The new Single Market Strategy: towards 2030

Written By

feyo sickinghe Module
Feyo Sickinghe

Of Counsel
Netherlands

I am a Principal Regulatory Counsel in our Regulatory & Public Affairs practice in the Netherlands and Brussels. I have a focus on tech and comms and digital markets regulation, drawing on in-depth business knowledge and extensive experience in TMT and public administration.

puck vandenbosch Module
Puck van den Bosch

Associate
Netherlands

As an associate in our Data Protection and Regulation Group, my main focus lies in the fields of privacy and EU data regulation.

On 21 May 2025, the European Commission presented its new ‘Single Market Strategy’. It aims to create a more simple, seamless and strong European market. It outlines ambitious actions to reduce trade barriers, support SMEs, and accelerate digitalisation. The strategy is driven by the current geopolitical landscape and trade-related uncertainties and aims to make the European market more stable and resilient. It is built on nine pillars, detailed across five chapters, each with specific legislative proposals and timelines.

The nine pillars 

In short, these pillars aim to achieve the following objectives:

  1. Fewer barriers: joint and focused efforts to take down the most harmful Single Market barriers - doubling down on efforts to tackle the so-called ‘Terrible Ten’, which is explained further below.
  2. More ambition: a new approach to boosting European services markets. This pillar will zoom in on specific services sectors that could bring the highest economic added value and are relevant for the twin transition.
  3. More focus: on small and medium-sized enterprises (SMEs) including innovative startups and scaleups. The Strategy puts forward a series of actions enabling SMEs to make the most of the EU market.
  4. More effective digitalisation: Member States and the EU need to work in sync. The use of digital tools can both boost efficiency and optimise the functioning of the EU market.
  5. More simplification: taking immediate action to reduce red tape and make things simple. This focuses both on simplification of processes and rules, with the principle of ‘1 in, 27 out’ as the guiding principle.
  6. More effective implementation and enforcement: the well-functioning of the European Market is a joint responsibility of the EU and the Member States. All Member States must work together to facilitate effective implementation and enforcement.
  7. More ownership: increasing political and national engagement. The Commission encourages Member States to prevent the introduction of new barriers, e.g., when transposing EU regulations into national law, and to address regulatory and administrative barriers at regional and national level.
  8. More synergy: paradigm shift in EU spending. The Commission wants to increase the potential to use the EU budget as a springboard to promote national reforms that advance Single Market policy objectives.
  9. More protection: acting as a shield from unfair trade practices. The Commission wants to ensure that the EU market offers a source of stabilisation and resilience that can shield EU businesses from trade disruptions and reduce external dependencies, particularly when supported by policies encouraging domestic consumption and investment.
     


The ‘Terrible Ten’

In the first chapter, the Commission devotes an entire chapter to the so-called ‘Terrible Ten’. According to the Commission, the Terrible Ten pose the most harmful Single Market barriers and require urgent attention. As the Commission regards them as a ‘first priority’, the most important points of the ‘Terrible Tens’ are summarised below. We outline the Commission’s key actions that are of relevance for the digital economy.

  1. Overly complex EU rules: the goal is to ‘stress test’ the EU acquis and adopt simplification packages, with concrete plans for public procurement. Key action: Adopt simplification omnibus packages to reduce unnecessary burden to safeguard effective implementation of policy objectives such as the Digital Omnibus aimed at streamlining and simplifying certain elements of the EU digital acquis.
  2. Lack of Single Market ownership among Member States: to address this lack of ownership, the Commission urges Member States to appoint high-level Single Market Sherpas to coordinate efforts, promote rule compliance, and remove obstacles. Amongst others, the Commission is planning to propose a ‘Single Market Barriers Prevention Act’. Key action: Propose a Single Market Barriers Prevention Act in Q3 2027.
  3. Complicated business establishment and operations: a proposed ‘28th regime’ would facilitate the digital setup of businesses and their operations across the Single Market. Key action: Establish common rules to facilitate the digital setup of businesses and their operations across the Single Market - Legislative proposal on ‘28th regime’ - Q1 2026.
  4. Recognition of professional qualifications: the Commission plans to simplify procedures, extend recognition schemes, and explore common rules for recognising third-country qualifications in order to speed up mobility of workers. Key action: Explore EU legislation to address barriers to the mobility of workers.
  5. Delays in standard-setting: the Commission plans to review the Standardisation Regulation to improve speed, flexibility, and stakeholder involvement, while also allowing common specifications when standards are delayed. Key actions: Allow the Commission to establish common specifications when needed (Omnibus proposal adopted together with the Strategy). Review the Standardisation Regulation (Legislative proposal - Q2 2026)
  6. Fragmented rules on packaging, labelling, and waste: amongst others, the Commission aims to harmonise labelling rules and promote digital labelling through the Digital Product Passport. Extended Producer Responsibility schemes currently vary widely, creating administrative burdens. Key action: Harmonise labelling rules via sectoral legislation and facilitate rollout of digital labelling solutions via the Digital Product Passport (DPP) (progressive introduction of DPP, including possible inclusion via the New Legislative Framework review in Q2 2026).
  7. Outdated product rules and poor compliance: to address this matter, the Commission plans to modernise the product legislation framework and to strengthen coordination. Key action: potentially create an EU Market Surveillance Authority to better manage cross-border challenges in Q3 2025.
  8. Restrictive national services regulations: although the Services Directive has reduced some barriers, many services remain restricted, affecting cross-border trade and investment. Differences in national authorisation and certification requirements make it difficult to provide services in other Member States. Key action: Launch an initiative to facilitate the provision of pan-EU services by providers authorised or certified in one Member State on the basis of EU law, potentially including the harmonisation of such authorisation and certification schemes (Q2 2026).
  9. Burdensome procedures for workers on temporary posting: the Commission proposed a digital interface for posting declarations and is working on a European Social Security Pass to ease verification. Strengthening the European Labour Authority and improving coordination are also on the agenda. Key Action: Launch a Fair Labour Mobility Package (2026).
  10. Territorial supply constraints (TSCs): TSCs limit cross-border trade in the Single Market by preventing retailers from buying products in one Member State and selling them in another. Key action: Develop tools to act against unjustified Territorial Supply Constraints to cover situations beyond those captured by competition law, such as unilateral practices of large manufacturers (Proposal - Q4 2026).


Next steps

The new Single Market Strategy initiates a series of ambitious and wide-ranging actions with a strong focus on simplification through the removal of (nationally imposed) barriers as well as through new, simplified legislation. It is now to the Commission to present concrete proposals and for the industry to provide input.


For more information, please contact Puck van den Bosch and Feyo Sickinghe

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