Council opens annual review of Tunisia sanctions list until 4 November

The Council of the European Union has received information from the Tunisian authorities that will be examined in the annual review of its sanctions listings against persons, entities and bodies linked to the situation in Tunisia. Listed parties have until 4 November 2026 to ask the Council for the information held about them or to submit observations. The notice was published in the Official Journal of the European Union of 28 October 2026 under reference C/2026/5668.

Two instruments, one review

The listing regime rests on two 2011 instruments adopted in view of the situation in Tunisia: Council Decision 2011/72/CFSP, published in the Official Journal on 2 February 2011 (OJ L 28, p. 62), and Council Regulation (EU) No 101/2011, published on 5 February 2011 (OJ L 31, p. 1). The names concerned appear in the Annex to the Decision and in Annex I to the Regulation.

The notice is addressed to everyone on those two lists, without exception: it covers “all persons listed in the Annex to Decision 2011/72/CFSP and in Annex I to Regulation (EU) No 101/2011”. The Council states that the information received from the Tunisian authorities will be considered within the framework of the annual review of the restrictive measures.

The review is governed by the review clauses of the two instruments themselves — Article 5 of Decision 2011/72/CFSP and Article 12(4) of Regulation (EU) No 101/2011 — which require the Council to keep the measures under periodic examination.

What listed parties can do before 4 November

• Request from the Council the information that relates to them, if they want access to their file.
• Submit observations to the Council, which “will be taken into account for the purpose of the Council’s periodic review”.
• Send either to the General Secretariat of the Council, unit RELEX.1, Rue de la Loi/Wetstraat 175, 1048 Bruxelles/Brussel, Belgique/België, or by email to sanctions@consilium.europa.eu.
• Do so before 4 November 2026, the cut-off set in the notice.

Both channels run through the same unit and the same address, and the deadline is the same for the request for information and for any observations filed. The notice does not state a separate date for a decision at the end of the review.

A short window, published in the C series

The notice appeared in the C series of the Official Journal on 28 October 2026, leaving seven days between publication and the 4 November cut-off. It is a procedural notice rather than a decision: it does not add or remove names, and it does not amend the annexes.

Its legal weight is nonetheless practical. The Council ties the observations it receives directly to the periodic review, so submissions arriving after the cut-off fall outside the terms published in C/2026/5668. The text also confirms that the file behind the listings is being refreshed with material supplied by the Tunisian authorities, which is the input the review will weigh.

Why it matters

Anyone still on the two lists has one week to see the material held against them and to contest it, and the notice sets the only procedural channel and deadline for doing so in this review cycle. For operators watching EU autonomous sanctions, the publication is the marker that the Tunisian file is live again: the outcome of the review will determine whether the entries in the Annex to Decision 2011/72/CFSP and Annex I to Regulation (EU) No 101/2011 are maintained, amended or dropped.

Source: Official Journal of the European Union, C 2026/5668, 28 October 2026, Section I, p. 1 (official reference: C/2026/5668).