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The UK prohibits directly or indirectly providing specified construction services to a person connected with Russia. The ban took effect on 20 May 2026 and reaches UK people and UK-incorporated or UK-consolidated businesses wherever they operate, as well as people and businesses in the UK and its territorial sea. The government published dedicated compliance guidance on 27 October 2026. This guide explains what work and recipients are covered, which exceptions may apply, and when providers should consider a licence from the Office of Trade Sanctions Implementation (OTSI).
What does the UK construction-services sanctions rule prohibit?
Regulation 54C of the Russia (Sanctions) (EU Exit) Regulations 2019 prohibits directly or indirectly providing the specified construction services to a person connected with Russia. Construction services were added to the prohibition with effect from 20 May 2026. The statutory text and the DBT and OTSI compliance guidance set out the rule and practical guidance for providers.
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This is an activity-based restriction, not a ban that applies only to businesses identifying as construction firms. A contractor, specialist subcontractor, equipment provider, or another service provider may need to assess the rule if the work falls within the covered categories and the recipient is connected with Russia. Equally, a project is not automatically prohibited just because it has some Russian link: the service, provider, recipient, and any applicable exception or licence must be assessed.
Who is covered by the rule?
The prohibition has both a personal and a territorial reach. It applies to UK people and UK-incorporated or UK-consolidated businesses wherever they are in the world, and to people and businesses operating in the UK or its territorial sea.
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The recipient test matters as much as the provider test. A person connected with Russia includes an individual ordinarily resident or located in Russia, and a non-individual entity incorporated or constituted under Russian law or domiciled in Russia. Assess the actual recipient of the service, not merely the party named on an invoice or contract. The guidance also advises considering indirect recipients, beneficiaries, and entity structures, including where services are routed through another business or a third country.
What counts as construction services?
The covered categories extend well beyond erecting a building. The relevant list is in Schedule 3J, paragraph 6A, of the regulations; it includes work before construction begins, building and civil engineering, installation, finishing, specialist trades, and rental of construction or demolition equipment with an operator.
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|---|---|
| Pre-erection site work | Excavation and other site preparation |
| Building and civil engineering | Buildings, roads, bridges, and pipelines |
| Prefabricated structures and specialist trades | Work on prefabricated structures, scaffolding, roofing, concrete, and carpentry |
| Installation | HVAC, plumbing, electrical systems, and glazing |
| Building completion and finishing | Painting, tiling, and related finishing work |
| Equipment rental with an operator | Rental of construction or demolition equipment when supplied with an operator |
These examples are illustrative, not a substitute for checking the statutory category. Evaluate what the service actually does and whether it falls within paragraph 6A. Work described as maintenance, technical support, or project assistance may still need careful review against the definitions and the separate restrictions on architectural and engineering services.
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Can a UK contractor finish a contract signed before the ban?
Only a narrow, time-limited transition applied to certain pre-existing contractual obligations. To qualify, the obligation had to arise under a contract concluded before 20 May 2026, or a necessary ancillary contract, and the work had to be completed before the end of 20 August 2026. The provider also had to notify OTSI by that date.
That transition deadline has passed. A contract signed before the prohibition is therefore not, by itself, a current basis for continuing prohibited services. Providers dealing with work that continued beyond the deadline should not assume the old contract protects it; they should assess whether another exception applies or whether an OTSI licence is needed.
Can emergency work or essential repairs still be carried out?
Some work may fall within exceptions, but the conditions are specific and should be checked against the regulations and current government guidance. Emergency work may qualify where it is urgently needed to prevent or mitigate an event likely to have a serious and significant impact on human health or safety, infrastructure, or the environment.
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An essential-maintenance exception may cover work necessary to keep buildings, infrastructure, and other constructions maintained and safe. The guidance includes structural-integrity work, plumbing and sanitation, electrical or energy systems, and repairs addressing damage caused by age or faults.
For emergency and essential-maintenance exceptions, the guidance requires providers to justify the work to OTSI within five working days of starting it. Do not treat that notification requirement as a general permission to perform otherwise prohibited work: first establish that the facts satisfy the relevant exception, keep a clear record of the necessity and scope, and meet the applicable deadline.
Other exceptions include activity necessary for official diplomatic or qualifying international-organisation purposes and services relating to UK statutory or regulatory obligations. The government’s exceptions guidance is a starting point; the exact legal conditions control.
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When should a provider seek an OTSI licence?
OTSI is the licensing authority for these trade sanctions. The government states that “Licences allow prohibited activity to be carried out lawfully.” A licence is different from an exception: an exception may place qualifying activity outside the prohibition under its terms, while a licence is an authorization for specified prohibited activity. The guidance says a licence is issued when the permitted activity is consistent with the purposes of the relevant sanctions regime and other obligations.
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Random freezes, missing sound and display glitches usually trace back to one bad driver. Find and replace yours safely.Free scan · under a minuteIf a service appears prohibited and no exception clearly covers it, do not proceed on the assumption that a licence will be granted. Review the relevant conditions and application route with OTSI, and obtain independent legal advice where the application of the prohibition or an exception is uncertain. A licence must cover the activity and circumstances at issue; it should not be treated as a general approval for a client or project.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How should construction businesses assess a project?
A practical review should follow the service and its beneficiaries through the project, rather than relying on an industry label or the immediate contracting party alone.
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- Check the provider connection. Establish whether the provider is a UK person, a UK-incorporated or UK-consolidated business, or is operating in the UK or its territorial sea.
- Define the work precisely. Map the actual tasks to the categories in Schedule 3J paragraph 6A. Check adjacent architectural or engineering work separately under the relevant restrictions.
- Identify recipients and beneficiaries. Determine who receives or benefits from the service directly and indirectly. Review relevant ownership, group, subcontracting, and third-country arrangements.
- Apply the Russia connection test. For individuals, consider ordinary residence or location in Russia; for entities, consider incorporation or constitution under Russian law and domicile there.
- Check each possible exception carefully. Confirm that the facts satisfy every condition, including any urgency or safety requirement and any required notification. The pre-existing-contract transition ended on 20 August 2026.
- Consider licensing before work starts. If the service is prohibited and no exception applies, consult OTSI’s licensing guidance and obtain advice before providing it.
- Document the assessment. Keep the service description, recipient analysis, supporting evidence, exception or licence basis, and relevant communications together so the decision can be reviewed.
The ban complements existing restrictions on architectural and engineering services, which may apply to other parts of the same project under separate definitions. A project-level review should therefore consider each service being supplied, not just the construction package as a whole. The government guidance on professional and business services also highlights that group structures and third-country arrangements can matter.
What should providers remember?
- The construction-services prohibition took effect on 20 May 2026.
- It covers specified construction activity supplied directly or indirectly to a person connected with Russia.
- The test turns on the provider’s UK connection, the actual service, and the recipient’s status and Russia connection—not the provider’s industry label alone.
- The pre-existing-contract transition ended on 20 August 2026, while emergency and essential-maintenance exceptions carry a five-working-day justification requirement.
- OTSI handles licences; an exception and a licence are distinct routes, each subject to its own conditions.
This is a general compliance explanation, not advice on a particular contract or project. The law and guidance described here are stated as checked on 13 November 2026. Consult the current regulations and official guidance, and seek independent legal advice when the application is uncertain.
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Do these construction sanctions apply to a UK contractor working outside the UK?
Yes, the rule can apply because UK people and UK-incorporated or UK-consolidated businesses are covered wherever they operate. The recipient and the precise service still need to meet the relevant tests.
Does any Russian shareholder make a construction client a person connected with Russia?
The stated definition focuses on an individual’s ordinary residence or location, and an entity’s Russian-law incorporation or constitution or domicile in Russia. Ownership or control questions may require additional sanctions analysis, so do not infer the answer from a shareholder’s nationality alone.
Do architectural or engineering services fall under the construction-services ban?
They are subject to separate existing restrictions and may affect the same project. Assess the actual service under the relevant definition rather than assuming it is covered—or exempt—because it accompanies construction work.
Where can I check the exact list of covered services?
Read Schedule 3J paragraph 6A in the Russia sanctions regulations alongside the DBT and OTSI construction-services guidance. The guidance gives examples, but the statutory wording determines the scope.
