动荡地缘政治环境下的石油储量——关注欧盟经济运营商的持股义务

A Focus on EU Stockholding Obligations of Economic Operators EU – April 2026 also arise in the use ofcentral stockholding entities, theavailability of compliance mechanisms such asticketingarrangementsas opposed tophysical storageand therules governingcross-border storageand the recognition ofstocks held in other Member States. Context: Renewed Focus on Oil Reserves ina Volatile Geopolitical Environment Recent geopolitical developments, including disruptionsaffecting key global shipping routes in the Middle Eastand increased instability in energy supply chains, havebroughtrenewed attention to the resilience of oilsupply systems in Europe. Although no immediate supplyshortage has materialized so far, the current environment hasheightened concerns regarding the reliability, accessibility andavailability of petroleum products across the EU. This fragmentation creates acomplex compliancelandscapefor companies operating across multiplejurisdictions. Impact on Affected Companies So far, no changes have been made to the regulatoryframework, despite the geopolitical situation. Nevertheless,the current outlook increases bothregulatory andoperational exposurefor companies subject to stockholdingobligations. In this context,strategic oil reserves, long regarded as alargely technical compliance requirement, are re-emerging asa central component of energy security policy. EU institutionsand Member States are expected to place greater emphasison ensuring that existingstockholding mechanismsarerobust, enforceable and capable of responding effectively topotential supply disruptions. Companies shouldreassess their compliance frameworks,considering the possibility of heightened scrutiny. Thisincludes verifying the accuracy of stock calculations underapplicable national rules, confirming the correct classificationof eligible products and ensuring that reporting processes andaudit trails are robust and defensible. This may occur in the context ofEU Oil Stocks Directive(Directive 2009/119/EC of 14 September 2009, availablehere), which imposes anobligation on Member States tomaintain minimum stocks of crude oil and/or petroleumproducts. Companies shouldprepare to monitor and respondto potential national measures. These may includecompulsory stock release obligations, export restrictionsor measures prioritizing domestic supply. Each of thesescenarios may have significant legal and contractualimplications, particularly for companies relying on cross-border arrangements or third-party storage. As a result,companies operating in the oil and refinedproducts markets should anticipate increasedregulatory scrutiny, particularly in relation tocompliance with stockholding obligations and theeffectiveness of their underlying arrangements. Legal Framework: EU Obligations on OilStockholding National authorities are expected to intensifyoversightactivities. Increased audit activity and stricter enforcementof compliance requirements are likely to be in the near term. The relevant core obligation is established under Article3(1) of the Oil Stocks Directive. Member States mustmaintain minimum stocksequivalent to at least 90 days ofaverage daily net imports, or 61 days of average daily inlandconsumption, whichever is greater. How We Can Support In this environment, companies benefit fromtargeted legaland regulatory supportdesigned to ensure complianceunder conditions of heightened scrutiny. This includescomprehensive assessments of stockholding obligationsacross relevant jurisdictions and detailed analysis ofcompliance methodologies under national law. This obligation is formally imposed on Member States.In practice, however, it is typically implementedthroughnational legislationthat places correspondingobligationson economic operators, including refiners, importersand traders. Support may also includeregulatory stress testingtoassess exposure under potential emergency measures,as well as assistance inaudits, investigations andenforcement proceedings. Strategic advice on thestructuring of stockholding arrangements can help companiesbalance compliance obligations with cost considerations andoperational flexibility. The directive allows significant flexibility in implementation.As a result,differences exist between jurisdictionsinthe identification of concerned entities, themethodologiesused to calculate stockholding requirements, theproductscoveredand the applicablereference periods. Divergences We have experience advising companies on obligationsarising from the implementation of Directive 2009/119/ECat the national level across several jurisdictions, includingin cross-border contexts. This allows us to deliver practicaland commercially focused advice tailored to the regulatoryframeworks applicable to each client. Contacts Thomas DelilleEU Public Policy LeadPartner, Brussels/ ParisT +32 2 627 1104E thomas.delille@squirepb.com In the current climate of geopolitical uncertainty, the abilityto combine legal expertise with str