On 7 October 2026, the Assembly of North Macedonia adopted the Law on Notification and Screening of Foreign Direct Investments, the country's first comprehensive FDI screening regime. We covered the text while it was still in parliamentary procedure in our earlier analysis of the draft law: the thresholds remain investments of at least EUR 50,000 involving the acquisition of at least 10% of share capital or voting rights in companies active in sensitive sectors, with mandatory screening before closing. The adopted text delivers three things the draft had not finalised: a precise timeline, a clear transition framework and the rule that divestment is a measure of last resort.
When will the new regime start to apply?
The regime will not apply immediately. The law provides an 18-month transitional period after entry into force, which means mandatory notification is expected to become applicable around April 2028. Until then, transactions close without screening, but investments that will be completed after the start of application must already be planned with the new filter in mind. The transitional period is meant for preparation by the authorities and the market, not for postponing the analysis.
How long will the screening procedure take?
The overall procedure, from confirmation that the filing is complete until the proposed decision is submitted to the Government, may not exceed 90 days, or 120 days in exceptional cases. The adopted text separates the phases: the Ministry of Foreign Affairs and Foreign Trade first assesses within 7 days whether the filing is complete and, if it is not, invites the parties to supplement it. The substantive review lasts up to 60 days, with a possible 30-day extension for particularly complex investments or where additional checks and consultations with other authorities are required. The time the Government needs to adopt its final decision falls outside these deadlines.
| Phase of the procedure | Deadline under the adopted law |
|---|---|
| Completeness check of the filing | 7 days (with an invitation to supplement if incomplete) |
| Substantive review by the Ministry | Up to 60 days, plus a 30-day extension in exceptional cases |
| Total until the proposed decision reaches the Government | No more than 90 days, or 120 days in exceptional cases |
| Final decision of the Government | Outside the counted deadlines |
What is new compared to the draft?
Besides the clarified deadlines, the adopted law confirms the hierarchy of measures. Divestment of the investor is ordered only as a last resort: when a prohibition on further investment and a restriction of ownership or voting rights are insufficient to eliminate the identified threat to national security, public order or strategic interests. The possibility remains for the Ministry to review, on its own initiative, investments that have already been completed, so existing foreign ownership structures in sensitive sectors are not entirely outside the regime. The thresholds, covered sectors and misdemeanour sanctions remain as analysed in our review of the draft.
What does this mean for transactions being planned now?
Every sale of a stake or acquisition in a sensitive sector whose closing is expected after April 2028 should build screening into the structure of the agreement from the outset. In practice, that means:
- an early assessment of whether the sector, value and stake trigger the notification obligation;
- mapping the ownership chain and the investor's beneficial owners up to the top level;
- a clause making closing conditional on the screening outcome (conditions precedent) with a realistic window of at least several months;
- allocating which party files the notification and who bears the risk if the decision is delayed or unfavourable;
- reviewing already completed investments in sensitive sectors, bearing in mind the retrospective ex officio review.
The transition period to 2028 is time for preparation, not for waiting: a transaction structure built today without a screening analysis may become unworkable precisely when the regime starts to apply.
Planning an investment or a sale of a stake closing after 2028?
Whether your transaction will require notification depends on the sector, the value, the stake and the investor's ownership structure, and with the adopted law the deadlines are finally known and can be built into the agreement with precision.
We provide assessments of the new regime's scope over specific transactions, preparation of the notification and contractual protection of the parties during the screening process.
Book a consultationRelated service: Foreign Investment
Source: North Macedonia adopts its first FDI screening law, Schoenherr, 8 October 2026; Law on Notification and Screening of Foreign Direct Investments (adopted on 7 October 2026).
This text provides general legal information and does not constitute legal advice for a specific case. For advice tailored to your situation, please consult an attorney.