Since the Foreign Subsidies Regulation became fully applicable, notification obligations have become a standing item on every cross-border deal checklist. Transactions involving an EU turnover above €500 million and foreign financial contributions above €50 million now require prior clearance.
Key thresholds in practice
Our deal teams increasingly see FSR analysis run in parallel with merger control from day one. Early mapping of financial contributions — including tax reliefs, guarantees, and below-market financing — has proven decisive for keeping signing-to-closing timelines intact.
Buyers backed by sovereign wealth funds or state-linked financing face the heaviest documentary burden. We recommend building an FSR data room module at the same time as the antitrust module.
What to do now
Acquirers active in the region should maintain a rolling three-year register of foreign financial contributions at group level. Those who prepared registers in advance closed on average six weeks faster in our recent mandates.
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