Belgium’s Second Annual FDI Screening Report: A Balance Between Openness and National Security

By Joost Haans & Sander De Volder, DLA Piper UK LLP (Brussels)

Belgium’s second annual report on its foreign direct investment screening mechanism, which was published on 12 September 2025 and covers the period July 2024 to June 2025, offers more than just numbers. It is a snapshot of how one of Europe’s most open economies for foreign investment is trying to find a balance between attracting international capital while shielding itself from risks to national security and strategic autonomy.

The headline figures – 100 cases notified, none blocked, and only one subject to conditions – might suggest the system is a mere formality. But a closer look reveals a maturing screening mechanism, deepening European integration with cross-border cooperation between national authorities, and emerging tensions between openness and vigilance, as not all cases are cleared without conditions or an in-depth screening phase.

Background

Belgium has historically been among the most trade- and investment-friendly countries in Europe. Its location at the heart of the EU, combined with strong logistics, R&D, and technology ecosystems, makes it an ideal landing spot for international investors.

Geopolitical turbulence, from U.S.-China rivalry to supply chain fragmentation, has made governments more cautious about who controls their critical infrastructure, data, and technologies. Belgium was relatively late in introducing a national FDI screening mechanism (mid-2023), but it is catching up swiftly. The second FDI screening annual report shows how this mechanism is now firmly embedded in Belgium’s economic governance.

The basic principle is straightforward: foreign investors are welcome, but when they acquire stakes in strategic sectors, such as energy, digital infrastructure, health, or dual-use technologies, the Belgian FDI authority (i.e., the various governments of Belgium) reserves the right to ask whether the deal is compatible with national security and public order or would affect Belgium’s strategic interests.

The figures

One hundred transactions were formally notified in the past year. Of these, 89 were approved without conditions, one was approved with mitigating measures, two were withdrawn, and eight were still pending when the reporting period closed. The authority eyed 16 non-notified transactions, requesting the investor in question to provide reasons and further details to determine whether the transaction was nonetheless notifiable. Until now, no fines were imposed for failure to notify.

Crucially, no deals were outright blocked. This could be read as evidence that Belgium has struck a pragmatic balance, i.e., scrutinizing deals without scaring investors away. But it also raises a critical point, if no transactions are prohibited, is the jurisdictional scope too broad or is Belgium genuinely that safe an environment for foreign investors? Other EU countries, such as Germany and France, have occasionally vetoed acquisitions. Belgium’s record of approving everything could signal confidence, or it could point to a reluctance to intervene, at least so far.

The financial scale of these investments also underscores their importance. The total estimated transaction value was EUR 131.5 billion, with roughly EUR 7 billion tied to the Belgian part of transactions. These do not represent marginal capital flows, as they significantly help shape the country’s industrial and technological future and overall competitiveness.

Sectoral focus

Perhaps the most telling insight lies in which sectors dominate in attracting foreign direct investment control. The top categories between July 2024 and June 2025 were:

• Sensitive information and personal data (21 cases) being the most prevalent, which not coincidentally is one of the broadest defined sectors in material scope;
• Digital infrastructure (14 cases), confirming the shift to an increasingly digital economic landscape;
• Energy (13 cases), clearly linked with safeguarding and self-sufficiency of Belgium’s energy supply;
• Health and biotech (12 cases), a clear marker of Belgium’s critical R&D role in a global context;

• Dual-use (9 cases), concurring with an increased global focus on defence capabilities and related expenditures.

This reflects a shift in what governments consider “strategic”. Traditional and physical concerns like energy security remain, but the largest category was data-related. This mirrors global anxieties about digital sovereignty, the control of personal information, and the security of communication networks. The fact that sensitive information, data protection and digital infrastructure top the list suggests Belgium is increasingly aware that critical assets are not just physical assets but also algorithms, data and networks.

Geography of investment origins

Another interesting finding is the geography of where the money comes from. Investors from the U.S. accounted for nearly half of all cases (45 out of 100), followed by the UK (22), Japan (8), Canada (7), and China (5). On one hand, this shows that Belgium’s main investors are generally from established allies. On the other, the small but notable presence of Japanese and Chinese investors highlights why the mechanism exists in the first place, knowing that even a handful of cases involving sensitive sectors could trigger national security concerns.

Within Belgium, the regional breakdown shows Flanders far ahead (71 cases), followed by Brussels (31) and Wallonia (16). This is unsurprising: Flanders hosts a dense industrial base, high-tech R&D activity and many logistics hubs, while Brussels attracts service and headquarters functions.

Interestingly, only five cases were escalated to a full screening procedure. Of these, most were eventually cleared, one was approved with conditions, and two remain unresolved. This shows the system is selective and will only intervene when absolutely necessary, as the vast majority of investments do not even trigger the deeper phase 2 screening stage.

The conditional approval is revealing. In that case, the investor had to take steps such as storing sensitive technology with a Belgian third party, guaranteeing continuity of operations, and appointing compliance officers. These kinds of measures illustrate the system’s flexibility, rather than banning deals outright, it can impose safeguards to reduce risks.

Impact on deal timelines and foreign investor confidence

One of the criticisms often levelled at screening mechanisms is that they introduce red tape and uncertainty. The Belgian case data however, tends to suggest otherwise:

• The average time to start a review after submission was just two days.
• Reviews (phase 1) took about 31 days on average, only slightly over the legal maximum of 30 (due mainly to pauses for additionally requested information).
• Even screening procedures (phase 2), the more complex stage, were resolved in about seven weeks on average.

From an investor’s perspective, these are mandatory yet manageable timelines. The fact that Belgium publishes an annual report with such granular statistics also builds transparency and predictability, two aspects that investors value highly in terms of deal certainty and timeline.

Main takeaways

Looking beyond the descriptive data, several broader lessons emerge from Belgium’s second annual FDI report:

• The system is functional and not symbolic. The sheer number of cases (100 in a year) shows that screening is not an exceptional procedure, and that it has become routine for foreign investors deploying capital in Belgium.
• Belgium favours mitigation over prohibition. The absence of blocked deals could mean Belgium has not yet faced a truly problematic case, but it also suggests a policy preference: allow investment with safeguards rather than outright bans.
• Data is the new economic battleground. The prominence of personal information and digital infrastructure highlights that the security frontier is shifting from factories and pipelines to data centres and algorithms.
• Economic allies dominate investment, but China is approaching. U.S., Canadian and UK investors lead, but the small number of Chinese cases underscores why vigilance is necessary.
• Transparency builds trust. By publishing detailed statistics, Belgium reduces uncertainty for investors and signals that screening is rules-based, not arbitrary.
• Europe is moving toward convergence. Belgium’s experience shows how national systems can align with EU-level reforms, offering a glimpse of a more coherent European investment security policy.

Current state of affairs: controlled openness

Belgium’s second annual FDI screening report confirms that the country is learning how to manage the tension between openness and security. Far from isolating itself, Belgium remains a highly attractive destination for foreign investors, with billions flowing into its economy. But it is now doing so under a framework that acknowledges new geopolitical and technological risks.

The broader takeaway is that guarded openness is becoming the new normal, not just in Belgium, but across Europe. Foreign investment remains welcome, but only if it aligns with long-term national and European interests.