Raif Hassan

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 2, 2025, the European Court of Justice issued its ruling in Stichting v Apple,[1]clarifying that any competent national court in the Member State whose app store was used for the purchase of products can hear collective actions[2] on behalf of users of digital platforms for damages caused by anticompetitive conduct, without the need to individualize alleged victims or determine the exact location of their alleged harm.