Competition law and enforcement developements Q1 and Q2 2025

A new market investigation “tool” was adopted in December 2024 and entered into force with effect from 1 July 2025. A detailed description of the new tool is found in the memo.

One of the most unusual cartel matters our team has worked on over the past years was ultimately closed after a lengthy investigation. The NCA announced the closure of the case in a brief press release on June 26, 2025. Undoubtedly, the moving companies involved in the alleged cartel had likely infringed Section 10 of the Competition Act on several occasions over a relatively long period. On that basis, the NCA issued a “Statement of Objections” where they concluded that the “by object infringements” deserved a fine of 10 % of both moving companies’ annual turnover, the 10 % being the regulatory maximum for cartel infringements. In the briefing memo, we explain the details of the case and our opinion of why the case was closed.