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Takeaways from the Competition and Consumer Protection Commission’s (CCPC) 2025 Annual Report

EU, Competition & Procurement

Takeaways from the Competition and Consumer Protection Commission’s (CCPC) 2025 Annual Report

The CCPC published its 2025 Annual Report on 14 July 2026. The Report highlights a number of developments in Irish competition law and policy.

Tue 21 Jul 2026

3 min read

The CCPC published its 2025 Annual Report (Report) on 14 July 2026. The Report highlights a number of developments in Irish competition law and policy.

Among the themes emerging from the Report are:

  1. Competition enforcement and cartel investigations
  2. Continued implementation of the administrative enforcement regime
  3. Merger control developments
  4. Procurement and bid-rigging detection
  5. Competition research and advocacy

Competition enforcement and cartel investigations

In December 2025, five school transport operators were found by a jury in the Central Criminal Court to have engaged in bid-rigging in relation to a tender competition for publicly funded school transport services. They have yet to be sentenced. The CCPC described the verdict as a milestone in the enforcement of competition law in Ireland.

The Report also records some ongoing investigations into suspected breaches of competition law.

In 2025, the CCPC’s Cartels Division opened six investigations into suspected cartel conduct, including suspected price-fixing, market-sharing, and bid-rigging arrangements, together with a separate investigation into suspected gun-jumping. The CCPC also conducted nine unannounced searches (dawn raids) at seven commercial and two residential premises in connection with cartel investigations, compared with two dawn raids in 2024.

As part of an investigation into suspected resale price maintenance (RPM) in the household appliances sector, the CCPC conducted an unannounced inspection at the premises of an Irish distributor and cooperated with the German competition authority (Bundeskartellamt) in relation to an inspection in Germany.

The CCPC undertook dawn raids in the betting sector as part of an ongoing investigation into potential breaches of competition law.

The Report also notes that the CCPC assisted the European Commission with an inspection at the premises of an Ireland-based e-commerce company under the Foreign Subsidies Regulation.

Continued implementation of the administrative enforcement regime

A theme of the Report is the continued implementation of the administrative competition enforcement regime.

In March 2025, Mr Brian Kennedy SC was appointed as Chief Adjudication Officer and in November 2025, a panel of 17 adjudication officers was appointed by the Minister. These appointments represent important steps in the establishment and preparation of the new adjudication framework provided for under the Competition (Amendment) Act 2022 Act.

The CCPC also published a new procedure for agreeing settlements in competition law investigations. Under the procedure, the CCPC may agree to the imposition of a reduced financial sanction where a business admits to breaching competition law and agrees to a streamlined procedure for concluding the investigation. The CCPC and the business may also agree measures designed to bring any infringement to an end and reduce the likelihood of future breaches occurring.

2025 saw a public consultation launched on the adjudication rules and guidelines. The Report notes that the rules and guidelines form part of the policies and guidelines developed by the CCPC on the operation of the new administrative enforcement regime for breaches of competition law. The finalised rules and guidelines were published in 2026.

The Report also records the use of powers available to the CCPC under the new regime. During 2025, in competition law generally (principally, non-merger control work), the CCPC issued three formal requests for information (RFIs) to several businesses and 4 witness summonses requiring individuals to attend before the CCPC and provide evidence in the context of administrative competition law investigations.

An example of this is the CCPC issuing an RFI to several retailers in Ireland active as part of the investigation into suspected RPM in the household appliances sector.

Merger control developments

The Report records continued growth in merger activity during 2025. View our recent report 'Irish merger control review 2025. Key trends and 2026 outlook'.

The CCPC received 90 merger notifications in 2025, representing an increase of 9.76% on 2024 and an increase of 32% over 2023. Professional services remained the most prominent sector. The CCPC made 91 determinations in 2025, which included 12 cases carried over from 2024.

The Simplified Merger Notification Process (SMNP) continued to play an important role in the CCPC's merger review regime with 63.7% of merger determinations made in 2025 under the process and with these mergers cleared in an average of 12.47 working days. This compares with 71.4% of SMNP determinations in 2024, cleared within 13.29 working days on average. The Report also notes that the average time required to reach a Phase 1 determination in non-extended cases was 17.05 working days.

While the majority of notified transactions did not raise competition concerns, five mergers were cleared subject to legally binding commitments during 2025. A small number of transactions also required more detailed review under extended Phase 1 investigations or Phase 2 reviews. The CCPC progressed six Phase 2 investigations in 2025. They cleared two unconditionally, and cleared three with remedies, while one was carried over to 2026.

The Report also highlights the CCPC's continued focus on the development of the merger control regime. During 2025, the CCPC advanced its work on updating the Guidelines for Merger Analysis, considering issues including:

Updated draft guidelines are expected to be published for consultation at some stage over the next few months– most probably, after the European Commission adopts its merger guidelines.

The Chairperson reiterated the CCPC's view that existing merger notification thresholds should be increased to focus resources on transactions more likely to raise competition concerns and to reduce the regulatory burden on businesses. These thresholds have now been increased by the Minister for Enterprise, Tourism and Employment and have been in force since 1 July 2026.

Procurement and bid-rigging detection

The Report further highlighted the importance, from a competition law perspective, of open and transparent public procurement processes and bid-rigging detection to the CCPC.

The CCPC welcomed the Government's commitment in its Action Plan on Competitiveness and Productivity to introduce legislation empowering the CCPC to screen public procurement data to detect potential bid-rigging. Legislation is expected in the final quarter of 2026.

The CCPC continued its engagement with public procurement stakeholders during 2025. It delivered talks and presentations on bid-rigging and whistleblowing to local authorities and procurement officers, delivered a presentation on bid-rigging at Procurex Ireland, and co-presented a webinar on bid-rigging with the Competition and Markets Authority for InterTrade Ireland client companies. This focus extended beyond Ireland, with the CCPC's Cartels Division participating in an OECD-led, EU-funded project on bid-rigging alongside competition authorities and public bodies from six other European jurisdictions. The project focussed on practical tools and good practice to strengthen procurement resilience, improve referral pathways, and enhance cross agency cooperation on suspected bid-rigging cases.

Beyond the public sector, the CCPC issued recommendations to the Leinster Senior League (part of the Football Association of Ireland) concerning the mandatory purchase of products and services required for league participation, including insurance. The CCPC said that suppliers for these arrangements should be selected through regular competitive tender processes and that procurement methods should be open, transparent, and free from conflicts of interest.

The CCPC made suggestions in relation to the Government’s development of Ireland’s first national public procurement strategy. The CCPC advocated for measures to raise awareness of the harms of bid-rigging, as well as providing better data to aid in identifying sectors where competition could be strengthened and to assist the CCPC in screening for bid-rigging patterns.

Competition research and advocacy

The Report highlights the CCPC's continued focus on competition advocacy and research.

In December 2025, the CCPC published its State of Competition in Ireland report. The study examined the evolution of competition in Ireland's non-financial services sector over a fifteen-year period and concluded that competition weakened in several important areas within the services sector of the economy. According to the Report, concentration levels and average mark-ups have risen in Ireland across several industries within the services sector, particularly since 2016.

These trends were most pronounced in information and communications services and in professional, scientific, and technical services, where a small number of businesses account for a larger share of turnover. Simultaneously, the study noted some positive trends, including the contribution of younger firms to productivity improvements and increased turnover.

Beyond this report, the CCPC has also published reports on barriers to entry and barriers to expansion, which examined factors that may influence concentration levels and business dynamism in Ireland. These studies identified barriers to entry facing businesses including difficulties in raising capital, regulatory burdens, and legal costs.

Alongside its research activities the Report highlights the CCPC's advocacy work in relation to the competitive functioning of certain markets.

Comments

In addition to its merger control function, the Report indicates the importance to the CCPC of the implementation of its administrative enforcement regime and the CCPC obtaining powers to screen data for bid-rigging. The CCPC has stated that it will continue to prioritise work that keeps Irish markets open and competitive and delivering the greatest impact for Irish consumers.

For more information, please contact Anna-Marie Curran, partner, Dervla Broderick, partner, Dr Vincent Power, partner, Alan McCarthy, partner, or any member of the EU, Competition & Procurement team.

Date published: 21 July 2026

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