Security Action for Europe (SAFE) Update—Financial Assistance Tentative Allocation

A&O Shearman

On September 9, 2025 the European Commission (EC) adopted the tentative allocation of the EUR150 billion in long-term, competitively priced loans under the Security Action for Europe (SAFE) Regulation. Adopted by the European Council on May 27, 2025, SAFE is designed to incentivize collaborative defense procurement among member states (MS), with a particular focus on priority pre-identified capabilities.

Background and allocation process

The EU’s recent drive to strengthen its defense technological and industrial base (ETDIB) has been shaped by a series of initiatives under the ReArm Europe—Defence Readiness 2030 Plan. Besides the Defence Readiness Omnibus unveiled earlier in June, SAFE notoriously stands out as the bloc’s new defense financial instrument.

Unlike other instruments, SAFE does not establish an ex-ante distribution key; instead, MS must apply voluntarily for financial assistance. Following its entry into force, the EC set an initial deadline of July 29, 2025—later extended to mid-August—for member states to express interest, ultimately receiving a total 19 requests. Notably, Austria, Germany, Ireland, Luxembourg, Malta, Netherlands, Slovenia, and Sweden did not submit proposals; though the EC confirms their intention to participate in joint procurement processes financed under SAFE.

Allocation principles and distribution

The SAFE Regulation includes two caveats for the attribution of financial assistance:

  • No more than 60% of the total envelope (EUR90bn) may be allocated to the three largest recipient MSs (Article 13).
  • The EC must apply principles of equal treatment, solidarity, proportionality, and transparency in its proposals for Council Implementing Decisions on loan distribution per Member Sate (Article 8.7).

Since the aggregate requests exceed the instrument’s budget, the EC proposes a methodology ensuring all applicants receive at least their minimum requested amount, with additional consideration for those with a significant spread between minimum and maximum requests. Hence, the EC has proposed the following indicative distribution of loan amounts:

Tentative allocation per member state

Member state Tentative allocation amount (EUR)

Poland

EUR43,734,100,805

Romania

EUR16,680,055,394

France

EUR16,216,720,524

Hungary

EUR16,216,720,524

Italy

EUR14,900,000,000

Lithuania

EUR6,375,487,840

Latvia

EUR5,680,431,322

Portugal

EUR5,841,179,332

Belgium

EUR8,340,027,698

Bulgaria

EUR3,261,700,000

Estonia

EUR2,660,932,171

Slovakia

EUR2,316,674,361

Czechia

EUR2,060,000,000

Croatia

EUR1,700,000,000

Cyprus

EUR1,181,503,924

Finland

EUR1,000,000,000

Spain

EUR1,000,000,000

Greece

EUR787,669,283

Denmark

EUR46,796,822

Total

EUR150,000,000,000

Strategic context

At European Council level, negotiations are ongoing regarding the operationalization of Articles 17 and 18 of the Regulation, which set out the participation framework for third countries with a security and defense partnership with the EU—with particular attention to the UK and Canada. As such, these countries could bypass the 35% limit set for non EU-EEA (plus Ukraine) participants. Yet, certain capitals remain cautious about eligibility criteria, a persistent issue that has delayed other defense initiatives like the European Defence Industry Programme (EDIP).

These debates also intersect with recent EU-U.S. trade developments. The latest EU-U.S. Joint Statement commits to substantially increasing procurement of military and defense equipment from U.S. suppliers; and the market is also witnessing a rise in partnerships between American and European defense firms. Recent examples include collaborations between Lockheed Martin and Germany’s Rheinmetall, Northrop and Poland’s WZL-2, and Thales with Huntington Ingalls Industries (HII). Particularly, as several member states continue to emphasize the need to prioritize European industry—Spain’s decision last August to reject participation in the F-35 program being a notable example.

Furthermore, this development coincides with broader regulatory updates, including the recent update to the EU’s dual-use export control list in Annex I of Regulation (EU) 2021/821, providing for the inclusion of new items such as quantum technology, advanced computing and semiconductor manufacturing and testing equipment. The Regulation will now be subject to a two-month scrutiny period by the European Council and the European Parliament; after which it will enter into force provided no objections are made.

Next steps

The College of Commissioners is expected to endorse the proposed loan distribution. MS must submit formal requests by November 30, 2025, including a detailed investment plan outlining intended defense procurements and compliance with SAFE eligibility rules. If the EC validates the request, it will propose a council implementing decision, which must be adopted within four weeks.

Once adopted, the EC will negotiate loan agreements and operational arrangements with each MS. These will define the terms of the loan, disbursement schedule, and implementation framework. If requested, pre-financing of up to 15% may be disbursed after signature.

Quick links

SAFE | Security Action for Europe - European Commission

2025 Update of the EU Control List of Dual-Use Items - European Commission

Downloads

SAFE update - Financial assistance tentative allocation PDF

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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