François-Charles Laprévote

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On January 9, 2026, the European Commission published long-awaited guidelines on its enforcement of the Foreign Subsidies Regulation (“FSR”) (the “Guidelines”).[1] In addition to delineating the FSR’s jurisdictional scope, the Guidelines clarify three key concepts: (1) when a foreign subsidy distorts competition; (2) how a distortion’s negative and positive effects are balanced against each other (the “Balancing Test”); and (3) when the Commission may use its so-called “call-in powers” to request the prior notification of transactions and public bids that fall below the mandatory FSR thresholds.

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]

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. 

In July 2025, the Commission published its draft Foreign Subsidies Regulation (FSR) guidelines for consultation. The guidelines discuss the FSR’s distortion and balancing tests and the EC’s powers to call in “below threshold” mergers and public tenders for ex ante review. 

On June 11, 2025, the French Competition Authority (“FCA”) issued its first-ever decision[1] sanctioning no-poach agreements as stand-alone infringements.[2] Fines totaling EUR 29.5 million were imposed on three companies operating in the engineering, technology consulting, and IT services sectors.  

On January 9, 2025, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) released its decision in a trade and investment barrier investigation into the European Union’s Foreign Subsidies Regulation (“FSR”).

In 2024, the FSR’s first year in operation saw a large number of filings but limited enforcement, with only a handful of Phase 2 reviews, one conditional merger clearance and two ex officio cases. With the FSR now up and running, in 2025, we expect the EC’s focus to be on demonstrating the FSR’s value and delivering practical results by stepping up enforcement, building a corpus of reasoned decisions, and – it is hoped – developing a more streamlined process for non-issue cases.

On January 21, 2025, the French Competition Authority (“FCA”) issued its first opinion on a collective agreement in the private-hire vehicle (“PHV”) services sector.[1]  Signed on December 19, 2023 by a trade organization representing two ride-hailing platforms and two driver trade unions, the agreement requires platforms to implement a system allowing drivers to set a minimum income per kilometer for the trip requests they receive. If approved by the Autorité des relations sociales des plateformes d’emploi (“ARPE”), the agreement would be extended across the entire sector.  The FCA, asked to assess whether the extension of such system could raise competitive concerns, could not rule it out, notably because only the market leader, Uber, is currently capable of implementing it.