As of 1 October 2026, the EPO PACE programme for accelerated examination has become considerably easier to use for applicants managing multiple European patent applications. For applicants managing larger portfolios, the new bulk PACE functionality can be genuinely useful. But acceleration should remain a strategic choice, not a default setting.
On 30 September 2026, the European Patent Office published its revised notice concerning the PACE programme for accelerated prosecution of European patent applications as OJ EPO 2026, A44. The revised programme entered into force on 1 October 2026 and replaces the previous notice of December 2025.
The most visible change is straightforward: applicants may now file PACE requests for multiple applications simultaneously using the dedicated bulk-request functionality in MyEPO.
That is a welcome practical development. But perhaps the more important message in the revised notice is that the EPO does not intend bulk PACE to become blanket PACE.
What has changed in the EPO PACE programme?
Since 1 February 2026, PACE has been restricted to the examination phase. The latest revision does not change that. What it changes is principally the way in which PACE requests can be filed.
For a single application, a request can now be filed either using EPO Form 1005 or directly through MyEPO.
For multiple applications, applicants can submit a single bulk request, provided they use the dedicated functionality in MyEPO. Bulk requests made by other means will not be processed.
For applicants responsible for substantial European patent portfolios, this removes a meaningful administrative inconvenience. Until now, PACE had to be requested separately for each individual application.
The underlying PACE service remains attractive. There is no official fee, and where accelerated examination has been requested, the EPO states that it will make every effort to issue the next examination action within three months of the relevant triggering event. Subsequent examination actions are likewise targeted within three months of the applicant’s response, provided the application remains in PACE.
Bulk functionality does not mean blanket acceleration
There is, however, an important qualification.
The revised notice expressly states that accelerated prosecution remains subject to practical feasibility and the workload of the examining divisions. Applicants requesting PACE for all or most of their applications may be required to select only a subset.
The EPO goes further and expressly asks applicants to use PACE responsibly, by requesting acceleration only for applications where it is genuinely needed.
That wording is important.
Interestingly, the December 2025 notice stated that applicants seeking acceleration for all or most applications “will, as a rule, be required” to limit their requests. The new notice says that such applicants “may be required” to select a subset.
It would probably be unwise to read too much into that change in wording. At the same time, it sits logically with the introduction of an official bulk-request facility: requesting PACE for several related applications is now expressly contemplated and technically facilitated.
The message appears to be: multiple PACE requests are perfectly legitimate, but indiscriminate portfolio-wide acceleration is not the purpose of the programme.
Where can bulk PACE add real value?
The real benefit of the new functionality is therefore not simply that an applicant can accelerate ten or twenty applications more easily. It is that applicants can now treat PACE more efficiently as a portfolio-management tool.
There may, for example, be good reason to accelerate a selected group of applications relating to a particular product, technology or transaction.
This could be attractive where:
- an upcoming product launch increases the value of obtaining certainty on the available claim scope;
- granted rights are desirable for licensing or enforcement discussions;
- a financing, acquisition or other transaction makes the status of a particular patent family commercially important;
- several related applications concern a strategically important technology for which an applicant wants examination to progress together; or
- an early EPO outcome may assist in determining the prosecution strategy for related cases in the portfolio.
In those circumstances, the possibility of selecting the relevant applications and placing them on PACE through a single MyEPO action is a useful improvement.
It reduces administration without changing the fundamental strategic decision: which applications actually need to move faster?
Faster is not always better
This is the important counterpoint.
There can be a tendency to regard faster patent prosecution as automatically desirable. It is not.
For many applications there is considerable strategic value in allowing prosecution to proceed at its normal pace.
A pending European application preserves flexibility. The applicant may wish to see how the relevant technology, product or market develops before committing to a final claim position. Developments in parallel patent families or the emergence of relevant prior art may also influence the preferred claim strategy.
There is also the question of divisional applications. Under Rule 36(1) EPC, a divisional application can only be filed while the parent European application remains pending. An application remains pending up to, but not on, the date on which the European Patent Bulletin mentions the grant. Accelerating a parent towards grant can therefore shorten the practical window in which the applicant can consider and file further divisionals.
Faster grant can also bring forward other decisions and expenditure. Once grant approaches, the applicant may have to make decisions concerning validation, the geographical scope of protection and, where applicable, whether to request unitary effect. Those decisions may be entirely welcome where the patent has immediate commercial importance — but less so where the commercial case is still developing.
In other words, pendency can itself have strategic value.
PACE should also be used only when the applicant is ready to move quickly
There is another practical consideration which should not be overlooked.
A PACE request can be filed only once for an application.
Moreover, an application will be removed from the PACE programme if, among other things, the applicant requests an extension of a time limit. Once an application has left PACE for one of the reasons specified in the notice, a second PACE request will not be processed.
Applicants should therefore think carefully before pressing the accelerator.
If an application involves difficult claim amendments, further technical input may be needed from inventors, or the applicant expects that additional time may be required to formulate responses, PACE may not be appropriate at that stage.
The programme works best where both sides of the procedure are ready to move quickly.
A useful new tool — if used selectively
The introduction of bulk PACE requests is a sensible and useful improvement to MyEPO, particularly for applicants and representatives managing larger portfolios.
But the principal benefit is not an invitation to accelerate everything.
It is the ability to identify a strategically relevant subset of applications and accelerate those applications efficiently when there is a genuine commercial or legal reason for doing so.
The EPO itself has now made that principle explicit by asking applicants to use the programme responsibly.
The right question is therefore probably not:
“Can we put these applications on PACE?”
but rather:
“What do we gain by having these particular applications examined — and potentially granted — sooner?”
If there is a clear answer to that question, the new bulk PACE functionality may be very valuable.
If there is not, ordinary prosecution may still be the better strategy.
Source: Notice from the European Patent Office dated 11 September 2026 concerning the “PACE” programme for accelerated prosecution of European patent applications, OJ EPO 2026, A44, published 30 September 2026 and in force from 1 October 2026.
