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United Kingdom

International merger control update: UK mandatory FDI regime, China interim rules, Slovakia threshold reforms, Georgia two-phase reviews, Indonesia removes fine cap; gun-jumping fines (October–November 2020)

Practice notes
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This month brings news of a fresh mandatory FDI framework in the UK, interim rules rolled out in China, proposed tweaks to Slovakia’s notification thresholds, Georgia’s launch of a two-phase review process, and the possibility of uncapped fines in Indonesia.

UK—new mandatory FDI regime proposed

Draft legislation has been published in the UK to establish a compulsory FDI notification system, enabling the government to step into deals on national security grounds. The key elements are:

  • Share acquisitions of 15% will be caught, with even smaller holdings within scope where there is ‘material influence’
  • Acquisitions of assets are covered, including land, tangible moveable property, and—capturing intellectual property—any idea, information, or technique with industrial, commercial or other economic value
  • Sectors expected to fall under the mandatory regime include: civil nuclear, communications, data infrastructure, defence, energy, transport, AI, autonomous robotics, computing hardware, cryptographic authentication, advanced materials, quantum technologies, engineering biologies, critical suppliers to the government and emergency services, military or dual-use technologies, and satellite and space technologies
  • Transactions in any other sector may still be ‘called in’ for review...
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Web page updated on 21/05/2026

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