Part I — Situation overview

On 16 September 2026 the United States House of Representatives passed, by 262 to 159, the sanctions law against Russia sponsored by Republican Senator Lindsey Graham, who died unexpectedly in July, and Democratic Senator Richard Blumenthal, which the Senate had already passed in August. According to Politico, the law is the first significant pro-Ukraine congressional legislation after a pause of nearly two years, and the President’s signature is almost certain. The text prescribes mandatory sanctions on the Russian leadership and energy sector, as well as on the shadow fleet, that is, tankers of opaque ownership used to circumvent sanctions. It also authorises the President to impose tariffs of up to one hundred per cent on the largest buyers of Russian energy. According to Democratic leader Hakeem Jeffries, the law does not oblige the President to impose sanctions, and it contains so many loopholes that enforcement is uncertain. On the same day Ursula von der Leyen, President of the European Commission, said in her annual address (the State of the Union, SOTEU) that increasing pressure on Russia does not always require new sanctions, but above all the enforcement of existing ones.

The Hungarian dimension was drawn by an analysis published a day earlier by Balkan Insight, the regional portal of the Balkan Investigative Reporting Network (BIRN). According to the outlet, Hungary buys around five million tonnes of Russian crude oil a year and is typically counted as the fifth-largest market for Russian oil. According to Reuters data, MOL brought 9.7 million tonnes from Russia into its Hungarian and Slovak refineries in 2025; through the pipeline of Croatia’s state-owned JANAF (Jadranski naftovod, the operator of the Adria oil pipeline) the annual average between 2022 and 2025 was 1.3 million tonnes, and 1.5 million tonnes in 2026. The two sides’ claims diverge sharply here: according to JANAF, it can serve the full annual demand of MOL’s Hungarian and Slovak refineries. According to MOL, however, the short capacity tests did not yield a clear result, and before a switch the entire supply chain would have to be tested at full refinery load, under different weather conditions and with several types of crude. The dispute is burdened by issues that have nothing to do with security of supply: the ownership and management dispute surrounding MOL and INA, the Croatian national oil company; the Croatian arrest warrant issued against MOL’s Chairman-CEO Zsolt Hernádi, extended until 2031; and the level of transit fees. MIAK has previously proposed a public exposure balance sheet for the tariff threat, capacity-expansion negotiations on the Adria pipeline and a public justification for every sanctions exemption; all of these assume that the performance of the replacement route is known — and that is exactly what is missing.

MIAK’s reading: in Hungary the debate on Russian oil is no longer about whether to decouple, but about the actual performance of the replacement route and who bears the cost of the switch. The first question is a matter of measurement, the second a matter of accounting — and neither can be decided fairly in a package deal in which a criminal case, a corporate ownership dispute and a fee negotiation become hostages to one another.

Part II — Foundations in the literature

Three sources provide the framework. Henry Kissinger, former US Secretary of State and National Security Advisor, describes in his memoir Years of Upheaval (1982) how, during the 1973–74 oil crisis, the solitary separate deals of consumer countries proved self-defeating. Cooperation got under way where no confrontation was needed: in stock-sharing, conservation and the development of new sources. The World Economic Outlook 2025 report of the IMF, the International Monetary Fund, states that resilience-enhancing policies may come with efficiency losses and higher consumer prices during the transition, and that ad hoc bilateral deals do not meaningfully reduce uncertainty. Elinor Ostrom, the American political scientist awarded the 2009 Nobel Memorial Prize in Economic Sciences for her research on the governance of common resources, shows in Governing the Commons (1990) that lasting cooperation requires verifiable performance and a quickly accessible, low-cost dispute-resolution forum. Without these, no credible commitment can be made either. The detailed treatment of the literature — by author, with quotations — is in section 6.4 Literature in detail.

Part III — MIAK’s concrete proposal

MIAK proposes three measurable measures. The first closes the capacity dispute with facts, the second decouples security of supply from the disputed bilateral issues, and the third makes the cost of the switch visible.

3.1 A full-capacity test on the Adria route under independent supervision (test protocol by 31 December 2026, public result by 30 June 2027)

MIAK proposes that the Government, together with the Croatian government, initiate a full-capacity test between the JANAF pipeline and MOL’s Hungarian and Slovak refineries. The test protocol — load level, duration, crude types, winter and summer operating conditions, measurement points — should be agreed in advance and in writing by the two operators, and the measurement should be supervised by an independent technical expert accepted by both sides. The summary of the result should be public: what sustained transport capacity was measured, where the bottlenecks were, and what investment would be needed to make up any shortfall. The proposal does not bring MOL’s business decisions under government competence: MOL is a privately owned listed company in which, according to BIRN, the state once again holds a stake above 15 per cent following the abolition of the public-interest asset management foundations. The state body exercising ownership rights can thus also initiate the publication of the test result at the general meeting. The test provides the data basis for K7 energy-market shock resilience and the G25 energy price shock preparedness plan: an emergency scenario that assumes the shutdown of the Druzhba (Friendship) oil pipeline cannot be planned without known replacement capacity. According to Kissinger’s experience (see 6.4.1), the compulsion for separate deals is dissolved by the publicity of the facts: where it has been shown that the situation is manageable, there is no need to race for concessions.

3.2 Decoupling the crude-oil security-of-supply agreement from the disputed bilateral issues (framework agreement by 31 March 2027)

MIAK proposes that the Hungarian and Croatian governments conclude a crude-oil security-of-supply framework agreement that deals exclusively with supply: long-term capacity booking, priority transport in the event of a Druzhba outage, publicity of the method for calculating the transit fee, and an independent expert dispute-resolution procedure with a fixed deadline for fee and capacity disputes. The text of the agreement should also state what it does not regulate: the ownership and management dispute over INA remains on the corporate-law and existing arbitration track, and Zsolt Hernádi’s case is a judicial matter — any surrender or extradition is decided by a court under the rules in force, not by the Government, so it cannot be the subject of the energy negotiations. The draft international treaty should be put to a 30-day public consultation under the KP3 transparent foreign policy programme point. KP10 regional resilience-building asks for neighbourly relations to be bilateral and reciprocal: the Croatian side’s interest is long-term, predictable throughput, the Hungarian side’s is guaranteed capacity. According to Ostrom’s research (see 6.4.3), cooperation survives in the long run where disputes have their own fast and low-cost forum — not where every dispute puts the whole relationship at risk.

3.3 A public statement of the Russian price differential and the cost of switching (at the same time as MOL’s 2026 annual report)

According to BIRN, the biggest and rarely stated cost of the switch is that MOL loses the profit derived from the difference between cheaper Russian crude and the world market price, on top of which comes the Croatian transit fee. MIAK proposes that the state body exercising ownership rights initiate at MOL’s general meeting the publication of a separate statement: how large the profit from the price advantage of Russian crude has been in recent years, and how large the estimated additional cost is when switching to seaborne crude (transit fee, refinery conversion, logistics). On its own side, the Government should publish, under the G19 radical transparency programme point, how much of the additional cost it considers justified to pass on in consumer prices, and whom the targeted compensation mechanism of G25 would cover. The aim is not for the switch to be free — according to the IMF’s analysis (see 6.4.2), more resilient supply comes with higher prices in the short term — but for the cost not to appear hidden in the transit fee dispute or in fuel prices. If the cost is known, it will also be clear in the Croatian negotiations what fee is acceptable, and how much of the cost depends not on the Croatian side but on the loss of the earlier price advantage.

The three proposals are bound together by a single principle: decoupling from Russian oil is a political decision, but its conditions — capacity and cost — are measurable. What can be measured must not be treated as a bargaining chip.

Part IV — Expected effects and risks

Dimension Expected effect Risk
Security of supply Known, proven replacement capacity; the emergency scenario for a Druzhba outage is based on real figures The full-capacity test may temporarily disrupt refinery operations; if the test reveals a shortfall, expansion may take years
Economy and consumer prices Publicity of the switching cost reduces the mistrust inherent in the fee dispute, and can make compensation targeted The statement brings the earlier price advantage to the surface, which may create political pressure on MOL; the boundary of business secrecy must be fixed in advance
Foreign policy and neighbourly relations The decoupled energy track reduces mutual susceptibility to blackmail, and is a credible signal towards the EU phase-out timetable The Croatian side may regard the decoupling as an offer without concessions, and the negotiations may drag on; Moscow may respond to an accelerating switch with retaliation

The main question to weigh is the sequence. If a political agreement is reached before the test, the fee and the capacity will be shaped by negotiating positions, not by facts; if, however, the test takes too long, the tariff threat or a Russian supply stoppage may overtake it. MIAK therefore proposes a short deadline for the test protocol, and would launch negotiations on the framework agreement in parallel with the test, not after it. The proposal tips into risk if the selection of the independent supervisor itself becomes a subject of dispute — this is handled if the two sides choose from a joint list agreed in advance, and the methodology of the report is also public. The second risk is the credibility of the decoupling: if they negotiate on a separate track in public but still as a package behind the scenes, the agreement will fall apart at the next dispute. That is why the text of the treaty must state what is not its subject.

Part V — Measurability and summary

5.1 What is worth following? (suggested KPIs)

MIAK proposes four performance indicators (KPIs, in English: Key Performance Indicator) from which it will be visible in 6, 12 and 24 months whether the proposals have been implemented:

  • Publicity of the full-capacity test: the suggested target is that the test protocol agreed by the two operators be public by 31 December 2026, and the independent supervisor’s summary report on the measured sustained transport capacity by 30 June 2027.
  • Share of crude arriving via JANAF in MOL’s imports: it is worth following quarterly the change relative to the 1.5 million tonnes of 2026, compared with Russian imports; the suggested path should be aligned with the end-2027 target date for the EU phase-out of Russian crude imports.
  • Existence of the framework agreement and its dispute-resolution deadline: the suggested target is that an agreement signed by 31 March 2027 lay down the capacity booking, the public method of fee calculation and a dispute-resolution deadline of at most 90 days.
  • Statement of the switching cost: it is worth following whether MOL’s 2026 annual report or general meeting materials contain a separate statement of the profit derived from the Russian price differential and of the estimated cost of switching to seaborne crude.

5.2 Summary

MIAK’s request is that the Government handle the JANAF question not as a diplomatic package, but as three separate tasks: measure the capacity, conclude the supply agreement independently of the disputed issues, and make the cost of the switch public. The US law and the EU phase-out timetable together mean that the replacement route may be needed not in a distant future but in the coming months — this situation can be prepared for with facts, not with statements. In EU sanctions votes, MIAK considers the enforcement-centred direction the one to follow, without new requests for individual exemptions.

Two MIAK foundational values are at stake. Data-drivenness, because today there are two contradictory corporate claims about capacity, and neither can be verified — as long as this is the case, the decision rests not on fact but on trust or mistrust. Transparency, because the price advantage of Russian oil and the cost of the switch are two sides of the same balance sheet: if only one is visible, the debate is about fees and the neighbour’s intentions, not about what it really should be about — who pays, and how much.

Part VI — Reasoning and further sources

6.1 Press framing by spectrum

In the international press the topic appeared in three frames that barely touched one another. The US domestic-politics reading came from Politico: the outlet presented the law from the angle of the balance of power in Congress, highlighting that 58 Democratic representatives voted against their leader, and that the main objection of the Democratic opponents was not the anti-Russian sanctions but the additional tariff authority granted to the White House. Al Jazeera — building on material from the AP news agency — framed the news from the angle of the war in Ukraine, and named China and India as the targets of the tariff threat. Neither article dealt with what the law means for an EU member state whose trade policy is an exclusive EU competence.

The Hungarian dimension was covered only by Balkan Insight, from the angle of the Croatian–Hungarian relationship. The article was written after the Senate vote but before the decision of the House. Its merit is that it placed the claims of MOL and JANAF side by side, and it also quoted a Hungarian energy market expert, András György Deák, who called the situation after MOL’s possible NIS deal (acquiring a stake in the Serbian state oil company) an asymmetric mutual dependence — that is, a relationship in which both sides depend on the other, but not to the same degree. The article’s emphases are, however, asymmetric: the Croatian side got to speak at length and with strong characterisations through a former INA executive, while the Hungarian government and the Croatian economy ministry did not respond to the outlet’s request. The framing is thus more about accumulated grievances than about measurable questions.

The Brussels specialist portals concentrated on the EU sanctions strategy. Euractiv read von der Leyen’s enforcement-centred turn as a sign of tension within the Commission, because Kaja Kallas, the EU High Representative for Foreign Affairs, was at the same time proposing the broadest listing since the full-scale invasion, covering 1,600 persons and companies. EUobserver wrote about the European Parliament’s report on disinformation, and noted that sanctions are decided by the member states and that the Parliament has no legal competence in this; only the introduction of the article was publicly readable. A gap common to the whole spectrum is that none of the sources treated the disputed question of pipeline capacity as a measurement problem.

6.2 Facts and data

Datum Value Source
Date and margin of the House vote 16 September 2026, 262–159 Politico, Al Jazeera, 16–17 September 2026
Democrats voting yes against their leader 58 Politico, Al Jazeera
Upper limit of the tariff authority up to 100% on buyers of Russian energy Al Jazeera, 17 September 2026
Hungary’s annual purchases of Russian crude oil around 5 million tonnes Balkan Insight (BIRN), 16 September 2026
MOL’s Russian crude imports 9.7 million tonnes (2025), split almost equally between the Hungarian and Slovak refineries Reuters data as cited by Balkan Insight
MOL’s crude arriving via JANAF annual average of 1.3 million tonnes (2022–2025), 1.5 million tonnes (2026) MOL’s statement to Balkan Insight
MOL’s diversification investment programme USD 500 million, expected completion 2027 MOL’s statement to Balkan Insight
Most recent Druzhba pipeline outage January drone attack near Brody, a shutdown of nearly three months Balkan Insight, 16 September 2026
Croatian arrest warrant for Zsolt Hernádi extended until 2031 Balkan Insight, 16 September 2026
State stake in MOL after the abolition of the trustee foundations 15% Balkan Insight, 16 September 2026
MOL’s planned stake in NIS 56%, awaiting US approval Balkan Insight, 16 September 2026
EU phase-out target dates Russian pipeline gas: October 2027; Russian crude oil: end of 2027 European Commission target as summarised by Balkan Insight

Two data points require a separate note. First: there are no independent measurement data on JANAF’s capacity, only two opposing corporate claims — JANAF refers to earlier deliveries made during the Druzhba shutdown, MOL to the inconclusive results of the short tests. MIAK therefore does not adopt a capacity figure from either side, and this gap is the direct reason for proposal 3.1. Second: the claims about transit fees above market price appear in the outlet as a Hungarian accusation and a Croatian denial, without numerical fee data — publicity of the fee calculation (3.2) would settle this too.

6.3 Policy dimensions

  • Foreign policy (programme points) — the centre of gravity of the topic: KP10 (regional resilience-building) is the framework for a neighbourly agreement based on reciprocity, KP3 (transparent foreign policy) for the public consultation on the draft treaty, KP8 (economic diplomacy integration) for separating economic and political interest representation, and KP4 (principled pragmatism) for the enforcement-centred direction followed in EU sanctions votes;
  • Economy (programme points) — G25 (energy price shock preparedness plan) for the emergency scenario and targeted compensation, G19 (radical transparency in economic decision-making) for the public statement of the switching cost;
  • Environment and climate (programme points) — K7 (energy-market shock resilience) for replacement capacity as a condition of shock resilience, K2 (energy transition plan) for the long-term reduction of fossil import dependence.

6.4 Literature in detail

6.4.1 Henry Kissinger: Years of Upheaval

The chapters of Kissinger’s memoir on the 1973–74 oil crisis describe how the consumer countries tried to handle the Arab oil embargo. According to the author, several European governments — above all France — used the crisis to strike separate, bilateral deals with the producer countries, often exchanging oil for arms deliveries. Kissinger, by contrast, argued that solitary national efforts were self-defeating, because every separate deal strengthens the producer’s bargaining position. According to his internal memo, the task was to put the facts about the energy situation before the partners: if they saw that the situation was manageable, they would not need to run after separate deals. He sums up the lesson of the February 1974 Washington Energy Conference by saying that cooperation was easiest to achieve where no confrontation was needed — in conservation, emergency stock-sharing and the development of new sources. The International Energy Agency grew out of this. In the Croatian–Hungarian situation the thesis applies in two directions. On the one hand, it is worth starting with the non-conflictual, technical question — measuring capacity and emergency transport — rather than with the hardest disputes. On the other hand, the risk of a separate deal here lies not towards a producer country, but in the matter of supply becoming a bargaining chip for unrelated issues. The volume is a copyrighted source, so the above summary is entirely a paraphrase.

📖 Source: Henry Kissinger: Years of Upheaval

6.4.2 IMF: World Economic Outlook 2025

In its chapter on industrial policy, the International Monetary Fund’s 2025 report documents that between 2009 and 2022 a third of the industrial policy interventions introduced affected at least one energy-sector product, and around 80 per cent of these were adopted in energy-dependent countries, typically to reduce fossil import dependence. The report, however, also states the cost:

“Policies that enhance resilience—such as onshoring—may come at the cost of efficiency, including higher consumer prices during the transition.”

And in the section on trade risks it warns that reliance on ad hoc bilateral deals does not meaningfully reduce uncertainty:

“Reliance on ad hoc bilateral deals for trade negotiations, which erode previous agreements and whose details and longevity remain unclear, would not meaningfully reduce trade policy uncertainty.”

Together the two theses provide the logic of proposals 3.2 and 3.3. Decoupling from Russian oil makes supply more resilient, but also temporarily more expensive — this cost should not be made to disappear, but should be stated and consciously distributed. And long-term security of supply cannot rest on an agreement whose details and durability are unclear, because it becomes open to renegotiation at the next political dispute.

📖 Source: IMF: World Economic Outlook, October 2025 — Global Economy in Flux, Prospects Remain Dim

6.4.3 Elinor Ostrom: Governing the Commons

Ostrom studied the governance regimes of commonly used resources — irrigation systems, fisheries, pastures — that have functioned for centuries, and compiled the design principles that distinguish lasting cooperation from the kind that collapses. Two of her principles are directly applicable. One is monitoring: in her view participants can make credible commitments only if compliance with the rules is verifiable and those doing the monitoring are accountable to the participants. The other is dispute resolution: the application of rules is never unambiguous in practice, so in lasting systems participants have a forum accessible quickly and at low cost for deciding disputes — without it, the rules start to be seen as unfair, and compliance deteriorates. Ostrom wrote about common resources, and the JANAF pipeline is not common property; the relationship between the two countries, however, shows the same structure: parties dependent on each other in the long term, between whom the assessment of performance (capacity) and consideration (fee) is disputed. The independent test of proposal 3.1 transposes the principle of monitoring, and the deadline-bound expert dispute resolution of proposal 3.2 the principle of a dispute-resolution forum. The volume is a copyrighted source, so the above summary is entirely a paraphrase.

📖 Source: Elinor Ostrom: Governing the Commons — The Evolution of Institutions for Collective Action

6.5 International comparison

Two Central European examples offer lessons for dismantling dependence on Russian pipeline oil. The Czech Republic stopped importing Russian crude oil via the Druzhba pipeline in spring 2025, after the capacity expansion of the TAL oil pipeline starting from Trieste and the IKL pipeline connecting to it in Germany; the precondition of the switch was the previously built and proven capacity of the replacement route, not a political announcement. In Germany, the Schwedt refinery, previously supplied almost exclusively by the Druzhba pipeline, was placed under state trusteeship from 2022, and its supply was switched to seaborne deliveries via Rostock and Gdańsk. The experience is that the capacity of the replacement route and the refinery’s adaptation to crude types was a longer, multi-stage process than assumed at the time of the decision. Both cases show what Kissinger’s 1974 experience also showed: the success of decoupling is decided not by political intent but by the known-in-advance performance of the replacement infrastructure. In the international energy security system, the mandatory oil stockholding rule for International Energy Agency member states and the EU stockholding requirement rest on the same idea: an emergency reserve bridges a short period, but lasting supply comes only from measured replacement capacity secured by contract.

Foreign policy

  • KP3 — Transparent foreign policy
  • KP4 — Principled pragmatism doctrine
  • KP8 — Economic diplomacy integration
  • KP10 — Regional resilience-building

Economy

  • G19 — Radical transparency in economic decision-making
  • G25 — Energy price shock preparedness plan

Environment and climate

  • K2 — Energy transition plan
  • K7 — Energy-market shock resilience

Proposed new programme point: Independent performance verification of replacement energy infrastructure and security-of-supply agreements separated from disputed issues — for the Foreign policy area.

6.7 List of sources

Press sources (MIAK foreign press monitor, 17 September 2026 — topic 1):

Knowledge-base references (books):

  • 📖 Henry Kissinger: Years of Upheaval
  • 📖 IMF: World Economic Outlook, October 2025 — Global Economy in Flux, Prospects Remain Dim
  • 📖 Elinor Ostrom: Governing the Commons — The Evolution of Institutions for Collective Action

MIAK internal materials:

  • MIAK policy area: Foreign policy (programme points; programme point ID: KP3, KP4, KP8, KP10)
  • MIAK policy area: Foreign policy (background material)
  • MIAK policy area: Economy (programme points; programme point ID: G19, G25)
  • MIAK policy area: Environment and climate (programme points; programme point ID: K2, K7)
  • MIAK foreign press monitor, 17 September 2026 — topic 1, score: 89/100

Supplementary public data sources:

  • United States Congress — text of the Graham–Blumenthal Russia sanctions law (congress.gov)
  • MOL Group — annual and half-year reports
  • JANAF — transport statistics
  • Eurostat — crude oil imports by country (nrg_ti_oil)
  • Council of the European Union — list of restrictive measures against Russia

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