Our support for Ukraine is total. But supporting Ukraine does not mean putting Belgium at risk. Without genuine European solidarity, the seizure of Russian assets is out of the question: at this stage, no sufficient and credible guarantee has been provided to us. Such a decision would violate international law and expose our country to immense financial, legal, economic and security risks. Belgium cannot, and must not, bear such a burden alone.
Background
The Russian assets frozen at Euroclear, and therefore on Belgian soil, have been the subject of numerous debates in Belgium and at European level ever since the European Commission (EC) proposed using these Russian assets to continue financial aid to Ukraine. This debate comes as the EU appears to be marginalised in the peace talks between the United States, Ukraine and Russia.
But what is Euroclear, an institution that was still fairly unknown to the general public until recently?
Why are we hearing about Russian assets sitting on Belgian soil? We address these notions below, before explaining the reasons for the Belgian Government's reluctance to use these Russian assets frozen at Euroclear.
Euroclear
Euroclear, whose headquarters have been based in Brussels since 2018, is an essential institution of the financial system. It is an international depository and settlement company for bonds, shares and investment funds that functions as a global clearing and settlement house. It processes major financial transactions between investors, large financial institutions and governments. The institution describes itself as “the notary of the financial world”. It holds 42,500 billion euros in financial securities and processes 330 million transactions a year, equivalent to 40% of global GDP in deposited or managed assets.
Euroclear is mainly owned by the SFPIM (12.2%), the French Caisse des Dépôts et Consignations (11.4%), the New Zealand sovereign wealth fund (8.7%) and the Singapore sovereign wealth fund (5.0%).
Sanctions against Russia
From the first day of the Russian invasion of Ukraine on 24 February 2022, the EU adopted a series of sanctions against Russia and those close to Vladimir Putin. Among these sanctions, renewed several times to date, is the freezing of Russian assets, the vast majority of which come from the Russian National Bank, amounting to 185 billion euros sitting on Belgian soil. Important clarification: these assets were frozen, not confiscated. This means Russia no longer has direct access to ownership of these securities. More broadly, at EU and G7 level, more than 350 billion euros have been frozen and immobilised as part of the Russian sanctions (in summary: 210 billion for the EU, of which 185 billion in Belgium).
What is the European Commission proposing?
By early 2026, Ukraine will have used up all the aid provided to it so far by the EU. With the United States now stepping back, the EU finds itself on the front line in meeting Ukraine's needs.
According to the IMF, Ukraine would need a loan of around 135 billion euros for 2026-2027 to cope with the war and its consequences. For several weeks, discussions and debates have been under way at European level to finance this aid. On 3 December 2025, the EC presented two options for financing Ukraine over the next two years: a new joint European loan or a “reparations loan” using the Russian assets frozen in the EU, therefore mainly in Belgium. The second option is the one favoured by the EC, and if it were chosen, it would only require a qualified majority vote among member states. Belgian approval would therefore not even be necessary. Unlike the joint European loan, which requires unanimity among the 27.
What does this reparations loan involve?
The EC proposes to cover two-thirds of Ukraine's financing needs for the next two years. This represents 90 billion euros. The final third would have to be secured by international partners, such as the United Kingdom, Canada or Japan.
It is Belgium, through Euroclear, that holds on its territory the majority of the Russian assets frozen in Europe (185 billion), and which would therefore be the most exposed member state in such a scenario. Euroclear's CEO states that these 185 billion euros “represent 10% to 15% of Russia's GDP”, a colossal sum.
Furthermore, the interest on these assets has already been used to help Ukraine via Euroclear. Indeed, as the CEO has indicated, this interest, which now amounts to around 5 billion euros over the past two years, is in fact income belonging to Euroclear. The Board of Directors of the Belgian company decided that the institution should not enrich itself off the back of this tragic situation. Unlike the interest, which can legally be mobilised, using the entire 185 billion euros of Russian funds deposited by the Russian National Bank at Euroclear as a loan would not be a realistic solution. Indeed, the risks for (i) our country, (ii) the stability of the financial system, and (iii) a key institution such as Euroclear are colossal.
The EC assures that guarantees will be put in place to address the risks raised by the use of these assets. A European Council meeting will be held on 18 December, where a decision is expected to be made.
What are the risks, concretely?
- Risk of financial destabilisation: the legality of such a seizure and use of these assets appears highly uncertain. Euroclear or Belgium could face legal action and, if so, would have to return these Russian assets. The risk of bankruptcy would be extremely high for Euroclear, and our country alone could not cope with this repayment. Along the same lines, the day sanctions against Russia end, the Russian assets would have to be returned immediately, here too the bankruptcy risk would be extremely high. Given the importance of the company (42,500 billion euros in financial assets), such a bankruptcy would have major consequences for the stability of the international financial system. Let us recall that the amount of these assets exceeds the amount of our federal budget.
- Reputational risk for Belgium and Europe: such a scenario would seriously and lastingly damage Belgian, and even European, credibility on the financial front. Indeed, such a confiscation of financial assets would deter international investors from placing their money in Europe, including through government bonds, which would automatically push up interest rates.
- Reputational risk for Euroclear: such a scenario would damage Euroclear's credibility and the trust its clients place in it. This could result in the institution relocating outside Belgium and the EU. Were this to happen, we would lose an essential link in the global financial system, and this would undermine Europe's financial power.
- Security risk: Belgium would become a priority target for destabilisation orchestrated by the Russian state (drone overflights, cyberattacks, interference, etc.).
- Risk of financial retaliation: according to Euroclear, its Russian counterpart, NSD, holds 17 billion euros in Western financial assets. Moscow could mobilise these assets to its advantage.
What is Belgium's position?
- Belgium has been an ally of Ukraine from the very start and intends to remain so.
- The federal Government is firmly opposed to a scenario in which Russian assets would be used without credible guarantees from the European Commission and without a mutualisation of risks by other member states. Our country has formally notified the European Commission of this on multiple occasions.
- The federal Government stresses that such confiscation and use of assets has never happened before, not even during the Second World War. This scenario is unprecedented, and the consequences are therefore more than uncertain.
- The Government recalls that the Belgian state is not, at this stage, a belligerent party.
What guarantees is the Belgian state demanding?
The Belgian Government's three conditions before considering a reparations loan via the Russian assets held notably at Euroclear:
- Mutualisation of all risks: Belgium will never accept bearing the risk of such an operation alone.
- Protection of liquidity: Euroclear must have the necessary funds available if needed. This must be guaranteed by the other member states or even by the EC (via its budget). If the institution encounters liquidity problems, this will have an impact on the financial market, as the ECB has itself confirmed. Furthermore, should Russia impose countermeasures against Belgium, the damage must be covered directly.
- Fair distribution of the burden: all countries that also hold Russian assets must contribute.
The federal Government considers that the EC's proposals on the first two points are not sufficiently robust. Moreover, the EC does not address the third requirement. Belgium therefore cannot accept the plan as presented to date.
Conclusion
Belgium reaffirms its support for Ukraine's war effort against the Russian invader. As a founding state of the Union and a tireless promoter of the European project, Belgium believes the efforts must be fairly shared among member states. We reiterate our search for peace in this conflict, which has now lasted almost 4 years, but this search for peace cannot come at any price.
The MR recalls that Belgium has been an ally of Ukraine from the very start and firmly intends to remain so. The MR also believes that the war's objectives must be clarified and that it would be appropriate to track this money, given the corruption still very much present in Ukraine, without however making this a condition for aid.
Should the European Commission proceed against Belgium's advice, this would constitute a profound and unprecedented breach of trust between Belgium and its European partners. Any country in a similar situation would have the same demands as those expressed by Belgium.
The risks for our country, for member states, but also for the financial markets are significant and must be properly weighed and contained.