On 11 December 2025, the Council and European Parliament reached political agreement to revamp the EU’s Foreign Investment Screening Regulation.  The revamp aims at responding to perceived growing risks to national and economic security in the EU. It forms part of the EU’s recently unveiled Economic Security Doctrine. While the full text has not yet been published, public sources offer some initial insights into key elements of the upcoming new regime.  This post identifies the three main knowns and unknowns that warrant monitoring.  For more details about the most debated aspects of the revamp, please read our previous posts here and here.

The knowns

  1. Pan-EU mandatory screening of investments into listed sectors. All Member States will have to put in place mandatory screening mechanisms for investments in certain sensitive areas, including dual-use items, military equipment, AI, quantum technologies, semiconductors, critical raw materials, key energy, transport and digital infrastructure, electoral systems, and a limited list of financial entities.  Member States will retain the ability to screen investments in other sectors.
  2. Screening to cover indirect investments into the EU.  The new regime will extend to investments made by EU subsidiaries controlled by a non-EU entity.  This clarification seeks to address the uncertainty introduced by the EU Court of Justice’s Xella ruling. 
  3. Strengthened cooperation between Member States and European Commission. Final decision-making authority on whether to allow screened investments will remain with the Member States, a position that the Council fought hard to maintain. However, the new regime will require greater cooperation between Member States and the European Commission to share information about the investments, the potential creation of an optional single portal for electronic filings (if at least nine Member States request it), and shared guidance on risk factors bearing on the national security assessment of investments.

The unknowns

  1. Deadlines and procedural timelines. The new regime will set common deadlines across Member States for submission of filings and review of the notified investments.  It remains to be seen what those deadlines will be. These timelines will be critical for deal planning, as they will impact how quickly investments can proceed and whether additional clearance steps will affect deal execution.
  2. Greenfield investments. It also remains to be seen whether the new regime will require Member States to screen greenfield investments in strategic sectors, something the Parliament was seeking.  We expect the Council’s position of leaving this decision to each Member State’s preference to prevail.  That said, the devil will be in the details, and investors should consider closely the final text on this point once it is published.
  3. Local workforce and technology transfers requirements.  The EU’s new Economic Security Doctrine and statements from EVP Séjourné indicate that the EU may require certain investments to include the employment of a local workforce and transfers of technology to European partners.   It remains unclear, however, to what extent those considerations will be addressed in the new regime.

Next steps The actual text of the EU’s revamped Foreign Investment Screening Regulation should become available in the coming weeks, once the Council and the European Parliament have formally endorsed it.  Once the Regulation enters into force, the new rules will apply after an 18-month transition period, meaning implementation is expected towards the end of 2027.  During this time, all 27 Member States will need to align their national laws with the revised framework.

With thanks to Martin Allende Pagadigorria for his assistance in drafting and researching this piece.

Photo of Sibel Yilmaz Sibel Yilmaz

Sibel Yilmaz advises on all aspects of competition law, foreign investment and foreign subsidies screening, with a focus on the life sciences and technology and industrial sectors.

Sibel has particular expertise in the life sciences sector and provide strategic advice in regard to…

Sibel Yilmaz advises on all aspects of competition law, foreign investment and foreign subsidies screening, with a focus on the life sciences and technology and industrial sectors.

Sibel has particular expertise in the life sciences sector and provide strategic advice in regard to M&A, licensing and collaborations, regulatory strategies and general compliance. Sibel has also represented clients in several investigations relating to alleged excessive prices and other non-competitive practices in the life science sector. Sibel advises various clients in the technology sector, including in the gaming sector. She is also a Non Governmental Adviser to the Swedish Competition Authority within the frame work of its role in the ICN.

Sibel is ranked among the world’s top antitrust practitioners by Global Competition Review, who included her in their most recent 40 Under 40 survey, as well as Chambers Global. She is described as “a brilliant and promising lawyer, who is highly recommended for complex merger work” and “an exceptional talent”, “absolutely a tip for the top.”

Sibel obtained received her Master of Law from Stockholm University and a LL.M. in Law and Economics from the University of Rotterdam. She is admitted to practice in Belgium (e-list) and Sweden.

Photo of Laurie-Anne Grelier Laurie-Anne Grelier

Laurie-Anne Grelier assists global companies, especially Asian multinationals, with navigating complex areas of European competition law, including antitrust and cartel investigations, the clearance of mergers, the structuring of distribution, collaborative and other commercial arrangements, and issues related to abuse of dominant position. Ms.

Laurie-Anne Grelier assists global companies, especially Asian multinationals, with navigating complex areas of European competition law, including antitrust and cartel investigations, the clearance of mergers, the structuring of distribution, collaborative and other commercial arrangements, and issues related to abuse of dominant position. Ms. Grelier also assists these companies in litigation before the European Courts, as well as with state aid and trade matters.

Photo of Romain Girard Romain Girard

Romain Girard advises multinational corporations and institutions on complex antitrust and foreign direct investment (FDI) regulatory matters. The Legal 500 UK recognizes Romain in the EU and Competition category, describing him as “helpful, knowledgeable and personable” and “his legal knowledge is spot on…

Romain Girard advises multinational corporations and institutions on complex antitrust and foreign direct investment (FDI) regulatory matters. The Legal 500 UK recognizes Romain in the EU and Competition category, describing him as “helpful, knowledgeable and personable” and “his legal knowledge is spot on – in particular, his awareness of legal developments in key jurisdictions across the world is very useful.”

Romain has extensive experience advising clients on all aspects of EU, UK and international antitrust and FDI matters and representing them before the European Commission, as well as UK competition authorities and courts. His practice covers multiple industries including financial institutions and private equity, telecommunications media and technology, cybersecurity, artificial intelligence, aerospace, metals and mining, automotive, defense, and life sciences.

Romain’s practice also covers international trade and EU/UK sanctions, with extensive experience navigating the complexities of these highly dynamic regimes both defensively (i.e. advising on third party audits and lawsuit), and offensively (advising on voluntary disclosures and complaints).