Since July 2023, Belgium has established a foreign direct investment (FDI) national security screening mechanism in accordance with the Cooperative Agreement of November 30, 2022.[1]

The Interfederal Screening Commission (“Comité de filtrage interfédéral”/”Interfederale Screeningscommissie”) (the “ISC”) is the competent authority in Belgium that screens transactions which reach the threshold of filing. This notification threshold is reached when a foreign investor acquires control in a Belgian company or entity active in the  sensitive sectors.

Control is deemed to be acquired when the foreign investor obtains at least 10% or 25% of the voting rights, creating the possibility to exercise a decisive influence over the activity of the company or entity. Sensitive sectors include, among others, the defence sector, energy, cybersecurity, technologies, electronic communications, digital or vital infrastructure, AI, semiconductor technology.  

Key takeaways from the second annual report on FDI screening

According to the second annual report, issued on September 16, 2025[2] by the secretariat of the ISC, between July 2024 and June 2025, 100 investment files were reviewed.

  • 89 investments have been approved;
  • 1 file was cleared with corrective measures;
  • 2 applications have been withdrawn by the investors;
  • 8 files are still pending;
  • No investment has been refused; 
  • In 5 files, a second phase, i.e. screening procedure, was initiated;
  • 16 non-notified investments required additional information and explanations to determine whether notification to the screening mechanism was necessary.

Most investors came from the United States (45% of the notified files), followed by the United Kingdom (22%), Japan (8%), Canada (7%), and China (5%).

The main sectors of investment are sensitive information/personal data (21%), digital infrastructure (14%), energy (13%), health (12%) and dual use technology (9%).

The total estimated investment amount for transactions under notification is EUR 131,523,960,089.

In 22% of the files, the main target was one or more Belgian entities. In 59% of the files the transactions are full acquisitions. In 91% of the transactions, the investor acquired control of the target company. Internal restructuring occurred in 22% of the files. Only in 12% of the investments a new entity was established for the transaction.

The legal review time for a screening procedure is a maximum of 30 days. However, in practice, the average review time is 31 days. The duration of a screening procedure can vary significantly depending on several factors, such as extension requests, the EU cooperation mechanism, requests for additional information, and the associated response times.

Conclusion

There were more files in the second year following the implementation of the screening mechanism than in the first year (from 68 files to 100 files). The estimated total value of investments demonstrates that many foreign investors continue to choose to invest in the Belgian market. Energy has emerged as one of the key sectors involved in the screening. Data, digital infrastructure, and healthcare still remain among the top five key sectors. No transaction has been rejected, which indicates a continuous open policy for foreign investments into the country.  

For more information on FDI, national security review and investment review in Belgium and EU, please contact DALDEWOLF CHINA & ASEAN DESK (Xiufang Ava Tu, [email protected]).

[1] Accord de coopération du 30 novembre 2022 entre l'Etat fédéral, la Région flamande, la Région wallonne, la Région de Bruxelles Capitale, la Communauté flamande, la Communauté française, la Communauté germanophone, la Commission communautaire française et la Commission communautaire commune visant à instaurer un mécanisme de filtrage des investissements directs étrangers/Samenwerkingsakkoord van 30 november 2022 tussen de Federale Staat, het Vlaamse Gewest, het Waals Gewest, het Brussels Hoofdstedelijk Gewest, de Vlaamse Gemeenschap, de Franse Gemeenschap, de Duitstalige Gemeenschap, de Franse Gemeenschapscommissie en de Gemeenschappelijke Gemeenschapscommissie tot het invoeren van een mechanisme voor de screening van buitenlandse directe investeringen.

[2] Annual report 2024-2025 Screening Foreign Direct Investments from the Belgian Federal Public Service Economics.