On 3 December 2025, the European Commission unveiled the next phase of its economic security agenda.  Building on the 2023 Economic Security Strategy and the 2024 European Economic Security Package (see our prior blog), the new communication sets out a more assertive and coordinated approach to managing risks linked to trade, investment, technology and critical infrastructure.

The EU intends to remain open to trade and investment, but that openness will increasingly be conditioned on economic security objectives.  For businesses and investors, this translates into more scrutiny, more due diligence, and a more integrated interplay between the EU and Member States.

From Crisis Response to Proactive Economic Security

A central message of the Commission’s package is that economic security can no longer be approached as a series of ad hoc crisis responses.  Instead, the Commission is seeking to put in place a more structured and anticipatory framework, one that identifies vulnerabilities earlier, aggregates information more effectively and aligns Member State action around a shared view of risk.

In practice, this means building an internal economic security lens within the EU machinery.  The Commission plans to consolidate information on critical supply chains, high-risk entities and sensitive transactions in a dedicated Economic Security Information Hub, and to better use the Economic Security Network to deepen coordination with Member States on risk assessments and mitigation strategies.  The Commission will also bring in structured business input, for example through a trusted adviser group drawn from EU industry, and new tools such as a Trade Resilience Information Portal to give companies better visibility on foreign restrictions and emerging vulnerabilities.  It also intends to expand the Observatory on Critical Technologies and to rely on the future Centre of Expertise on Research Security to help universities and research organizations undertake due diligence when engaging with foreign partners.

Tightening the Existing Toolbox

Foreign Investment Screening

While investment screening remains a Member State responsibility, the Commission intends to issue guidelines for national screening authorities.  Substantively, the guidelines will ensure that national authorities apply a common economic security lens when assessing transactions, including cumulative risks created by multiple investments in the same sector or value chain.  These guidelines will be complemented by the upcoming revised EU FDI Screening Framework Regulation a final version of which is expected to be agreed by the European Parliament and Council in the coming weeks.

Crucially, the Commission’s description of inbound investment risks goes beyond the long-established concerns connected to security and public order (defense and security supply chains, critical infrastructure, dual-use and critical technologies, and sensitive data) and economic resilience (supplier dependencies or single points of failure in strategic supply chains, and technology leakage).  It explicitly describes a third economic dimension: “low competitiveness” outcomes where investments bring limited technological upgrading, little local value creation or primarily rely on imported labor.  This new criterion was already foreshadowed by Commission Executive Vice-President Séjourné’s public comments a week prior, but it remains to be seen how it will be implemented in practice, within the stricter legal framework of Member States screening regimes.

This framing moves investment control decisions  one step closer to a “net benefit” style test, familiar from regimes such as Canada’s ICA or Australia’s FIRB, where investors may be expected not only to avoid harm but to demonstrate positive contributions such as technology transfer, upgrading of industrial capabilities, local jobs and skills, or integration into European value chains.  The EU is not there yet, but the language opens the door to remedies and commitments framed around economic benefit, not just security safeguards.

Export Controls

The Commission also announces a full evaluation of the Dual-Use Export Control Regulation.  The review will examine whether the current framework remains fit for purpose considering new geopolitical dynamics and the increasing use of unilateral export controls in the face of slow progress in multilateral regimes.  As part of this process, the Commission intends to work with Member States on how the EU could more efficiently adopt EU-level controls to tackle areas of emerging technology with dual-use potential.

Sectors such as AI, quantum, semiconductors and biotechnology will likely face heightened policy attention.  Exporters in these areas should anticipate a more active discussion on the future scope and design of EU controls, including how to address the increasing fragmentation of national implementation and the risk of technology leakage through research cooperation.

Trade Defense, Competition, and Funding

Trade defense instruments will incorporate economic security considerations in cases where the risks are relevant, both during investigations and in the design of measures.  The Communication also underscores the role of the Foreign Subsidies Regulation and EU State aid tools in addressing distortions linked to third country policies, particularly where these create or deepen strategic dependencies.  The Commission highlights the Clean Industrial State Aid Framework, the Research, Development and Innovation Framework, the General Block Exemption Regulation and Important Projects of Common European Interest (“IPCEIs”) as tools that can be used to build resilience.

On funding, the Commission signals a shift toward closer alignment with economic security objectives.  EU programs are expected to prioritize projects that strengthen resilience or reduce critical dependencies, while guidance to be issued in early 2026 will clarify how high-risk entities may be restricted from accessing EU funding in sensitive sectors.  Member States and public financial institutions are likewise encouraged to channel support toward initiatives that reinforce the EU’s economic security.

New Measures: Portfolio Monitoring, Supply Dependencies and Critical Raw Materials

Alongside adjustments to existing tools, the Commission mentions the upcoming introduction of several proposals to broaden the EU’s economic security framework in areas relevant to mature industries and investors.

For instance, the Commission plans to work with supervisory authorities to monitor portfolio investments in high-risk sectors.  Although these non-controlling stakes would typically fall outside the current foreign investment screening coordination mechanism, the Commission views them as increasingly relevant channels through which foreign actors may gain access to sensitive technologies, data or strategic influence.

The Commission is also exploring ways to encourage companies in specific high-risk sectors to avoid single-supplier dependencies, including by promoting dual sourcing where reliance on a dominant supplier creates vulnerabilities.  This is framed as exploratory but signals an expectation that operators in strategic sectors strengthen supply-chain resilience.

As outlined in the RESourceEU plan, the Commission intends to support the development of secondary markets for critical raw materials, including through the upcoming Circular Economy Act.  The objective is to facilitate the financing of critical raw materials projects deemed high risk for economic security and to reduce the EU’s exposure to concentrated supply sources.

The Commission also intends to review the Blocking Statute to strengthen protection against the extraterritorial application of third-country sanctions, to explore possible new measures to address global overcapacity and other distortive market developments, and to introduce European preference criteria in public procurement for certain strategic sectors.

Taken together, these measures indicate a shift toward a more integrated approach to monitoring investment structures, assessing supply chain risk and reinforcing the resilience of critical inputs, complementing the more established investment control and trade defense tools.

Conclusion

Is this simply more of the same, or a genuinely new approach?  Formally, the Commission works with familiar instruments: foreign investment screening, export controls, competition law, trade defense, funding conditionality.  What has changed is how these tools are framed, coordinated and justified.

Economic security will now operate as a cross-cutting doctrine, shaping not just crisis responses but routine decisions on investment, trade, funding and technology policy.  For investors and businesses, the shift is subtle but significant: the EU remains open, but access increasingly comes with expectations around resilience, security and tangible economic benefit for Europe.

Companies that anticipate these expectations and build them into their investment and compliance strategies early, will be better placed to navigate the next phase of EU economic security policy.