Alber & Geiger Newsletter – Q4 2026

I. PUBLIC PROCUREMENT: COMMISSION PROPOSES NEW EU FRAMEWORK

On 9 September 2026, the Commission published its proposed Public Procurement Act, replacing the three existing procurement directives with a single regulation. The proposal opens a new legislative debate on how public purchasing can support competitiveness and supply resilience.

Why it matters:
Suppliers, manufacturers and public contractors should assess potential changes to tender access and procedures, and prepare evidence on how the proposed framework would affect their ability to compete across the EU.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

II. INNOVATION: NEW EUROPEAN INNOVATION ACT PROPOSAL

The Commission proposed the European Innovation Act on 9 September 2026. It seeks to improve the route from research to market through a harmonised framework for R&D procurement and EU-wide tools for intellectual-property valuation and commercialisation.

Why it matters:
Technology companies, investors and research institutions should monitor the legislative process and identify barriers to procurement and IP-backed finance that they can bring to policymakers during negotiations.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

III. CYBERSECURITY: CYBER RESILIENCE ACT REPORTING BEGINS

From 11 September 2026, manufacturers of products with digital elements must report actively exploited vulnerabilities and severe security incidents under the Cyber Resilience Act. Early warnings are due within 24 hours and fuller notifications within 72 hours. Most other obligations apply from 11 December 2027.

Why it matters:
Hardware and software manufacturers should review incident escalation, reporting responsibilities and notification workflows now, while planning for the broader product-security requirements coming in 2027.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

IV. CUSTOMS: COUNCIL APPROVES LANDMARK REFORM

On 3 September 2026, the Council approved the customs reform text, including a new EU Customs Authority and Data Hub. It introduces greater responsibilities for non-EU e-commerce platforms and provides for a small-parcel handling fee by 1 November 2026. Parliament approval and publication were identified as the next steps.

Why it matters:
Online marketplaces, importers and logistics operators should monitor final adoption and implementing measures, assess the impact on parcel costs and prepare for changes to customs data and importer responsibilities.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

V. ARTIFICIAL INTELLIGENCE: REVISED TIMELINES AND Q4 ACTIONS

The Council adopted the AI simplification regulation on 29 June 2026. Its revised timetable sets high-risk rules for stand-alone systems on 2 December 2027 and for systems embedded in products on 2 August 2028. The Council identifies 2 December 2026 as the deadline for providers to implement transparency solutions for artificially generated content.

Why it matters:
AI providers and businesses deploying AI should revisit their implementation plans,assess which transparency duties apply to their products and engage on forthcoming guidance and sector-specific requirements.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

VI. SANCTIONS: EXPANDED FINANCIAL AND SUPPLY-CHAIN EXPOSURE

The EU adopted its 21st Russia sanctions package on 23 July 2026, expanding restrictions on financial institutions, crypto services, the shadow fleet and entities supporting Russia’s military industry. The measures also target circumvention involving operators in third countries.

Why it matters:
Financial institutions, exporters, shipping companies and multinational businesses should reassess counterparties, payment routes and supply-chain exposure, including relevant transition periods and restrictions on dual-use goods.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

VII. SPACE SECURITY: EU STRENGTHENS ITS THREAT RESPONSE

On 28 September 2026, the Council strengthened the EU Space Threat Response Architecture. The decision expands its coverage to threats against Member States and their space systems and services, enables provisional EU responses to urgent threats and establishes a space security toolbox, including the possibility of targeted restrictive measures.

Why it matters:
Satellite operators, space technology companies and businesses relying on space services should assess operational exposure and monitor how the new response framework shapes security cooperation and policy priorities.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

VIII. AGRIFOOD: COUNCIL AGREES FOOD AND FEED SAFETY POSITION

On 30 September 2026, the Council agreed its negotiating position on the remaining food and feed safety simplification package. It covers pesticide residues, plant protection products, biocides and other requirements. Negotiations with Parliament will follow its position, with an agreement targeted by year-end.

Why it matters:
Agrifood businesses, importers and chemical producers should monitor proposed changes to authorisations and residue limits, assess supply-chain implications and contribute evidence before the final rules are agreed.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.

Also on the regulatory radar this quarter

  • Public Procurement Act and European Innovation Act negotiations offer opportunities for early stakeholder engagement.
  • Customs implementing measures will determine operational detail and small-parcel costs.
  • AI transparency and cyber incident reporting require attention alongside onger-term implementation planning.

Key dates & actions

  • Now: Check Cyber Resilience Act reporting workflows; the reporting obligations have applied since 11 September 2026.
  • By 1 November 2026: Monitor the customs handling-fee timetable and the Commission’s decision on its level, as announced by the Council.
  • 2 December 2026: Review the AI-generated-content transparency deadline identified in the Council’s AI simplification announcement.
  • Throughout Q4: Prepare policy positions on procurement, innovation and agrifood proposals, and monitor institutional negotiations.
  • Throughout Q4: Monitor implementation of the new EU space threat response framework and review sanctions exposure before transactions or exports.

If any of these files affect your operations, supply chains, investments or transactions, Alber & Geiger can design tailored engagement strategies with the European Commission, Parliament, Council and Member State governments. Structured advocacy, coalition-building and technical evidence can help organizations contribute to policy development.

Alber & Geiger can help organizations voice their interests and concerns to EU policymakers.


Sources

Official EU publications underpin the news summaries. The “Why it matters” paragraphs and actions are Alber & Geiger editorial analysis. Click a source below to read the announcement.

  1. Public Procurement Act proposal – 9 September 2026
  2. European Innovation Act – Commission proposal, 9 September 2026
  3. Cyber Resilience Act reporting – 11 September 2026
  4. EU customs reform – Council approval, 3 September 2026
  5. AI simplification – Council adoption, 29 June 2026
  6. 21st Russia sanctions package – 23 July 2026
  7. EU space threat response – Council decision, 28 September 2026
  8. Food and feed safety – Council position, 30 September 2026