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The new EU foreign subsidies regime will impact all multinational companies regardless of their country of origin. As of October 12, companies engaging in large transactions and bidding for large public procurement contracts in the EU are obliged to seek prior clearance from the European Commission. Implementing rules provide some welcome reporting relief, but the notification process requires that companies put in place mechanisms to track in real time a wide range of foreign financial contributions granted directly or indirectly from non-EU state funding.

Being prepared will avoid negatively impacting your ability to bid for large tenders or having a transaction held up because the review deadlines do not start running unless the foreign subsidies’ notification is complete. Upfront preparation will also allow you to engage early in prenotification contacts with the Commission to obtain waivers where appropriate to further reduce the notification reporting burden.

This Starter Kit provides a high-level summary of the new regime and some tips on how to approach setting up a system that will allow you to gather the information you will be required to report on should you trigger a notification. If you are interested in learning more, including having access to our FSR Reporting Tool and related Q&A, please reach out to your usual Baker McKenzie contact or one of our FSR experts.

FSR Starter Kit



Fiona Carlin is the head of the EU Competition & Regulatory Affairs practice in Brussels. She is the former Chief Executive of much of Baker McKenzie’s EMEA Region and the former Chair of the Firm’s Global Competition and Antitrust Law Practice comprising more than 320 lawyers in over 40 countries. She has remained an active practitioner throughout her various leadership roles with a particular focus on regulated industries.
Fiona is also the Chair of the European Advisory Board of Catalyst, a leading non-profit organisation dedicated to expanding opportunities for women and business. She was a founding and long-standing member of Baker McKenzie's Global Diversity & Inclusion Committee and is dedicated to creating an inclusive high performance culture where the talent of our lawyers and business professionals can flourish.
Fiona has been listed in "The International Who’s Who of Competition Lawyers" since 2009, and is among Global Competition Review's Top 100 Women in Antitrust. Chambers quotes clients as citing her "legal and pragmatic advice" and describing her as "globally minded".


Bram Hoorelbeke is a counsel in Baker McKenzie's European Competition & Regulatory Affairs Practice in Brussels. He started his career in 2007 as a lawyer in the EU, Competition and Regulatory department of a highly regarded Benelux law firm. Bram joined Baker McKenzie in 2017 and is the assistant editor of Competitio, the leading review on Belgian Competition law.


Nina Niejahr is a senior counsel in the Firm's Brussels-based EU Competition & Regulatory Affairs Practice. She has over 20 years of experience in advising clients on all aspects of EU law, focusing on State aid and competition law. Nina is ranked by Chambers for her State aid practice and listed by Who's Who Legal and the German JUVE directory as recommended/"oft empfohlen". Nina also regularly litigates in the EU Courts in Luxembourg. She has published and speaks at seminars and conferences on a variety of topics of EU State aid law and litigation.

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