SCEEUS Commentary No. 17
Executive summary
- Russia uses the prospect of peace negotiations as a tool to subvert the threat of sanctions;
- With the 28-point plan, Russia has been able to set the parameters for further negotiations;
- Several provisions of the 28-point plan, but also the modified 19-point plan, either contradict international law and/or undermine Ukraine’s political/territorial sovereignty;
- A negotiated settlement contradicting international law carries severe risks for European security.
The 28-point plan regarding a negotiated settlement of the Russo-Ukrainian war and a broader deal on European security and Russia’s international standing, leaked to the media on 21 November 2025, is a document put together by the U.S. and Russia. On 24 November, it was reported that a 19-point plan, put together by Ukraine, European allies and the U.S., had been presented as a counter-offer. Although the details of the latter document are currently not fully known, certain implications of the 28-point plan can already be mentioned.
Political risks
Two major risks with the 28-point plan can be highlighted.
Firstly, the plan has set the parameters for further negotiations. As such, the plan represents a Russian diplomatic success. For example, the plan envisages Russian encroachment on Ukrainian territorial and political sovereignty, and places limitations on NATO, G7 and Ukrainian allies in Europe. The 19-point plan has only modified, and not removed completely, these contentious issues from the agenda.
Secondly, several provisions in the 28-point plan contradict core principles of international law – including core tenets of the U.N. Charter, the OSCE Helsinki Act (1975) and the Charter of Paris for a New Europe (1990). The plan’s core provision that ‘Ukraine will receive reliable security guarantees’ (point 5) is also contradictory, as it is followed by a prohibition of any stationing of allied forces on Ukrainian territory (point 8) – in effect making any security guarantees contingent on a Russian veto.
Negotiations as a tool of derailment
Throughout 2025, the Kremlin has used the prospect of peace negotiations as a tool to subvert the threat of new sanctions, or otherwise hinder a development considered contrary to Russian interests. Three instances can be mentioned.
In August, Trump threatened ‘severe consequences’ for Russia if the Kremlin refuses negotiations. A new and major sanctions package, the so called ‘Sanctioning Russia Act of 2025’, had already been passed by the U.S. Senate. However, Putin responded by suggesting a Trump-Putin summit in Alaska, promising the possibility for a negotiated settlement to the war. When the meeting came to a naught, Trump failed to follow through on his threat of sanctions.
In October 2025, it was reported that U.S. government officials were in talks regarding the possible deliveries of Tomahawk cruise-missiles to Ukraine. Unsurprisingly, Putin told Trump that such a move would damage ‘the peace process and damage U.S.-Russia ties’, suggesting instead a top-level meeting in Budapest. Although the meeting never took place, the plan to deliver Tomahawks was also scuttered.
In the context of the 28-point plan, it should be noted that the full enforcement of the U.S. Treasury Department’s sanctions against Rosneft and Lukoil took place on 21 November 2025 – the same day that the plan was leaked to the media. Once more the Kremlin is using the prospects of negotiations to influence U.S. policy in a direction more favorable to Russian interests.
Conclusions and policy recommendations
The 28-point plan appeared at a time characterized by political uncertainty. Russia and Ukraine fight a war of attrition. Both countries struggle with manpower, materiel, and finances. Domestic turbulence has weakened the political standing of Volodymyr Zelensky, the President of Ukraine. Meanwhile, Russia has implemented more coercive measures on the domestic front, for purposes of mobilization to the armed forces, while systematically destroying Ukrainian energy infrastructure.
Unsurprisingly, the Kremlin has reinforced its opinion that any further negotiations should begin with the 28-point plan. Therefore, per their political reasoning, any failure to find a negotiated settlement to the war will be the fault of others – Ukraine, Europe, and perhaps the U.S.
The fact that the U.S. presidential administration was willing to admit co-authorship of the 28-point plan is indicative of the current state of U.S. diplomacy and commitments to European security. With the emergence of the alternative 19-point plan, the U.S. has in effect sponsored two separate documents.
It is imperative that European states, and the EU, take a more pro-active role in the negotiation process, involving also Ukraine at all stages. A negotiated settlement contradicting international law and norms will undermine European security and make Russia more – not less – likely to renew its military aggression also in the future.
To be credible, security guarantees for Ukraine need to involve the possibility of allied troops on Ukrainian territory.




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