CELIS Update on Investment Screening and Economic Security – December 2025
By Helene Schramm with the help of intern Maria-Arancha Simiuc
INVESTMENT SCREENING MECHANISMS
Switzerland – Swiss Parliament adopts Investment Screening Act
On 2 December 2025, the Swiss parliament approved an Investment Screening Act. The regime has a highly limited scope and applies only to investments made by foreign states. The law is subject to a facultative referendum. It is expected to enter into force in 2027 after the enactment of the implementing ordinance.
Under the Swiss Investment Screening Act, notification is required for the takeover of a Swiss company by a foreign state investor in a security-critical sector where specific turnover thresholds are met. All of these cumulative requirements are further defined by the act. The security-critical sectors are listed and divided into two categories with different turnover thresholds. The most sensitive areas include water supply and security-related IT. Other security-critical companies with higher thresholds include systemically important banks, infrastructure undertakings, and medical companies.
In cases where notification is required, the act sets out approval criteria centred on public order and security, as well as procedural rules.
Greenland – Proposal for a Greenlandic investment screening (FDI) act
On 28 October 2025, the Government of Greenland proposed an act on foreign investment screening. The proposal is currently under parliamentary review and is scheduled to enter into force on 1 January 2026. The initiative emerged following concerns over threats to national security and public order. It forms part of Greenland’s Foreign, Security and Defense Strategy for 2024-2033 “Greenland in the World – Nothing about us without us”.
The act covers foreign investments except investments by some Danish nationals. Foreign investments falling under its scope include acquisitions of ownership or certain forms of control over entities domiciled in Greenland, as well as any other activities that may threaten national security or public order.
For specific sensitive sectors, such as defence, IT security, or critical technologies, the act requires mandatory authorisation. For other sectors, notifications are voluntary. Upon notification, the government may approve the investment, impose conditions, or prohibit it. Without such voluntary notification, the government has the right to assess whether the investment poses a threat to national security or public order within five years of its completion. If the government identifies such a threat, it may order the unwinding of the investment.
Greece – Greek FDI Screening Regime Becomes Fully Operational
On 11 November 2025, the Greek FDI screening regime became fully operational. The screening law had already been enacted in May 2025 but had remained non-operational. With the publication of the implementing regulations, the notification process has now been activated.
The regime applies to non-EU investors. Notifications are required for acquisitions of at least 25% in sensitive sectors, such as energy, transport or IT, and for acquisitions of at least 10% in highly sensitive sectors, including defence and cyber-security. Furthermore, add-on acquisitions require notification whenever specified thresholds are crossed.
The regime is both mandatory and suspensory. The administrative process has been described as strict, formal, and burdensome due to extensive documentation requirements and a rigid filing procedure.
ECONOMIC SECURITY STRATEGIES
European Union – EU Targets Strategic Dependencies and Critical Technologies in New Economic Security Drive
The European Commission expressed its commitment to strengthening Europe’s economic security in a Joint Communication with the High Representative, published on 3 December 2025. The Communication is framed around the growing risks to economic security, which have intensified in recent years. These risks include (i) the growing instability of global trade and investment, (ii) predatory practices targeting critical supply chains and technologies, and (iii) the deterioration of the security landscape and the rise of hybrid attacks.
The Commission suggests reacting with a paradigm shift towards a more proactive, strategic, and assertive use of EU tools. These tools are targeted at specific high-risk areas. The communication offers a non-extensive list of tools, such as trade agreements, the Cybersecurity Act, the FDI Screening Regulation, regulation on dual-use exports, sanctions, and the Data Union Strategy. The Commission suggests applying these tools in particular to stay ahead in critical technologies, industries and services.
A main concern are the EU’s dependencies, especially in relation to raw materials, energy and semiconductors. Competitiveness and productivity are underlined as key elements for reducing dependencies. In 2023 the Draghi report suggested reforms to improve competitiveness of the EU, however, only a small percentage have been implemented. The communication underlines how dependencies create the security risks. Risk assessment should be improved by identifying strategic dependencies and better anticipating third-country actions.
To implement the strategy set out in the communication, the Commission is working on legislative changes, guidelines, and other supportive measures.
As part of the strategy for safeguarding public order and security across the EU, on 11 December 2025, the Council and the European Parliament have agreed on the revision of the FDI screening regulation. The revision has been proposed by the Commission on 24 January 2024. The revision establishes a minimum scope of screenings, ensuring greater harmonisation across the EU. Sensitive areas falling under the minimum scope are (i) dual use items and military equipment, (ii) hyper-critical technologies, such as artificial intelligence, quantum technologies and semiconductors, (iii) critical raw materials, (iv) critical entities in energy, transport and digital infrastructure, (iv) electoral infrastructure, and (v) a limited list of financial system entities. Furthermore, the revised FDI screening regulation includes provisions aimed at improving cooperation and interoperability as well as streamlining processes. Nevertheless, screening decisions remain the exclusive responsibility of Member States, which have full discretion over the decision to authorise investments.
United States – Trump Administration Unveils National Security Strategy Centered on Sovereignty and Strategic Autonomy
On 5 December 2025, the President of the United States published the National Security Strategy. The strategy lists five priorities: (i) limiting migration, (ii) protecting core rights and liberties, (iii) burden-sharing and burden-shifting, (iv) seeking peace, and (v) economic security.
To strengthen economic security, the United States of America intend to prioritise national interest and security in trade relations, including by improving trade relations in their favour. The strategy further states that supplychain dependencies should be eliminated, particularly in the defence sector. Key supply chains as well as technological advancements should be monitored to mitigate security threats.
Other core focuses of the economic security strategy include the revival of the defence industrial base, reindustrialisation, the financial sector, and the energy sector. In the energy sector, the strategy aims to restore American dominance in oil, gas, coal, and nuclear energy, explicitly disregarding climate change considerations. This strategy is contrasted with Europe’s approach to climate change. With regard to reindustrialisation, the strategy suggests a focus on emerging technologies and the strategic use of tariffs. The importance of emerging technologies and of the United States maintaining competitiveness in this area is also highlighted throughout the economic security strategy.
United Kingdom – House of Commons Report Finds UK Economic Security Framework Unfit for Future Challenges
On 24 November 2025, the United Kingdom’s House of Commons published its Eleventh Report of Session 2024-26 titled ‘Towards a New Doctrine for Economic Security’, assessing the growing threats to the United Kingdom’s economic security and possible responses. The report concludes that the current security regime is not adequate for future challenges and calls for significant improvements to economic security.
The report suggests a “whole-of-society approach” bringing together government and the market. This should be implemented through a doctrine consisting of six elements: (i) early diagnosis of risks, (ii) domestic capabilities in key industries, (iii) diversification of critical supply-chains, (iv) defence against hostilities in markets and cyberspace, (v) deterrence of coercion and malign influence, (vi) cooperation with allies to increase resilience. It is proposed that the doctrine be adopted into law through an Economic Security Bill.
