The new European Commission, which took office in December 2024, will likely rebalance its policy priorities, putting greater emphasis on competitiveness and innovation and less on risk-prevention and regulation. Over the past five years, the EU adopted several sweeping tech regulations, such as the Digital Services Act (DSA), the Digital Markets Act (DMA), and the AI Act. For the next five years, the focus is likely to be on implementing and streamlining these rules, rather than adopting new overarching tech regulatory frameworks. The Commission will also seek to facilitate greater public and private investment in technology, a sector in which the EU has lagged over the past 20 years, as noted by Mario Draghi in his report on Europe’s competitiveness.

Tech Policy Central to the EU

For the 2024-2029 term, Henna Virkkunen has been appointed as the Executive Vice-President (EVP) for Tech Sovereignty, Security and Democracy. Virkkunen’s portfolio places tech policy at the heart of the new Commission’s agenda, reflecting its strategic importance for EU competitiveness.

Virkkunen, a former Member of the European Parliament from Finland with a robust track record in tech policy, assumes leadership of the Directorate-General for Communications Networks, Content and Technology (DG CNECT). In contrast to the often-aggressive stance of her predecessor, Thierry Breton, towards industry leaders, Virkkunen is expected to be more collaborative. Virkkunen’s alignment with von der Leyen’s vision is anticipated to bring coherence to the Commission’s tech agenda. DG CNECT no longer reports to two Commissioners (Vestager and Breton in the last Commission), which will simplify its management. Placing it under EVP Virkkunen, who is relatively senior in the College of Commissioners, underscores that digital policy is a priority for this Commission.

Virkkunen will need to coordinate closely with other Commissioners, such as Stéphane Séjourné (EVP for Prosperity and Industrial Strategy), who will oversee the development of a European competitiveness fund to support emerging technologies. This initiative should align with Virkkunen’s efforts to strengthen EU capabilities in AI and semiconductors through Important Projects of Common European Interest. Virkkunen also effectively oversees four other Commissioners, including Ekaterina Zaharieva (Startups, Research and Innovation), who has been mandated to set up a European AI Research Council in order to bolster innovation, and Michael McGrath (Democracy, Justice, the Rule of Law and Consumer Protection), who will revise data retention rules to address potential privacy and security concerns.

Virkkunen’s Ambitious Policy Agenda

Henna Virkkunen’s mission is both expansive and strategically aligned with the EU’s overarching goals of digital sovereignty and competitiveness. She has three core priorities: artificial intelligence (AI), cloud computing, and quantum technologies.

AI is at the heart of Virkkunen’s mission, and the European Commission wants Europe to lead the world on AI. Through the AI Act (the first legislative instrument in the world to set rules on AI), it sought to ensure that AI remain human-centric and trustworthy. The Data Act and the Data Governance Act (among others) were developed to promote the creation of, and ensure access to, high-quality data, which the Commission views as being essential to building high-performance, robust AI systems. Now, the European Commission seeks to foster AI innovation through greater investment and funding, and to promote the adoption of AI by private and public sectors alike.

To promote AI development, the EVP has been tasked with spearheading the AI Factories Initiative. This Initiative aims to create “AI ecosystems” bringing together universities, industry and financial actors with supercomputing centres, thereby providing each with the ability to experiment on and leverage the benefits of artificial intelligence. In December 2024, the sites of the first seven AI Factories were confirmed, and the European Commission approved the creation of a EUR 1.5 billion fund for their development. Fifteen EU Member States will participate in these seven AI Factories.

To line up the Commission behind the roll-out of AI in Europe, Virkkunen is set to chair the Project Group on AI. Established on 7 January 2025 and comprising two other EVPs and five Commissioners, the Project Group will develop a strategy to drive AI adoption by industry, public services and society in Europe. It will oversee preparations for the EU’s Apply AI Strategy, the European AI Research Council, and the strategic roadmap for digitalisation and AI in the energy sector. Notably, President von der Leyen may attend and even chair the Project Group. It will also be staffed by the Secretariat-General, the DG that answers directly to the Commission President.

EVP Virkkunen also seeks to ensure that the EU has the physical infrastructure needed to pursue its ambition. She is set to modernize and strengthen Europe’s digital infrastructure. Virkkunen has mentioned two possible legislative endeavours. A Digital Networks Act would boost secure high-speed broadband (both fixed and wireless) throughout the European Union. The plan is to incentivise the development of integrated connectivity and computing infrastructures, reduce bureaucracy for network providers, and ensure high-speed connectivity for all. Meanwhile, a Cloud and AI Development Act would boost investment in cloud capacity for businesses.

Finally, Virkkunen is set to draft a long-term EU Quantum Plan, including a proposal for a Quantum Act to consolidate the Union’s quantum research efforts. Virkkunen believes that the EU leads on quantum research, yet this remains too fragmented to bring its potential to market.

Enforcement

Virkkunen is also set to oversee the enforcement of existing regulations. Enforcement of the DMA’s rules for online competition fall under the purview of two Directorates-General: DG CNECT (under the responsibility of Virkkunen) and the Directorate-General for Competition (DG COMP), under the responsibility of Teresa Ribera (EVP for a Clean, Just and Competitive Transition). The two EVPs and their DGs will need to coordinate closely.

Looking Ahead

The new Commission is expected to publish its 2025 Work Programme in February, at which point we should have a clearer roadmap of its legislative priorities. Poland’s Presidency of the Council of the EU in the first half of 2025, with its focus on cybersecurity, tech innovation and economic competitiveness, is expected to further promote the Commission’s agenda.

The team at Covington, which cuts across a wide range of regulatory areas, is well placed to advise you on these policy developments, and how to engage with the relevant decision-makers on these questions.

__________________________

Clovis de Bryas of Covington & Burling LLP contributed to the preparation of this blog.

Photo of Atli Stannard Atli Stannard

Atli Stannard is special counsel in the firm’s Public Policy practice. He guides clients in highly regulated industries through complex EU policymaking processes, protecting and advancing their core business and regulatory priorities.

Atli’s practice covers all aspects of EU policymaking and legislative advocacy…

Atli Stannard is special counsel in the firm’s Public Policy practice. He guides clients in highly regulated industries through complex EU policymaking processes, protecting and advancing their core business and regulatory priorities.

Atli’s practice covers all aspects of EU policymaking and legislative advocacy, including the regulation of the tech, food and beverage, pharmaceutical and medical devices, and industrial sectors, and on EU trade, environmental and ESG, and competition policy. He has handled matters before the European Commission, European Parliament, Council of the EU, and Member State and UK governments. Clients rely on him to identify regulatory risks and opportunities, and engage in the policy process to defend and promote their business interests. 

  • Technology: Atli has worked extensively for clients on matters relating to EU data, content, platform, Artificial Intelligence, and competition policy.
  • Food and beverage: Atli helps clients developing novel plant-based foods to secure the necessary regulatory authorizations and engage in broader EU food policymaking. He regularly engages with EU and national authorities to ensure that health and environmental regulations are based in rigorous scientific evidence. He has drawn on his trade policy expertise to assist clients seeking to import food products into the EU.
  • Drug & medical devices: Atli has counseled clients and engaged with the EU institutions on matters relating to genomics, the regulation of medical devices and in vitro diagnostics, health technology assessment, orphan medicines, and pricing.
  • Industrial: Atli helps clients engage with EU and national bodies on the environmental benefits of their innovative technologies, and on EU plastics, chemical, and product regulation.

In his EU trade policy work, Atli regularly advises clients facing on EU market access and customs classification issues, trade defense actions (tariffs and safeguard measures), and non-tariff barriers (including sanitary and phytosanitary measures). He helps clients engage in the EU’s negotiation of new trade agreements. He counsels clients on the impact of the upcoming Carbon Border Adjustment Mechanism, and how to shape and comply with its requirements.

Atli is a member of the firm’s ESG and Business and Human Rights Practices, and works with clients to assess the impact of and engage with new and upcoming Environmental, Social and Governance rules, including the EU Green Deal, supply chain diligence and the EU’s developing sustainable finance rules.

Atli’s competition policy advocacy work encompasses mergers, challenges under Articles 101 (anticompetitive agreements) and 102 (abuse of dominance) TFEU, and referrals under Article 22 of the EU Merger Regulation.

Atli has counseled international investors extensively on the EU’s proposals for a regime on foreign subsidies, and on the EU’s new FDI screening rules and coordination mechanism, as well as on EU tax policymaking. He also works closely with litigation colleagues to protect clients’ legitimate interests in multiple venues.

Photo of Pauline Agius Pauline Agius

Pauline Agius is an associate in the firm’s Public Policy Practice group. With extensive work experience across the EU and APAC regions, Pauline helps clients navigate complex regulatory issues internationally. Her practice focuses on pharmaceutical and medical devices, energy, and infrastructure sectors.

  • Pharmaceutical

Pauline Agius is an associate in the firm’s Public Policy Practice group. With extensive work experience across the EU and APAC regions, Pauline helps clients navigate complex regulatory issues internationally. Her practice focuses on pharmaceutical and medical devices, energy, and infrastructure sectors.

  • Pharmaceutical and medical devices: Pauline has helped clients raise Japanese Diet members’ awareness of the benefits of cannabis-derived medicine for people with severe Autism Spectrum Disorder and of the importance of access to non-invasive prenatal testing. Pauline counsels clients on the regulation of medical devices in the EU.
  • Energy: Pauline provided regulatory advice and assisted with a bid submission to the first ever offshore wind project off the coast of Japan. Pauline has project finance and project development experience, as part of which she advised on a number of solar, LNG and hydropower transactions across Southeast Asia, Africa and South America.
  • Infrastructure: Pauline provided regulatory advice and assisted with a bid submission for a prospective integrated resort – a first in Japan.

Pauline has an MBA from INSEAD, a degree in Accounting and Finance from LSE, and speaks fluent Mandarin and Japanese.

Photo of Bart Szewczyk Bart Szewczyk

Having served in senior advisory positions in the U.S. government, Bart Szewczyk advises on European and global public policy, particularly on technology, economic sanctions and asset seizure, trade and foreign investment, business and human rights, and environmental, social, and governance issues, as well…

Having served in senior advisory positions in the U.S. government, Bart Szewczyk advises on European and global public policy, particularly on technology, economic sanctions and asset seizure, trade and foreign investment, business and human rights, and environmental, social, and governance issues, as well as conducts international arbitration. He also teaches grand strategy as an Adjunct Professor at Sciences Po in Paris and is a Nonresident Senior Fellow at the German Marshall Fund.

Bart recently worked as Advisor on Global Affairs at the European Commission’s think-tank, where he covered a wide range of foreign policy issues, including international order, defense, geoeconomics, transatlantic relations, Russia and Eastern Europe, Middle East and North Africa, and China and Asia. Previously, between 2014 and 2017, he served as Member of Secretary John Kerry’s Policy Planning Staff at the U.S. Department of State, where he covered Europe, Eurasia, and global economic affairs. From 2016 to 2017, he also concurrently served as Senior Policy Advisor to the U.S. Ambassador to the United Nations, Samantha Power, where he worked on refugee policy. He joined the U.S. government from teaching at Columbia Law School, as one of two academics selected nationwide for the Council on Foreign Relations International Affairs Fellowship. He has also consulted for the World Bank and Rasmussen Global.

Prior to government, Bart was an Associate Research Scholar and Lecturer-in-Law at Columbia Law School, where he worked on international law and U.S. foreign relations law. Before academia, he taught international law and international organizations at George Washington University Law School, and served as a visiting fellow at the EU Institute for Security Studies. He also clerked at the International Court of Justice for Judges Peter Tomka and Christopher Greenwood and at the U.S. Court of Appeals for the Third Circuit for the late Judge Leonard Garth.

Bart holds a Ph.D. from Cambridge University where he studied as a Gates Scholar, a J.D. from Yale Law School, an M.P.A. from Princeton University, and a B.S. in economics (summa cum laude) from The Wharton School at the University of Pennsylvania. He has published in Foreign Affairs, Foreign Policy, Harvard International Law Journal, Columbia Journal of European Law, American Journal of International Law, George Washington Law Review, Survival, and elsewhere. He is the author of three books: Europe’s Grand Strategy: Navigating a New World Order (Palgrave Macmillan 2021); with David McKean, Partners of First Resort: America, Europe, and the Future of the West (Brookings Institution Press 2021); and European Sovereignty, Legitimacy, and Power (Routledge 2021).