What is the ruling on reciting the Qur'an outside of prayer without seeking refuge (from Satan)?

Scholars have unanimously agreed that the isti'adhah (seeking refuge with Allah) is not part of the Qur'an, but it is required for its recitation. The majority of jurists hold that it is a sunnah (recommended act), while 'Ata' and Al-Thawri held that it is obligatory, based on the apparent meaning of the verse: "So when you recite the Qur'an, seek refuge with Allah" (Qur'an 16:98). The majority argued that the command indicates recommendation, and it is diverted from obligation by the consensus of the predecessors on its being a sunnah.

As for prayer, some scholars held it to be obligatory, while most held it to be mustahabb (recommended). Therefore, seeking refuge (al-isti'adhah) before reciting the Qur'an is an emphasized sunnah and not obligatory according to the majority of scholars. So, whoever does not seek refuge incurs no sin, but he has abandoned what is better.