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Dec 18, 2025

Omnibus I at the End of the Line

On Monday 8 December 2025, the EU trilogue found an agreement regarding the so-called “Omnibus I” proposal that had been put forward by the European Commission on 26 February 2025. The Omnibus I is part of the simplification packages proposed by the Von der Leyen Commission II to reduce the regulatory compliance burden on companies. It deals specifically with the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The so-called “Stop-the clock” directive adopted in April 2025, also as part of Omnibus I, already postponed the date of application of the CSRD and CSDDD. This new directive intends to simplify certain substantive provisions of the CSRD and CSDDD.

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Dec 10, 2025

NIS-2 Implementation Act: New compliance obligations for numerous companies

After the German Bundestag passed the NIS-2 Implementation and Cybersecurity Strengthening Act (“NIS2UmsuCG”) in November 2025 and the Bundesrat approved the act, it was published in the German Federal Law Gazette on 5 December 2025 and came into force the following day. The NIS2UmsuCG transposes the NIS2 Directive (EU) 2022/2555, which was adopted at EU level, into national law after some delay. It provides for comprehensive amendments, in particular to the Act on the Federal Office for Information Security (Gesetz über das Bundesamt für Sicherheit in der Informationstechnik – “BSIG”). By way of the NIS2UmsuCG, further companies will now have to fulfill the cybersecurity obligations laid down in the amended BSIG in addition to the already previously regulated operators of critical facilities (“KRITIS”). The scope of the BSIG will thus be extended to approximately 30,000 additional companies in many economic sectors.

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Dec 5, 2025

Implementation of the EU Packaging and Packaging Waste Regulation (PPWR) in Germany

On 17 November 2025, the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety (BMUKN) presented the draft bill for the new Packaging Law Implementation Act (VerpackDG-E). The current Packaging Act (VerpackG) is to be adjusted to align with the requirements of the EU Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40, PPWR), which will apply from 12 August 2026. This article provides an overview of the background and key changes in packaging legislation.

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Nov 14, 2025

Fifth EU Annual Report on Foreign Direct Investment

On October 14, 2025, the European Commission (the “Commission”) published its fifth annual report on the screening of foreign direct investments in the Union. In it, it describes the latest developments in the area of foreign direct investments (“FDIs”) in the EU, as well as legislative developments at the member state and European level and other trends in FDI screening.

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Oct 31, 2025

Customs Law: ECJ clarifies ex officio reimbursement

In its judgment C-206/24 of 1 August 2025, the European Court of Justice (ECJ) ruled on the conditions under which a customs authority is obliged to reimburse import duties levied without legal basis ex officio. The ECJ clarified: Ex officio reimbursement requires that the customs authority itself determines within three years of the entry in the accounts that the duties were levied without legal basis – and that it also knows the identity of the affected person and the reimbursement amount. If this information is missing, the authority must take reasonable, but not disproportionate, measures to obtain it. If unsuccessful, the obligation to reimburse terminates after the deadline – even if the authority determined within the deadline that the duties were not legally owed.

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Oct 29, 2025

The 19th Sanctions Package against Russia

On October 23, 2025, the European Union (EU) adopted its 19th package of sanctions against Russia. The new package targets the energy and financial sectors in particular. At the same time, however, export and service bans were tightened and personal restrictions expanded.

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