On 9 September 2022, the Council of the European Union adopted Decision (EU) No 2022/1500 suspending the application of all provisions of the agreement_ between the European Union and the Russian Federation that facilitated the issuance of visas to the citizens of both territories (the “Visa Facilitation Agreement”). This suspension adds on to the series of restrictive measures previously adopted by the EU following Russia’s aggression against Ukraine, which we have discussed in previous newsflashes_.

The suspension is effective as of 12 September 2022 and repeals Council Decision (EU) 2022/333 of 25 February 2022, which had already partially suspended the Visa Facilitation Agreement.

As a result, Russian visa applicants will now fully be subject to Regulation (EC) No 810/2009 (the “Visa Code”).

  • Applicants will now have to pay a visa fee of 80 euros, up from 35 euros, and the list of applicants that can be exempted from visa fees has been shortened.
  • The processing time for a visa application is now extended to 15 days, compared to 10 days under the Visa Facilitation Agreement. That period may be extended to 45 days when further assessment is needed.
  • Applicants lose easy access to multiple-entry visas. They can no longer automatically qualify for multiple-entry visas for belonging to certain categories of citizens. The nature and duration of each multiple-entry visa must now be assessed individually.
  • Applicants now also need to provide a full list of documentary evidence regarding the purpose of the journey as listed in Annex II of the Visa Code. Previously, the Visa Facilitation Agreement allowed for certain categories of citizens to prove the purpose of their visit with a single document.

Following the Council’s decision, the European Commission issued guidelines_ to support Member States in handling short-stay visa applications lodged by Russian citizens.

The Commission notably encourages Member States, where necessary, to make full use of the 45-day extension period when deciding on a visa application. The guidelines also recommend requesting additional supporting documents or limiting the type of documents that are accepted. Finally, the Commission encourages Member States to consider issuing visas with shorter validity periods, or single-entry visas, due to the increased likelihood that Russian applicants may no longer fulfil entry conditions over time.

Our expertise

Contact our experts Philippe-Emmanuel Partsch_, Björn ten Seldam_ and Miriam Postiglione_ in the EU Financial & Competition Law_ practice for assistance understanding these measures and how they could potentially impact your activities.

This communication, which we believe may be of interest to our clients and friends of Arendt, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice.


Philippe-Emmanuel Partsch

Philippe-Emmanuel Partsch is the partner in charge of the EU Financial & Competition Law practice of Arendt & Medernach. He specialises in EU and Luxembourg competition law, regulatory aspects of mergers and acquisitions, State aid rules, EU banking and financial law, tax law, telecommunications, public procurement and environmental law. Philippe-Emmanuel advises a wide range of public and private clients, both nationally and internationally, on EU and competition law and sectoral regulation. He represents them before regulatory authorities and the EU and national courts. In addition, he is a member of several high-level Committees within the Luxembourg financial sector and of the Comité Fra...



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