CRRC(SH:601766) Di Yi Cai Jing·2026-01-11 10:44Core Insights - The EU's Foreign Subsidies Regulation (FSR) has led to over 200 transactions being reported to the European Commission by mid-October 2025, significantly exceeding the initial estimate of 30 transactions per year [1][4] - The FSR's broad applicability and complex reporting requirements have created substantial compliance burdens and uncertainties for both the EU and multinational transaction participants [1][5] Group 1: FSR Implementation and Impact - The FSR has triggered a large number of submissions, with nearly half (47%) of reported transactions involving EU investors, many of which have no clear connection to jurisdictions outside the EU [4] - Compliance procedures under the FSR are burdensome, requiring companies to detail all foreign financial support received over the past three years, often necessitating cross-departmental collaboration [5] - The European Commission has initiated an evaluation of the FSR, responding to feedback that the current review system is cumbersome and slows down transaction processes [5][6] Group 2: Future Developments and Regulatory Adjustments - Future enforcement of the FSR is expected to become more targeted, with potential simplification of review processes for low-risk transactions while maintaining vigilance for those in critical sectors [2] - A draft guideline from the European Commission aims to clarify the application of key FSR provisions, including the assessment of distortive effects and the initiation of pre-review for transactions below the reporting threshold [6] Group 3: Impact on Chinese Enterprises - Chinese enterprises have faced significant regulatory challenges under the FSR, with the Chinese Ministry of Commerce highlighting the adverse effects on their operations in Europe [7][8] - Reports indicate that Chinese companies' bids for public procurement projects are increasingly subjected to second-stage reviews by the European Commission, reflecting heightened scrutiny [8] - High-risk sectors for Chinese enterprises include automotive, pharmaceuticals, energy, battery, and chemicals, with state-owned enterprises being particularly vulnerable to investigations [8][9] Group 4: Strategic Recommendations for Enterprises - Despite regulatory obstacles, international expansion remains an irreversible trend, necessitating companies to identify viable investment opportunities within complex regulatory frameworks [9] - Companies are advised to conduct thorough risk assessments and develop effective response plans to navigate the regulatory landscape successfully [9]