Before issuing a proposal for a Quantum Act, the European Commission has issued a call for evidence (“Call for Evidence”), asking for views from all stakeholders on the best approach to addressing structural problems that the Commission has identified in the areas of research, industrial capacity, and supply chain resilience. Industry stakeholders already grappling with multiple EU data and cyber-related laws, regulations, and assessment procedures may be most interested in the proposal to develop an EU-level monitoring and resilience framework for supply chain products needed to build quantum technologies. The Call for Evidence is open until 26 November 2025
In July 2025, the European Commission published its Quantum Strategy (“Strategy”), which aims to support the development of quantum computing-enabled products and services in the EU, and thereby improve the EU’s competitiveness in the quantum computing and technology markets. The Strategy focuses on five main areas: supporting academic and scientific research into quantum computing; developing hubs to support the production of quantum computers and associated infrastructure; strengthening the quantum industry through investment and work to secure supply chains; integrating quantum computing into Europe’s space, security, and defence strategies; and supporting the growth of the skills needed to develop and operate quantum computers.
The Strategy also stated that the Commission will propose a Quantum Act in the course of 2026. This Act will address what the Commission sees as three structural problems that are holding back the development of quantum technology in the EU:
- A fragmented research landscape. The Commission argues that this has led to duplicated work and makes it harder to turn research advances into tangible products;
- Limited investment and industrial capacity. Among other things, the Commission identifies a lack of fabrication capabilities for quantum chips and hardware, and a lack of coordination on Member State support for the quantum industry; and
- Concerns around supply chain resilience and governance. Specifically, the Commission identifies a lack of systematic monitoring of important inputs / intellectual property e.g., in the context of foreign direct investment, and fragmented governance of the sector.
Before issuing its proposal for the Quantum Act, the Commission has issued a call for evidence (“Call for Evidence”), asking for views from all stakeholders on the best approach to addressing these structural problems. It sets out multiple potential options and requests feedback on what stakeholders think would be most appropriate:
- Fragmented research landscape. The Commission proposes either relying on existing mechanisms (e.g., Member State programmes, Horizon Europe, the European Competitiveness Fund, and the European Defence Fund) or integrating quantum matters into the EuroHPC Joint Undertaking, i.e., creating a single EU-wide framework for quantum research and innovation.
- Limited investment and industrial capacity. Here, the Commission proposes three options: leaving investment solely to private entities and markets; encouraging ad hoc national and EU-level investment in quantum technologies; or developing dedicated EU wide tools for investment and development of industrial capacity, backed by public-private investment.
- Concerns around supply chain resilience and governance. The Commission proposes either leaving the current regime as it is, or developing an EU-level monitoring and resilience framework. Such a framework might include conduct of systematic supply chain analysis for products needed to build quantum technologies, a means of identifying potential chokepoints or areas of low resilience, and a structured method of ensuring cooperation between Member States.
The Call for Evidence is open until 26 November 2025, and states that the Commission is most interested in views of stakeholders with a direct interest in quantum technologies, e.g., public authorities, researchers, experts in standardization and cybersecurity technologies, and industry. The responses will then be used in the impact assessment for the Quantum Act when it is first proposed.
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Covington’s Technology Regulatory and Public Policy Practices will continue to monitor developments related to the Quantum Act. If you have any questions about the issues raised in the blog, or are interested in engaging with the legislative process, please do not hesitate to contact us