On 12 September 2025, the Federal Public Service Economy published its second annual report (the Report) on the screening of foreign direct investments (FDI) and the operations of the Belgian Interfederal Screening Committee (the ISC). The Report covers the period of 1 July 2024 to 30 June 2025, comprising the second year of implementation of the Belgian FDI screening mechanism, and follows the publication of a similar report in 2024 (See, VBB Belgian Antitrust Watch – News and Insights of 7 October 2024).

Clean Record Continues, but Figures Suggest More Mature ISC

The Report shows that the procedure has continued to run smoothly for most notifications with only few delays and, so far, no blocking decisions.

Between 1 July 2024 and 30 June 2025, the ISC handled 100 notifications, reflecting a significant increase over the 68 notifications recorded last year. 89 of those notifications have been approved without any accompanying measures, while 8 were still pending on 30 June 2025.

Just like last year, only five notifications entered into a second in-depth screening phase. Three of these notified investments have already been cleared, two of them without mitigating measures (and requiring on average 49 days to be processed). Two cases remain under review.

Importantly, for the first time investments have been made subject to mitigating measures. In one case, these included:

• placing specific technology, source code, and/or know-how in the custody of a third party in Belgium;
• guarantees to ensure the continuity of defined processes; and
• the appointment of compliance officers.

In addition, while the Report confirms that again no notified investments were rejected, it reveals that over the covered period two notifications ended up being withdrawn.

Unlike last year, the ISC has not opened any ex officio investigations. Interestingly, however, the ISC has proactively launched 16 inquiries into non-notified investments, requesting information with a view to determining whether these should have been notified. Unfortunately, the Report does not indicate if these inquiries resulted in a subsequent “voluntary” notification.

Overall, these figures reveal a more active screening approach under the control of a more experienced ISC. Not only are many more investments being notified, the ISC is adopting a more targeted approach by opening relatively less in-depth reviews, but more often entering into negotiations on mitigating measures. The ISC’s proactive inquiries into non-notified investments also display a more active policing of the market.

Timing

During the second year of implementation, notifications continued being accepted quickly. The first phase review files were on average closed in 31 days, just like last year.

The Report again shows the importance of filing a complete notification. In 85% of cases, the ISC was able to immediately accept a complete filing. This marks a significant increase over last year’s 44%. However, in 15% of cases, information was missing from the initial submission, preventing the ISC from accepting the filing and causing an average acceptance delay of two days. 7 notifications received requests for additional information during the notification process, marking an increase from four such requests last year.

The Report also emphasises the importance of the Coordination Committee on Intelligence and Security (CCIS). The CCIS plays a key role in establishing a link between the FDI screening mechanism and the Belgian intelligence, security, cybersecurity, and crisis management services, as well as the Federal Public Services of Defence, Foreign Affairs, and Justice. Its main role is to assess the risks for national security, public order, and strategic interests. The CCIS has 25 days to issue its opinion, subject to exceptions which the Report indicates remain rare (in less than 10% of notifications).

Data, Digital Infrastructure and Health Remain Most Screened Sectors

The sectors targeted most by the notifications involved sensitive information and personal data (21%), digital infrastructure (14%), energy (13%), healthcare (12%), and dual use (9%):