The EU deserves credit when it delivers. In the past year, the EU institutions have moved the simplification agenda from speeches and mission letters to concrete proposals, parliamentary votes and political compromises. That is no small feat politically. And it promises to make a real difference for companies operating every day in Europe.

In recent weeks, we saw two more examples of how this legislative agenda is moving forward. First, the European Parliament adopted its position on the Chemicals Omnibus, voting for more workable transition periods and simpler rules on labelling legibility and advertising obligations. Then, shortly after, the Parliament and Member States reached an agreement on the AI Omnibus, postponing rules on high-risk AI applications to help businesses avoid impending legal uncertainty.

Taken together with the simplification to corporate sustainability and due diligence rules delivered by Omnibus I – now published in the Official Journal – these are mounting signs that the EU institutions can deliver tangible changes to reduce regulatory burdens for businesses, all while upholding core EU political priorities.

But it’s not all sunshine and roses. The Deforestation Regulation (EUDR) is a live example of how the simplification mindset has not yet fully set in – and of why retrofitting isn’t the best way to create workable rules. In its new EUDR assessment, the Commission confirmed it would not address the majority of challenges that businesses have flagged including unclear legal terminology, potential double reporting and IT systems that risk failing under the weight of data.

To me, this mixed picture underscores the task ahead. While businesses are yet to feel the impact of simpler rules on the ground – understandably, as these changes don’t materialise overnight – the legislative exercise is seeing some success. However, the EU still needs a mindset shift: from simplification by retrofit to simplification by design. I see three files on the horizon that illustrate what simplification by design can look like.

The first is one of the most debated files on the agenda, the recently proposed Industrial Accelerator Act (IAA), where the proposed transaction regime raises a familiar red flag: unnecessary regulatory overlap. The proposal comes as the EU is already revisiting and optimising its existing deal‑review toolkit – merger control, foreign subsidies screening and investment screening – to modernise these measures and respond to economic security concerns. Yet the IAA proposes to add a new layer, effectively a fourth screening regime on top of these three already in play.

That is hard to square with simplification. The question here is about scope discipline. These screening provisions do not need to be part of the IAA. Introducing a parallel mechanism risks incompatible outcomes, adds uncertainty in a deal environment already marked by complexity and risks degrading – rather than complementing – the framework already dedicated to this purpose. Simplification starts with defining what a regulation needs to cover – and, just as importantly, what it does not.

The next two files that come to mind are expected later this year, meaning there is still time for the Commission to get these proposals right.

One is the Circular Economy Act (CEA) – and the lesson here is to push for maximum harmonisation from the get-go. Today’s waste management landscape across the EU remains extremely fragmented, marked by uneven performance and divergent national regulatory frameworks. For the CEA, the best way to solve this issue from the outset and deliver simplification for companies is by grounding this legislation in an internal market legal basis. Given the challenges companies face doing business across 27 separate legal regimes, the goal across all new legislation should be to avoid a patchwork of differing national or regional frameworks.

Then there is the Digital Fairness Act (DFA), which raises a larger stock-take question: is new legislation always what the EU needs to achieve its objectives? In many areas, the problem is not the absence of rules – it is that implementation of existing rules is uneven and enforcement is unclear.

The DFA is framed around tackling issues like dark patterns, addictive design, targeted advertising and influencer marketing. But much of that terrain is already covered by the EU’s existing consumer and digital rulebook, including legislation like the Unfair Commercial Practices Directive, Digital Services Act and General Data Protection Regulation.

The most credible simplification path is therefore not legislating again, but rather going back to the basics of the Single Market, improving consistency through clearer guidance and harmonising enforcement across Member States. That would protect consumers while reducing legal uncertainty for companies operating across borders.

Ultimately, the simplification agenda is not about whether the EU should have high standards. It should. Businesses are not asking for all EU rules to be scrapped – and certainly not for obligations at EU level to be replaced by 27 different national regimes. The question is whether EU legislation is proportionate and workable in practice.

In recent years, the balance of the EU’s rulebook has tilted too far towards complexity, cumulative burden and disproportionate compliance costs. Has every part of every initiative been necessary for the EU to achieve its objectives? I would argue: clearly not. The objective now must be to reset this balance – establishing a regulatory environment where businesses can grow and innovate without unnecessary obstacles.

There is an ongoing debate about whether Europe should simplify or deregulate. To me, a semantic debate about what to call the process is a distraction from the task at hand. Omnibus I, the Chemicals Omnibus and the AI Omnibus – so far – show that simpler rules are on the way and that Omnibus proposals can make a difference. We need to see more of that, and we need to see it implemented fast.

Even more important, a retrofit approach can never replace thinking about regulation through a simplification lens from the outset. Businesses do not experience regulation one file at a time, but all at once. Simplification by design is therefore a reflex that the EU needs to apply across all sectors and policy areas. That is how simplification becomes an operating model, not a reactive fix: rules that are workable and coherent from day one. I would welcome seeing far stronger signs that this reflex is starting to kick in.

Read more of our views on simplification here.