On July 10, 2025, the French Competition Authority (“FCA”) published both its 2024 Annual Report,[1] and its 2025-2026 Roadmap,[2] which outlines its priorities for the year ahead.
2024 was a record year for the FCA: it imposed fines totalling €1.4 billion—10% higher than the previous record set in 2021—, and reviewed a record 295 mergers and acquisitions. Looking forward, the FCA set out three priority areas for its action in 2025-2026: (i) digital markets; (ii) sustainability; and (iii) improving consumers’ and SME’s purchasing power. The 2025-2026 Roadmap reveals a clear interest in AI and ‘green-washing’ issues in particular. The FCA also indicated that it would, by the end of 2025, publish its proposal for a call-in power allowing it to review below-threshold mergers.
A Continued Focus On Antitrust Issues In Digital Markets and AI
The 2025-2026 Roadmap confirms that digital markets remain a key priority of the FCA,[3] and places a particular emphasis on artificial intelligence issues. Recalling its June 2024 Generative AI market study[4], the FCA noted it stands “ready to act” in the AI field. Indeed, previous FCA market studies have led to investigations, for instance in the graphics card sector.[5]
Substantively, the FCA announced it will supplement its AI market study with an analysis on access to energy for players in the sector. This is consistent with the FCA’s interest in inputs in the AI sector: its previous market studies examined practices linked to cloud infrastructure, computing power, access to data and talent. It also announced that the FCA would adopt its first roadmap on its own use of AI in 2025, which it intends to update every three years. The FCA’s intent appears to be to start using AI to streamline its internal processes, and potentially to help detect anti-competitive behaviour.[6]
With respect to other digital markets, the FCA noted it would also publish a market study on online video creation, which could also lead to investigations in the sector.
Procedurally speaking, the FCA referred to its novel investigating powers contained in the “SREN” law,[7] which, among other things, defines the FCA’s role in the implementation of the DMA.[8] In addition, the law prohibits certain practices in the cloud sector, namely self-preferencing;[9] the granting of cloud commercial credits for (i) an unlimited period of time, or (ii) subject to an exclusivity obligation; and finally, unfairly making a contract for the supply of products or services conditional on the conclusion of a contract for cloud computing services. The SREN law empowers the FCA to investigate and sanction such “cloud” self-preferencing practices; it also requires the Authority to release a report on its “cloud” self-preferencing decisional practice in November 2025.[10]
Pursuing Sustainability Within Competition Policy
The 2025-2026 Roadmap highlights the FCA’s action in providing informal guidance on sustainability cooperation between competitors, following its 2024 notice.[11] Indeed, the FCA has so far published two letters providing informal guidelines, on the standardisation of carbon footprints in animal nutrition marketing and a collective financing for costs linked to the agro-ecological transition.[12] There is a clear appetite from the FCA to pursue this practice, which may be an attractive option for companies seeking legal certainty.
However, the FCA also noted that it is determined to sanction practices which prevent consumers from making an informed decision on the sustainability characteristics of products and services, drawing from its market study on environmental rating systems. Importantly, it also implied that the FCA will also use the European Commission’s horizontal agreement guidelines, specifically its sustainability chapter, in its own practice.
Finally, with respect to abuses of dominant position and mergers, the Roadmap indicates some tentative openness to sustainability arguments, noting that the FCA will “give further consideration to how to take sustainability into account.”[13]
Supporting Consumers’ Purchasing Power
The final key priority of the FCA is sanctioning anticompetitive practices and carefully reviewing mergers which may weigh on households and SME’s budgets. The FCA mentions the transport and energy sectors as calling for particular attention, as well as “business services.”[14] The FCA also specifically noted it would ensure the restructuring of the food retail sector—the subject of many mergers reviewed by the FCA in 2024 and 2025—does not lead to higher prices or lower quality. The FCA also mentioned it would continue its enforcement in French overseas territories and would publish an opinion on reforms regarding the establishment of fees for regulated legal professions.
The FCA finally noted that a record 15 companies had requested leniency (11 full applications, and 4 summary applications) in 2024, and highlighted its continued ex-officio enforcement, consisting of four dawn raids in 2024 and one in 2025.[15]
Conclusion
Overall, this year’s Roadmap is in line with the FCA’s previous priorities, with a clearer focus on artificial intelligence issues, in particular. It remains to be seen how the FCA’s investigations in that sector will take shape.
[1] FCA, Annual Report, 2024, available at (in French): https://www.autoritedelaconcurrence.fr/sites/default/files/2025-07/Rapport-annuel-2024-final
[2] FCA, Roadmap 2025-2026, available at: https://www.autoritedelaconcurrence.fr/sites/default/files/2025-07
[3] The FCA recalled its ongoing investigation and interim measures concerning Meta’s alleged abuse of dominance in the online advertising sector and mentioned it is currently reviewing an application for interim measures in the search engine sector.
[4] FCA, Opinion 24-A-05 of June 28, 2024 on the competitive functioning of the generative artificial intelligence sector, available at: https://www.autoritedelaconcurrence.fr/en/press-release/generative-artificial-intelligence.
[5] FCA, Annual Report, 2024, p.4-5.
[6] FCA, Annual Report, 2024, p.5, see also Roadmap 2025-2026, p.4.
[7] French law 2024-449 of May 21, 2024 to Secure and Regulate the Digital Space, available at (in French): https://www.legifrance.gouv.fr/dossierlegislatif/JORFDOLE000047533100/
[8] SREN law, Article 53 confirms that the FCA (and DGCCRF) are the national competent authorities under the DMA. As such, for instance, they may still investigate practices which could be covered under the DMA if these also constitute a breach of competition law, and may be informed of potential breaches of competition law by third parties. The FCA (and DGCCRF) must provide the European Commission with this information if it considers that there may be a breach of the DMA.
[9] Defined as the practice by (i) a company both active in providing cloud services and software, of (ii) providing its software through third party cloud services in significantly different conditions (with respect to price and functionality) than through its own cloud services, where there is no justification for the difference in conditions.
[10] SREN law, Article 26.
[11] Notice on informal guidance from the FCA in the area of sustainability, available at https://www.autoritedelaconcurrence.fr/en/press-release/autorite-publishes-its-notice
[12] Respectively, Informal Guidance 24-DD-01, June 14, 2024, available at: https://www.autoritedelaconcurrence.fr/en/press-release/autorite-publishes-its-notice-provision-informal-guidance-companies-questions, and Informal Guidance 25-DD-01, January 29, 2025, available at: https://www.autoritedelaconcurrence.fr/en/press-release/sustainability-autorite-de-la-concurrence-publishes-informal-guidance-creation-system.
[13] Roadmap 2025-2026, p.5.
[14] Roadmap 2025-2026, p.7.
[15] Ibid.