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 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.

On December 18, 2025, the Court of Justice delivered a preliminary ruling in connection with an appeal by OSA, a Czech collective management organization handling copyright and collecting royalties (“CMO”), against an Article 102 TFEU infringement decision of the Czech Competition Authority.[1]   

Background

On December 18, 2025, the Court of Justice delivered its preliminary ruling in a case concerning an appeal by Lukoil against a Bulgarian competition authority decision which had imposed a fine on Lukoil for its refusal to grant access to third parties to essential infrastructure (fuel storage facilities, port terminals, and pipeline networks), originally constructed with public funds and subsequently privatized by Lukoil.[1]

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 December 10, 2025, the General Court confirmed the Commission’s decision to reject Bategu Gummitechnologie’s antitrust complaint against certain train manufacturers for allegedly colluding to circumvent EU standards and abusing their alleged collective dominant position by boycotting Bategu’s products.[1]

On December 10, 2025, the General Court delivered the latest judgment in the long-running Intel saga.[1] The General Court upheld the Commission’s 2023 decision to fine Intel for abusing its dominant position in the market for x86 central processing units (“CPUs”) between October 2002 and December 2007 through ‘naked restrictions,’[2] but reduced Intel’s fine from €376 million to €237 million to reflect the “temporal and material scope of the infringement”.