In March 2025, the European Union published a white paper for European Defense Readiness 2030, which identifies defense needs and envisions a massive €800 billion four-year “ReArm Europe” investment plan. This initiative is a significant step change from the EU’s prior defense industrial strategy and earlier funding programs.

Rearming Europe would be financed by €150 billion in EU common debt made available as loans to Member States and €650 billion in national spending that EU fiscal rules would not constrain. This new package is intended to support EU Member State efforts to ramp-up defense capabilities and, if implemented, it would effectively double the overall amount of defense spending in Europe. Covington is working with clients in defense industry sectors across the wider West to maximize business opportunities created by this new funding.

Unleashing Europe’s Defense Potential

Given the “rapid deterioration of the geopolitical context and rising tensions,” the white paper pledges to unleash the EU’s resources and latent industrial and technological power on defense. It aims to swiftly increase support for Ukraine and deter Russia’s further aggression, while reducing dependency on U.S. military support. Further, it paves the way to tackle long-term security threats such as the “systemic” challenge posed by China and growing hybrid threats.

The EU seeks to support collaborative capability development among Member States, to enhance coordination and generate economies of scale.  Here, joint procurements will be a privileged tool, notably by setting up a European Military Sales Mechanism. This mechanism will support manufacturing capabilities and deliver more complex projects through aggregated demand and increasing predictability for the sector. To do so, it will incentivise long-term common procurements, as envisioned also by the European defense common procurement act.

In the near-term, investments and procurements on defense industrial capabilities will focus on rebuilding Europe’s depleted stocks of military hardware and equipment. Key capability domains include air and missile defense, artillery systems, ammunition and missiles, drones and counter-drone systems, military mobility, artificial intelligence, quantum, cyber & electronic warfare, strategic enablers and critical infrastructure protection.

To quickly expand its defense capabilities, Europe is also exploring strengthening its defense industrial collaboration with trusted partners such as the Republic of Korea, Norway, and Japan (with which the EU signed Security and Defence Partnerships last year), as well as its traditional allies and partners, such as the United Kingdom and the United States.

Omnibus Simplification on Defense

The European Commission has also launched a strategic dialogue with the defense industry to identify pathways for simplification and harmonization on rules and procedures, which impact the European defense and technological industrial base and limit its agility to ramp-up defense capabilities, in response to calls by Member States to deregulate the industry.

The Strategic Dialogue presents a key opportunity to engage with the Commission and ensure that industry perspectives are well considered. Key regulatory issues to be addressed will include:

  • The cross-certification of defense products and mutual recognition of certifications;
  • Accelerated grants of construction and environmental permits for defense industrial projects;
  • “Removing obstacles” in accessing finance, including sustainable investments.

The discussion will also shape procedures under the upcoming platform for joint purchases of critical raw materials proposed under the Critical Raw Materials Act.

The Commission intends to put forward a proposal for a Defense Omnibus Simplification by June 2025, based on the recommendations of the dialogue. Concretely, the Omnibus will target the Directive on public procurement in the fields of defense and security, the directive on intra-EU transfers of defense-related products, and the rules and procedures to be awarded grants from the European Defense Fund.

Mobilizing 800 Billion for Defense Capabilities and Tech Innovation

The announced ReArm Europe plan will facilitate increased European defense spending over the next four years through a set of five measures.

First, it will entail a new regulation proposal for a Security Action for Europe (SAFE)  instrument to increase European defense spending through a fund of €150 billion of loans raised by the EU and then made available as loans to requesting Member States. SAFE eligibility conditions include the following, among others:

  • Procurement must involve at least two countries, one of which must be an EU Member State, and the other must be an EU Member State, an EEA or EFTA State (Iceland, Liechtenstein, Norway, and Switzerland), or Ukraine.
  • Third countries with whom the EU entered into a Security and Defence Partnership—such as Korea and Japan—as well as acceding, candidate and potential candidate countries, may negotiate agreements with the EU to participate fully in SAFE procurements.
  • Entities from countries that do not have a Security and Defence Partnership with the EU may be eligible for partial participation: up to 35% of the cost of production of the project and under certain conditions. This would include defense firms from the United States and the United Kingdom, although there have been reports that the UK government is in discussions with the EU on security and defence collaboration that would enable full participation.

This proposal will be subject to an expedited legislative procedure that does not require approval by the European Parliament. Then, the Commission will launch a call for interest and Member States will have up to two months to submit their applications, as of the entry into force of the SAFE regulation. Indeed, some EU Member States have already started to prepare expressions of interest for projects involving tens of billions of euro.

Second, the EU has invited Member States to request the activation of the “national escape clause” of the Stability and Growth Pact by the end of April, with a detailed guidance. Under this clause, increased Member State defense spending would not be limited by the 3% budget deficit ceiling of these EU fiscal rules. This increased flexibility is foreseen to facilitate at least €650 billion over the next four years.

Third, the European Commission will propose soon enhanced flexibility and further incentives to use structural and cohesion funds for defense, representing around one-third of EU spending. After a mid-term review of cohesion policies, national, regional and local authorities will be enabled to allocate funds from their current programs towards defense projects.

Finally, the European Investment Bank’s role in defense investments will be expanded, as its recent decisions have also indicated.

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The team at Covington is well placed to advise you on these policy developments, and how to engage with the relevant decision-makers in these areas. We can help gather intelligence, analyse legislative initiatives, navigate the complex regulatory environment at the EU and Member State level, and design and execute strategy.

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Pol Revert Loosveldt of Covington & Burling LLP contributed to the preparation of this article.

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

Photo of Elżbieta Bieńkowska Elżbieta Bieńkowska

Elżbieta Bieńkowska is a senior advisor in the firm’s Brussels office. Elżbieta, a non-lawyer, served as European Commissioner for the Internal Market, Industry, Entrepreneurship and SMEs in Jean-Claude Juncker’s team from 2014 to 2019. In that capacity, she was responsible for much of…

Elżbieta Bieńkowska is a senior advisor in the firm’s Brussels office. Elżbieta, a non-lawyer, served as European Commissioner for the Internal Market, Industry, Entrepreneurship and SMEs in Jean-Claude Juncker’s team from 2014 to 2019. In that capacity, she was responsible for much of the European Commission’s regulatory activity that affects the EU’s 450 million citizens, and all companies doing business in the EU. Elżbieta oversaw all product regulation in the EU, setting the rules for goods and services in sectors as diverse as chemicals, cars, electronics, IT infrastructure, machines, medical devices, and hydrogen. She managed the EU’s treatment of IP, led the Commission’s extensive work on standardization, and ran the EU’s industrial policy.

In her time at the Commission, Elżbieta launched the circular economy package, focusing on the regulation of packaging, waste, and batteries. She laid the foundations for the EU’s new industrial strategy, which ultimately resulted in the 2023 proposals for a Net-Zero Industry Act and the Critical Raw Materials Act. She was an early proponent of EU research into AI, and led the Commission’s renewed focus on fostering the space and defense industry in Europe.

Before joining the European Commission, Elżbieta served as Minister for Infrastructure and Development of Poland as well as Deputy Prime Minister. In this role, she was in charge of the allocation of European Union funding and responsible for significant investments in Poland’s transport infrastructure.

Photo of Daniel Feldman Daniel Feldman

Dan Feldman co-chairs the firm’s ESG and Business & Human Rights practices.

Drawing on his prior positions in government service spanning multiple Administrations, former Ambassador Dan Feldman’s practice focuses on environmental, social, and governance (ESG) counseling, business and human rights (BHR), global public…

Dan Feldman co-chairs the firm’s ESG and Business & Human Rights practices.

Drawing on his prior positions in government service spanning multiple Administrations, former Ambassador Dan Feldman’s practice focuses on environmental, social, and governance (ESG) counseling, business and human rights (BHR), global public policy, as well as broader international regulatory compliance. He is a member of the firm’s Global Problem Solving initiative.

As Chief of Staff and Counselor to Secretary John Kerry when he was appointed the first Special Presidential Envoy for Climate (SPEC) by President Biden, Dan helped drive the U.S. government’s international climate agenda, coordinating high level interagency policy-making, engaging with corporate stakeholders, and contributing to key bilateral and multilateral climate discussions, including the 2021 Leaders’ Summit on Climate and the landmark UN Conference of Parties (COP26) in Glasgow.

Previously, Dan served as deputy and then U.S. Special Representative for Afghanistan and Pakistan at the U.S. Department of State in the Obama Administration, as Director of Multilateral and Humanitarian Affairs at the National Security Council in the Clinton Administration, and as Counsel and Communications Adviser to the U.S. Senate Homeland Security and Governmental Affairs Committee. He also has served as a senior foreign policy and national security advisor to a number of Democratic presidential and Congressional campaigns.

Dan has extensive experience counseling multinational corporations on mitigating risk and maximizing opportunities in the development and implementation of their ESG and sustainability strategies, with a particular background in advising on BHR matters. He was one of the first attorneys in the U.S. to develop a practice in corporate social responsibility, and has been cited by Chambers for his BHR expertise. He assists clients in strategizing about their engagements with a range of key stakeholders, including Members of Congress, executive branch officials, foreign government officials and Embassy representatives, multilateral institutions, trade and industry associations, non-governmental organizations, opinion leaders, and journalists.

Photo of Victoria Nuland Victoria Nuland

Victoria Nuland, a non-lawyer, is a Senior Advisor in the Public Policy practice. She is also the Shelby Cullom Davis Professor in the Practice of International Diplomacy at Columbia University’s School of International and Public Affairs and a board member of the National…

Victoria Nuland, a non-lawyer, is a Senior Advisor in the Public Policy practice. She is also the Shelby Cullom Davis Professor in the Practice of International Diplomacy at Columbia University’s School of International and Public Affairs and a board member of the National Endowment for Democracy. She is a retired Career Ambassador in the U.S. diplomatic service, with 35 years of experience in foreign policy and international strategy, negotiation, media and management at the Department of State and the White House. Toria served six U.S. Presidents and 10 Secretaries of State of both political parties.

Until March 2024, Toria served as Undersecretary of State for Political Affairs where she oversaw and managed the work of all six regional bureaus at the Department of State and the counter-terrorism bureau, addressing complex crises in Ukraine, Africa, Latin America, and the Middle East, and worked to broaden and strengthening America’s alliances and partnerships across the globe. Between July 2023 and February 2024, Toria served concurrently as Acting Deputy Secretary of State and added China policy to her portfolio.

From 2019 to 2021, she was a Senior Advisor at the Albright Stonebridge Group, an international commercial diplomacy firm. She was also professor of practice at Yale University and a fellow at the Brookings Institution.

At the State Department, Toria served as Assistant Secretary for European and Eurasian Affairs from 2013 to 2017 under President Barack Obama and Secretary John Kerry. She was State Department Spokesperson during Secretary Hillary Clinton’s tenure from 2011-2013, and Special Envoy and Chief Negotiator on the Treaty on Conventional Arms Control in Europe from 2010-2011.

During George W. Bush’s presidency, Toria served as U.S. Ambassador and Permanent Representative to NATO from 2005- 2008. Prior to this appointment, she was Deputy National Security Advisor to the Vice President from 2003- 2005.

Toria joined the State Department’s Foreign Service in 1984. In addition to two tours at NATO in Brussels, Toria served overseas in Moscow, Russia, Ulaanbaatar, Mongolia and Guangzhou China, and also had many assignments in Washington. She has a BA in history from Brown University.

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).