It has been three years since the Foreign Subsidies Regulation (FSR) entered into force. This instrument, designed to tackle distortive foreign subsidies and “level the playing field”, has attracted both praise and criticism. Whilst the European Commission (Commission) declared the instrument fit for purpose in its first statutory review of the FSR in July 2026, it also noted that modifications may be necessary. In our yearly FSR review, we analyse what these changes may be by looking at the FSR enforcement highlights of the past year, including the Commission’s investigations and key cases, the FSR Guidelines, the Commission’s first statutory evaluation and the outlook for future developments.
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