Brussels à Jour - The Review of the Merger Guidelines – 20 Years on
2 July 2025
Since mid-October 2023, certain M&A transactions and participations in public procurement proceedings must be notified to the European Commission (“Commission”) under the Foreign Subsidies Regulation (Regulation (EU) 2022/2560, “FSR”). This past year was a busy year for the Commission, for FSR lawyers and, most importantly, for companies falling within the scope of application of the FSR. The FSR has been criticized by many, not only for the burden it puts on transactions and public procurements, but also for its very broad scope.
