What Ireland’s First Year of FDI Screening Reveals
By Sean Ryan, Partner and Head of EU, Competition and Regulatory
The Department of Enterprise, Tourism and Employment has published Ireland’s first annual FDI Screening Report. It is the first detailed look at how the new regime has worked in practice, and the picture that emerges is measured.
“Ireland is signalling that it remains open for international investment,” Sean Ryan says, “while taking its screening obligations seriously where critical infrastructure, technologies and inputs are involved. The numbers tell that story clearly.”
Ten points stand out from the report.
1. 102 notifications in one year
A total of 102 notifications were submitted between January and December 2025, giving an early picture of the volume of in-scope third country investment activity in Ireland.
2. Only 24 transactions went to full investigation
Of the 102 notifications, 66 did not meet mandatory criteria and were not formally screened. Twenty-four triggered an in-depth investigation following the issue of a Screening Notice.
3. Just two transactions approved with conditions
Of all transactions investigated, only two were approved subject to conditions, both to ensure continuity of critical services provided by the target company. No deals were prohibited.
4. Energy and Telecoms top the list
Energy (7), Telecoms (6) and ICT (6) were the three most notified sectors, followed by Health (4) and Pharmaceuticals (3). The pattern reflects Ireland’s strategic economic profile.
5. Critical infrastructure dominates screening
Eighteen of the 24 screened transactions related to critical infrastructure. A further four involved critical technologies and dual-use items, three covered supply of critical inputs, and one involved access to sensitive information.
6. US and UK are the biggest investors
The US (9 transactions) and the UK (8) accounted for the majority of directly screened deals. The UAE (2), Monaco (1) and China (1) also featured.
7. Twenty-three direct investments and three indirect
Ireland’s FDI screening captures both direct and indirect investments. Of the 24 screened transactions, 23 were direct investments by third country investors, and three were indirect (two from the UK, one from Japan).
8. Decisions made faster than the law requires
The statutory deadline for screening is 90 days, extendable to 135. In practice, the average screening took 40.5 days, with two thirds of decisions issued in under 40 days.
“That speed matters commercially,” Sean says. “Investors and target companies need certainty on timing. A decision in under six weeks, when the law allows for over four months, is a clear signal that the Department is running the regime efficiently.”
9. No transactions were called in
Under the Act, the Minister has discretionary call-in powers to screen transactions. No transactions were screened under the call-in powers in year one.
10. Ireland is active in the EU-wide screening network
Ireland shared 23 notifications with the European Commission and other Member States under the EU cooperation mechanism, and reviewed 74 notifications from other Member States with an Irish element.
Our experience
Whitney Moore’s EU, Competition and Regulatory team advised on a number of the transactions notified to the Department during the first year, including matters that went to full investigation following the issue of a Screening Notice.
If you would like to discuss how Ireland’s FDI screening rules might affect your business or a planned transaction, please get in touch with Sean Ryan or the team.
Sean Ryan