Topics

On 16 October 2025, the CMA launched a public consultation on its draft revised Merger Remedies Guidance (the Draft Guidance).[1]  The revision reflects the Government’s call for a more business-friendly, pro-growth approach to merger control.[2]

On November 3, 2025, the French Competition Authority (the “FCA”) imposed a EUR 7.6 million fine on the Parfait group for failing to comply with commitments entered into in the context of its acquisition of a hypermarket and shopping center in Martinique (the “Decision”),[1] illustrating the FCA’s continued vigilance regarding effective implementation of merger remedies. The Parfait group has appealed the Decision.

Introduction

In May 2025, the Commission launched a public consultation on possible reforms to its merger guidelines, covering seven core topics that underpin how the Commission assesses the competitive impact of mergers.[1] On October 29, the Commission summarized the main trends of the 243 responses[2] it received.[3] The highlights are as follows:

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.

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. 

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.

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.