ARTICLE
2 February 2026

Top 10 EU Regulatory Milestones To Watch In 2026

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A&O Shearman

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The proposal is aimed at accelerating scaleup in strategic sectors (net-zero technologies, defence, technology)...
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Industrial Accelerator Act Merger control guidelines Foreign subsidies regulation (FSR) Digital Markets Act (DMA) review AI development
  • AI act implementation
  • Cloud and AI development act implementation
Expected proposal Expected proposal Expected proposal Expected proposal Expected proposal
Q1 2026 Q2 2026 Q3 2026 Q2 2026 Q1 and Q2 2026

Description

The proposal is aimed at accelerating scaleup in strategic sectors (net-zero technologies, defence, technology) through permitting, offtake arrangements, and financing tools, as well as outlining the European Commission's approach to local content rules in strategic sectors.

Description

The review aims to modernize the EU's merger assessment framework by expanding beyond traditional price effects to include resilience, innovation, sustainability, and broader considerations.

Description

The Commission's review is assessing the implementation and enforcement of the FSR, and could be accompanied by legislative proposals addressing notification thresholds, review periods, and procedural complexity.

Description

The review is anticipated to revisit scope, gatekeeper obligations, enforcement tools, and reporting duties, with possible clarification of how the DMA interacts with the broader digital services rulebook that has been developed since its adoption, notably, with the AI Act.

Description

The cloud and AI development act is expected to create conditions for EUbased cloud and AI infrastructure through investment incentives, permitting streamlining, and security standards.

Impact on M&A and project financing

The proposal will impact investment planning, contractual structuring, risk sharing and bankability for M&A and project finance transactions.

Impact on M&A and project financing

Impact on deal feasability structuring, approval strategies, long-stop dates, risk allocation and possible remedies.

Impact on M&A and project financing

The changes may clarify or even simplify FSR notification obligations and could therefore have a positive impact on transaction timelines and compliance costs for deals involving non-EU subsidies.

Impact on M&A and project financing

This could reshape revenue models and data access assumptions, providing further insights into large AI platforms' considerations under antitrust rules.

Impact on M&A and project financing

Together with the further standards expected for the entry into force of the AI Act, this could create incentives and reduce risk for data centre projects.

Public procurement Energy union package for the decade ahead Product requirements Chemicals Corporate governance
  • Public procurement act
  • Simplifying defence and sensitive security procurement
  • Development of the CO₂ transportation infrastructure and markets
  • Setting-up of the energy efficiency framework)
  • Setting-up of the renewable energy framework
  • Circular economy act
  • New legislative framework of product rules
  • PFAS restrictions
  • REACH revision
  • European Venture Capitals (EuVECA) Directive Review
  • Shareholders' Rights Directive Review
Expected proposal Expected proposal Expected proposal Expected proposal Expected proposal
Q2 and Q3 2026 Q3 2026 Q3 2026 Q3 and Q4 2026 Q3 and Q4 2026

Description

Reforms under consideration seek to modernise procurement procedures, reinforce security-of-supply requirements, and integrate strategic autonomy criteria, with specific adjustments for defence procurement.

Description

Legislative update to align EU energy law with 2040 climate and energy targets, covering CO₂ transport, energy efficiency, and renewable integration.

Description

New rules on product passports, durability and repairability standards, recycled content targets, and take-back obligations for priority sectors.

Description

The EU is expected to advance a decision on a broad PFAS restriction, as well as the revision of its cornerstone chemicals legislation (REACH), potentially introducing grouping approaches, new authorisation requirements, and enhanced data obligations across multiple value chains.

Description

The Commission is expected to propose targeted updates to the Shareholders' Rights Directive, enhancing shareholder identification, proxy advisor oversight, and cross-border voting mechanisms. A parallel revision of the EuVECA regulation will expand its flexibility, asset scope, and cross-border activities.

Impact on M&A and project financing

These changes will influence tender design and award criteria, potentially impacting joint venture structures, bid strategies, and financing models for projects reliant on public contracts.

Impact on M&A and project financing

It will reshape market rules and investment incentives, influencing valuations and financing for large-scale energy infrastructure and clean technology projects.

Impact on M&A and project financing

It will affect compliance costs, supply chain structures, and asset valuations, creating both risks and opportunities for investments in manufacturing and recycling sectors.

Impact on M&A and project financing

It will tighten regulatory compliance obligations and liability exposure for chemicalintensive businesses, affecting due diligence, transaction structuring, and financing terms for acquisitions in sectors such as manufacturing, electronics, and automotive.

Impact on M&A and project financing

The reforms may affect governance rights and minority protections in M&A transactions, and broaden fundraising avenues for EU managers, impacting deal structures and

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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