Compliance teams of companies operating in several EU Member States are already stretched by the EU product safety laws and regulations, the Green Deal, the Digital Services Act, new sanctions regimes and constantly evolving labour rules. Then, every autumn, Brussels adds another layer: the European Commission’s work programme for the coming year.
On 21 October 2025 the European Commission published its agenda for next year. It is easy to treat that document as just another institutional brochure. For 2026, however, that would be a mistake. The Commission has given its work programme a clear political narrative and a telling title: “Europe’s Independence Moment”. Behind that title lies a coherent legal and policy story about how the EU plans to protect its citizens, reform its economy and simplify its rules in a world that feels less stable than it has for decades. The work programme was developed in close cooperation with the European Parliament, the Council and the EU’s advisory bodies.
This blog takes you through the agenda and outlines the European Commission’s ambitions for 2026. Rather than simply listing initiatives, it explains how they fit together – and what they mean for businesses for example active in the manufacturing industry, lawyers, public authorities and individuals who rely on EU law for market access, guidance and protection.
Executive summary
The European Commission’s work programme presents a political and legal roadmap to make the EU more resilient in a world it describes as “in its most precarious state for decades”.
A central theme is simplification: lighter, more transparent rules and measurable cuts in administrative burdens, particularly for small and medium-sized enterprises (SMEs), combined with stronger and more consistent enforcement.
The main legislative priorities focus on:
- reshaping the Single Market to deliver sustainable prosperity (including a 28th Regime for innovative businesses, a European Innovation Act, and new legislation on cloud, AI, quantum, advanced materials and biotech);
- speeding up the energy and climate transition (building an ‘Energy Union’, introducing new CO₂ and renewable energy frameworks, a Circular Economy Act and a strategy for fusion power);
- reinforcing defence, security and migration management (simplified defence procurement, additional support for Ukraine, implementation of the Pact on Migration and Asylum, and reinforced Frontex); and
- supporting people through jobs, housing and social cohesion (a Quality Jobs Act, Fair Labour Mobility Package, housing initiatives and strategies to combat poverty and child poverty).
For product compliance, the programme further develops the Omnibus approach (particularly for energy-related products and taxation) and keeps the Registration, Evaluation, Authorization and restriction of Chemicals (REACH) and medical devices high on the agenda.
The work programme also aims to convert the regimes on the restriction of hazardous substances in electrical and electronic equipment (RoHS), electromagnetic compatibility (EMC), equipment for potentially explosive atmospheres (ATEX), low voltage (LVD), radio equipment (RED), pressure equipment (PED), simple pressure vessels (SPVD) and lifts into concrete digitalisation measures and legislation on “common specifications”.
In addition, the Commission’s work on toys appears to be largely concluded for now, following the adoption of the Toy Safety Regulation by the Council and the European Parliament.
By contrast, there are no developments on AI liability since the withdrawal of the AI Liability Directive in early 2025.
Across areas such as food, water, democracy and the digital public sphere, the programme connects legal initiatives to everyday essentials and core values, embedding them into a broader budgetary and enlargement strategy for “the Union of tomorrow”.
From a Precarious World to EUROPE’S Independence Moment
The European Commission opens its work programme with a sober reflection: “since this Commission took office, Europe has had to confront a world in its most precarious state for decades”. It highlights dangers to security and democracy, threats to the economy and industrial sector – such as violations of European airspace and efforts at economic coercion – and, of course, Russia’s ongoing war against Ukraine, all unfolding against the backdrop of a rapidly unravelling international order on which Europe has long depended.
Consequently, the European Commission argues that this should be ‘Europe’s Independence Moment’: a period in which Europe rises to safeguard and shape its own future, protects its citizens from the impacts of climate change, assumes responsibility for its own defence and security, takes control of the technologies and energy that drive its economy, and deliberately determines what kind of society and democracy it wants to become.
Legally, the work programme is not binding as such. But as the European Commission’s annual plan of action, it is the closest thing the EU has to a roadmap for its legislative and policy agenda. Each year, it sets out a list of the most important new policy and legislative initiatives for the year ahead, in line with the President’s Political Guidelines, the mission letters sent to Commissioners and the State of the Union speech, and in consultation with the European Parliament and Member States. It also includes annexes listing new initiatives, evaluations and fitness checks, pending proposals, intended withdrawals and planned repeals.
For practitioners, this makes the 2026 work programme an early-warning system. It signals which regulatory waves are coming and which long-running files are likely to be put on hold.
A Central Thread: Simpler Rules, Stronger Delivery
Running through the entire work programme is one central thread: simplification. The European Commission has set itself two challenges: to strengthen Europe’s strategic autonomy and competitiveness, and to make the law easier to navigate. It openly acknowledges that EU companies, particularly SMEs, see regulatory obstacles and administrative burdens as one of their greatest challenges, and notes that both the Draghi report and Letta report identify complex laws and bureaucracy as constraints on the EU’s economic potential.
In response, the European Commission has set measurable targets: to reduce administrative burdens by at least 25% overall and by at least 35% for SMEs, without undermining policy objectives. It has already put forward ‘omnibus’ and other simplification proposals that aim to deliver more than EUR 8.6 billion in annual savings for businesses and citizens. Building on this progress, more than half of the 2026 legislative initiatives are expected to have a significant simplification component, with laws designed to be lighter, clearer and easier to implement.
In concrete terms, the programme outlines new or continued efforts to simplify rules in key sectors: automotive, environment, taxation, food and feed safety, medical devices and energy products. It promises streamlined reporting, faster permitting and better alignment between legal requirements and market realities, including in areas such as public procurement and digital legislation.
At the same time, the Commission is clear that simpler rules do not mean weaker enforcement. It stresses that robust implementation is “as vital as good law-making” and accompanies the work programme with a first annual Overview Report on Simplification, Implementation and Enforcement, which describes how it monitors and enforces EU law.
For lawyers and compliance officers, this means you can expect the regulatory landscape to change shape. Some processes may become less burdensome on paper, but the obligations that remain are likely to be enforced more consistently across the EU.
Sustainable Prosperity: Rewiring the Single Market for a New Era
From the broad principle of making EU law ‘simpler but stronger, the European Commission moves to its first key theme: sustainable prosperity and competitiveness. It recalls that Europe has long been a hub of industry, entrepreneurship and innovation, shaped by industrial and technological revolutions and intense global competition. Its unique social market economy gives it significant strengths. Nonetheless, deep‑seated structural constraints continue to hold back competitiveness, and the European Commission explicitly commits to speeding up the full implementation of the Draghi report’s recommendations.
The core of this agenda is to remove bottlenecks within the Single Market and create more favourable conditions for innovation and investment. To that end, the European Commission intends to unlock what it terms the ‘full potential’ of the Single Market by 2028, by dismantling barriers in the areas of capital, energy, services and telecoms, and by establishing “a fifth freedom for knowledge and innovation through a strengthened European Research Area”.
Against this backdrop, several concrete legislative initiatives stand out:
- European Product Act, due for adoption in Q3 2026, intended to ensure that all products on the single market are safe and suited to an increasingly digital and circular economy. The Act will revise the New Legislative Framework, which lays down the principles for market access, CE marking and conformity assessment, as well as the Market Surveillance Regulation, which governs how authorities and customs enforce EU rules against unsafe or non-compliant products, and the Standardisation Regulation.
- 28th Regime for Innovative Companies, a single EU-level regime designed for companies that want to operate efficiently across the Single Market without being constrained by 27 slightly different national frameworks.
- European Innovation Act, intended to make it easier to do business and access finance, with a focus on start-ups, scale-ups and SMEs. It is intended to complement efforts to establish the Savings and Investment Union, including by strengthening shareholder rights and addressing competitiveness in the banking sector.
- Cloud and AI Development Act and Quantum Act, designed to safeguard digital sovereignty and strategic autonomy and ensure that the infrastructure underpinning artificial intelligence and quantum technologies reflects European values and interests.
- Advanced Materials Act, Critical Raw Materials Centre and European Biotech Act II, to keep the EU at the technological frontier, to safeguard industrial sovereignty and reduce strategic dependencies.
The European Commission further signals that it plans to update its merger-control guidelines to offer businesses “clear, up-to-date and positive guidance” on the circumstances under which mergers can be expected to enhance innovation, resilience or investment, while still adhering to the core objectives of safeguarding competition and protecting consumers. Alongside this, the work programme includes an initiative to update antitrust procedural rules, which will be of particular interest to competition lawyers.
Taken together, these measures present a Single Market that is no longer merely a zone of free movement, but a consciously designed ecosystem for innovation and strategic autonomy.
Energy, Climate and the Circular Economy: Law TO ENABLE THE Transition
The question of independence is also particularly concrete in the field of energy. The European Commission emphasises that lowering energy prices for households and businesses remains a central priority for competitiveness and strategic autonomy, as well as for reducing external dependencies.
To achieve this, the 2026 programme envisages a genuine ‘Energy Union’: stronger governance, upgraded grids, the removal of bottlenecks and less red tape for cross‑border energy projects. It announces a legislative package for the coming decade, including rules on CO₂ transport infrastructure and markets, an energy‑efficiency framework and a renewable‑energy framework. There will also be a review of the EU emissions trading system for maritime, aviation and stationary installations and of the market stability reserve, alongside an update of national targets and flexibilities in climate policy.
The European Commission indicates that it will also present a strategy for developing the first fusion power plants in Europe, contributing to long‑term energy self‑reliance.
Alongside the energy and climate agenda, the Circular Economy Act will constitute a key pillar. It will seek to stimulate both demand for and supply of circular products and to reduce dependence on critical resources, thereby reinforcing Europe’s ‘Clean Industrial Deal’ and supporting lead markets for sustainable products.
For legal and compliance teams, this implies a further evolution of product‑law regimes, expanded producer responsibilities and more extensive climate‑related reporting, all framed by a deliberate effort to make regulatory requirements more coherent and predictable.
Defence, Security and Migration: LEGAL FRAMEWORKS in a Geopolitical Union
The focus then shifts from markets to security. In the context of an increasingly complex and shifting threat environment, the European Commission underlines that Europe’s defence must be built in Europe and that security considerations will run through all of its work in the coming year.
Building on the Readiness 2030 framework and the Defence Readiness Roadmap, the EU intends to reinforce the defence industry and its ability to react to threats. Financial tools such as the Security Action for Europe (SAFE), together with the integration of defence into fiscal rules, are meant to support and complement these regulatory measures.
On the legislative side, a key milestone will be the streamlining of rules on defence and sensitive security procurement, aimed at making cross-border cooperation easier, fostering innovation and support the European defence industrial base. This is accompanied by initiatives such as the European Drone Defence Initiative, crucial for the Eastern flank, and a Qualitative Military Edge programme to guarantee that Ukraine has prompt access to a continuous supply of high-quality military equipment.
Security, however, extends beyond defence alone. The European Commission is calling for a “system-wide shift” in the way migration is managed and external borders are protected. It identifies 2026 as the year when the Pact on Migration and Asylum will be fully implemented in practice, with the objective of preventing abuse, reducing pressure on national systems and striking a balance between responsibility and solidarity.
Furthermore, the European Commission proposes targeted sanctions against migrant smugglers and traffickers, aimed at freezing their assets, restricting their movement and cutting off their profits. Frontex is to be further strengthened, with a larger standing corps and an enhanced role in assisting Member States with returns, supported by the digitalisation of return procedures. A European critical communication system will link police, fire and emergency services, alongside updated rules to tackle organised crime and a stronger Europol.
For lawyers, this security agenda will translate into new layers of compliance for defence contractors, critical-infrastructure operators, transport and logistics actors, and anyone involved in cross-border data-sharing and law-enforcement cooperation.
Supporting People: Jobs, Housing and Social Cohesion
Although the work programme has a tough focus on defence and autonomy, it repeatedly returns to people’s everyday concerns. It insists that Europe’s competitiveness and security are “first and foremost about people, their jobs, families and livelihoods”, and reaffirms the social market economy as a foundation of the European project.
To safeguard social cohesion and fairness between generations, the European Commission aims both to reinforce social protection systems and to promote sustainable growth and competitiveness. It proposes a Quality Jobs Act to ensure that working conditions keep pace with the modern economy and give workers greater influence. A Fair Labour Mobility Package – featuring a European Social Security Pass, a stronger European Labour Authority and a scheme for skills portability – is intended to make it easier for workers to move and have their qualifications recognised across the EU.
Looking beyond employment, the European Commission acknowledges the hardship caused by the cost-of-living and housing crises. It promises a new initiative on short-term rentals to tackle inefficient use of existing housing, and a European Affordable Housing Plan to mobilise public funding and private capital for more affordable, sustainable homes, supported by updated State aid rules that allow EU Member States to provide support more quickly and with fewer formalities.
The social agenda is further developed through the EU’s first Anti-Poverty Strategy, designed to address the structural roots of exclusion and reinforce support services, and through a strengthened Child Guarantee centred on investment and reforms to tackle child poverty. The package also includes an Intergenerational Fairness Strategy to promote solidarity between age groups and a dedicated Strategy for Outermost Regions, along with communications on Eastern border regions, islands and coastal communities, so that no part of the EU is left behind.
For practitioners in labour, social and housing law, these measures will shape future disputes and policy debates on fair working conditions, non-discrimination, access to housing and the just transition.
Food, Water and Nature: Protecting Everyday Essentials
Any evaluation of independence would be incomplete without food and water. The European Commission considers food supplies and healthy ecosystems as “essential for Europe’s wellbeing”. Based on the findings of the Strategic Dialogue on the Future of Agriculture and its Vision for Agriculture and Food, it announces measures to boost the competitiveness of farmers and the agri-food production and supply chain, support rural areas and streamline agricultural regulations.
To improve farmers’ position and guarantee a steady supply of high-quality European food, the European Commission plans a new “buy European food” initiative and a revision of the rules on unfair trading practices (UTPs) in the food chain. The updated framework is intended to enhance transparency, foster cooperation and capacity building, and firmly establish the principle that farmers should not be systematically required to sell below production costs.
At the same time, a Livestock Strategy will seek to secure the competitiveness, resilience and sustainability of the EU livestock sector and the broader agri-food chain. Meanwhile, “Vision 2040 for fisheries and aquaculture” and an Ocean Act will steer ocean governance and the development of a sustainable blue economy.
Water also gains new prominence through the implementation of a Water Resilience Strategy. Through a Digital Action Plan and a Water Resilience Platform, the European Commission intends to engage all actors, promote water efficiency and reinforce the sector’s competitiveness, while embedding climate-impact preparedness as a permanent element of EU policy and enhancing wildfire management.
For agricultural, environmental and competition lawyers, these initiatives will translate into concrete obligations and potential disputes over contracts, labelling, supply-chain fairness, conservation requirements and water-use permits.
Democracy, Rule of Law and the Digital Public Domain
Finally, the work programme returns to core values. The freedoms on which Europeans depend rest on democracy, the rule of law and fundamental rights. Yet extremism, disinformation, cyberattacks and foreign interference undermine confidence in institutions and the integrity of elections.
As a response, the European Commission proposes a comprehensive annual rule-of-law cycle, with shared benchmarks and a role for all EU institutions in monitoring and dialogue. It also reiterates that access to EU funding must be conditional on respect for the rule of law, supported by safeguards and positive incentives for reforms in the next multiannual financial framework.
Concerned about the weakening of traditional media in some communities, the European Commission warns that where independent media are dismantled or hollowed out, disinformation flourishes and democracy is put at risk. It therefore announces a Media Resilience Programme to strengthen independent journalism and media literacy, underpinned by a proposal to substantially increase media funding in the next EU budget.
Online, the planned Digital Fairness Act is intended to address unfair and misleading commercial practices. Meanwhile an Action Plan against Cyberbullying aims to create safer digital environments for young people, with a particular focus on children, social media and mental health. In parallel, a new EU Anti-Corruption Strategy and a thorough overhaul of the anti-fraud framework will reinforce oversight and accountability, alongside proposals to strengthen Eurojust and modernise the rules on audiovisual media services.
For practitioners in constitutional, media and digital law, this agenda may influence future litigation and policy development on platform regulation, media freedom, anti-corruption measures, data protection and consumer rights.
Updates on 2025 Product-Compliance Topics
If you followed the European Commission’s 2025 work programme closely, you will recall a number of product-compliance files that dominated that agenda: the first Omnibus packages; the planned overhaul of REACH; the evaluation of the Medical Devices Regulation (MDR) and In Vitro Diagnostic Regulation (IVDR); the fitness checks on pressure equipment and simple pressure vessels; the lift safety regime; the new toy-safety framework; and the uncertain future of the AI liability directive.
The 2026 work programme and its annexes do not restart these discussions from zero. Instead, they move several of them into a new phase.
Omnibus initiatives
On the Omnibus side, the European Commission is now very clear about the next wave. In addition to the six omnibus packages already adopted, the 2026 work programme announces three further omnibus initiatives:
- An Omnibus to simplify energy product legislation, planned for the second quarter of 2026.
- An Omnibus on taxation, also scheduled for the second quarter of 2026.
- A Citizens Omnibus, a legislative package foreseen for the fourth quarter of 2026.
In its Q&A on the 2026 work programme, the European Commission confirms that simplification initiatives and Omnibus packages will continue to target “key areas such as automotive, environment, taxation, food and feed safety, medical devices, simplifying energy product legislation and policies relevant for citizens”. For companies and authorities that had already adjusted to Omnibus I and II in 2025, this next round will be equally important – not least because it will bundle changes across multiple legal acts in a single package.
REACH
The 2025 REACH reform and the broader chemicals package have not disappeared. They now appear in the 2026 work programme as pending proposals. These include a draft regulation on the European Chemicals Agency (ECHA), which would amend REACH and several related chemicals instruments, alongside a separate simplification proposal to adjust substantive and procedural requirements for chemical products. The underlying message is clear: the REACH overhaul announced in 2025 remains active. It is progressing through the legislative process rather than being redesigned for 2026.
Medical devices
For medical devices, the 2025 evaluation of the MDR and IVDR has evolved into a clear simplification target. While the 2026 work programme does not provide for a stand-alone revision of the MDR/IVDR, it explicitly identifies medical devices as one of the sectors where omnibus and simplification proposals are expected to deliver significant net cost reductions. For manufacturers and notified bodies, that means simplification is coming – but most likely in the form of cross-cutting packages rather than a single ‘MDR 2.0’.
Pressure equipment, simple pressure vessels and lifts
The files on pressure equipment, simple pressure vessels and lifts have moved from evaluation into concrete legislation action. The annex on pending proposals points to a horizontal product‑safety package on “digitalisation and common specifications”. One element is a regulation that would amend several EU product regulations (including the general market surveillance framework and more recent product rules, such as those relating to personal protective equipment, machinery, batteries and ecodesign requirements for sustainable products) to facilitate digital information flows. The other element is a directive that would revise a broad set of ‘New Legislative Framework’ directives, including those relating to simple pressure vessels, pressure equipment and lifts, with regard to digitalisation and common specifications.
In practice, this means that, for simple pressure vessels, pressure equipment and lifts, the 2025 fitness checks to which you may have contributed have already been translated into draft legal amendments. You should anticipate more digital documentation, greater use of electronic means for declarations and instructions, and a more prominent role for common specifications alongside (harmonised) standards.
Toys
The new Toy Safety Regulation – a major file between 2023 and 2025 – no longer appears in the core work‑programme documents considered here, as it has now been adopted by the Council (13 October 2025) and the European Parliament (25 November 2025). The Regulation tightens safety requirements for toys, strengthens protection against hazardous chemicals, introduces a digital product passport and imposes additional obligations on economic operators and online marketplaces.
AI liability
By contrast, the 2026 work programme has very little to say about AI liability, reflecting the European Commission’s decision in February 2025 to withdraw the AI Liability Directive (AILD). The politically sensitive AI liability initiative is missing from the 2026 flagship proposals and from the simplification agenda. Where AI is mentioned, it is largely in relation to the Cloud and AI Development Act and broader digital‑sovereignty ambitions, rather than a stand‑alone civil‑liability regime for AI systems.
Takeaways
For product‑compliance lawyers and in‑house teams, the implications are as follows:
- The Omnibus approach seen in 2025 is becoming more sector-specific and more ambitious in 2026, especially for energy products and taxation.
- The REACH and medical-devices files remain active and are being integrated into broader simplification efforts.
- The evaluations of pressure equipment, simple pressure vessels and lifts have matured into a horizontal digitalisation package that will change how conformity information is created and shared.
- The Toy Regulation will enter into force 20 days after its publication in the Official Journal of the European Union, with the new rules becoming fully applicable after a transition period of 4.5 years.
- AI liability, while still relevant in practice, is not being pushed as 2026 flagship in the documents currently available.
If you advise on any of these areas, now is the time to align your product‑compliance strategy with this next wave of Omnibus‑driven simplification and digital transformation in EU product law.
Looking Ahead: Turning a Work Programme into a Strategy
All these strands – product compliance, simplification, competitiveness, defence, social cohesion, food and water security, democracy and external action – ultimately come together in one further chapter: preparing the EU for the future.
If you want to explore the agenda in more depth, you can consult the full Commission work programme 2026 and its annexes, as well as the official Q&A, factsheet and Commission’s press release for a more political perspective.
And if you are asking what this all means for your organisation in practice, now is the time for a structured discussion with your EU law advisers. Europe’s Independence Moment is more than a slogan; it is an extensive legislative programme. With the right preparation, you can seize this opportunity to shift from reactive compliance to proactive, strategic engagement with the legislation that will shape your business.
