Progress toward an EU-level outbound investment screening mechanism remains gradual, given that investment policy remains primarily within Member State competence. Member States submitted their interim progress reports in July 2025, and the Commission’s fuller policy assessment will follow once comprehensive implementation reports are received by June 30, 2026. More immediately, the proposed IAA reflects a related but distinct EU effort to condition inbound investments in strategic industries, demonstrating the EU’s broader ambition to manage the intersection of foreign capital and economic security through multiple overlapping instruments. In the meantime, foreign investors planning transactions that impact the EU should have a strategy in place to deal with multiple parallel notification processes across Member States to ensure a consistent approach. Potential FDI filings need to be considered early in the transaction process, and parties need to ensure they are appropriately factored into transaction timetables. Missing a mandatory filing can lead to fines, render transactions legally void or even constitute a criminal offense.
European Union
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