EU Commission 2025 work programme leaked with 46 new initiatives and major gaps

The European Commission's draft 2025 work programme has been leaked ahead of its official presentation to MEPs in Strasbourg next week, offering the clearest picture yet of how Ursula von der Leyen's second term intends to legislate. The document lists 46 new initiatives, 24 legislative and 22 non-legislative, alongside 120 pending files carried over from the previous mandate and 31 proposals earmarked for evaluation or fitness checks. The draft remains subject to change before adoption, but its priorities are already visible: competitiveness commands ten initiatives, simplification eight, and security six, with innovation, preparedness and social fairness each allocated four.

Simplification drive anchored in three omnibus packages

The most concrete expression of the simplification agenda is a trio of omnibus packages. The first, due on 26 February, will reopen the Corporate Sustainability Due Diligence Directive (CSDDD), the Corporate Sustainability Reporting Directive (CSRD) and the EU Taxonomy Regulation. Two further packages follow in the second quarter, targeting small and medium-sized enterprises and investment rules respectively. The Commission argues that cumulative reporting burdens have become disproportionate, particularly for mid-sized firms caught between national and EU requirements. Critics, including some companies that have already invested in compliance systems, warn that reopening agreed texts risks regulatory uncertainty and amounts to deregulation by another name. The same 26 February date also carries the Clean Industrial Deal, a package aimed at channelling investment into energy-intensive sectors and infrastructure.

Beyond the omnibus bundles, the simplification column includes a European Business Wallet for digital document management (Q4), a revision of the REACH chemical regulation to ease procedures (Q4), a Common Agricultural Policy paperwork reduction package (Q2), a Sustainable Finance Disclosure Regulation overhaul (Q3) and a Cybersecurity Act review (Q4). The breadth suggests the Commission is treating simplification as a cross-cutting method rather than a single policy area. Whether the European Parliament and Council accept the reopening of recently adopted legislation, CSRD only entered full application in 2024, will test the political capital von der Leyen has accumulated since her re-election.

Competitiveness agenda leans on Letta and Draghi diagnoses

The Single Market Strategy, promised for early 2025, is explicitly framed as a response to Enrico Letta's report on the single market's unfinished business. Letta, the former Italian prime minister, argued that regulatory fragmentation, national barriers and weak enforcement cost the EU hundreds of billions of euros annually. The Commission's strategy will also reflect Mario Draghi's forthcoming competitiveness review, though that report had not been published when the work programme was drafted. A Digital Networks Act, due at year-end, tackles the telecoms sector's €200 billion investment shortfall, a figure the Commission has cited repeatedly to justify consolidation-friendly spectrum and infrastructure rules. The Critical Medicines Act (11 March) and a European Biotech Act (Q4) complete the health-industrial strand.

Energy policy carries two near-term deadlines: an affordable energy action plan by end of February and a roadmap to phase out Russian energy imports by end of March. The EU still imports roughly 15% of its gas, pipeline and liquefied, from Russia, down from over 40% before 2022 but stubbornly persistent via indirect routes. The Climate Law amendment to enshrine a 2040 emissions target is slated for the second quarter, a necessary step after the 2030 and 2050 targets were fixed in the first mandate. The European Democracy Shield, a non-legislative initiative to counter foreign interference, appears in Q2 as a follow-up to the defence of democracy package.

Migration returns overhaul signals EPP alignment

The work programme's migration chapter reveals a clear political calibration. A new common approach to returns, including the controversial concept of external return hubs, is scheduled for 11 March. A broader European Migration and Asylum Strategy follows in Q4, and a 'pact for the Mediterranean' covering cooperation with non-EU countries on migration arrives in Q3. The timing and emphasis mirror the European People's Party's manifesto commitments and reflect pressure from member states such as Italy, the Netherlands and Austria to harden the external dimension of asylum policy. The Commission has historically resisted return hubs on legal and fundamental rights grounds; their inclusion suggests a political decision has been taken to accommodate the Parliament's centre-right majority.

Notable absences in transport and automotive

What the draft omits is as revealing as what it includes. An automotive industrial action plan, pencilled in for 5 March in Commissioner Apostolos Tzitzikostas's mission letter, is absent. So is a proposal on greening company car fleets, another mission-letter commitment. The industrial maritime strategy and a high-speed rail plan, both expected this year, are also missing. Transport insiders suggest the Commission may be delaying these files to avoid clashing with the omnibus simplification push or because inter-service agreement on state aid and competition aspects has not been reached. The automotive sector, already navigating the 2035 CO2 standards for new cars and vans, had lobbied for a dedicated industrial dialogue; its absence from the work programme will be noted in Stuttgart, Munich and Paris.

Budget timeline sets up 2026 showdown

Discussions on the next Multiannual Financial Framework (MFF) for 2028, 2034 have begun, but the Commission's formal proposal is not expected until the third quarter, likely July or September. That timing compresses negotiations into an 18-month window before the current budget expires, virtually guaranteeing a bruising summit in late 2026 or early 2027. The MFF will need to accommodate enlargement costs (Ukraine, Moldova, Western Balkans), defence spending, and the repayment of NextGenerationEU borrowing, all while net contributors such as Germany and the Netherlands push for a lower ceiling. The work programme's silence on own-resources reform, new EU revenue sources, suggests that debate has been parked until after the MFF proposal lands.

Parliament scrutiny and member state pushback await

The draft will be presented to the European Parliament's plenary in Strasbourg next week, triggering committee scrutiny across multiple policy areas. The three omnibus packages will face the steepest examination: the legal affairs and environment committees must decide whether reopening CSRD and CSDDD violates the principle of regulatory stability. Member states will coordinate through Coreper, with the simplification agenda likely to split the Council between those demanding less red tape and those insisting that sustainability reporting not be watered down. The migration returns proposal, due 11 March, will test whether a qualified majority can be assembled for external hubs, a question that has divided interior ministers for years.