2025 was a fascinating year for UK competition and consumer enforcement, with the CMA changing its policies and practices in a number of areas. Our Year in Review summarises the most important developments of the past year and what we expect in 2026, as the CMA implements its reworked procedures for merger and market cases, begins to use its new consumer fining powers, and imposes digital conduct requirements for the first time. We also anticipate a Government consultation on significant changes to the decision-making model for mergers and markets.

On December 12, 2025, the Digital Markets Act (“DMA”) High-Level Group (“HLG”)[1] endorsed a joint paper on the regulatory interplay on AI-related issues.[2] This paper assesses how to best implement the different legal frameworks that govern AI systems. It underlines the importance of achieving a coherent and consistent implementation of these frameworks and of the cooperation between competent authorities to achieve it.

On November 10, 2025, the Commission conditionally cleared Abu Dhabi National Oil Company’s (“ADNOC”) c. €15 billion acquisition of German chemicals company Covestro AG (“Covestro”) under the Foreign Subsidies Regulation (“FSR”),[1] following a Phase II review.[2]

Following a complaint by Eurotunnel operators France Manche SA and The Channel Tunnel Group on June 25, 2021, the French Competition Authority (“FCA”) examined allegations that DFDS and P&O Ferries had entered into an anticompetitive capacity-sharing agreement on the Calais–Dover route.

On November 1, 2025, the Commission issued a policy brief[1] in which it rejected calls to extend the legal professional privilege to in-house counsel communication. The Commission examined the question after stakeholders called for such an extension as part of the revision process of the regulation governing antitrust investigation, Regulation 1/2003.[2]

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we submitted our observations on Topic Paper G – Public Policy, Security, and Labour Market Considerations.