Across Europe competition authorities are increasingly targeting M&A transactions that fall below traditional turnover thresholds. The European Commission (EC) and several National Competition Authorities (NCAs) are expanding their toolkits through call-in powers, post-closing antitrust enforcement and expansive interpretations of existing frameworks to close the gap around below-threshold deals in fear of missing out on so-called killer or roll-up acquisitions. While killer acquisitions mean large established market players buying nascent competitors to eliminate future competition, roll-up acquisitions refer to a company systematically taking over small competitors to achieve consolidation of a fragmented market.

BLOMSTEIN starts the New Year with three celebrations: Elisa Theresa Hauch is promoted to the Antitrust Partnership; Konstantin Kuhle, former Member of the German Bundestag, joins as Special Counsel, and Bruno Galvão is appointed Counsel.

On 23 October 2025, the European Commission adopted another set of sanctions against Russia and Belarus. The new package targets key sectors such as energy and finance, the military industrial base, special economic zones, as well as enablers and profiteers of Russia’s aggression against Ukraine. It is noticeable that the new measures increasingly target third country companies outside of Russia. The EU legislator is trying to further reduce the risk of circumvention of the restrictions by extending the scope of important restrictions.

BLOMSTEIN is becoming (even) more international: On 1 October 2025, we are expanding our European presence and will open an office in Brussels. With BLOMSTEIN already being strongly connected across Europe and globally, the new Brussels office marks the natural next step in our international footprint and strengthens our proximity to European institutions. 

The NIS 2 Directive (EU) 2022/2555 is intended to raise the level of IT security in Europe significantly. The directive applies not only to federal government authorities, but also to entities deemed essential or important in sectors considered particularly critical. In order to determine whether a company is subject to the regulation, it must first be established whether it operates within one of the affected sectors. Secondly, the company must meet certain thresholds in order to be classified as an essential or important entity. For the entities concerned, stricter requirements will apply to network and information systems, and reporting obligations will be expanded. Management responsibilities will also increase. The directive will affect significantly more companies and sectors than before. As well as broadening the scope within sectors already regulated under the NIS 1 Directive such as energy, transport and healthcare, the NIS 2 Directive now covers additional areas, including digital services, postal and courier services, wastewater and waste management, and 'manufacturers of critical products'.

 On August 1, 2025, additional cybersecurity requirements will come into force for a large number of electronic devices under the Radio Equipment Directive (Directive 2014/53/EU; RED). Despite this approaching deadline, many issues are still unclear, in particular the scope of application of the new regulations and the interpretation of the term "internet-connected radio equipment ".

We continue to grow and strengthen our team with outstanding talent. As of July 1, 2025, Christopher Wolters and Leonard Freiherr von Rummel will become partners; Ramona Ader, Laura Louca and Philipp Trube will join the counsel ranks. With these promotions, we foster continuous, organic growth and strong individual development opportunities for all career levels across all practice groups.

Companies from Western countries increasingly find that their (sanctioned) contractual partners from Russia are trying to circumvent arbitration clauses by resorting to Russian courts. In an order of 1 June 2023 (12 SchH 5/22), the Kammergericht (i.e., the Higher Regional Court of Berlin) shed light on topics surrounding these issues, affirming the admissibility of arbitral proceedings even though the Russian company had already lodged a claim in Russia. In addition, the Kammergericht provided clarifications on the service of legal documents when Russian authorities refuse to serve documents under international conventions. Important conclusions can be drawn from this decision for future proceedings, both for procedural and substantive issues.

BLOMSTEIN Senior Associate Dr. Leonard von Rummel wurde im Rahmen der gestrigen Mitgliederversammlung des Forum Contracting e.V. in den Vorstand des Vereins gewählt.

CELIS Institute invited BLOMSTEIN partner Roland M. Stein to join the Institute as Deputy Director. This appointment marks yet another milestone in the yearlong collaboration between CELIS Institute and BLOMSTEIN, further strengthening their shared commitment to advancing strategic dialogue amongst various stakeholders on foreign direct investment policy and economic security.