Analysis
The Brussels Bet: How Europe’s Merger Reform Could Birth Global Champions—or a Cartel in Disguise
In the autumn of 2025, three of Europe’s proudest industrial names—Airbus, Thales, and Leonardo—did something that would have seemed improbable a decade ago. They agreed to pool their satellite businesses into a single entity, provisionally codenamed “Project Bromo,” with combined revenues of roughly €6.5 billion and a workforce of 25,000 engineers spread across the continent. The target was unmistakable: SpaceX, whose Starlink network had already launched more than 10,000 satellites into orbit and was rewriting the rules of communications sovereignty across Europe and beyond.
Project Bromo is not merely a corporate transaction. It is a political statement—and perhaps the most vivid preview yet of the logic animating the European Commission’s landmark review of its EU merger guidelines, the first substantial overhaul since 2004. With a draft of the revised framework expected imminently in spring 2026 and final adoption pencilled in for later this year, Brussels is preparing to make a calculated wager: that the old orthodoxy of pure consumer-welfare competition law is no longer fit for a world where geopolitical rivalry, technological scale, and strategic autonomy have become existential concerns.
It is a wager worth examining with clear eyes—because the upside is a genuinely competitive, innovation-driven European economy, and the downside is something considerably less flattering: a continent that dressed up industrial protectionism in the language of strategic necessity.
What’s Actually Changing—and Why Now
The architecture of EU merger control has not changed at its foundations in over two decades. The 2004 Horizontal Merger Guidelines set out a framework rooted in the “significant impediment to effective competition” test—essentially asking whether a proposed deal would harm consumers through higher prices, reduced choice, or diminished innovation. It was a coherent, principled framework, and for much of the post-Cold War era, it served Europe reasonably well.
What it was not designed to do was navigate a world in which a single American entrepreneur could deploy more communications infrastructure in three years than Europe had built in three decades, or in which Chinese state-backed industrial groups were assembling champions in semiconductors, green energy, and rail at a pace that made European fragmentation look almost wilfully self-defeating.
The Commission’s review is exploring whether and how merger control should incorporate considerations such as resilience, investment incentives, sustainability, defence and security, and other public policy considerations—a significant departure from the narrower consumer-welfare calculus of the original guidelines. In December 2025, EU Competition Commissioner Teresa Ribera indicated that the European Commission would adopt a more forward-looking and innovation-focused approach to deal reviews ahead of the publication of its final revised merger guidelines.
The intellectual scaffolding for this shift was erected most forcefully by Mario Draghi. His September 2024 report, The Future of European Competitiveness, delivered a searing diagnosis: Europe as a business location must not put companies at a significant competitive disadvantage compared to other markets. Draghi drew explicitly on the wreckage of the Siemens-Alstom case—the proposed 2019 rail merger blocked by the Commission despite the looming dominance of China’s CRRC, which had become the world’s largest train manufacturer. That decision had become a kind of shorthand for everything the critics believed was wrong with European competition policy: technically correct, strategically catastrophic. Draghi called for regulatory reforms to facilitate industry consolidation and mergers, joint procurement in defence, and a new trade agenda.
The Competitiveness Compass, issued on 29 January 2025, appears more willing than Draghi to loosen merger rules to support the creation of European ‘champions’—the Commission’s five-year strategic roadmap that translated the Draghi Report’s ambitions into political commitments. Von der Leyen’s mission letter to Competition Commissioner Ribera included an explicit mandate to modernise competition law to ensure that “innovation and resilience are fully considered” in merger assessments—language that would have been unthinkable in Brussels just ten years ago.
The Case for Thinking Big
Let us be honest about what the proponents of reform are actually arguing, because their case is stronger than the headlines typically allow.
The central contention is not that consumer welfare should be ignored—it is that the timeframes and metrics used to assess it have become dangerously myopic. When a European telecoms operator wants to merge with a domestic rival to fund the €20 billion in capital expenditure required to build out 5G infrastructure, blocking that deal on the grounds of short-term price effects is a form of economic self-harm. The counterfactual is not vigorous competition between two financially strained operators; it is a decade of underinvestment, patchy coverage, and continued technological dependence on equipment from Huawei or Ericsson.
There is insufficient broadband infrastructure because there are too many national mobile or telecoms operators that lack the scale to make the necessary investments, while mergers are sometimes prevented by European competition policy. This is the Draghi diagnosis applied to one sector, but the logic extends across the economy.
In semiconductors, in defence, in artificial intelligence, and in clean technology, the story is similar. European companies are individually too small to fund the research pipelines that their American and Chinese competitors sustain. Since innovation in the tech sector is rapid and requires large budgets, merger evaluations should assess how the proposed concentration will affect future innovation potential in critical innovation areas—a framing that asks regulators to think less like price watchdogs and more like industrial strategists.
The satellite sector offers the most vivid illustration of what scale can enable. Until now, Europe lacked a space industry player comparable in scale to the likes of SpaceX or Lockheed Martin in the US, or CASC in China. Project Bromo is explicitly designed to rectify that. The merger will use economies of scale to defend its profitable business building large satellites while building the capability to compete in the new LEO broadband market. The new entity is also positioned as the prime industrial contractor for IRIS², the EU’s sovereign secure communications constellation—a programme that is simultaneously a defence asset, a climate monitoring tool, and an assertion of European technological autonomy.
The Airbus model lurks in the background of all these discussions. When European governments pooled their aerospace industries in the 1970s to create what became Airbus, the move was derided in some quarters as socialist central planning dressed up as industrial policy. Half a century later, Airbus employs 134,000 people, generates annual revenues exceeding €65 billion, and competes with Boeing on genuinely equal terms. There is nothing theoretically absurd about applying that logic to satellites, or to artificial intelligence, or to battery technology.
Von der Leyen stressed the EU’s Competitiveness Compass, saying that “Every single Member State has endorsed the Draghi report,” while regretting IMF analysis results of “internal barriers” within the Single Market, “equivalent to a 45% tariff on goods and a 110% tariff on services.” When internal fragmentation imposes a tariff-equivalent burden of that magnitude, the argument for mergers that can transcend national boundaries becomes very difficult to dismiss.
The Risks That Brussels Must Not Minimise
And yet. The sceptics are not wrong to be nervous, and their arguments deserve more than a dismissive paragraph.
Finland, Ireland, the Czech Republic and two Baltic countries warned against loosening EU merger rules in response to calls by some companies for easier regulatory scrutiny of their deals in order to better compete with non-EU rivals. Their February 2026 joint note to fellow EU ministers was blunt in its pushback: “Size in itself should not be the primary objective” of mergers; efficiency, innovation, and fair competition matter more.
This coalition of smaller economies is not being parochial. They are articulating a genuine and historically grounded concern. The history of European industrial policy is littered with champions that became comfortable monopolists—companies that used state protection and regulatory forbearance not to innovate and compete globally, but to extract rents from captive domestic consumers and suppress more agile domestic rivals. France Télécom did not exactly cover itself in glory during its period of dominance. European banking consolidation in the 2000s produced institutions that were too big to fail and too slow to evolve. The Alstom that Siemens wanted to acquire was itself a partially failed privatisation experiment.
There is a growing push from certain quarters to weaken merger control—ostensibly to spur greater investment and innovation, higher productivity and growth, or the creation of European champions. The CEPR economists who penned that warning are not ideological zealots for consumer welfare. They are registering a legitimate empirical concern: that the evidence linking larger firm size to higher investment, greater innovation, and better consumer outcomes is significantly weaker than the industrial-policy lobby suggests.
The telecom sector is the test case most frequently invoked by reform advocates—and it is also where the evidence is most contested. The five dissenting countries dispute telecom claims that consolidation boosts investment, calling the evidence inconclusive. What we do know from multiple markets is that reducing the number of mobile operators from four to three reliably produces higher prices for consumers. Whether those higher prices are eventually offset by better network investment is an empirical question that depends heavily on the regulatory environment, the specific market, and the commitments extracted at the point of merger clearance—not a general principle that can be assumed away in the guidelines.
There is also a subtler risk: that the champions framework becomes a vehicle for the largest incumbents to capture the regulatory process. Competition Commissioner Ribera has been admirably clear that the reforms are not intended to “shield” European companies from competition. Ribera has made many public statements that EU competition policy and enforcement should support the global competitiveness of European firms, but they should not be loosened to shield those firms from competition to create European champions. The question is whether that intention survives contact with the lobbying reality of Brussels, where defence contractors, telecoms operators, and technology companies are already positioning themselves to benefit from any loosening of the framework.
The Geopolitical Stakes: Why This Cannot Be Ignored
To understand why this debate has acquired such urgency in 2026, one must look beyond the competition law textbooks to the shifting architecture of the global economy.
The world that produced the 2004 Merger Guidelines no longer exists. That world assumed a stable, rules-based international trading system; cheap Russian energy underpinning European industrial competitiveness; and a transatlantic security relationship robust enough to allow European defence spending to remain at modest levels. All three pillars have crumbled simultaneously. The return of tariff-based industrial policy in the United States, China’s increasingly assertive mercantilist strategy, and Russia’s weaponisation of energy dependencies have collectively forced Europe to rethink assumptions it had treated as permanent.
The Draghi Report comes at a moment when the return of expansive industrial policy by the United States and China has caught the European Union flat-footed. Europe’s economic model has been premised on establishing an open and competitive market that benefits from free trade in a rules-based international system. That premise is now a strategic vulnerability as much as it is a principled commitment.
In defence, the pressure is most acute. European governments are under intense political pressure to scale up military production, reduce dependence on American platforms and munitions, and build an indigenous industrial base capable of sustaining a prolonged conflict if necessary. None of that is achievable with the current fragmentation of European defence industry—dozens of national champions competing on essentially national scales for essentially national contracts. Consolidation is not a luxury here; it is a security imperative.
In artificial intelligence, the gap with the United States is stark and widening. European AI research is world-class at the laboratory level; European AI companies are systemically under-capitalised at the commercial level. The challenge is not talent or ideas—it is the ability to assemble the compute infrastructure, the data assets, and the investment capital to convert laboratory breakthroughs into commercial-scale deployments. Larger firms, with deeper balance sheets and broader data access, are better positioned to make that conversion. The argument for consolidation in European AI is correspondingly stronger.
The proposed merger of the space business of Airbus, Thales and Leonardo to create a European satellite company capable of competing with Elon Musk’s SpaceX is likely to be a key development in 2026. The deal could provide a blueprint on the assessment of combinations involving European companies in strategic sectors. How the Commission handles Project Bromo will send a signal about the credibility of the entire reform programme—and about whether Brussels can calibrate the framework to reward genuinely strategic consolidation rather than simply providing cover for anti-competitive consolidation dressed up in the language of sovereignty.
My Verdict: Necessary, But Only Half the Answer
After examining the evidence, the lobbying, the institutional history, and the geopolitical context, my conclusion is this: the reform is broadly necessary but dangerously incomplete without accompanying measures that its proponents are not yet willing to discuss with equal candour.
The case for updating the 2004 guidelines is overwhelming. A framework that treats all efficiency arguments with the same scepticism, regardless of whether we are talking about a grocery chain merger or a satellite manufacturing consolidation designed to counter Chinese and American state-backed competitors, is not analytically coherent. The world has changed. The guidelines should reflect that.
But the reform will succeed only if three conditions are met simultaneously—and currently, only one of them is receiving serious attention.
First, the revised guidelines must embed robust, sector-specific criteria for assessing dynamic competition rather than simply inviting “innovation effects” as a general get-out clause that any large company can invoke. The Commission has good instincts here, and the stakeholder workshops held in December 2025 and January 2026 suggest that DG Competition understands the risks of opening the door too wide. The draft guidelines are expected to clarify how merger control should assess transactions in markets where competition takes place through research pipelines, technological capabilities, or access to data rather than traditional price competition. That is the right focus. It should be executed with precision, not generosity.
Second, and far more important, any relaxation of merger scrutiny must be paired with the completion of the Single Market. This is the point that the champions debate consistently obscures. European companies are not small because they are over-regulated—they are small because they operate in a fragmented market that prevents them from achieving the scale that the Single Market was theoretically designed to provide. Von der Leyen herself has acknowledged IMF analysis showing internal barriers within the Single Market “equivalent to a 45% tariff on goods and a 110% tariff on services.” Relaxing merger rules without dismantling those internal barriers simply rewards consolidation at the national level rather than creating genuinely European-scale companies. It would produce German champions, French champions, and Italian champions—not European ones.
Third, the governance framework for assessing “strategic” mergers must be ring-fenced from political interference with exceptional care. The moment that member state governments can effectively lobby for the clearance of a merger on “strategic” grounds—as opposed to the Commission making an independent, evidence-based assessment—the entire framework is at risk of capture. The Siemens-Alstom case is remembered as a story of bureaucratic timidity; it is less often recalled that the French and German governments were loudly demanding clearance. Had the Commission caved to political pressure then, the principle of independent merger review would have been significantly weakened. The same risk attaches to the reformed guidelines, at greater scale.
One year after the publication of the Draghi report, out of 383 recommendations, only 43 had been fully implemented, with 87 still untouched. That implementation gap matters enormously in this context. Reforming merger rules is, in Brussels terms, relatively tractable. Completing the Single Market, deepening the Capital Markets Union, and aligning national industrial policies behind common European objectives are profoundly difficult. If the Commission delivers on the former while making only rhetorical progress on the latter, it will have produced not European champions but European oligopolies—companies large enough to dominate European markets but not genuinely competitive on the global stage.
A Final Word: The Stakes of Getting This Right
The Siemens-Alstom decision of 2019 has become a kind of original sin in this debate—the moment when European competition policy, in the eyes of its critics, chose textbook purity over strategic realism. The reformers are right that the world has moved on since then. They are right that Europe cannot sustain its current fragmentation in sectors where the United States and China are deploying state resources at a scale that no European company, operating at a national level, can match.
But the lesson of industrial policy, throughout modern economic history, is not that it never works—it is that it works only when the politics are disciplined enough to resist capture by incumbents, the institutions are strong enough to enforce accountability, and the internal market conditions are deep enough to turn national consolidation into genuine cross-border competitiveness.
Project Bromo is a promising template. It is cross-border, strategically motivated, and explicitly designed to compete globally rather than to dominate domestically. If the Commission’s revised merger guidelines create conditions in which more mergers of that character can proceed, while maintaining robust scrutiny of deals that would primarily serve to eliminate domestic competition, then this reform will deserve to be remembered alongside the creation of Airbus as a genuine exercise in European industrial statecraft.
If, on the other hand, the guidelines become a mechanism through which large incumbents can neutralise smaller rivals under the banner of “strategic necessity,” Europe will have traded one kind of competitive failure for another—and the consumers and startups who currently benefit from the continent’s still-vigorous competitive markets will pay the price.
Brussels is placing a bold bet. The odds, for once, are not entirely unfavourable. But a half-reformed competition framework, without a completed Single Market to give it meaning, is not a European champion strategy. It is a European cartel strategy with better branding.
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Legal
Xponential Fitness Franchise Lawsuit: The $3.97M Judgment
The pitch was intoxicatingly simple. Buy a boutique fitness studio, tap into a proven corporate playbook, and ride the post-pandemic wellness boom to financial independence. For the franchisees of Pure Barre and CycleBar, that promise has officially ruptured. Xponential Fitness, the aggressive conglomerate behind these ubiquitous neon-lit studios, was just ordered to pay $3.97 million for misleading the very people who bankrolled its rapid expansion. This is not merely a localized dispute between disgruntled business owners and a corporate parent. It is a systemic indictment of a business model that treats human ambition as expendable capital.
Boutique fitness is no longer just about endorphins and community; it is an industrialized asset class. Over the last decade, private equity firms and corporate consolidators transformed the neighborhood yoga or cycling studio into a hyper-financialised franchising machine. Yet the glossy facade of the global wellness economy, valued at roughly $5.6 trillion by industry analysts, hides a deeply asymmetrical power dynamic. At the center sits Xponential Fitness, a company that scaled ruthlessly by selling a “business in a box” concept to mid-career professionals, retirees, and corporate defectors.
The structural flaw in this ecosystem is one of misaligned incentives. The franchisor makes the bulk of its money on initial franchise fees, mandatory equipment purchases, and royalty percentages drawn from top-line revenue, whether the individual studio turns a profit or bleeds cash. This creates a dangerous temptation to sell the dream at volume, irrespective of the unit-level reality. As borrowing costs have climbed globally, the debt burdens shouldered by these small operators have become mathematically unsustainable, exposing the cracks in the corporate narrative.
The Core Development: Anatomy of a Judgment
The recent $3.97 million judgment is a watershed moment in the expanding Xponential Fitness franchise lawsuit saga. The core allegation arbitrated in this case is as old as commerce itself: selling a financial fiction. Legal arbiters found that the parent company systematically misled franchisees regarding the financial viability, build-out costs, and operating metrics required to open and sustain a boutique studio.
For the prospective buyer, the primary shield against corporate deception is supposed to be the Franchise Disclosure Document (FDD). In the case of CycleBar and Pure Barre, plaintiffs successfully argued that the initial investment figures presented in these legal disclosures were artificially suppressed. A prospective owner might be told a build-out costs $350,000, only to discover that mandatory corporate vendors, supply-chain markups, and required marketing spends push the actual capital expenditure well past $500,000 before the doors even open.
This financial penalty validates a narrative that has been building since June 2023, when a devastating report by short-seller Fuzzy Panda Research accused Xponential of hiding hundreds of failing studios and running a business model that inevitably destroyed franchisee capital. Shortly thereafter, the company’s founder and chief executive, Anthony Geisler, abruptly resigned amid mounting internal investigations. Reuters has reported extensively on the Federal Trade Commission’s mounting scrutiny of deceptive practices within the franchise sector, signaling that this $3.97 million ruling is likely the beginning of a much wider regulatory reckoning.
To understand the mechanics of the deception, one must look at the mandated supply chains. Franchisees are rarely allowed to source their own exercise bikes, ballet barres, or flooring. They must buy proprietary equipment directly from the franchisor or its designated affiliates. If a franchisor quietly inflates the cost of a stationary bike or a specialized sound system, it captures immediate margin while the franchisee takes on a heavier Small Business Administration (SBA) loan. When revenues fail to meet the lofty projections touted during the sales pitch, the local operator is left holding a crushing debt load while the corporate parent reports another quarter of franchise fee growth to Wall Street.
The Analytical Layer: The Illusion of Sweat Equity
Why do intelligent, well-capitalised professionals fall into this trap? The answer lies in the psychological architecture of the franchise pitch. Boutique fitness specifically preys on the modern desire for purpose-driven entrepreneurship. Buyers are not just purchasing a cash-flow vehicle; they are buying an identity. They want to be the mayor of their local wellness community. Corporate sales teams weaponize this emotion, presenting the franchise as a turnkey operation where success is guaranteed so long as the franchisee follows the manual.
Why is Xponential Fitness being sued? Franchisees allege the company engaged in deceptive sales tactics by dramatically understating the costs required to open a studio and overstating potential revenues. The lawsuit claims corporate leadership manipulated financial performance representations, leaving hundreds of local owners burdened with insurmountable debt and failing boutique fitness locations.
The primary legal battlefield in these disputes is Item 19 of the Franchise Disclosure Document. This section allows, but does not technically require, a franchisor to make Financial Performance Representations (FPRs). If a Pure Barre parent company penalty is going to fundamentally change the industry, it will be by forcing regulators to close the loopholes in Item 19. Historically, franchisors have manipulated these figures through omission. They might report the average gross revenue of studios open for more than two years, conveniently excluding the dozens of locations that went bankrupt in month 18. They present a survivor’s bias as a baseline expectation.
The unit economics of a boutique fitness studio are notoriously fragile. A CycleBar misleading franchise owners about capacity utilization is a fatal blow. These businesses have high fixed costs—commercial rent in premium retail plazas, expensive proprietary equipment leases, ASCAP music licensing fees, and corporate royalty payments. The variable costs, primarily instructor wages and local marketing, are also rising. To break even, a studio needs a highly specific number of recurring monthly memberships. If corporate projections overestimate local market demand by even 15 percent, the studio will mathematically never turn a profit.
The Financial Times has repeatedly highlighted how private equity’s reliance on franchise models often strips unit-level profitability to inflate corporate valuations. When a brand is owned by an institutional investor looking for an exit within five to seven years, the incentive is to rapidly expand the footprint. More signed franchise agreements equal higher projected revenue, which justifies a higher multiple during an IPO or sale. The actual, long-term survival of a Pure Barre studio in a suburban strip mall is entirely secondary to the immediate liquidity event of the corporate parent.
Implications & Second-Order Effects: The Coming Wave
The downstream consequences of this $3.97 million judgment extend far beyond the balance sheet of Xponential Fitness. This ruling provides a vital piece of case law for hundreds of other distressed franchisees currently bound by mandatory arbitration clauses. It pierces the corporate veil of deniability.
The most immediate secondary effect will be felt in the commercial real estate sector. Boutique fitness franchises have been a crucial tenant class for commercial landlords recovering from the retail apocalypse. If the financial models underpinning these studios are fundamentally broken, landlords are sitting on millions of square feet of precarious leases. When a franchisee defaults, the corporate parent rarely steps in to assume the lease. Instead, the local operator declares personal bankruptcy, the landlord is left with an empty, highly specialized space that is expensive to retrofit, and the commercial real estate market takes another silent hit.
Furthermore, this saga is poised to trigger severe tightening in small business lending. A vast majority of boutique fitness franchise risks are underwritten by SBA loans, which require the borrower to sign a personal guarantee. This means that when the business fails, the bank can seize the franchisee’s home, their retirement accounts, and their children’s college funds. The World Bank warns that high interest rates will continue to expose highly leveraged, low-margin business models. A franchise that looked viable with a 4 percent loan in 2019 is a financial death trap at 9 percent in today’s macroeconomic climate. Lenders, suddenly aware that franchisor revenue projections may be fictionalized, will inevitably demand higher collateral and impose stricter underwriting standards on the entire franchise sector.
What follows, however, is the regulatory response. The Federal Trade Commission, under Chair Lina Khan, has already signaled an aggressive pivot toward investigating the power imbalances inherent in franchise agreements. For decades, the FTC Franchise Rule has been treated as a disclosure requirement rather than a consumer protection enforcement mechanism. The agency essentially operated on the premise that as long as the franchisor put the risks in the FDD, the buyer was responsible. This ruling gives regulators the political capital to shift from passive disclosure oversight to active fraud enforcement. If the FTC begins demanding audited, unit-level profitability metrics before a franchisor can legally sell a new territory, the entire velocity of the $800 billion franchise industry will decelerate.
Competing Perspectives: The Architecture of Risk
Yet, to lay the entirety of the blame at the feet of corporate executives is to ignore the fundamental premise of capitalism. A dissenting perspective—one fiercely defended by corporate franchisors and trade groups—is the principle of caveat emptor. Let the buyer beware.
The International Franchise Association and corporate defense attorneys argue that a franchise agreement is a commercial contract between sophisticated adults, not a consumer protection issue. Prospective franchisees are explicitly instructed, in bold lettering on the first page of the FDD, to hire independent legal counsel and financial advisors before signing. The documents state clearly that business ownership carries an inherent risk of total capital loss and that previous corporate success does not guarantee future individual results.
From the franchisor’s vantage point, the failure of a specific CycleBar or Club Pilates location is rarely a result of corporate malice. Instead, they point to poor local execution. They argue that failed franchisees simply did not follow the mandated marketing playbook, hired subpar instructors, or failed to aggressively manage their local sales funnels. In this view, disgruntled franchisees are simply failed entrepreneurs seeking a scapegoat for their own operational incompetence.
The Economist frequently notes that regulatory overreach in the franchise sector risks stifling a model that has historically provided a reliable ladder to the middle class for millions of entrepreneurs. If regulators make it legally perilous for a franchisor to estimate potential earnings, the flow of capital into small business creation could dry up. The defense insists that while bad actors exist, punishing an entire corporate structure for the failure of localized units destroys the very mechanism that allows brands to scale efficiently across global markets.
That said, the “sophisticated buyer” defense begins to look dangerously thin when an arbitration panel uncovers evidence of systemic, intentional obfuscation. When a corporation knows that its mandated supply chain costs are destroying unit economics, yet continues to sell new territories using outdated or manipulated financial models, the line between aggressive salesmanship and actionable fraud evaporates.
The Bill Comes Due
The $3.97 million judgment against Xponential Fitness is not a fatal blow to a publicly traded conglomerate of its size. It is, instead, a dangerous precedent. It forces a glaring light onto the dark matter of the modern franchise economy: the undeniable reality that corporate growth is frequently subsidized by the localized ruin of individual operators.
The tension here is irreducible. A corporate entity has an obligation to its shareholders to maximize revenue, while a franchisee needs unit-level profitability to survive. For years, the industry pretended these two goals were perfectly aligned. This legal ruling officially shatters that pretense. The era of selling financial illusions under the guise of wellness is over.
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Analysis
UK Labour Productivity: Are We Finally Seeing a Rebound?
For fifteen years, the defining feature of the British economy has been its sluggishness. Since the financial crash of 2008, the sheer inability to extract more economic value from every hour worked has baffled successive Chancellors, thwarted real wage growth, and starved the Treasury of critical tax receipts. It became the dismal science’s favourite domestic mystery. Yet, a quiet shift is beginning to register on the macroeconomic dashboard. After years of false dawns, UK labour productivity is finally displaying faint but distinct signs of life. The question is whether this is a genuine structural shift or simply a temporary statistical illusion masking deeper economic decay.
To understand the magnitude of this potential turning point, one must look at the depths of the stagnation. Before 2008, British output per hour grew at a reliable rate of roughly two percent each year. Then, it simply stopped. If the pre-crisis trend had continued, the average British worker would be producing nearly a third more today than they currently do. Instead, the country fell drastically behind its international peers. French and American workers routinely produce in four days what takes a British worker five.
This gap has had brutal consequences for living standards. However, the Office for National Statistics reported a surprising uptick in output per hour worked over the most recent consecutive quarters. It is the first time since the brief, chaotic volatility of the pandemic era that we have seen sustained positive momentum. Still, the baseline is incredibly low. The British economy is finally creeping forward, but it is starting a lap behind its closest competitors.
The Core Development
The recent data regarding UK labour productivity cannot be dismissed as a mere rounding error. In the final quarters leading into this year, output per hour worked rose by 0.8 percent, a figure that sounds marginal but represents a seismic shift in the context of recent British economic history. This growth is largely being driven by the services sector. Specifically, professional, scientific, and technical activities have begun to integrate automation and capital upgrades at a much faster rate than the stubbornly sluggish manufacturing base.
Bank of England Governor Andrew Bailey noted recently that corporate behaviour is finally shifting. Faced with an incredibly tight labour market and the highest borrowing costs in a generation, British firms are being forced to invest in efficiency rather than simply hiring cheap labour to solve capacity problems. For years, the abundance of low-wage European labour allowed businesses to expand without investing in software, robotics, or machinery. Brexit, whatever its broader macroeconomic frictions, effectively ended that specific growth model.
Firms are now replacing absent workers with better technology. We are seeing a belated wave of capital deepening. The Bank of England’s most recent monetary policy estimates suggest that business investment, long the Achilles heel of the UK economy, has recovered to its pre-pandemic trajectory. When workers have better tools, they produce more value. It is a fundamental law of economics that the UK seemed to have forgotten.
Moreover, the reallocation of capital away from failing companies—kept alive by a decade of zero-percent interest rates—towards more dynamic firms is finally yielding results. Insolvencies have risen sharply since 2023. That causes short-term economic pain. Yet, the capital and labour freed from those failing enterprises are flowing into higher-margin, highly productive sectors. It is the exact kind of Schumpeterian creative destruction that the British economy has desperately needed to clear the dead wood and spark genuine growth.
Decoding the UK productivity puzzle
To gauge whether this momentum will last, we have to ask why it disappeared in the first place.
What is the UK productivity puzzle? The UK productivity puzzle refers to the prolonged stagnation of output per hour worked following the 2008 financial crisis. While historical British productivity grew by roughly two percent annually, the post-2008 era saw this growth flatline, severely trailing G7 peers and suppressing domestic real wage expansion.
The puzzle was never just one problem; it was a confluence of structural failures. Cambridge economist Diane Coyle has long argued that measurement errors in the digital economy obscure true output, but even adjusting for intangible assets, the British shortfall is glaring. The UK suffers from chronic underinvestment, terrible regional inequality, and planning laws that make building laboratories, railways, or data centres aggressively difficult.
That said, the current rebound suggests some of these historical drags are easing. The transition to hybrid work, initially feared to be a drag on efficiency, has allowed professional services to slash overhead costs while maintaining output. Furthermore, the sheer shock of recent energy price spikes forced industrial firms to become radically more energy-efficient. Necessity remains the mother of capital expenditure.
A deeper look at the latest structural analysis from the Resolution Foundation reveals a highly unequal recovery. The gains are heavily concentrated in London and the South East. The “long tail” of underperforming British companies—the thousands of small and medium-sized enterprises that lag far behind their German or French counterparts in adopting basic management software—remains largely unchanged. The UK essentially operates with a vanguard of globally competitive firms dragging a vast, inefficient hinterland behind them. If the government cannot find a mechanism to force technology adoption down into the mid-market, this productivity rebound will hit a hard ceiling.
Implications and Second-Order Effects
If this productivity rebound solidifies, the downstream effects on the British economy will be profound. For the Treasury, it is the ultimate silver bullet. Productivity growth is the only sustainable way to increase tax revenues without raising tax rates. Even a 0.5 percent annual improvement in the trend rate of productivity growth would wipe tens of billions off the national debt over a decade. It provides the exact fiscal headroom that recent Chancellors have desperately lacked when trying to fund an ageing National Health Service.
For the average citizen, it translates directly to real wage growth. In a low-productivity environment, any increase in wages is inherently inflationary. Firms simply pass the cost of higher salaries onto consumers. But when workers produce more per hour, companies can afford to pay them more without raising prices. It breaks the dreaded wage-price spiral that has defined British monetary policy over the last three years.
Financial markets are already beginning to price in this structural improvement. Sterling has shown recent resilience against the dollar, and foreign direct investment is tentatively returning to British infrastructure. A recent analysis by the Organisation for Economic Co-operation and Development (OECD) highlighted that the UK is uniquely positioned to benefit from the deployment of artificial intelligence in the services sector. Given its heavy reliance on finance, legal, and consulting industries, Britain has a structural advantage if it can deploy AI tools rapidly.
However, policymakers must not mistake a cyclical bump for a permanent victory. Achieving a high-wage, high-productivity economy requires relentless policy discipline. The government will need to commit to long-term infrastructure projects, reform the archaic Town and Country Planning Act of 1990, and dramatically improve technical education. Without these foundational changes, the current £15 billion uptick in output will simply be a brief detour on a long road of managed decline.
The Illusion of Progress
Not everyone is convinced that the British economic engine has genuinely restarted. Skeptics argue that the recent data is heavily distorted by the aftermath of the pandemic and the subsequent inflation shock.
The dissenting view is rooted in the mechanics of labour hoarding. During the tight labour markets of 2022 and 2023, firms held onto staff even as demand cooled. They were terrified they would not be able to re-hire them when the economy recovered. This artificially depressed output per hour. What we are seeing now, critics argue, is simply the unwinding of that phenomenon. Firms are quietly shedding excess staff, meaning the same amount of work is being done by fewer people. That mathematically boosts productivity on a spreadsheet. Yet, it is a one-off accounting adjustment, not a structural leap in technological capability.
The Financial Times’ macroeconomic team recently highlighted the persistently low levels of public investment. You cannot build a high-productivity private sector on top of crumbling public infrastructure. With the NHS struggling to clear waiting lists, a significant portion of the working-age population remains economically inactive due to long-term sickness. Nearly 2.8 million Britons are currently out of the workforce for health reasons.
“We are mistaking a dead cat bounce for a sustained economic lift-off,” notes Torsten Bell, an economic policy expert. “Until we solve the chronic lack of domestic capital investment and the health-related shrinkage of our labour force, any productivity figures in the green are just statistical noise.”
The Verdict
The debate over British economic output is ultimately a debate about the country’s future place in the world. The UK is standing at a precarious inflection point. The recent data provides a tantalising glimpse of what a higher-functioning British economy could look like: one where capital is deployed efficiently, wages rise in real terms, and living standards actually improve.
Yet, one quarter of positive data does not erase fifteen years of stagnation. The structural rot—chronic underinvestment, a fragmented skills pipeline, and massive regional disparities—has not been magically cured by a few months of positive service sector returns. What we have been granted is a window of opportunity. The tentative rebound in output per hour proves that the British economy is not inherently doomed to low growth. It can adapt, and it can innovate. But turning this statistical blip into a generational economic renaissance will require a level of political courage and corporate ambition that has been entirely absent for the last decade. A nation cannot shrink its way to prosperity.
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Analysis
UK Stablecoin Regulation: Can Britain Catch Up?
On the morning of 3 June 2026, a parliamentary committee room heard an admission that would have been unthinkable five years ago. Tulip Siddiq, Economic Secretary to the Treasury, faced MPs’ questions about why London — a city that once branded itself the fintech capital of the world — has only a handful of fully regulated stablecoin issuers, while the European Union has licensed 18 across multiple member states since its Markets in Crypto-Assets (MiCA) regime went live. “We’ve been too cautious,” she said. The quiet in the room afterwards wasn’t disagreement. It was recognition that the UK’s prized financial services sector has let a critical piece of the digital money infrastructure slip.
The global stablecoin market was worth $178 billion at the end of May 2026, according to data from CoinGecko, and Circle’s USDC alone processes more than $5 trillion in on-chain transfers each year. The Bank for International Settlements has described stablecoins as “the rails of programmable money” — the plumbing that will carry everything from tokenized deposits to instantaneous cross-border trade settlement. Britain’s own fintech ecosystem gave the world Monzo, Revolut, and Wise. Yet when Revolut wanted to issue its own fiat-backed token this spring, it chose a MiCA licence from the Central Bank of Ireland, not one from the UK. The picture is more complicated than simple sluggishness, but the outcome is the same: the country that wrote the rulebook on global finance now finds itself reading from someone else’s.
The Core Development: Why the UK’s Stablecoin Regime Stalled
The UK’s legislative foundation for stablecoin regulation arrived with the Financial Services and Markets Act 2023, which gave the Treasury sweeping powers to bring fiat-backed stablecoins into the regulatory perimeter. What followed, however, was a sequence of consultation papers, discussion documents, and a sandbox — the Digital Securities Sandbox — that, while innovative, has not yet translated into a live authorisation pathway for issuers. As of 10 June 2026, the Financial Conduct Authority’s cryptoasset register lists just 42 firms with full anti-money-laundering registration, and only three of those are actively testing stablecoin issuance inside the sandbox, none with the ability to launch at scale.
Contrast that with the EU. Since MiCA’s stablecoin provisions took full effect in January 2025, Circle, the world’s second-largest stablecoin operator, secured a licence, and Tether, with a market capitalisation of $97 billion, has signalled it will follow. The European Banking Authority has published detailed technical standards on capital requirements, liquidity buffers, and recovery plans. This regulatory clarity is drawing a flock of new entrants, while the UK’s “near-final” regime — the Treasury’s phrase in its June 2026 consultation response — remains exactly that: near-final.
A Bank of England discussion paper released on 5 June 2026 underscores the stakes. It estimates that if stablecoins used for UK payments grow to just 5% of the sterling broad money supply — roughly £150 billion — the failure of a single systemic stablecoin could impose £12 billion in resolution costs. The Bank is understandably risk-averse. But the same paper notes that “a well-designed regulatory framework can mitigate these risks while enabling innovation,” a sentence that feels like a quiet rebuke to those who have used financial stability as a justification for indefinite delay.
What a Catch-Up Strategy Demands
Catching up is not about copying MiCA wholesale. It’s about designing a regime that is both rigorous and commercially attractive — one that recognises stablecoins as a distinct class of payments infrastructure, not merely a crypto curiosity. Three things are essential.
First, the UK must move from a sandbox to a full authorisation pathway within 12 months. The current two-phase approach — the sandbox giving way to a statutory instrument that will bring regulated stablecoins into the Payment Systems Regulator’s oversight — is sensible on paper, but the timeline is too slow. The European Banking Authority approved its first full MiCA licence 14 months after the regime went live. The UK’s first full authorisation, by the Bank of England’s own estimate, will not arrive before late 2027. Every quarter that passes without a domestically issued, pound-referenced stablecoin, more liquidity migrates to dollar- or euro-denominated instruments issued from Dublin, Paris, or Zug.
Second, the tax treatment of stablecoin transactions needs to be clarified. HMRC’s 2024 guidance on decentralised finance left significant ambiguity about whether exchanging stablecoins for sterling triggers a capital gains event. A survey of 130 UK fintech firms by Innovate Finance in April 2026 found that 67% cited “unresolved tax treatment” as a reason they would not launch a sterling stablecoin this year. The Treasury’s consultation response acknowledged this, but stopped short of a concrete commitment to treat stablecoin redemptions as exempt.
Third, the Bank of England and the FCA should signal, before the autumn, the capital and liquidity requirements they will apply to systemic stablecoin issuers. A working paper by the IMF published on 8 June 2026 warns that inconsistent capital regimes across jurisdictions create regulatory arbitrage — where issuers choose the softest regime. The paper directly cites the UK as a jurisdiction “at risk of late-mover disadvantage” if it does not calibrate requirements precisely. The Bank’s paper already leans in this direction, proposing a leverage ratio floor of 5% and a high-quality liquid asset requirement of 100% of face value. Publishing those numbers in a binding rulebook, rather than a discussion document, would give the market something to price in.
Why is the UK falling behind on crypto regulation?
The UK’s crypto framework, including stablecoins, has been delayed by a combination of post-Brexit regulatory bandwidth constraints, extreme caution after the FTX and Terra collapses, and a political environment that prioritised other financial reforms. The FCA, tasked with simultaneously building a new consumer duty regime and overhauling listing rules, simply had limited resources to devote to cryptoassets. The result is a regulatory vacuum that is being filled by competitors.
Implications: London’s Claim as a Global Financial Hub
The second-order effects of delay are already visible. The London Stock Exchange Group’s plan to build a blockchain-based trading venue for tokenized securities, announced in 2024 with considerable fanfare, depends on the availability of regulated, sterling-settled stablecoins for delivery-versus-payment. Without them, that project becomes an elegant piece of technology waiting for a foundational layer that doesn’t exist. A person familiar with the initiative, who asked not to be named, said the LSEG team now intends to use euro stablecoins issued under MiCA for initial trials, a quiet but significant shift.
The talent dimension is equally sharp. The global competition for developers who understand zero-knowledge proofs, smart contracts, and compliance engineering is fierce. Dublin, Lisbon, and Zurich have all rolled out tax incentives to attract crypto talent. London remains a magnet, but a Financial Times report published in May 2026 tracked 250 fintech engineering jobs that moved from London to EU cities in the first quarter alone, many citing “regulatory certainty” as a factor. When Circle opened its European headquarters in Paris last year, CEO Jeremy Allaire told the FT: “We go where the clarity is.”
Still, there are legitimate counterarguments to the narrative that the UK has simply been slow.
A Deliberate Caution That Has Its Merits
Professor Rosa Lastra, the Sir John Lubbock Chair in Banking Law at Queen Mary University of London, argued in a Bank of England guest paper that the UK’s incrementalism is not indecision but a principled recognition that stablecoins, once systemic, effectively become public money substitutes. “A state cannot outsource its seigniorage to an algorithm without rigorous constitutional safeguards,” she wrote. The UK’s phased approach — demanding that systemic stablecoins hold reserves wholly at the Bank of England, for instance — may indeed create a safer domestic framework than MiCA, which allows for a broader range of reserve assets including government bonds and reverse repo agreements.
The counter-counterpoint, and one the industry makes loudly, is that safety without a functioning market is academic. The question is not whether a flawlessly safe regime can be designed in a decade; it’s whether a sufficiently safe regime can be delivered now, while the UK still has a chance to anchor a significant share of sterling-referenced stablecoin activity. If the answer is no, the market will simply use dollar and euro stablecoins for all the use cases the Treasury’s own consultation says it wants to enable — from programmable payments for energy grids to instant settlement of corporate treasuries. That outcome would leave the UK with all the financial stability risks and none of the commercial upside.
What follows, however, is an uncomfortable truth: the EU’s MiCA, for all its bureaucratic heft, is functioning. It has issued licences, attracted the two largest dollar stablecoins, and triggered a wave of euro-referenced stablecoins that didn’t exist two years ago. The UK’s regime, by contrast, is still an elaborate set of carefully worded intentions.
Closing
In the end, the stablecoin catch-up is not a technology problem. The UK has the engineering talent, the legal expertise, and the financial infrastructure that most jurisdictions can only envy. It is a problem of political will — of deciding that the benefits of being a home jurisdiction for the digital money layer outweigh the perceived risks of moving from consultation to implementation. The Treasury’s June 2026 response suggests that decision is close. The question is whether it will arrive before the window of competitive advantage has quietly shut.
In the race for the rails of 21st-century finance, hesitation is a luxury the UK can no longer afford.
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