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United KingdomGOV.UK

UK bans construction services to Russia-connected persons

Construction services joined the regulation 54C ban on 20 May 2026; the 20 August contract wind-down has ended and notified essential maintenance is available.

By Taxxa AI OyPublished 27 October 2026

Financial Sector & Markets

Industry: Construction

UK sanctions now treat construction services as a prohibited professional and business service for Russia-connected clients. A person must not provide construction services, directly or indirectly, to a person connected with RussiaGOV under regulation 54C of the Russia (Sanctions) (EU Exit) Regulations 2019, as amended by the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026Legislation. The prohibition sits alongside the existing bans on accounting, advertising, architectural, auditing, business and management consulting, engineering, IT consultancy and design, and public relations services. A person connected with Russia is the defined term in regulation 21, and the covered services are defined in Schedule 3J.

The construction-services definition is broad. It uses the 1991 Central Product Classification and covers pre-erection work at construction sites such as site investigation, demolition, site formation and clearance, excavating and earthmoving, site preparation for mining and scaffolding; construction work for buildings across residential, warehouse, industrial, commercial, public entertainment, hotel, educational, health and other buildings; construction work for civil engineering including highways, streets, roads, railways, airfield runways, bridges, tunnels, subways, waterways, harbours, dams, pipelines, cables, mining and manufacturing constructions and sport and recreation constructions; assembly and erection of prefabricated constructions; special trade construction work including foundation work and pile driving, water well drilling, roofing and waterproofing, concrete work, steel bending and erection including welding, masonry work and other special trade work; installation work including heating, ventilation and air conditioning, water plumbing and drain laying, gas fitting, electrical work, insulation work, fencing and railing and other installation work; building completion and finishing work including glazing, plastering, painting, joinery, carpentry, interior fitting, decoration and ornamentation fitting; and renting of construction or demolition equipment with an operator.

The amending Regulations were made on 18 May 2026, laid before Parliament on 19 May 2026 and came into force on 20 May 2026Legislation. They extend to England and Wales, Scotland and Northern Ireland. The prohibitions in regulation 54C are subject to exceptions and licences.

Two construction-specific exceptions were written into regulation 60DA. Acts satisfying obligations under contracts concluded before 20 May 2026, or ancillary contracts necessary to satisfy such contracts, did not contravene the construction-services prohibitionLegislation where the act was carried out before the end of 20 August 2026Legislation and the person notified the Secretary of State of the provision of services by the end of 20 August 2026, whether before or after the actLegislation. That wind-down window has now passed, so work continuing after that date needs analysis under the remaining exceptions or licences rather than reliance on the transitional route.Legislation

One remaining exception is essential maintenance. The prohibition is not contravened by an act where the person provides justification to the Secretary of State, before the end of five working days beginning with the day the act beganLegislation, that the act is necessary for essential maintenance.Legislation Essential maintenance means construction services necessary to ensure buildings, infrastructure and other constructions are well-maintained and safe, including maintenance to ensure structural integrity, maintenance of plumbing, sanitation, electrical or energy systems, and repair of damage caused by age or faults.

Advisers should map which live engagements touch the listed construction codes, confirm the client's connection status under regulation 21, diary the five-working-day justification point for any essential-maintenance workLegislation, and keep the Secretary of State notification evidence with the engagement file.

Legal basis: regulation 54C and Schedule 3J paragraph 6A of the Russia (Sanctions) (EU Exit) Regulations 2019GOV, as amended by regulations 12 and 16 of the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (S.I. 2026/543).

Map live construction engagements for Russia-connected clients and diary the five-working-day essential-maintenance justification to the Secretary of State.

Sources