In late February, the European Commission unveiled its ambitious Clean Industrial Deal – a comprehensive agenda addressing the intertwined challenges of decarbonisation and competitiveness, as highlighted in the Draghi report in September 2024 and the Competitiveness Compass in January 2025. 

The CID spans numerous guidelines, legislative proposals, acts and more across six major themes: Affordable Energy, Lead Markets for Clean Tech products, Public and private financing measures, circularity and access to materials, global markets and international partnerships, and skill enhancement (see figure 1).  

One quarter in, it’s time to take stock and assess to what extent the Commission was able to stay on track with their ambitions. Many of the announced milestones were achieved: 

• As part of the Omnibus package, the Commission published in late February its proposed updates to the Carbon Border Adjustment Mechanism (CBAM) regulation, aiming to streamline and simplify its implementation. 

• Also still in February, the Commission published its proposal to amend the InvestEU Regulation by increasing its risk-bearing capacity. This amendment seeks to enhance the programme's ability to support strategic investments by increasing the EU budgetary guarantee, thereby attracting more private capital into strategic projects. 

• At the start of March the Commission proposed extending the Gas Storage Regulation until the end of 2027, mandating member states have their gas storage facilities 90% full before the winter season. Notably, the proposal introduces greater flexibility in terms of deadlines and deviations from the 90% target, depending on market conditions.  

• At the end of March a list of 47 Strategic Projects was adopted to secure and diversify access to critical raw materials within the EU. These projects – focusing on extracting, processing, and recycling essential materials like lithium, nickel, and rare earth elements – will benefit from coordinated support by the Commission, Member States and financial institutions.  

Some crucial agenda items are however still pending, namely the adoption of the Delegated Act on Low-Carbon Hydrogen and the proposal for the updated 2040 Climate Target. 

The second quarter is poised to be pivotal, with anticipated releases including the revised Clean Industrial State Aid Framework (CISAF) and updated guidance on tariff methodologies for electricity network charges. 

Click here to learn more about our work across energy and to hear our thoughts on upcoming developments - from CBAM to network tariffs.