaving the list.
Key points
- The General Court publishes the number of sanctions cases, not their outcome. The success rate has to be reconstructed from the judgments.
- Between 2009 and 2017, for the Iran and Syria regimes, an academic study found 62% of listings annulled. The picture has changed markedly since.
- For Russia, since 2022, most actions have been dismissed. Annulments happen, but remain the exception.
- An annulment concerns a dated act. If later renewals are not challenged, the person stays listed.
What the official statistics show
The General Court treats “restrictive measures (external action)” as a separate subject-matter. Each year it publishes the number of cases brought, completed and pending, but not how they were decided.
| Year | New cases | Completed cases | Pending at 31 December |
|---|---|---|---|
| 2021 | 42 | 56 | 51 |
| 2022 | 103 | 32 | 122 |
| 2023 | 63 | 69 | 116 |
| 2024 | 63 | 88 | 91 |
| 2025 | 105 | 71 | 125 |
Source: judicial statistics of the General Court of the European Union, 2022 and 2025.
The effect of the war in Ukraine is clear: the number of actions more than doubled in 2022. According to the Court, 47 of the 63 cases brought in 2024 were linked to the war. In 2025, 84 of the 105 new cases fell within the same group, which also includes the regimes targeting Belarus, Moldova and Iran’s military support to Russia.
2009-2017: the era of annulments
The most cited study, published in 2019 in the Yale Journal of International Law by Elena Chachko, covers the Iran and Syria regimes. Of 204 merits decisions delivered between July 2009 and March 2017, the General Court annulled the listing in 126 cases, or 62%. For first challenges, the rate reached 73%.
These victories were often temporary. The Council relisted 57% of the persons whose listing had been annulled, usually on stronger reasons and evidence.
The Council learned from that period. At a hearing before the UK House of Lords (2016-2017 session), its legal service explained that in 2012-2014 it was still losing twice as many cases as it won, and that the trend had reversed from 2015.
Russia: mostly dismissals
For the Russia regime, no study gives a complete success rate. Published studies agree on one point: most actions are dismissed. A few annulments have nonetheless shaped the case law:
- Prigozhina (T-212/22, 8 March 2023): a family link with a listed person was not enough under the criteria then in force.
- Aven and Fridman (T-301/22 and T-304/22, 10 April 2024): the General Court found the reasons for the 2022 acts insufficiently substantiated and annulled them.
- Pumpyanskiy (T-541/24, 10 September 2025): annulment of the September 2024 and March 2025 renewals. He nevertheless remained listed.
The Council, for its part, has broadened its criteria. Since February 2022, it can list “leading businesspersons” operating in Russia. In June 2023, it extended that criterion to their immediate family members and other persons who benefit from them. On 26 March 2026, the Court of Justice confirmed the validity of the leading businesspersons criterion in a judgment on five joined appeals (C-696/23 P and others). A listing criterion can only be struck down if it is manifestly inappropriate.
Annulled, but still listed
Russia listings are renewed every six months, in March and September. An annulment judgment only covers the acts challenged. Aven and Fridman won against the 2022 acts, but the 2023 renewals had not been challenged: they remained listed.
Two practical lessons:
- each renewal must be challenged, by amending the pending action or by a new action, within the two-month time limit plus the ten-day extension on account of distance;
- action is also needed before the Council, by submitting observations before each review. A strong file at that stage sometimes prevents a renewal.
Duration, interim measures and damages
Proceedings before the General Court lasted on average about nineteen months in 2025, all subject-matters combined. The Court does not publish a duration specific to sanctions.
Interim relief is rarely granted. In 2025, six applications were made in sanctions cases; none was granted.
Compensation is exceptional. In Safa Nicu Sepahan (T-384/11), the General Court awarded EUR 50,000 for non-material damage, upheld by the Court of Justice on 30 May 2017. As far as we know, damages claims in the Russia cases have been dismissed, for example in Abramovich (T-313/22).
What makes the difference
The annulments obtained have one thing in common: the Council could not establish, with precise, specific and consistent evidence, that the person met the criterion relied on at the date of the act. Old press articles, a family link or a position left long ago are not always enough.
Conversely, where the criterion is broad and the person’s position is established, an action has little chance of success. Analysing the Council’s file, requested at the outset, is decisive.
Situation at 29 July 2026. This article is for general information only and does not constitute legal advice.
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