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1 November 2022

European Union Energy Market Interventions

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Russia’s invasion of Ukraine and the ensuing conflict with the European Union have led to a collapse of EU imports of Russian fossil fuels and natural gas during late spring and summer 2022. This has in turn caused the price of natural gas to surge excessively and thus also the price of electricity across Europe, which has given rise to a significant energy crisis.

In response to this energy crisis, the EU recently adopted the temporary Emergency Intervention Regulation with a view to combating the high energy prices(1) (the “Regulation”). 

Below, the main features of the Regulation will be described, along with reflections on the importance of the Regulation for the purposes of M&A transactions involving in-scope en-ergy companies as well as how the Regulation could potentially trigger new investor-state arbitration disputes under the “foreign investor” avenue provided for by the Energy Charter Treaty (“ECT”)(2).

Pernille Nørkær


+45 30 37 96 40

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Thomas Mygind

Senior Associate

+45 30 37 96 58

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Henrik Ringgaard Diget


+45 30 37 96 81

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