The Withdrawal of a European State from the ECT in Light of the Achmea Case - European Investment Law and Arbitration Review View The Withdrawal of a European State from the ECT in Light of the Achmea Case by - European Investment Law and Arbitration Review The Withdrawal of a European State from the ECT in Light of the Achmea Case 3 1

This essay explores the possibility that a claim may be brought against the EU under the Energy Charter Treaty (ECT) for a breach by an EU Member State. The extent to which the EU might be held responsible is relevant in situations where the Member State is no longer a party to the ECT, such as Italy. This essay takes into account the impact of the Achmea judgment on Article 26 ECT and analyses whether an intra- EU dispute (i.e. against the EU) might still be brought under the ECT. Moreover, it attempts to address the issue of which parties can bring this claim and discusses how to allocate and attribute responsibility to the EU in case of a breach of the ECT by a Member State. Further, it considers the hypothetical case where a national court does not enforce an ECT award on the basis of the Achmea judgment. This author concludes that foreign investors in Italy, including ones from EU Member States, may bring a claim against the EU under the ECT when the breach is due to the implementation of EU binding decisions by EU Member States. Finally, the essay briefly deals with the jurisdictional immunity of the EU.

European Investment Law and Arbitration Review