Strasbourg Assembly Backs Plan to Make Russia Pay €3.3 Billion in Court Awards

Russia owes more than €3.3 billion under European Court of Human Rights judgments, and on 30 September 2026 the Parliamentary Assembly of the Council of Europe (PACE) finally put forward concrete proposals to collect it. PACE adopted Resolution 2678 (2026) and Recommendation 2315 (2026), the first documents in Council of Europe history to endorse specific mechanisms for enforcing ECtHR monetary awards against a state that refuses to pay.

The debt spans more than 1,700 final judgments owed to more than 50,000 victims. They include roughly 30,000 Georgian nationals from three Georgia v. Russia inter-state cases, about 2,000 Moldovan nationals in Transnistria-related cases, and some 18,000 Russian applicants. Those figures exclude any claims from Russia's aggression against Ukraine. The Court is still hearing four inter-state cases brought by Ukraine and the Netherlands, plus about 5,700 individual applications linked to the conflicts in Ukraine and Georgia. PACE estimates future awards "could potentially amount to billions, tens of billions, or hundreds of billions of euros" (Resolution, §8).

Why has nothing been collected so far?

Russia was expelled from the Council of Europe in March 2022 over its full-scale invasion of Ukraine. It has expressly refused to abide by any ECtHR judgment and passed domestic legislation to that effect. The Committee of Ministers, which supervises execution of judgments, has limited itself on just satisfaction largely to stocktaking. PACE now calls that response "not sufficient" (Resolution, §5).

Rapporteur Tony Vaughan's accompanying report argues that "we cannot sit back and wait" and "must pursue novel measures to implement the judgments now" (§16). Russian assets held in Europe, the report contends, give member states the leverage to make Russia pay.

What does PACE propose?

Building on earlier work by the Committee of Legal Advisers on Public International Law (CAHDI), PACE outlined two pathways.

• An ad hoc funding mechanism. The Council of Europe would create a body mandated "to recover Russian State-owned assets" and distribute them to successful applicants (Recommendation, §2.1). An amendment widened its scope from Ukraine's inter-state cases to all ECtHR cases against Russia.
• Domestic enforcement. PACE calls for a comprehensive study of member states' laws to identify openings for domestic enforcement, urges states to enable it wherever legally possible, and proposes a Committee of Ministers recommendation to that effect (Resolution, §13.2; Recommendation, §§2.3-2.4).

What about frozen Central Bank assets?

PACE makes a detailed case for repurposing roughly €260 billion in immobilized Russian Central Bank assets, earmarking them for future ECtHR awards to Ukraine (Resolution, §13.1; Recommendation, §2.2). The approach rests on judgments of an international court whose jurisdiction Russia accepted, arguably the strongest legal basis among current proposals. The ECtHR is the only forum on track to rule on war-related damage in Ukraine with monetary awards legally binding on Russia.

The Strasbourg mechanism would partially overlap with the Council of Europe's compensation structure for Ukraine — the Register of Damage, the International Claims Commission and a future fund — which currently covers damage only since 24 February 2022. The ECtHR route would also reach victims of violations committed between 2014 and 16 September 2022, when Russia ceased to be party to the Convention.

Can ECtHR judgments be enforced in third states?

The proposal tests the traditional reading of Article 46 of the European Convention. The Convention does not bar domestic enforcement by states other than the respondent. In practice, though, the only known attempt — brought by three Russian nationals in 2024 — failed when a Lithuanian court held that execution fell within the remit of the Committee of Ministers and that Lithuania had no jurisdiction.

The PACE report counters that "Article 46, properly interpreted, does not preclude member States from taking steps at a domestic level to enforce ECHR just satisfaction awards against other States – particularly non-member States" (§38). Sovereign immunity remains a major obstacle. The report develops one route around it: countermeasures in cases brought by Ukraine (§§49-51).

For practitioners, the immediate consequence is procedural: asset recovery litigation involving Russian state property in European jurisdictions may accelerate, and the Committee of Ministers is due to reconsider its Russia strategy at its December 2026 human rights meeting before replying to PACE. The assembly's documents call for action but decide nothing themselves.

In their 2023 Reykjavik Declaration, Council of Europe leaders pledged "every effort" to secure execution of the Court's judgments against Russia. Three years on, no concrete steps have followed. PACE now argues the Convention's premise of "collective enforcement" demands that change.