Cartels

On March 17, 2026, the French Competition Authority (“FCA”) fined the National Union of French Ski Instructors (Syndicat national des moniteurs du ski français, “SNMSF”) €3.4 million for imposing an exclusivity obligation on its member instructors.[1] The FCA found that the SNMSF had implemented an exclusivity obligation prohibiting its ski instructors from teaching at competing ski schools or developing their own clientele outside the French Ski School (Ecole de Ski Française,“ESF”) network. The decision confirms the FCA’s continued scrutiny of labor markets and reaffirms that sports activities are subject to competition law. It also marks the first time the FCA has applied Article L. 464-2 of the French Commercial Code, allowing it to seek financial contributions from professional association members (in this case, the SNMSF’s members).

On January 9, 2026, the French Competition Authority (“FCA”) published the results of its third study on the French leniency procedure.[1]  The Study publishes feedback from more than 60 competition law practitioners on (i) the impact of procedural changes introduced in 2023, (ii) the key factors that encourage or discourage undertakings from applying for leniency, and (iii) the impact of potential follow-on damage actions on leniency applications.  The FCA will determine on the basis of the responses whether and how to adapt its leniency program.

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.

In the past year, the General Court has ruled on several challenges to Commission dawn raids initiated against Symrise,[1] Michelin,[2] and Red Bull,[3] clarifying the limits of the Commission’s investigatory powers. In all three cases, the General Court upheld the legality of the inspections,[4] though refined the evidentiary and procedural standards governing dawn raids.[5] The most recent Michelin and Red Bull judgments, in particular: (i) clarified what constitutes “sufficient indicia” for the Commission to initiate a dawn raid; (ii) validated the Commission’s use of new digital tools to gather indicia for dawn raids and its practice of gathering information onsite and later reviewing that information over extended periods of time at the Commission’s premises (“extended inspection”); and (iii) confirmed the Commission’s margin of discretion in selecting the most appropriate investigative measure—such as dawn raids or requests for information—in antitrust investigations.

On October 1, 2025, the General Court dismissed Laudamotion’s application for annulment of the European Commission’s (“Commission”) decision rejecting a complaint that Lufthansa’s concurrent acquisition of flight slots previously held by Air Berlin and conclusion of a wet lease agreement for 40 Air Berlin aircrafts constituted an anticompetitive concertation in breach of Article 101 TFEU.[1] The General Court reconfirmed that to sustain an infringement finding, there can be no alternative plausible explanation for the alleged anticompetitive concertation.

On September 8, 2025, the Commission imposed a fine of around €172,000 on Eurofield SAS and its parent company, Unanime Sport SAS, for providing incomplete information during an ongoing antitrust investigation. This marks the first time the Commission has imposed a fine for the provision of incomplete information in reply to a request for information (“RFI”) in the context of an antitrust procedure.[1] The Commission announced it “will not hesitate to pursue similar cases in the future.” [2]

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 June 2, 2025, the Commission fined Delivery Hero and Glovo €329 million for a cartel in the online food delivery sector.  During Delivery Hero’s non-controlling minority shareholding in Glovo from 2018 to 2022, the parties (1) agreed not to poach each other’s employees; (2) divided national markets among themselves, and (3) exchanged commercially sensitive information.[1]

On May 28, 2025, the French Court of Cassation issued a ruling dismissing an appeal from Ambulances Sannac, a French company providing private ambulance services (“Sannac”) against a decision of the French Competition Authority (“FCA”) finding it had entered into anticompetitive agreements in the sector of inter-communal hospital medical transport. The appeal was dismissed entirely due to a procedural oversight[1].