The EU’s Defense Readiness Roadmap and Omnibus: What are the Implications for Defense Procurement?
What You Need to Know
Key takeaway #1
The EU’s Defense Readiness Roadmap 2030 is a comprehensive plan to boost the EU Member States’ ability to deter foreign aggression. The plan aims to close capability gaps, address pressing security threats, strengthen the European defense industrial base and encourage public and private investments in defense.
Key takeaway #2
The Defense Readiness Omnibus is a key initiative to strengthen the European defense industrial base and create a genuine EU-wide market for defense equipment. It is a set of proposals to remove legal and administrative hurdles in areas such as public procurement, permitting, and cross-border cooperation.
Key takeaway #3
The Defense Readiness Omnibus includes a proposal to amend the EU Defense Procurement Directive. This amendment would simplify procedures, reduce administrative burdens, and give Member States more flexibility.
Client Alert | 10 min read | 10.23.25
On October 16, 2025, the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy presented their Defense Readiness Roadmap 2030 to the EU Member States. This comprehensive plan aims to strengthen European defense capabilities. It follows, and should be read together with, the Commission’s Defense Readiness Omnibus that was published in June 2025. The Omnibus contains a set of proposals to facilitate defense investments and boost EU Member States’ responsiveness to today’s security challenges.
In this alert, we focus on the significance of these proposals for defense procurement. We will address their competition law implications in more detail in a follow-up alert.
1. The Defense Readiness Roadmap 2030
1.1 Background and overview
In March 2025, the Commission and the High Representative presented a White Paper for European Defense-Readiness, which outlined ideas for accelerating defense investments, strengthening the European defense industry, closing capability gaps and ensuring long-term readiness. In June, EU heads of state and government directed the Commission and the High Representative to translate these ideas into a roadmap with specific objectives and milestones.
The main objective of the Defense Readiness Roadmap is to ensure that by 2030 the EU Member States have a defense posture that is strong enough to credibly deter any foreign aggression and tackle any defense-related crisis, including high-intensity warfare. The EU’s role is to complement and strengthen the individual efforts of the Member States by facilitating collaboration, efficiency and interoperability.
The key proposals in the Roadmap concern:
- Capability development: The Roadmap calls on Member States to form Capability Coalitions in nine key areas to close capability gaps through joint development and procurement.
- European Readiness Flagships: To swiftly address the most pressing security threats, the Roadmap proposes prioritizing investments in four initial pan-European projects, namely:
- the European Drone Defense Initiative to develop state-of-the-art anti-drone capabilities,
- the Eastern Flank Watch to fortify the EU’s Eastern land and maritime borders,
- the European Air Shield to develop an integrated, multi-layered air and missile defense shield, and
- the European Space Shield to enhance the protection and resilience of EU space assets.
- Strengthening the EU Defense Industrial Base: To ensure that the European Defense Technological and Industrial Base (EDTIB) delivers the necessary capabilities at the necessary scale and speed by 2030, the Roadmap proposes ramping up production capacity, tapping the full potential for innovation, and securing supply chain resilience by reducing dependencies in raw materials and other critical inputs. A key instrument to support this industrial ramp-up will be the European Defense Industry Programme (EDIP), on which the Council and the European Parliament reached a political agreement on October 16, 2025, the same day the Roadmap was presented. The EDIP provides for the mobilization of an initial budget of EUR 1.5 billion over the period 2025-2027 to strengthen the EDTIB.
- Boosting defense investment: The goal is to establish a genuine EU-wide market for defense equipment with simplified and harmonized rules by 2030. The key initiative to achieve this goal is the Defense Readiness Omnibus discussed below, but the Roadmap also proposes increased support for public and private investment in defense. Under the EU’s current multi-annual budget (2021-2027), various instruments supporting the defense industry already exist, such as the European Defense Fund, ASAP, and EDIRPA. The Commission proposes to substantially increase the allocations to defense and space in the next budget (2028-2034). In the meantime, the activation of the national escape clause (NEC) provides Member States with additional fiscal space to increase their defense spending, while the Security Action for Europe (SAFE) offers EU-backed long-maturity loans totaling EUR 150 billion to Member States for defense investments.
1.2 Objectives and milestones regarding defense procurement
As regards defense procurement, the Roadmap’s objectives can be summed up as “buy more, buy together and buy European”.
The Roadmap highlights the problem that defense procurement remains predominantly national, which results in fragmentation, cost-inflation, and a lack of interoperability. It also notes that less than half of defense equipment is currently procured within the EU, and that non-EU suppliers have even gained market share, which runs counter to the EU’s objective of strategic independence.
The EU aims to increase defense investments procured from European suppliers to at least 55% of the total by 2030. The Roadmap also anticipates that at least 40% of defense procurement will be organized as joint procurement by the end of 2027. Simplifying defense procurement procedures should give Member States more flexibility to meet their procurement needs (see below).
2. The Defense Readiness Omnibus
2.1 Overview
The Defense Readiness Omnibus aims to facilitate at least EUR 800 billion in investments over the next four years by removing legal and administrative hurdles in areas such as public procurement, permitting, and cross-border cooperation.
The Omnibus consists of a package of legislative and non-legislative proposals, some of which are defense-specific, whereas others concern broader issues with relevance for defense:
- Defense specific proposals:
- EU funding: The Commission proposes amendments to the Regulation establishing the European Defense Fund (EDF) to simplify award criteria, introduce more flexibility, clarify the rules applicable to direct awards, improve the access rights of co-financing Member States to the results of development projects, and make it possible to fund testing activities conducted outside the EU territory (e.g., in Ukraine). The changes should reduce the administrative burden and ensure faster time-to-grant as well as more predictable implementation.
- Defense procurement: As further discussed below, the Commission proposes amending the Defense Procurement Directive to make procedures faster and more efficient.
- Intra-EU transfers of defense products: Proposed amendments to the Defense Transfers Directive are intended to simplify and accelerate intra-EU transfers between Member States, among others by expanding the use of general transfer licenses.
- Non-defense specific proposals with relevance for defense:
- Permitting: The Commission proposes a new regulation which would introduce a fast-track system for defense-related infrastructure projects – such as new manufacturing facilities – with a 60-day permitting window and a presumption of permit-granting if no decision is made within that time period.
- Environmental and chemicals legislation: The package includes amendments to REACH and other chemicals legislation to align them with defense readiness objectives, clarifying the existing possibility for Member States to allow for exemptions for certain substances, where justified in the interests of defense. The Commission more generally encourages Member States to make use of existing public interest exemptions in EU legislation, clarifying that they may take defense readiness aspects into account when applying such exemptions.
- Access to finance: The Commission proposes various adjustments to the eligibility criteria for the InvestEU Fund, to improve the deployment of the fund in support of the defense sector while keeping the necessary safeguards. The Omnibus also clarifies which prohibited weapons should be excluded from certain sustainable investment indices under the Benchmarks Regulation. Furthermore, the Omnibus contains a guidance notice on the application of the EU’s sustainable finance rules to the defense sector.
- Competition law: While emphasizing that competition rules apply to the defense sector and that defense readiness depends on competitive markets, the Commission acknowledges that it must take into account the specificities of the defense industry and the European defense equipment market in its competition enforcement (mergers, antitrust and State aid control). This will be discussed in more detail in a follow-up alert.
2.2 Key proposals concerning defense procurement
The Commission proposes amending the Defense Procurement Directive (Directive 2009/81/EC) to simplify procedures, reduce administrative burdens, and give Member States more flexibility. If adopted, the proposal would significantly reduce the regulatory complexity and costs of bidding for defense contracts.
First, the threshold amounts for contracts covered by the Directive would increase significantly:
- from EUR 443,000 to EUR 900,000 for supply and services contracts, and
- from EUR 5,538,000 to EUR 7,000,000 for works contracts.
This increase would enable Member States to focus their resources on larger contracts, while alleviating the administrative burden on industry for smaller contracts. The Commission estimates that doubling the threshold for supply and services contracts would simplify approximately 25% of all procedures under EU defense procurement rules.
Second, the Commission proposes expanding the range of available procedures for Member States. The open procedure and the dynamic purchasing system, both based on the EU Public Contracts Directive (Directive 2014/24/EU), would be added to Member States’ procurement toolkits.
Third, the Commission proposes facilitating the procurement of innovative defense solutions to encourage the development of cutting-edge technology. To that end, a modified and more flexible innovative partnership procedure based on the Public Contracts Directive would be introduced in the Defense Procurement Directive. Furthermore, a simplified procedure for the direct procurement of innovative products and services resulting from competing parallel research and development projects would be added.
Fourth, a temporary derogation until 31 December 2031 would allow Member States to rapidly replenish stocks by making immediate purchases as part of common procurements using a negotiated procedure without prior publication of a contract notice. This derogation would be available for the procurement of identical defense products, or products subject to only minor modifications, conducted by at least three Member States.
Fifth, the maximum duration of framework agreements would be extended from seven to ten years, enabling Member States to establish longer-term relationships with suppliers.
Finally, statistical reporting requirements for defense procurement are to be reduced.
In addition, in an accompanying communication, the Commission calls on the Member States to review their own procurement rules to remove additional national requirements (‘gold plating’) that would complicate the award of such contracts.
However, the Commission has resisted calls from some stakeholders to relax its approach to the application of the primary law exception in Article 346 of the Treaty on the Functioning of the European Union (TFEU) concerning measures to protect the essential security interests of Member States. The Omnibus package makes it clear that the use of this exception will continue to be closely scrutinized.
Furthermore, the Commission does not propose expanding the existing exclusions under Article 13 of the Defense Procurement Directive. It only clarifies that the exclusion under Article 13(c) for contracts awarded in the framework of a cooperative program based on research and development conducted jointly by at least two Member States for the development of a new product also applies to contracts leading to substantial changes or improvements to an existing product. This codifies guidance already contained in the 2019 Commission notice on guidance on cooperative procurement in the field of defense and security.
The proposed Omnibus package will now be debated by the co-legislators, the European Parliament and the Council. According to the Roadmap, the Commission hopes for swift adoption by the end of 2026.
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