The sanctions against Russia and the new obligations for Platforms

On 1 March 2022 the EU Council adopted Regulation (EU) 2022/350 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine. 

The Regulation is generally applicable, binding in its entirety and directly applicable in all Member States. Under the Regulation, it shall be prohibited to broadcast TV programs via cable, satellite, IP-TV, internet service providers, internet video-sharing platforms or applications, whether new or pre-installed. 

The Regulation concerns the restriction of publication and dissemination of any content the following sources *:

RT – Russia Today English;

RT – Russia Today UK;

RT – Russia Today Germany;

RT – Russia Today France;

RT- Russia Today Spanish) and


*As of today, these are the only entities, referred to in Annex XV to the Regulation. The list in Annex XV to the Regulation is subject to further amendments (additions).

Under the Regulation, the validity of all TV and radio broadcasting licenses or permits within the range of restrictions shall be suspended.

So far, there are no official statements, comments and/or information, regarding the actual (technical) implementation of the obligations under the Regulation by the Platforms.

Below you can find some random examples of how the Platforms can functionally adjust to the current situation (before we have been given clear practical guidelines) in order to be able to fulfill their obligations under the Regulation:

  • Platform operators should be informed and monitor the publications quoting or sharing through third countries any content from the prohibited sources (RT and Sputnik) and erase them, should that be the case. 
  • Identify domains of the prohibited sources (RT and Sputnik) and add them to an automatic banning system for publishing links, images and videos from these domains (if any);
  • Inform, in the appropriate manner, the users of the Platform about prohibitions introduced by the Regulation;
  • Include information about the prohibitions of the Regulation in the relevant Rules (General Terms) for use/publishing in the Platform.

This Statement does not constitute legal advice or consultation but is rather an expression of Dimitrova, Staykova & Partners Law Firm team’s opinion.