Two years ago, the Foreign Subsidies Regulation (FSR) entered into force. This EU Regulation that aims to ensure that companies active on the internal market do not gain a competitive advantage through subsidies granted outside the EU.
This yearly review analyses the outcomes of two years of FSR enforcement by the European Commission (Commission). We delve into the key investigations, regulatory developments and the main takeaways of the last two years. We examine the unexpectedly high volume of notifications, the anticipated rise in investigations that will be started on the Commission’s own initiative, the Commission’s willingness to separate EU and non-EU activities, and the main criticisms of the FSR.