A&G Newsletter — Q4 2025

I. Commission unveils 2026 Work Programme: “Europe’s Independence Moment”

The European Commission set out its 2026 Work Programme on 21 October 2025, prioritising security, competitiveness, and simplification across the acquis. The package includes dozens of new initiatives, withdrawals, and a strong simplification angle, with factsheets and annexes published alongside the main communication.

Why it matters: Expect targeted streamlining of compliance burdens, recalibration of files that stalled in the last cycle, and a tighter linkage between industrial policy, security, and climate goals.

II. EUDR: targeted changes—core timelines largely intact, phased enforcement proposed

On 21 October 2025, the Commission proposed targeted amendments to the EU Deforestation Regulation (EUDR). The draft keeps the 30 December 2025 application date for large and medium undertakings, introduces a six-month enforcement grace period to 30 June 2026, and shifts obligations for micro and small undertakings to 30 December 2026. The proposal also clarifies transitional arrangements.

Why it matters: Importers of covered commodities should proceed on the basis that 30 Dec 2025 remains the operative date for most operators, with grace only on enforcement—not on substantive obligations. Supply‑chain due diligence, data, and geolocation readiness can’t wait.

III. Defence industry: political deal on the European Defence Industry Programme (EDIP)

Parliament and Council reached a political agreement on 16–17 October 2025 on EDIP—aimed at common procurement, industrial ramp‑up, and delivery of the Defence Readiness Roadmap 2030.

Why it matters: EDIP will shape eligibility, financing, and timelines for cross‑border defence projects. Companies should map pipelines against anticipated calls and prepare for streamlined participation rules.

IV. Crisis preparedness: Council gives final green light to EU compulsory licensing in crises

On 27 October 2025, the Council approved a regulation enabling compulsory licensing of IP during EU‑level crises to ensure availability of critical products.

Why it matters: Health, life‑sciences, and IP‑rich sectors should reassess risk allocations in supply, manufacturing, and consortium agreements—especially where surge capacity and cross‑border manufacturing are relevant.

V. Workforce information & consultation: revision of the European Works Council (EWC) Directive adopted

The European Parliament adopted the revised EWC directive on 9 October 2025, and the Council confirmed the revision on 27 October 2025. The update aims to strengthen worker representation in multinationals and clarifies procedures for information and consultation.

Why it matters: Multinationals with EU footprints should prepare for changes to EWC agreements, timelines, and potential enforcement—HR, legal, and industrial‑relations teams need to align early.

VI. Borders & mobility: EU Entry/Exit System (EES) roll‑out begins

From 12 October 2025, Member States started introducing the new digital Entry/Exit System at external borders. EES will register non‑EU nationals’ entries and exits and replace passport stamping, with phased national deployments.

Why it matters: Carriers, airports, tourism, logistics and frequent travellers should anticipate procedural changes, peak‑time bottlenecks during ramp‑up, and data‑system impacts.

VII. Road transport: targeted amendment to eurovignette (tolls & user charges)

On 2 October 2025, the Commission tabled a targeted amendment to clarify and simplify provisions of the eurovignette directive on road tolls and user charges. The aim: legal certainty and consistent application.

Why it matters: Hauliers, shippers, and fleet operators may see changes in cost structures and reporting once the amendment advances.

VIII. Agriculture: Commission’s “future CAP” proposal

Published 24 October 2025, the Commission’s proposal for the next Common Agricultural Policy seeks tighter alignment with climate objectives while supporting farm viability, investment and innovation.

Why it matters: Food, forestry, inputs and agri‑tech should assess funding channels, sustainability metrics, and conditionalities foreseen in the next CAP cycle.

Also on the regulatory radar this quarter

  • Sustainability reporting & due diligence “simplification”: Parliament’s Legal Affairs Committee backed draft changes reducing scope and simplifying rules.
  • 2040 climate target: Member States are haggling over flexibilities to land the –90% by 2040 goal ahead of COP30.
  • Foreign Subsidies Regulation enforcement: The Commission continues to adopt decisions under the FSR toolbox—deal planning should factor FSR timelines.

Key dates & actions

  • EUDR: Plan to comply by 30 Dec 2025 if large/medium; micro/small targeted for 30 Dec 2026; proposed grace on enforcement to 30 Jun 2026—subject to adoption.
  • EES: Expect phased deployments from Oct 2025; update passenger communications and border‑ops playbooks.
  • EDIP: Prepare project pipelines and consortia for calls following the political agreement.

If any of these files affect your operations, supply chains, workforce, or transactions, A&G can design tailored engagement strategies with the Commission, Parliament, Council, and national authorities—leveraging structured advocacy, coalition‑building, and technical input to shape outcomes.