📍 Baltic States — EU Infringement Snapshot (Nov 2025)

The European Commission has released its latest infringement package — a routine check on whether Member States have fully updated their national laws in line with recent EU rules.

This month, all three Baltic countries appear in the list, mostly for delayed or incomplete transposition.

🇱🇻 LATVIA

• Energy Efficiency Directive (EED 2023/1791) – full transposition not notified, incl. public-sector reduction and data-centre reporting.

• Renewable Energy – Annex IX update – updated feedstock list not transposed.

• Firearms Directive (EU 2021/555) – incorrect transposition of civilian-firearms rules.

• Critical Entities Resilience (CER 2022/2557) – only partial transposition.

→ Status: reasoned opinion (one step before Court referral).

🇱🇹 LITHUANIA

• Energy Efficiency Directive (EED) – full transposition not notified.

• Renewable Energy – Annex IX – national law not aligned.

• MiFID amendment (2024/790) – missing implementation of consolidated-tape rules.

• NEC Directive (2016/2284) – persistent non-compliance with NOx and NMVOC limits.

→ Status: referred to the Court of Justice.

🇪🇪 ESTONIA

• Energy Efficiency Directive (EED) – incomplete transposition.

• Renewable Energy – Annex IX – updated feedstock list not reflected.

• MiFID amendment (2024/790) – missing national implementation.

• Cyberattacks Directive (2013/40/EU) – incorrect transposition.

→ Status: reasoned opinion.

• EPBD (2024/1275) – failure to phase out incentives for fossil-fuel boilers by 1 Jan 2025.

For Latvia and Estonia, the Commission is requesting technical completion of updated EU rules and both remain at early procedural stages.

Lithuania faces a more serious escalation, with one case already before the Court over air-pollution non-compliance.

The main impact for 2025–2026 will come from implementing the new requirements, not from the letters themselves.

Image: photos/photo_73@26-11-2025_13-18-35.jpg