May 2026 – We are pleased to share our updated and extended overview and critical analysis of the European cybersecurity reform, Cybersecurity Act 2.0 (CSA2), now including additional jurisdictions.

The European Union's International Procurement Instrument has issued its first implementing measure, targeting Chinese medical device suppliers with total exclusion from EU public procurement contracts valued at €5 million or more. The Lyon Administrative Court's landmark ruling establishes that contracting authorities must conduct genuine diligence into bidders' commercial substance, even when registered in the EU, to determine their true origin and eligibility to participate in tenders.

The EU Foreign Subsidies Regulation introduces new regulatory scrutiny for non-EU companies investing in Europe, with particular implications for Middle Eastern state-linked entities and sovereign wealth funds. The first major FSR merger investigation involving UAE-based e& and PPF Telecom reveals how the Commission applies this regime to government-backed investors from the Gulf region.

The European Commission's Industrial Accelerator Act proposes to reshape battery supply chains by conditioning access to EU public procurement and support schemes on strict origin requirements. As China controls over 80% of global battery manufacturing capacity, the legislation introduces escalating component-count thresholds that could fundamentally alter market access, financing structures, and supplier eligibility across the battery value chain.

The European Commission's Industrial Accelerator Act introduces sweeping changes to the automotive sector, establishing new "Made in the EU" requirements for electric vehicles and imposing conditions on foreign investments in battery manufacturing and critical raw materials.