Camilla Cozzani

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On June 30, 2026, the European Commission published its Staff Working Document (the SWD)[1] accompanying the guidelines on its enforcement of the Foreign Subsidies Regulation (FSR) (the Guidelines)[2] published on January 9, 2026.[3] The SWD sets out the feedback received through various rounds of consultation, and explains how this feedback was taken into account in the final Guidelines. This alert memorandum reviews the key stakeholder-driven changes reflected in the final Guidelines and their implications for the Commission’s future enforcement practice.

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic Paper D – on Sustainability and Clean Technologies.

In two rulings of April 8, 2025, the French Cour de cassation confirmed that dawn raids may lawfully be conducted at employees’ private residences without requiring additional safeguards beyond those set out in the French Commercial Code.[1] 

On August 19, 2024, the French Competition Authority (“FCA”) unconditionally cleared Bouygues Telecom’s acquisition of sole control of La Poste Telecom (together “the Parties”) through the acquisition of La Poste Group’s 51% stake. SFR owned the remaining 49% of La Poste Telecom and had a right of first refusal on La Poste Group’s shares that were for sale, as well as a right of approval over the buyer of those shares.[1] The acquisition was completed on November 15, 2024.[2]

On November 23, 2023, the Court of Justice (“ECJ”) delivered two important judgments in the Ryanair v. Commission cases concerning Ryanair’s challenge of two State aid schemes granted by France and Sweden to airlines holding “national operating licenses”[1] during the COVID-19 pandemic.[2]