Robbert Snelders

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The following is part of our annual publication Selected Issues for Boards of Directors in 2026. Explore all topics or download the PDF.

Antitrust in 2025 was marked by policy developments and enforcement that, while remaining aggressive, became less overtly anti-business. The U.S. continued several Biden-era cases but became more open to settlements, while maintaining the new and more burdensome HSR merger notification form and the more aggressive and less economically focused 2023 Merger Guidelines. It also faced leadership uncertainty, particularly at the DOJ. The European Commission conducted DMA enforcement actions and launched a broad consultation on the Merger Guidelines. The UK CMA shifted toward a more restrained approach, taking greater account of growth and signaling flexibility in merger remedies. China’s SAMR began intervening in transactions below filing thresholds and continued using antitrust as a tool amid geo-political tensions.

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.

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.

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic Paper E – Digitalization.

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic Paper D – on Sustainability and Clean Technologies.

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic C – Innovation And Other Dynamic Elements In Merger Control.

As part of our response to the European Commission’s consultation on possible reforms to its merger guidelines,[1] we provided our views on Topic Paper B – Assessing Market Power.