EU Legislation Roundup: October 2026

Over the last month

October marked a shift from proposals to final decisions, with defence, workplace safety and air passenger rules all reaching adoption. Meanwhile, the European Union (EU) eased or delayed burdens in methane reporting and securitisation, while tightening control over critical raw materials. Record sanctions listings against Russia and continued scrutiny of foreign direct investment (FDI) show that economic security remains a central priority.

For in-house teams, several items already require attention. Sanctions screening tools need the 1,569 new Russia listings, which have applied since October 12. Providers of high-risk artificial intelligence (AI) systems can now rely on the first harmonised AI Act standard for quality management. Revised air passenger rules are also in force, giving airlines and booking platforms a year to adapt. Employers handling hazardous substances may also wish to start gap analyses ahead of national transposition.

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Climate & Energy

Methane Regulation: fossil-fuel importers may get extra year for reporting

In negotiation

On October 14, 2026, the Commission proposed a one-year delay to parts of the Methane Regulation. It cited winter energy prices and security of supply. The delay would cover monitoring, reporting and verification (MRV) obligations for gas, oil and coal importers. Methane-intensity reporting by importers and EU producers would also move back, while the Regulation’s scope and ambition stay unchanged. On October 19, the Parliament adopted its position, opening the way to negotiations with the Council.

Why this matters: Importers of liquefied natural gas (LNG) and coal, and their non-EU suppliers, would gain more time to build data-collection systems. Until the delay is adopted, however, current obligations still apply from January 1, 2027, so the relief is not yet certain. Energy and procurement teams may wish to keep supplier data workstreams running and retain existing data clauses in supply contracts. Negotiations are likely to test whether a one-year delay is enough and whether it should extend to EU producers.

EU Climate Resilience Framework: shared warming baseline proposed for national risk planning

New proposal

On October 27, 2026, the Commission proposed a European Climate Resilience Law alongside a wider EU Framework for Climate Resilience. The law sets a common warming trajectory of 1.5 °C by 2030,  2°C by 2050 and 3 °C by 2100. Member states would use this shared baseline to assess climate risks, while a single national strategic plan simplifies planning duties. Climate risk assessments would also become more regular and comparable, supported by new tools such as the European Climate Viewer. Further measures, including a heatwave plan and a climate insurance alliance, will follow separately. 

Why this matters: Insurers, infrastructure operators, property owners and adaptation solution providers will likely feel the effects first, including those outside the EU. Since duties fall mainly on member states, the shared baseline would shape public planning and infrastructure decisions, not company obligations. In negotiations, member states may resist the binding warming trajectory and the cost of more regular risk assessments. No immediate action is required, although risk and sustainability teams may wish to start testing key assets against the proposed trajectory.

Consumer & Products

Air passenger rights: airlines face new compensation and information duties

Adopted - applies from Oct. 23, 2027

Previously covered: EU Legislation Roundup: June 2026

On October 22, 2026, the revised Air Passenger Rights Regulation entered into force, following its publication in the Official Journal. Most of its provisions apply from October 23, 2027. It updates the rules on delays, cancellations, compensation, refunds, rerouting, tarmac delays and baggage liability. Airlines must prove that extraordinary circumstances directly caused a disruption and that they took all reasonable measures. A non-exhaustive list of such circumstances is now set out in the law. Airlines can no longer deny boarding on a return journey because the passenger skipped the outbound journey. This applies when both journeys are covered by the same air transport contract. Airlines and ticket sellers combining separate contracts must warn passengers before purchase that missed-connection rights do not apply.

Why this matters: Airlines, travel agents and online booking platforms selling covered flights are the most affected. Faster automatic refunds and wider rerouting duties may raise operating costs. Booking interfaces, fare displays and customer terms will also need updating. Legal, sales and customer-service teams may wish to review booking terms, passenger notices and claims handling before October 2027.

CMRD revision: employers face tighter exposure limits for cobalt and other carcinogens

Adopted - application date to be confirmed

On October 19, 2026, the Council adopted the sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive (CMRD). It sets occupational exposure limits for cobalt and its compounds, polycyclic aromatic hydrocarbons, 1,4-dioxane and isoprene. Where exposure cannot be reduced below these limits, employers must provide adapted protective equipment and allow regular breaks. Member States will have two years after entry into force to transpose the rules into national law.

Why this matters: Manufacturers in the battery, steel, chemicals, metalworking and construction sectors are most exposed, particularly where welding or cobalt handling is involved. Tighter limits are likely to raise costs for monitoring, protective equipment and safer processes, with smaller businesses feeling this most. Health and safety teams may need to map exposure to the listed substances and test current controls against the new limits. Tracking national transposition in each country of operation is also essential, as detailed requirements may vary.

Corporate & Tax

EU Inc: Startups and scaleups gain an optional EU-wide company form - In negotiation

Previously covered: EU Legislation Roundup: March 2026

On October 23, 2026, the Council adopted its negotiating position on “EU Inc”, a new corporate law for innovative companies. Businesses could choose this “28th regime” instead of one of the 27 national corporate law systems. Registration would be online, within two days and at a maximum cost of €100, with access to the single market. While backing the main provisions, the Council simplifies registration and the digital share register and tightens anti-money laundering checks. Employee stock options are kept but limited to small mid-caps, defined by reference to 750 employees and €150 million turnover. Meanwhile, employee participation would follow the rules of the registered-office country, with an optional mechanism where thresholds elsewhere are exceeded.

Why this matters: Founders, startups and scaleups are most affected, along with their investors, including non-EU funds, and corporate and HR teams. If adopted as proposed, one company form could cut set-up costs and legal fragmentation across member states. Discussions with Parliament will likely focus on employee participation, the stock option scope and member states’ powers to refuse registration. Although no immediate action is yet required, legal and HR teams may need to start assessing the stock option terms. The Council’s position gives Member States 21 months to implement the regulation. This could mean application from 2028 at the earliest, depending on when the legislation is formally adopted.

Defense & Security

Defence Omnibus: suppliers gain faster procurement and simpler intra-EU transfers - Adopted – application date to be confirmed

Previously covered: EU Legislation Roundup: September 2026

On October 21, 2026, the Parliament and the Council signed the Defence Readiness Omnibus acts. This completes the legislative procedure following the Council’s adoption on  October 9 and Parliament’s vote on  September 16, 2026. The acts will now be published in the Official Journal and will enter into force 20 days after publication. The first act widens national exemptions from EU chemicals rules and makes the European Defence Fund more flexible. Some of its Fund provisions apply retroactively from  January 1, 2025. The second act reduces authorisations for moving defence products within the EU, promotes general licences and raises procurement thresholds. It also allows framework contracts of up to ten years and supports joint procurement between Member States.

Why this matters: Defence manufacturers, dual-use suppliers and their subcontractors stand to benefit from faster approvals and more predictable tenders. Businesses handling regulated chemicals in defence supply chains may need to track how Member States apply the wider exemptions. Bid and contracts teams may wish to review upcoming tenders and transfer licences against the simplified rules once published. Investors could also reassess defence pipelines in light of easier access to funding.

Critical Raw Materials Act: large users face supply-chain risk assessments - In negotiation

On October 20, 2026, the Parliament adopted its position on amendments to the Critical Raw Materials Act (CRMA). Under the text, the Commission would identify large businesses relying on strategic raw materials. Those companies would need to assess supply-chain risks, including in components, and report the results to management. Parliament also backs a raw materials centre with a proposed EUR 2 billion fund and export controls on magnet scrap. Price-stabilisation tools, including contracts for difference, are also proposed.

Why this matters: Suppliers to EU battery, hydrogen, chip and drone manufacturers, including those outside the EU, could face detailed supply-chain mapping requests. Recyclers and non-EU traders may also lose access to EU magnet scrap if the export controls survive negotiations. Talks are likely to focus on the raw materials centre, joint purchasing and contracts for difference. No immediate action is required, although procurement teams may need to start mapping critical raw material dependencies in key products.

Financial Regulation

Banks and investors face lighter, more risk-sensitive securitisation rules - In negotiation

On October 21, 2026, the Parliament and the Council reached a provisional agreement to revise the EU securitisation framework. The package amends the Securitisation Regulation and the Capital Requirements Regulation (CRR). It creates a new “resilient” category, strengthens the simple, transparent and standardised (STS) label and brings STS verifiers under EU-level supervision. Investment limits for some institutional investors would also rise. Bank capital requirements would become more risk-sensitive, while due diligence and transparency duties would ease.

Why this matters: Banks, insurers, institutional investors and businesses that use securitisation for funding are all affected. Lower capital charges on low-risk deals could free bank capital for lending and cut investor compliance costs. Structuring and treasury teams may wish to review current and planned transactions against the new categories. As details may still change before formal approval, businesses should check final texts before committing to new structures.

Health & Life Sciences

Pharma package: developers face new protection periods and supply obligations - In negotiation

Previously covered: EU Legislation Roundup: September 2026

On October 8, 2026, the Parliament referred the pharmaceutical package to committee for its second reading. This follows the Council’s adoption of its position on September 28, 2026. New medicines would receive eight years of data protection and one year of market protection, extendable by up to two years. Combined protection is capped at eleven years, or twelve with a transferable exclusivity voucher for priority antibiotics. Orphan medicines would receive nine years of market exclusivity, and generic makers could prepare for launch before patents expire.

Why this matters: Originator businesses, generic and biosimilar manufacturers and their suppliers would all see changes to market-entry timing. Revised protection periods may affect returns on some products, while the wider generics exemption supports day-one launches. Regulatory and intellectual property (IP) teams may wish to model protection periods and voucher options against current pipelines. Commercial teams could also plan for new supply obligations linked to regulatory protection.

Sanctions & Export Controls

Russia sanctions: businesses dealing with Russia must screen 1,569 new listings - In effect since Oct. 12, 2026

On October 12, 2026, the Council listed 1,569 individuals and entities in Russia’s military-industrial complex. This is its largest single package to date. They cover 826 Russian businesses and 743 chief executives, including suppliers of semiconductors, radars, satellite systems and explosives. Listed persons face asset freezes and a ban on making funds available, while individuals are also subject to travel bans. Around 4,600 persons are now listed under the regime.

Why this matters: Banks, distributors of electronics and optics, and non-EU groups with EU subsidiaries face exposure, including through intermediaries. Breaching the asset freeze can lead to criminal and administrative penalties. Compliance teams may wish to upload the new listings to screening tools and re-screen customers and end-users in dual-use electronics trades, and review sanctions clauses with third-country intermediaries.

Co-authored by Uendi Barreti and Paola Paccani (Knowledge)

Further reading

Passenger package: Multimodal booking and rail ticketing | Think Tank | European Parliament

Methane rules: Parliament backs longer delay for energy importers and producers | News | European Parliament

Amendments to the Critical Raw Materials Act | Think Tank | European Parliament

Simplification: Council gives final green light to new laws boosting defense industry and readiness - Consilium

EU adopts largest-ever package of listings against Russia - Finance

Flash update – EU: EU Inc. / 28th Regime – New Pan-European Business From