Photo of Matthieu Coget

Matthieu Coget

Matthieu Coget's practice sits at the intersection of law and policy. He advises primarily on the EU’s evolving regulatory response to geopolitical and trade tensions, including foreign investment screening, sanctions and export controls, and trade safeguards. Matthieu also advises on reputational risks arising from cross-border transactions involving strategic supply chains. In addition, he regularly supports clients in designing and implementing policy engagement strategies.

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On June 3, the European Commission published its Tech Sovereignty Package, a set of legislative and policy initiatives designed to address what the Commission characterizes as Europe’s technological dependencies on non-European suppliers. The Package marks a further step in the evolution of the EU’s technology policy, with initiatives spanning the full tech stack—from chips and infrastructure to software, cloud, and artificial intelligence. Through this “ecosystem” approach, the Commission seeks to reduce supply-side dependencies by strengthening domestic capabilities in Europe and stimulating demand in downstream sectors.

The Package comprises four components: two legislative proposals—(i) the Cloud and AI Development Act (CADA), and (ii) the Chips Act 2.0—as well as two non-legislative initiatives—(iii) the EU Open Source Strategy and (iv) a Strategic Roadmap for Digitalisation and AI in Energy.

Continue Reading EU Tech Sovereignty Package

EU Member States are currently designing two possible new Important Projects of Common European Interest (“IPCEIs”) to support the development of AI and compute infrastructure in the EU (together the “Digital IPCEIs”), subject to European Commission (“Commission”) approval.

On 10 March 2026, the “matchmaking” phase under the IPCEI on Artificial Intelligence (“IPCEI-AI”) was officially launched in Berlin. It brings together companies whose AI projects have been pre-selected through national calls for expressions of interest (“CEIs”) in each participating Member State. Its objective is to form European consortia eligible for State co-funding under the IPCEI-AI. National CEIs in 17 participating Member States are now closed; Finland and Lithuania are still expected to launch their CEIs.

A second digital IPCEI on Compute Infrastructure Continuum (“IPCEI-CIC”) was launched in late 2025 by 15 Member States. Several of these participating Member States – including Belgium, Croatia, Estonia, Finland, France, Germany, Hungary, Lithuania, the Netherlands, Romania, Slovakia, and Spain – have not yet launched their CEIs.  

Continue Reading Important Projects of Common European Interest (IPCEIs) on Artificial Intelligence and Compute Infrastructure Continuum

On 4 March 2026, the European Commission (the “Commission”) published its proposal for a regulation establishing a framework for the acceleration of its industrial capacity and decarbonisation in strategic sectors (“Proposed Industrial Accelerator Act”, or “Proposed IAA”), accompanied by four annexes. The initiative is intended to strengthen the EU’s industrial base while accelerating decarbonisation in key manufacturing sectors considered strategically important (i.e., energy-intensive industries, net-zero technology manufacturing, and the automotive manufacturing ecosystem). These sectors currently represent less than 15% of EU GDP, and the Commission’s objective is to increase this share to 20% by 2035. The Proposed IAA was delayed three times before publication and underwent significant rewriting, which reflects both internal debates within the Commission and diverging reactions from Member States.  It also reflects the challenges posed by the broader geopolitical context, as the Commission aims to address economic security concerns through industrial policies whilst navigating international trade relationships and commitments.

The Proposed IAA introduces a regulatory framework combining three policy tools. First, it establishes demand-side measures designed to create “lead markets” for low-carbon and “Made in EU” industrial products through public procurement and certain public support schemes. Second, it introduces conditions for allowing certain foreign direct and indirect investments (“FDI”) in strategic sectors, aimed at maximising the industrial benefits of such investments within the EU. Third, it includes measures to streamline permitting procedures and facilitate industrial clustering, with the objective of accelerating the deployment of manufacturing projects.

This blog summarises the key aspects of each tool and their potential implications for companies active in the covered industries or looking to invest in the covered industries.

Continue Reading European Commission Publishes the Proposed Industrial Accelerator Act

On 10 February 2026, the EU released the agreed compromise text of the new Regulation on the screening of foreign investments in the EU (the “New FIR Regulation”).  The three EU institutions (Commission, Parliament and Council) reached the compromise on the text in December 2025 (see our blog) following several months of trilogues (see our blog).  The text, while not yet officially published, is expected to remain unchanged.  The New FIR Regulation will repeal and replace the current FDI Screening Regulation (EU) 2019/452 (the “2019 FDI Regulation”).  The New FIR Regulation further integrates the EU’s investment screening framework into the EU’s economic security strategy.

Against the backdrop of rising geopolitical friction, the New FIR Regulation aims to address the risk that investors structure transactions to get access to the EU market by anchoring their investments in Member States with lighter FIR controls.  To do so, the New FIR Regulation establishes a unified minimum screening framework across the Member States (e.g., through mandatory national screening mechanisms, harmonised review timelines, and strengthened cooperation obligations), whilst preserving Member States’ ultimate sovereignty on matters of national security.  This will be a major evolution from the 2019 FDI Regulation, which was limited to establishing an information-sharing mechanism while leaving Member States wide discretion as to whether and how to screen foreign investments.

This post discusses the five major areas of change for prospective investors, before offering a few forward-looking considerations.

Continue Reading New Foreign Investment Screening Regulation – Key Takeaways from the Agreed Compromise Text

On 16 December 2025, the European Commission presented the Automotive Package (the “Package”), a set of interlinked legislative and policy initiatives aimed at supporting the European automotive sector’s transition to clean mobility. The Package has four core components: (i) a proposal to revise the CO₂ emission performance standards for cars and vans, (ii) the so-called “Battery Booster Strategy”, (iii) a proposal on greening corporate vehicle fleets, and (iv) a proposal for an “Automotive Omnibus” regulation that would amend several pieces of automotive legislation to simplify regulations for vehicle manufacturers. Together, these initiatives signal a material recalibration of the EU’s approach to vehicle decarbonization.

Continue Reading The EU Automotive Package: Increased Compliance Flexibility, but Growing “Made in the EU” Conditionality

On 3 December 2025, the European Commission adopted the RESourceEU Action Plan, signaling that Europe’s industrial competitiveness will increasingly depend on its ability to secure and diversify critical raw material (“CRM”) supply chains.  For companies, inside and outside the EU, RESourceEU is more than a technical update: it marks a policy shift toward a more interventionist and security-driven approach to CRM governance.

The analysis below outlines the drivers behind the initiative, its main components, and the implications for multinationals trading into the EU.

Continue Reading RESourceEU Action Plan – Strengthening the EU’s Access to Critical Raw Materials

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.

Continue Reading Strengthening EU Economic Security – More of the Same or a New Approach?

On 23 May 2025, the European Commission adopted several pieces of secondary legislation under the Net-Zero Industry Act (“NZIA”), including an Implementing Regulation on Non-Price Criteria in Renewable Energy Auctions (“Implementing Act”). The Implementing Act gives legal effect to Article 26 NZIA, which obliges each Member State to apply, from 30 December 2025, non-price criteria to either at least 30% of their annual auctioned capacity or, alternatively, to at least six gigawatts annually.

Continue Reading Adoption of Implementing Act on Non-Price Criteria in Renewable Energy Auctions

On July 27, the United States and the European Union announced a trade framework agreement, following a meeting between President Donald Trump and European Commission President Ursula von der Leyen. The deal avoided imposition of a 30% reciprocal U.S. tariff on EU goods that was set to take effect August…

Continue Reading U.S.-EU Trade Framework: Outcome and Next Steps

On 4 June 2025, the European Commission published a decision recognising 13 critical raw material projects located in non-EU countries as “Strategic Projects” under the Critical Raw Materials Act (“CRMA”, Regulation (EU) 2024/1252). This first set of Strategic Projects based outside the EU adds to the 47 Strategic Projects based within the EU announced earlier this year. These Strategic Projects are recognized as significantly contributing to the security of the EU’s supply of strategic raw materials, and will benefit from preferential access to finance and other advantages. For more information on the CRMA and the framework for Strategic Projects, see our previous blog post here.

Continue Reading EU Designates 13 Non-EU Critical Raw Materials Projects as Strategic