October 27, 2025 | Technology | North America | Active

Electronic Arts (EA) / PIF, Silver Lake, Affinity Partners: Mapping EU Foreign Subsidy Risk

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This report sets out how the EU Foreign Subsidies Regulation (FSR) may shape the proposed acquisition of Electronic Arts (EA) by PIF, Silver Lake, and Affinity Partners. Distinct from antitrust and EU State aid control, the FSR is a regime that empowers the European Commission (EC) to examine financial contributions from non-EU governments that distort competition in the internal market. We discuss why the FSR matters for this transaction, what an in-depth review could test, and what type of remedies could neutralise any subsidy-driven market distortions. Drawing from precedent and our discussions with lawyers, we explain why an FSR ...

Contents

1. EU Foreign Subsidies Regulation (FSR): An Overview
   1. Definition and Notification Thresholds
   2. Timing, Process and Remedies
2. FSR Precedents: PPF / e& and Covestro / ADNOC
   1. PPF / e&: FSR Review
   2. Covestro / ADNOC: FSR Review
   3. Comparing FSR In-Depth Reviews: PPF / e& vs Covestro / ADNOC
3. Electronic Arts: FSR Process and Investigation Considerations
   1. Buyer Profile: Public Investment Fund (PIF)
   2. What Could Trigger an FSR Phase II Review of the EA Buyout?
   3. Potential FSR Remedies in EA Acquisition
4. Electronic Arts: FSR Timing Considerations
5. Trading Recommendation

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