The IAA responds to a structural decline in the Union's manufacturing base. According to the Commission, the manufacturing sector's share of EU GDP has fallen from 17.4% in 2000 to 14.3% in 2024, while the sector continues to account for approximately 26.2% of the Union's greenhouse gas emissions.2
The IAA proposal forms part of a broader policy sequence that includes the Clean Industrial Deal3 and the Competitiveness Compass,4 and delivers on the commitment made by President von der Leyen in her 2025 State of the Union Address to introduce legislation boosting demand for "Made in EU" products in strategic sectors.
The IAA is a broad instrument. Beyond the permitting provisions examined in this article, it introduces mandatory "Made in EU" and low-carbon requirements in public procurement and public support schemes, establishes a novel conditionality regime for foreign direct investments exceeding EUR100 million in emerging strategic sectors, and sets an objective for manufacturing to account for at least 20% of the Union's GDP by 2035.5
Those provisions are outside the scope of this article. Instead, this article focuses on the IAA's permitting framework and, in particular, on the question whether the introduction of yet another accelerated permitting regime — layered on top of several existing and envisaged instruments — achieves the simplification and coherence it promises.
The IAA's permitting framework
Extension of the NZIA permitting provisions
The IAA does not establish a fully autonomous permitting regime. Its permitting provisions operate alongside and expressly amend existing frameworks, including the Net-Zero Industry Act (NZIA), (Regulation (EU) 2024/1735)6 and the Single Digital Gateway Regulation (Regulation (EU) 2018/1724).
The NZIA, which entered into force on June 29, 2024, with certain provisions — including those on public procurement and auctions — subject to staggered application dates extending to June 30, 2026, and December 30, 2025, respectively,7 introduced mandatory maximum timelines for the permit-granting process for net-zero technology manufacturing projects: 12 months for projects with a yearly manufacturing capacity below 1 GW, and 18 months for projects of 1 GW or more.8 Shorter timelines apply to net-zero strategic projects: 9 months (below 1 GW) and 12 months (1 GW or more).9
The IAA extends the NZIA's streamlined permitting provisions — including single points of contact and mandatory maximum timelines — to all energy-intensive industry decarbonization projects.10 These are defined as projects that significantly and permanently reduce CO₂-equivalent emissions from facilities in energy-intensive industries, including steel, cement, chemicals and aluminum.
The practical effect is that a category of industrial projects that was not previously covered by the NZIA's accelerated procedures is now brought within substantially the same procedural framework.
Single access points and the permit-granting procedure
The IAA requires Member States to establish a single access point at national level for the submission of permit applications for industrial manufacturing projects.11 This single access point is to operate through European business wallets, as proposed under a separated EU legislative initiative currently under negotiation, and must enable interoperability and automated data exchange between competent authorities, the re-use of data already held by public authorities, and transparency throughout the permit-granting procedure.12
Member States must further establish a single permit-granting procedure based on a single application covering all permits required for industrial manufacturing projects.13 A competent authority designated by each Member State is to coordinate this procedure to ensure the adoption and issue of a comprehensive decision within the applicable time limit.
Within 45 days of receipt of the application, the competent authority must either acknowledge that the application is complete or request any additional information required.14
Industrial manufacturing acceleration areas
The IAA introduces the concept of Industrial Manufacturing Acceleration Areas (IMAAs), a designation mechanism by which Member States identify geographic zones particularly suitable for industrial deployment.15 Member States are required to designate at least one IMAA within 12 months of the IAA's entry into force.16
When designating IMAAs, Member States must define a clear geographic scope:
- prioritize locations where industrial manufacturing is not expected to have a significant environmental impact
- prioritize locations outside Natura 2000 sites and other protected areas; take into account climate risks
- prioritize artificial and built surfaces, industrial sites and brownfield sites.17
Prior to adoption, the plans or programs on the designation of IMAAs are subject to environmental assessment under the Strategic Environmental Assessment Directive18 and, where relevant, to appropriate assessment under Article 6(3) of the Habitats Directive.19
Within designated IMAAs, Member States must prepare and issue an aggregated baseline permit covering the permits and administrative authorizations commonly required for industrial manufacturing projects in the area.20 Individual project promoters are then required to obtain only those additional permits that fall outside the scope of this aggregated baseline permit.
A significant feature of the IMAA framework is that all industrial manufacturing projects located within an acceleration area are to be considered strategic projects for the purposes of proposed Regulation 2025/984 on speeding-up environmental assessments.21 The implications of this classification are discussed in Section 3 below.
The broader permitting landscape
Parallel permitting regimes
The IAA sits within an increasingly dense landscape of EU permitting acceleration instruments. The principal parallel regimes are as follows.
The NZIA imposes mandatory timelines of 12 and 18 months for net-zero technology manufacturing projects, with shorter timelines for strategic projects, and requires Member States to designate single points of contact.22 The IAA extends these provisions to energy-intensive industry decarbonization projects.
The proposed Regulation on speeding-up environmental assessments (COM(2025) 984 final, December 10, 2025), tabled as part of the Environmental Omnibus — one of the Commission's omnibus simplification packages (COM(2025) 980 final) — provides a horizontal, cross-sectoral framework for environmental assessments.23 Its annex establishes a "toolbox" for strategic sectors comprising three elements: a presumption of overriding public interest; tacit approval at intermediate administrative stages (except where the project is subject to an environmental impact assessment or where the principle of tacit approval does not exist in the national legal system concerned); and expedited dispute settlement.24 The IAA classifies all energy-intensive industry decarbonization projects, as well as all industrial manufacturing projects within designated IMAAs, as strategic projects for the purposes of this toolbox.25
The European Grids Package (COM(2025) 1005 final, December 10, 2025) proposes amendments to the Renewable Energy Directive, the Electricity Market Design Regulation and the Gas Directive to accelerate permit-granting for grid, storage and recharging infrastructure, and to strengthen cross-border coordination of network planning.26 This includes proposed measures to streamline administrative procedures, introduce indicative timelines for permitting, and enhance coordination between transmission system operators (TSOs) across Member States, particularly for cross-border infrastructure.
The Renewable Energy Directive (RED III) (Directive (EU) 2023/2413) introduced its own permitting acceleration framework, including the designation of "renewables acceleration areas" with compressed timelines — 12 months inside designated areas, two years outside — and a presumption that renewables installations are in the overriding public interest, including target adjustments to environmental assessment procedures within designated acceleration areas.27
The Critical Raw Materials Act (CRMA) (Regulation (EU) 2024/1252) established differentiated permitting timelines of 12 to 27 months for critical raw materials projects and its own single-point-of-contact mechanism.28
A single industrial manufacturing project — for example, a steel decarbonization facility incorporating on-site renewable generation and requiring new grid connection infrastructure within a designated IMAA that requires grid connection and involves the processing of critical raw materials — could engage several of these frameworks simultaneously. Which timeline governs, which single point of contact takes precedence and how the respective environmental assessment procedures interact are questions to which the legislative texts do not provide clear answers.
The proliferation of sector-specific and horizontal acceleration frameworks — each with its own scope, timelines, single points of contact, environmental assessment procedures and dispute resolution mechanisms — risks producing precisely the fragmentation these instruments are intended to address. For project promoters and competent authorities alike, the challenge is no longer the absence of accelerated permitting rules, but their multiplicity.
It bears emphasis that several of these instruments — including the IAA itself, proposed Regulation 2025/984 and the Grids Package — remain at proposal stage and are subject to amendment through the ordinary legislative procedure. Recent Commission’s communication has indicated an objective to advance adoption of these instruments, including IAA, by 2026. The coordination challenges identified here may therefore be addressed, or compounded, as the legislative process unfolds.
Subsidiarity
In the IAA proposal, the Commission's subsidiarity justification is that fragmented national permitting itself constitutes the internal market barrier: divergent procedures risk investment diversion and delay decarbonization efforts that transcend national borders.
Only coordinated EU-level action, the Commission argues, can guarantee a level playing field, prevent investment diversion and ensure that climate and industrial policies reinforce one another.29 The reasoning has force: the IAA's own explanatory memorandum identifies fragmented national permitting as one of the three principal sub-problems the proposal is designed to address.30
Whether the IAA delivers on that justification is, however, open to question. The proposal introduces procedural convergence — single access points, mandatory timelines, a single permit-granting procedure — but does not harmonize the underlying national permitting regimes that project promoters must navigate.
Member States retain their substantive planning, environmental and building consent requirements. The risk is that a uniform procedural layer overlays fundamentally divergent substantive regimes, producing formal consistency without material simplification. In that sense, the subsidiarity case for action at Union level may be stronger than the instrument chosen to implement it.
Aarhus convention
The acceleration of permitting procedures across these instruments raises questions under the UNECE convention on access to information, public participation in decision-making and access to justice in environmental matters (the Aarhus convention), to which the union and all Member States are parties.
As noted in section “Industrial manufacturing acceleration areas” above, the IAA classifies energy-intensive industry decarbonization projects and all industrial manufacturing projects within designated IMAAs as strategic projects for the purposes of the Environmental Omnibus Regulation on speeding-up environmental assessments (proposed Regulation 2025/984). The procedural features of that Regulation — including its compressed consultation timelines and tacit approval mechanism — therefore apply directly to the categories of project the IAA is designed to accelerate.
Three specific features of this emerging framework warrant scrutiny. First, the Environmental Omnibus Regulation compresses public consultation to between 30 and 90 days;31 whether 30 days satisfies the Convention's requirement for "reasonable time-frames" in the context of complex industrial projects with significant environmental effects is not beyond challenge. Second, the tacit approval mechanism introduced by the Environmental Omnibus Regulation — whereby intermediate administrative steps are deemed approved if authorities do not respond within the deadline — is expressly excluded for final decisions and for projects subject to environmental impact assessment, and does not apply where tacit approval does not exist in national law.32
These safeguards are significant, but intermediate steps approved by administrative silence may in practice narrow the scope for public input at stages where environmental concerns could otherwise be raised. Third, the treatment of dispute resolution for permitting decisions relating to industrial and net-zero projects — characterized as "most expeditious" under the Environmental Omnibus Regulation and as "urgent" under the NZIA for net-zero strategic projects33 — may affect the practical exercise of access-to-justice rights under Article 9 of the Convention, which requires Parties to ensure that members of the public have access to effective judicial or administrative review procedures to challenge acts or omissions that contravene national environmental law.
These are not conclusions as to non-compliance — the Environmental Omnibus Regulation itself expressly recalls the Union's obligations under both the Aarhus Convention and the Espoo Convention (the UNECE Convention on Environmental Impact Assessment in a Transboundary Context, which requires assessment of cross-border environmental effects before decisions are taken on proposed activities).34 They are, however, tensions that the co-legislators will need to address as these instruments advance through the legislative process.
Conclusion
The IAA is the latest in a growing series of EU instruments designed to accelerate industrial permitting, alongside parallel initiatives targeting energy and environmental infrastructure permitting. Its ambition is clear: to extend to energy-intensive industries the procedural streamlining that the NZIA introduced for net-zero technologies, and to create, through IMAAs, designated zones where permitting is simplified further still.
Taken together with the NZIA, proposed Regulation 2025/984, the European Grids Package, RED III and the CRMA, the IAA forms part of a permitting landscape of considerable — and still-evolving — complexity.
The central paradox is that the cumulative effect of multiple simplification instruments may itself become a source of regulatory uncertainty — not for want of accelerated procedures, but because of their multiplicity and imperfect coordination. For project promoters, the practical challenge will lie in determining which regime applies, which timeline governs, which single point of contact is competent and how overlapping environmental assessment requirements interact.
For Member State authorities, the challenge will be implementing these frameworks in a manner that is both timely and consistent with subsidiarity constraints and the access-to-information, public participation and access-to-justice guarantees of the Aarhus Convention. Market participants and their advisers should monitor these parallel legislative processes closely.
Footnotes
(1) European Commission, Proposal for a Regulation of the European Parliament and of the Council establishing a framework of measures for the acceleration of industrial capacity and decarbonisation in strategic sectors and amending Regulations (EU) 2018/1724, (EU) 2024/1735 and (EU) 2024/3110, COM(2026) 100 final, 4 March 2026.
(2) COM(2026) 100 final, Explanatory Memorandum, p. 1.
(3) Communication from the Commission, The Clean Industrial Deal: A joint roadmap for competitiveness and decarbonisation, COM(2025) 85 final, 26 February 2025.
(4) Communication from the Commission, A Competitiveness Compass for the EU, COM(2025) 30 final, 29 January 2025.
(5) COM(2026) 100 final, Article 2 (industrialisation objective) and Chapters III–IV (procurement and FDI provisions).
(6) Regulation (EU) 2024/1735 of the European Parliament and of the Council of 13 June 2024 establishing a framework of measures for strengthening Europe's net-zero technology manufacturing ecosystem and amending Regulation (EU) 2018/1724 (OJ L, 2024/1735, 28.6.2024).
(7) The NZIA’s provisions on public procurement and auctions were subject to different staggered application dates. Article 25(1) (procurement) applied only to contracts concluded by central purchasing bodies and to contracts of EUR 25 million or more until 30 June 2026; Articles 26 and 28 (auctions) applied from 30 December 2025. The distinction reflects the phased implementation schedule under the NZIA, whereby procurement obligations — which required Member States to adapt their public purchasing frameworks — were given a longer transitional period than the auction provisions.
(8) Regulation (EU) 2024/1735, Article 10(1).
(9) Regulation (EU) 2024/1735, Article 16.
(10) COM(2026) 100 final, Article 6.
(11) COM(2026) 100 final, Article 4(1).
(12) COM(2026) 100 final, Article 4(2).
(13) COM(2026) 100 final, Article 5(1).
(14) COM(2026) 100 final, Article 5(3).
(15) COM(2026) 100 final, Article 25.
(16) COM(2026) 100 final, Article 25(1).
(17) COM(2026) 100 final, Article 25(3).
(18) Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment.
(19) Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora.
(20) COM(2026) 100 final, Article 26(1).
(21) COM(2026) 100 final, Article 27(4), referring to Article 14 of the proposed Regulation on speeding-up environmental assessments (COM(2025) 984 final).
(22) Regulation (EU) 2024/1735, Articles 6, 10 and 16.
(23) Proposal for a Regulation of the European Parliament and of the Council on speeding-up environmental assessments, COM(2025) 984 final, 10 December 2025. Tabled as part of the Environmental Omnibus: Communication from the Commission, Simplifying for sustainable competitiveness, COM(2025) 980 final, 10 December 2025.
(24) COM(2025) 984 final, Annex, sections I–III.
(25) COM(2026) 100 final, Article 27(4).
(26) European Commission, European Grids Package, COM(2025) 1005 final, 10 December 2025. The Package includes proposals to amend the Renewable Energy Directive, the Electricity Market Design Regulation and the Gas Directive.
(27) Directive (EU) 2023/2413, Articles 15b, 15c, 16a, 16b and 16f.
(28) Regulation (EU) 2024/1252, Articles 10 and 11.
(29) COM(2026) 100 final, Explanatory Memorandum, section 2.
(30) COM(2026) 100 final, Explanatory Memorandum, section 1.
(31) COM(2025) 984 final, recital (31) and Article 8.
(32) COM(2025) 984 final, Annex, section II.
(33) Regulation (EU) 2024/1735, Article 15(4); COM(2025) 984 final, Annex, section III.
(34) COM(2025) 984 final, Article 13.
