11 November 2026

Over the three years that the EU Foreign Subsidies Regulation (FSR) has been in force, the European Commission has shown that it is serious about addressing potential market distortions caused by foreign subsidies. The FSR is now a key consideration for M&A, public procurement and investment in the EU.

In this briefing, we examine the trends that have emerged from three years of FSR enforcement, share practical advice on data gathering and notification preparation, and explore what businesses can expect from the next phase of the regime. We also take a closer look at the experience of Chinese companies engaging with the FSR process.

Key takeaways:

• The European Commission has made strong and consistent use of the tools available to it under the FSR, while also clearly demonstrating flexibility around information disclosure.
• Best practice when it comes to FSR data gathering varies between companies, but a ‘dry run’ and mock filing are advisable for establishing timelines and the relevant stakeholders.
• Several adjustments to ease the administrative burden of the FSR are expected to come into force in early 2027, including allowing frequent filers of FSR public procurement notifications to make a single annual or biannual submission.
• Businesses operating across both China and EU should expect increasing conflict between the two jurisdictions following the issuing of new regulations in China in April 2026.