NLconnect reference list of sanctioned media domains

Background and context

Since March 2022, the European Union has imposed a ban on the transmission of various Russian media entities. This measure is part of the EU’s sanctions package against Russia following the invasion of Ukraine. The ban covers not only television broadcasting but also the online distribution of content from media channels that, according to the EU, contribute to Russian war propaganda. Internet Access providers (ISPs) are required to hinder the online distribution of such content through DNS blocking.

NLconnect is the trade association of the Dutch telecoms, broadband and fiber industry. Members include telecoms contractors, equipment vendors, mobile and fixed operators and ISP’s. We are not in favor of such DNS blocking measures: we support a free and open internet, and DNS blocking is not a very effective tool. Moreover, DNS is a fundamental internet protocol, and interfering with it could undermine trust in the proper functioning of the internet itself. We therefore supported our members Freedom Internet and A2B Internet, who—together with others in the Freedom of Internet Coalition—brought a case before the Court of Justice of the European Union against this measure.

Challenges in implementation

At the same time, NLconnect immediately urged its ISP members to comply with the European obligations. This turned out to be challenging, as the regulation neglects to clarify which specific domain names are associated with the sanctioned media entities. Internet access providers are not equipped to identify domain names associated with media entities that governments wish to block. Nor should they be expected to take on responsibilities that go beyond their role of providing neutral and reliable internet access. Clear and authoritative guidance from governments or regulators is therefore essential to ensure consistent and lawful implementation of the sanctions. Such guidance was initially provided by the Dutch regulator ACM, which published a limited list of five domains that could be blocked without breaching EU net neutrality rules.

Lack of updated guidance in the Netherlands

Following this, Dutch ISPs — members of NLconnect — started implementing the sanctions in practice. In the period that followed, the European Commission issued six additional “waves” of sanctions, adding new media entities to be blocked. Unfortunately, the ACM did not provide further guidance. As a result, Dutch providers individually expanded their blocking lists based on their best interpretation of the EU measures.

NLconnect’s request to the Dutch government

In the summer of 2025, enforcement of the sanctions in the Netherlands came under public scrutiny. NLconnect, on behalf of the sector, contacted the Ministries of Economic Affairs and of Foreign Affairs, requesting the publication of an updated national blocking list. The minister of Foreign Affairs acknowledged that it is unclear which websites are actually subject to the sanctions and that implementation across the EU is inconsistent. The Netherlands therefore called on the European Commission to provide more clarity through a central EU-wide list. Such a list has not yet materialized.

Because Dutch ISPs, who had also been approached by the Public Prosecutor regarding compliance, still lacked clear guidance, NLconnect took two steps. First, members were advised to use the list of the German regulator BNetzA as a reference for DNS blocking, as the German authority has maintained its list properly. Second, NLconnect sent a formal letter on 25 September 2025 to the Ministers of Foreign Affairs and Economic Affairs, requesting that an adequate national list of domains be issued, or alternatively that the Dutch government instruct ISPs to follow an existing list from another member state, such as the one maintained by BNetzA.

Response from the Dutch government and guidance from the European Commission

In response, the Ministry of Foreign Affairs stated that no Dutch list would be provided and also gave no indication of which foreign list could be used as a reference. Instead, it referred to a 2023 publication by the European Commission. This guidance mentions several “national lists”, drafted by the regulators in Lithuania, Austria, and Estonia. Notably, the German BNetzA list is missing from this guidance, while it does include a Danish list compiled by our Danish sister telecoms industry association Teleindustrien. Apparently facing the same challenge, Teleindustrien created a consolidated list based on earlier lists from Danish authorities and the Danish regulator, supplemented with the Austrian and Finnish lists. The Finnish list was subsequently retrieved by NLconnect, as it was not included in the Commission’s guidance.

Because the European Commission refers to the Danish industry initiative,  NLconnect decided to carry out a similar exercise: compiling a comprehensive and consistent list of domains that must be blocked at DNS level, which its members can use to comply with the EU sanctions against Russian media entities.

NLconnect reference list of sanctioned media domains

In this document, the domain lists available to us from national regulators in EU member states — namely Germany (BNetzA), Austria (RTR), Estonia (TTJA), Finland (Traficom) and Lithuania (LRTK) — as well as the list published by the Danish trade association Teleindustrien, have been retrieved, analyzed, deduplicated and combined into one consolidated reference list (tab 2). Subdomains that appeared on some lists, but were already covered by wildcard entries on the same or other lists, have been removed.

The consolidated list contains 796 domains. NLconnect advises its members to use this list to ensure compliance with the EU sanctions. We have also shared the list with Dutch regulator ACM and the Public Prosecutor. We are publishing this list to be fully transparent about the advice we have provided to our members. Members may refer to this list to meet their own transparency obligations under Article 3 of the Open Internet Regulation.

If anyone identifies a potential false positive—i.e. a domain that, in their view, should not be included—they can report this via info[AT]nlconnect.org . NLconnect will assess such notifications and, where appropriate, raise them with the relevant regulator that included the domain on its list.

Governance of updates and discontinuation

NLconnect intends to update this list following each new EU sanctions wave issued by the European Commission, and after those measures have been incorporated by national regulators into their respective reference lists. In addition, NLconnect will review—at least once per year—whether national regulators have updated their lists and will update this reference list accordingly. Where a new sanctions wave has been adopted, NLconnect will proactively update this list as soon as the relevant changes are reflected in the regulators’ lists.

NLconnect will discontinue this list and the related advice to members as soon as an adequate reference list is published by the European Commission or BEREC, or when the sanctions have been lifted. We sincerely hope that the sanctions can be lifted soon, and above all, that the war itself will come to an end as quickly as possible

Content of the spreadsheet

• Tab 2 contains the NLconnect reference list of sanctioned media domains;
• Tab 3 provides an overview of the sanction waves under the EU regulation and the corresponding media entities;
• Tab 4 lists the sources, background information and remarks related to the country lists; 
• Tab 5 contains the deduplicated combined list, in which subdomains that are already covered by wildcard entries are still included;
• Tab 6 shows the content of the individual country lists before deduplication.