THE SHELL LEAKS FILES — 27 OCTOBER 2026
SLF-2007-100
The Sakhalin Papers XC: Built but Not Approved — Germany’s November 2021 Decision and the Regulatory Battle Over Nord Stream 2
On 26 October 2021, Germany’s Federal Ministry for Economic Affairs concluded that certifying Nord Stream 2 would not endanger German or European gas supplies. Just three weeks later, Germany’s energy regulator suspended certification of the pipeline’s operator. The original government records reveal that these were not contradictory decisions: they concerned different legal requirements. Meanwhile, Polish and Ukrainian energy companies had been admitted to the proceedings, raising objections to Gazprom’s control of the project. The documentary trail shows how a completed pipeline, backed by almost €9.5 billion in planned investment, remained unable to begin commercial operations — and how Shell’s substantial financing ultimately became a $1.126 billion write-down.
Archive reference: SLF-2007-100
Publication date: 27 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-099, The Sakhalin Papers LXXXIX, 26 October 2026
Principal sources: German Federal Network Agency certification proceedings, Case BK7-21-056; German Federal Ministry for Economic Affairs security-of-supply assessment dated 26 October 2021; original German regulatory announcement of 16 November 2021; Polish PGNiG and Ukrainian Naftogaz corporate statements; contemporaneous Reuters reporting; German Energy Industry Act; Düsseldorf Higher Regional Court proceedings; European General Court judgment of 27 November 2024; and Shell’s authenticated financial disclosures filed with the US Securities and Exchange Commission. read more
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