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The Act on the Adjustment of Criminal Offenses and Penalties for Violations of Restrictive Measures of the European Union (Gesetz zur Anpassung von Straftatbeständen und Sanktionen bei Verstößen gegen restriktive Maßnahmen der Europäischen Union), which came into force on 6 February 2026, adapts in particular the Foreign Trade and Payments Act (Außenwirtschaftsgesetz – AWG) and the Foreign Trade and Payments Ordinance (Außenwirtschaftsverordnung – AWV) to the requirements of the EU Directive on the definition of criminal offences and penalties for the violation of Union restrictive measures, Directive (EU) 2024/1226. The aim is to close loopholes in criminal liability and create a hrmonized, effective EU-wide criminal regime for violations of EU sanctions. The changes will in some cases lead to an increase in penal risks for companies and responsible persons. Numerous violations of EU sanctions that were previously only punishable as administrative offenses under German law will in future be prosecuted as criminal offenses, while at the same time new offenses will be introduced and existing penalties expanded. The most important changes for companies are outlined below.

With the political agreement on a Free Trade Agreement (“FTA”) between the European Union (“EU”) and India on January 27, 2026, a significant breakthrough has been achieved after years of negotiations. This article summarizes the key elements of the planned agreement and outlines the next steps toward its entry into force.

On 9 January 2026, the Mercosur-EU-Free Trade Agreement (Mercosur-EU-FTA) was approved by a majority of the member states of the European Union. This brings the agreement close to the finish line. This article provides an overview of the agreement's key aspects and the next steps.

On December 8, 2025, an agreement was reached in the EU trilogue procedure on the so-called "Omnibus I" proposal, which the European Commission had presented on February 26, 2025. Omnibus I is part of the simplification packages proposed by the Commission to reduce the regulatory burden on companies. The Omnibus I package addresses, in particular, the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). The so-called "stop-the-clock" directive, which was also adopted as part of Omnibus I in April 2025, had already postponed the application of the CSRD and CSDDD. The new directive is now intended to simplify certain substantive provisions of the CSRD and CSDDD.

After the German Bundestag passed the NIS2 Implementation and Cybersecurity Strengthening Act (“NIS2UmsuCG”) in November 2025 and the Bundesrat approved it, the Act was published in the Federal Law Gazette on December 5, 2025, and entered into force the following day. The NIS2UmsuCG transposes the NIS2 Directive (EU) 2022/2555, adopted at the EU level, into national law, although with some delay. It introduces comprehensive amendments, particularly to the Federal Office for Information Security Act (“BSIG”). With the NIS2UmsuCG, in addition to the operators of critical infrastructure (“KRITIS”) already regulated, further entities will now be required to comply with the cybersecurity obligations stipulated in the amended BSIG. The scope of the BSIG is thus extended to approximately 30,000 additional companies across numerous sectors of the economy.

On November 17, 2025, the Federal Ministry for the Environment, Climate Protection, 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 adapted to the requirements of the EU Packaging Regulation (Regulation (EU) 2025/40, Packaging and Packaging Waste Regulation – PPWR), which will apply from August 12, 2026. This article provides an overview of the background and key changes in packaging law.

On 14 October 2025, the European Commission (the “Commission”) published its fifth annual report on the screening of foreign direct investments in the Union. This report describes the latest developments in foreign direct investments (“FDIs”) in the EU, as well as legislative developments at Member State and European levels and other trends in FDI screening.

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 refund import duties levied without legal basis ex officio. The ECJ clarified that a refund ex officio requires the customs authority to determine, within three years of the entry in the accounts, that the duties were levied without legal basis – and to know the identity of the person concerned and the amount of the refund. If this information is lacking, the authority must take reasonable, but not disproportionate, measures to obtain it. If this is not possible, the obligation to refund lapses after the deadline – even if it has determined within the deadline that the duties were not legally owed.

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