By Oliver Bretz
In my reading, the 2025 summary of Belgian FDI screenings highlights a striking feature that UK dealmakers should not overlook: While the US economy is many times larger than the UK’s, filings linked to US investors exceed UK-related filings by a much smaller margin. By contrast, UK investors account for a substantial share of Belgian FDI notifications across 2024 and 2025, representing roughly a quarter of all filings over that period.
This pattern is not accidental. It is largely a structural consequence of geography and Brexit. The Belgian FDI regime applies to non-EU companies and individuals, and the UK is now the only major non-EU economy in Belgium’s immediate geographic and economic vicinity. UK businesses remain deeply integrated into Belgian and wider EU supply chains and continue to invest frequently across borders, but they now do so from outside the EU perimeter.
The number of Belgian FDI notifications increased from 68 in 2023–2024 to 100 in 2024–2025. This increase is widely understood to reflect growing awareness of the regime among companies and their advisers, rather than a sudden shift in enforcement policy.
At the same time, the Belgian screening system is notably broad in scope. It is built around an expansive concept of “establishment”. The existence of a Belgian subsidiary is not required, the acquisition of material or decisive influence is not required, and in sensitive sectors even minority investments at the level of 10% of the voting rights may fall within scope. As a result, UK-linked transactions are relatively more likely to trigger Belgian FDI scrutiny, sometimes unexpectedly and even where Belgium is not a central focus of the deal.
Looking ahead, the Belgian regime will likely need to be aligned with the revised EU FDI Regulation, which aims at greater harmonisation and more stringent screening standards across Member States. The bottom line is that for UK companies and investors, Belgian FDI screening has become a recurring feature of deal planning. Early assessment is no longer optional.
The Screening of Foreign Direct Investment – Annual Report 2024-2025 can be found here.
