The Interfederal Screening Committee (ISC) has published its annual report for 2024-2025, offering key insights into the operation of Belgium’s foreign direct investment (FDI) screening mechanism. Now in its second year, the number of cases notified has increased, but does not appear to have led to longer average timelines for the verification procedure.
Between July 2024 and June 2025, 100 notifications were received. None was blocked, but two were withdrawn by the investors during the screening process. The report does not detail the reasons for the withdrawals, but it could suggest that those procedures would have faced some difficulty in obtaining clearance. Eighty-nine investments were approved unconditionally and two, one of which had been pending since the previous year, were authorised subject to mitigating measures. These numbers suggest that the ISC aims to ensure that national security concerns are addressed without unnecessarily hindering foreign investment. The ISC does keep an eye out for missed filings. In 16 instances of non-notified investments, the ISC requested additional information to determine whether notification was required.
The United States accounted for 45% of the notified investments, followed by the UK, accounting for 22%.
Key sectors under review included sensitive information/personal data, digital infrastructure, energy, health and dual use.
Mitigating measures included:
- storing specific technology, source code, and/or knowhow with a designated third party in Belgium;
- the provision of assurances to maintain the continuity of certain processes; and
- the appointment of compliance officers.
The average processing time during the verification procedure was 31 days, slightly exceeding the legal time limit of 30 days in certain cases. The report explains that this extension can occur when the procedure is suspended to request additional information or when the deadline falls on a non-working day. In seven cases, the ISC secretariat requested further details from investors, which contributed to the extended timelines.
The report highlights enhanced interfederal cooperation and efficient coordination with European partners. Looking ahead, the report points to ongoing review of the relevant EU Regulation for the screening of foreign direct investments aimed at further harmonising national regimes. To conclude, the President of the ISC expresses a “commitment to a rigorous, transparent, and proportionate assessment of investments, in full respect of the rule of law and European obligations.”
The full report can be accessed here.
