For years, Brussels viewed the blocking of EU policy on Russia as a Hungarian issue. Viktor Orban's administration often postponed sanctions and aid to Ukraine, including a suggested addition of Russian Orthodox Patriarch Kirill to the sanctions list.

Then Hungary shifted its stance and dropped its long-held block. Yet the obstruction did not disappear with the prior leadership; it simply relocated.

As EU leaders met in Brussels for their June summit, Bulgarian prime minister Rumen Radev announced Sofia would veto the EU's proposed 21st sanctions package against Russia.

His concerns spanned geopolitics and supply issues: including Patriarch Kirill on the EU's asset-freeze and travel-ban list, risks to Lukoil which runs Bulgaria's sole refinery, and possible interruptions to fertiliser deliveries and spare parts for the Sofia metro.

Each point merits review on its own terms. Yet the broader matter is structural: under the EU's unanimity rule, one capital can stall steps against Russian banks, export-control circumvention, the shadow fleet and third-country sanctions networks until its national concerns are met.

This extends past the individuals involved. The EU's challenge was never solely Orban. It is a system where unanimity can convert one national objection into a continental veto.

A safeguard turned inside-out

EU sanctions on third countries start with a common foreign and security policy decision under Article 29 TEU, which Article 31(1) requires to be adopted by unanimity. The economic steps that follow are then passed by qualified majority under Article 215 TFEU.

The first stage acts as the gate; without it, the second cannot proceed.

Unanimity is upheld as a shield for sovereignty. When used repeatedly as a blocking tool, it reverses the protection it was intended to offer: one government gains foreign-policy power over the remaining 26.

That is not consensus in any real sense. Consensus calls for persuasion and compromise. A veto turns a narrow national objection into leverage over an entire package.

Bulgaria's concerns are not all without merit.

Steps that affect its only refinery or key infrastructure warrant careful economic review. The listing of any individual, cleric or otherwise, must rest on adequate evidence, meet proportionality standards, and survive review before the EU courts, which have overturned listings in the past.

Those standards support legal checks and targeted exemptions. They do not support holding unrelated measures hostage to one national objection.

Stop turning one objection into a veto on everything

The council's first step should be practical: where legally possible, separate personal listings from sectoral sanctions and country-specific exemptions.

If Sofia objects to the listing of Patriarch Kirill, that dispute should not automatically stall measures aimed at Russia's military-industrial base, shadow fleet or sanctions-evasion networks.

Omnibus packages let any capital convert its narrowest objection into leverage over the whole.

The second response already exists in the Treaties. Article 31(1) TEU permits a government to issue a formal declaration of constructive abstention. The abstaining state need not apply the CFSP decision, but it must accept that the decision binds the Union and avoid any action likely to conflict with or hinder its implementation.

The decision cannot pass only if the states making such declarations reach at least one third of the member states and represent at least one third of the Union's population.

The mechanism is uncommon, but it is not merely theoretical. Since Russia's full-scale invasion, it has been applied to Ukraine-related assistance measures under the European Peace Facility and for the creation of EUMAM Ukraine.

Constructive abstention is no complete fix. It is voluntary, and sanctions needing economic implementation under Article 215 TFEU must still apply uniformly across the Union.

Yet it remains an underused political exit route.

When a government objects to one measure without rejecting the Union's wider policy, standing aside should become the standard choice over blocking the other 26.

That would not end unanimity. It would clarify that obstruction is a political decision, not a Treaty obligation.

A veto without reasons is power without accountability

No capital should be able to block the other 26 without placing its case, and its evidence, on the record.

Until the voting rules shift, any government blocking a common foreign-policy decision should be required to issue a precise statement of reasons.

Not a press-conference reference to peace, sovereignty or the national interest, but a public document naming the measure it opposes, the concrete harm it foresees, the evidence supporting that claim and the narrower option it would accept.

A veto exercised behind closed Council doors can impose costs on the entire Union while remaining domestically convenient, and procedurally simple, for the government using it. A duty to give reasons would not end unanimity. It would require the blocker to own the objection, the evidence and the outcomes.

In the longer term, the European Council should activate Article 31(3) TEU - the treaty's built-in switch from unanimity to qualified-majority voting - for defined categories of non-military foreign-policy decisions, starting with restrictive measures.

The clause itself must be triggered unanimously, and it cannot cover decisions with military or defence implications: the Treaties' clearest catch-22. But a difficult reform is not a case for endless paralysis. The European Parliament has repeatedly supported wider use of qualified-majority voting for sanctions and greater reliance on constructive abstention.

When Hungary's new government indicated it was ready to drop Budapest's long-held objection to sanctioning Patriarch Kirill, Brussels seemed to face one fewer veto to handle.

Bulgaria's threatened blockade reveals how false that relief proved. The flaw was never limited to Orban. It is built into a rule that makes obstruction movable.

The veto shifted from Budapest to Sofia and it will shift again. Europe can continue swapping the actor, or finally alter the rule.