EUROPEAN COMMISSION

Brussels, 5.5.2026

SWD(2026) 125 final

COMMISSION STAFF WORKING DOCUMENT

Accompanying the document

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS

Report on Competition Policy 2025

{COM(2026) 180 final}

Contents

INTRODUCTION    

I.    POLICY DEVELOPMENTS AND ENFORCEMENT TRENDS    

1.    Antitrust and cartels    

1.1. Recent enforcement trends in antitrust and cartel enforcement    

1.2. The fight against cartels remains a top priority    

1.3. Modernising and simplifying antitrust rules and guidance    

1.4. Significant judgments by EU Courts in antitrust and cartels    

1.5. Cooperation within the European Competition Network (ECN) and with national courts    

2.    Merger control    

2.1. Recent enforcement trends    

2.2. Modernising and simplifying the Merger Guidelines    

2.3. Significant judgments by EU Courts in merger control    

3.    State aid control    

3.1. Recent enforcement trends in State aid control    

3.2. Modernising and simplifying State aid rules and guidance    

3.3. Significant judgments by EU Courts in State aid    

3.4. Monitoring, recovery and cooperation with national courts    

4.    The Foreign Subsidies Regulation    

4.1. Context    

4.2. Developments on rules and guidance    

4.3. Enforcement    

5.    The Digital Markets Act    

5.1. Context    

5.2. Enforcement    

5.3. Developments on rules    

5.4. Regulatory cooperation and transparency    

6.    Developing the international dimension of EU competition policy    

6.1. Multilateral relations    

6.2. Bilateral relations    

7.    Benefits of EU competition policy for consumers and citizens    

7.1. Benefits of EU competition for consumers and citizens    

7.2. Ex post evaluation    

II.    SECTORAL OVERVIEW    

1.    Energy & Environment    

1.1. Overview of key challenges in the sectors    

1.2. Contribution of EU competition policy to tackling the challenges in the green economy    

1.3. Contribution of EU competition policy to tackling the challenges in energy markets    

2.    Information, Communication, Technologies & Media    

2.1. Overview of key challenges in the sectors    

2.2. Contribution of EU competition policy to tackling the challenges    

3.    Financial services    

3.1. Overview of key challenges in the sector    

3.2. Contribution of EU competition policy to tackling the challenges    

4.    Taxation & State aid    

4.1. Overview of key challenges on tax evasion and avoidance, and fiscal aid    

4.2. Contribution of EU competition policy to tackling the challenges    

5.    Basic industries & Manufacturing    

5.1. Overview of key challenges in the sectors    

5.2. Contribution of EU competition policy to tackling the challenges    

6.    Agri-food & Fisheries    

6.1. Overview of key challenges in the sectors    

6.2. Contribution of EU competition policy to tackling the challenges    

7.    Pharmaceutical & Health services    

7.1. Overview of key challenges in the sectors    

7.2. Contribution of EU competition policy to tackling the challenges    

8.    Transport, Post, Housing & other services    

8.1. Overview of key challenges in the sectors    

8.2. Contribution of EU competition policy to tackling the challenges    

III.    SUPPORTING EU COMPETITION ENFORCEMENT    

1.    Digital Transformation    

1.1. Case Management modernisation    

1.2. Improving digital exchanges with Member States, consumers and citizens    

1.3. Advanced data support and digital solutions for competition investigations    

2.    Single Market Programme    

3.    External Communication & Advocacy    

INTRODUCTION

This Staff Working Document (SWD) consists of three parts. Part I presents the policy developments and enforcement trends in 2025 across the three competition instruments: State aid, antitrust and cartels and merger control. It also includes developments regarding the Digital Markets Act (DMA) 1  and the Foreign Subsidies Regulation (FSR) 2 : two Single Market instruments complementing the EU competition policy framework. Part II focuses on specific sectoral policy developments and enforcement actions in 2025, while Part III discusses activities supporting competition enforcement 3 .

I.POLICY DEVELOPMENTS AND ENFORCEMENT TRENDS

EU competition policy strengthens the integrity of the Single Market. Its primary objective is to promote and maintain fair and efficient competition contributing to predictable market conditions for companies to grow and invest in the EU. By keeping markets open and dynamic, a robust competition policy acts as a key enabler of competitiveness and sustainable and inclusive growth. It also increases companies’ resilience as it enables strong and diversified supply chains and addresses behaviours undermining the Single Market. Complementing traditional competition instruments, the DMA increases market contestability in the digital sector and addresses unfair behaviour by proactively tackling issues arising from digital gatekeepers, while the FSR addresses market distortions caused by subsidies from non-EU governments - ensuring a genuinely level playing field across all markets.

In 2025, the European Commission (Commission) continued to modernise and simplify EU competition policy to ensure that it fully supports a clean, just and competitive transition. This modernisation and simplification effort combined with robust enforcement of the EU competition rules, the DMA and the FSR contributes to bringing down remaining barriers to the Single Market, promotes competitive and affordable clean technologies and the free flow of products and capital and ensures that digital markets remain contestable and fair.

1.1. Recent enforcement trends in antitrust and cartel enforcement

The figures below provide an overview of the number and type of antitrust decisions in the past ten years, including decisions rejecting complaints, and letters informing complainants of the Commission’s intention to reject their complaint in the last six years. In parallel, based on the possibility for stakeholders to request individual guidance when facing genuine uncertainty about the legality of their actions 4 , in 2025, the Commission issued its first two guidance letters. One addressed an agreement for the joint purchasing and setting of minimum technical specifications for electric container-handling equipment used in ports, and the second one the creation of a licensing negotiation group in the automotive sector for the licensing of standard essential patents (see below Part II, section 8.2.6 and 5.2.3 respectively). 

Figure 1: Antitrust and cartel decisions 2016-2025

Figure 2: Rejection of complaint decisions 2016-2025

Figure 3: Rejection of complaint letters 5 2020-2025

1.2. The fight against cartels remains a top priority

Cartels cause an immense damage to the EU economy and harm businesses and consumers. Detecting and sanctioning cartels therefore remains a core mission for the Commission. Cartel enforcement is even more important at a time when companies are adjusting to new market realities, as the temptation to collude risks increasing.

In 2025, the Commission continued to build up a diversified portfolio of cartel cases, covering different sectors and behaviours, based either on leniency applications or leads obtained from its own ex officio activities which resulted in new dawn raids 6 .

The Commission’s ex officio strategy enables the detection of new cartel cases outside the leniency regime. Building on its experience and lessons drawn from recent investigations, the Commission is constantly refining methods to proactively identify suspicious patterns of behaviour. This strategy combines the use of pro-active market screening with intelligence gathered through market contacts and cooperation with other authorities and ensures that the Commission is able to act even in the absence of leniency applications. This approach also enables the Commission to safeguard the deterrent effect of EU competition policy by maintaining a credible enforcement presence across markets, including those where incentives to cooperate under the leniency programme may be weaker.

The leniency programme also continues to play an important role in the detection and investigation of cartels. The Commission receives a significant number of leniency applications covering a broad spectrum of collusion scenarios stretching across a wide range of sectors. Potential leniency applicants frequently use practical arrangements to improve this programme, including the option to reach out to designated Leniency Officers within the Directorate General for Competition (DG Competition) for informal guidance and to discuss potential leniency applications on a ‘no-names’ basis. The Commission’s online platform - eLeniency tool 7 - remains the primary means to submit applications and access leniency materials, the use of oral statements being less frequent.

In 2025, the Commission adopted several cartel decisions. On 1 April 2025, the Commission imposed fines totalling approximately EUR 458 million on 15 major car manufacturers and the European Automobiles Manufacturers' Association (ACEA) for participating in a long-lasting cartel concerning end-of-life vehicle recycling 8 . So far, this is the largest case (in terms of number of addressees) concluded under the Commission’s Cartel Settlement Procedure (see below Part II, section 1.2.10.2).

On 2 June 2025, the Commission fined Delivery Hero and Glovo, two major food delivery companies, a total of EUR 329 million for participating in a cartel in the online food delivery sector 9 . This is the first time the Commission has sanctioned a cartel in the labour market (so-called no-poach arrangement) and the use of a minority shareholding to collude (see below Part II, section 6.2.2).

On 4 July 2025, the Commission also fined Alchem International Pvt. Ltd. and its subsidiary Alchem International (H.K.) Limited EUR 489 000 for their participation, for more than 12 years, in a cartel affecting an important pharmaceutical ingredient necessary to produce abdominal antispasmodic drugs  10  (see below Part II, section 7.2.2).

On 15 December 2025, the Commission fined several automotive starter batteries manufacturers as well as the trade association Eurobat a total of around EUR 72 million for engaging in a long-running cartel concerning automotive starter batteries 11 . The decision clarifies that while a surcharge is in general a legitimate tool which contract partners can use to reflect changes in raw material costs in product prices, it is clearly illegal for suppliers to secretly coordinate to introduce and use such a surcharge as an industry-wide standard (see below Part II, section 5.2.3).

The Commission remains dedicated to investigating possible anticompetitive conduct that impacts the clean, just and competitive transition.

1.3. Modernising and simplifying antitrust rules and guidance

In 2025, the Commission continued to modernise and simplify EU antitrust rules to ensure that they fully support a clean, just and competitive transition. The developments outlined below concern rules of horizontal nature. The developments on sectoral rules and guidance are included in the relevant sections of Part II.

1.3.1.    Revision of Regulations 1/2003 and 773/2004 ongoing

Regulation 1/2003 12 and its implementing act, Regulation 773/2004 13 , establish a procedural framework aimed at ensuring the effective and uniform application of Articles 101 and 102 TFEU.

The evaluation of the two Regulations concluded in 2024 shows that they have generally achieved their objective of effective, efficient and uniform application of EU competition rules and remain relevant. That evaluation also identifies several areas for further reflection 14 . The evidence gathered in the evaluation indicated that the effectiveness and efficiency of some of the Commission’s investigative tools, in particular requests for information and inspections, is increasingly affected by digitalisation as these tools were conceived for ‘paper world' investigations with less data. The evaluation has shown that certain other aspects of the Commission’s procedures are also not optimally efficient. For example, the interim measures power, while intended for urgent situations where harm to competition is imminent, is procedurally intensive, meanwhile commitment procedures, while generally regarded as an efficient alternative to prohibition decisions, remain relatively lengthy. Finally, the procedures for granting access to file and for rejecting formal complaints were found to be resource-intensive and not optimally efficient. All these elements also stand in the way of having faster investigations. In addition, by decentralising enforcement, the Regulations have allowed national competition authorities (NCAs) to become effective enforcers of Articles 101 and 102 TFEU. This has been supported by the creation of the European Competition Network (ECN) which has been pivotal to achieving a uniform and effective application of EU competition rules. Still, the evaluation indicated that the cooperation within the ECN could be enhanced further, in particular by avoiding unnecessary parallel investigations and further improving the interplay between EU and national competition laws to ensure the coherent enforcement of all available legal instruments.

As a follow-up, the Commission launched the revision process on 10 July 2025. It seeks to keep up with transformative changes, such as the digitalisation of the economy and its impact on the Commission's enforcement tools, speed up investigations, and optimise the system of parallel enforcement by the Commission and the NCAs. The process began with a stakeholders’ consultation via a call for evidence and a public consultation questionnaire to gather feedback on options for revising the rules, running from July to October 2025 15 . On 15 December 2025, the Commission organised a reality check to engage further with stakeholders on their perspectives regarding the various policy options outlined in the call for evidence. The reality check was organised around four breakout sessions covering the following topics: (i) the Commission’s evidence-gathering toolbox (inspections, preservation orders and interviews); (ii) convergence and cooperation in the ECN, the handling of complaints, and third-party participation in proceedings; (iii) granting access to the file: confidentiality rings; and (iv) the Commission’s decision-making procedures: interim measures, commitments and remedies. The discussion also collected views on simplifying the rules and on the practical implications of the proposed policy options, to ensure they are well-targeted and achieve the intended benefits.

1.3.2.    Work on Guidelines on exclusionary abuses ongoing 

Exclusionary abuses harm consumers and citizens; they lead to higher prices, reduced innovation, limited choice, and poorer quality of goods and services.

In 2025, the Commission continued working on the future Guidelines on exclusionary abuses of dominance. The purpose of the initiative is to codify the case-law on Article 102 TFEU, ensuring legal certainty and predictability of the legal framework while providing operational guidance to companies. The initiative also aims to contribute to the modernisation of the EU’s competition policy by strengthening and making more effective and efficient the enforcement of Article 102 TFEU, thereby keeping markets open, encouraging investments and enabling the development of innovative products and services.

Following the public consultation on the draft Guidelines in 2024 16 , the Commission organised a workshop in February 2025 to continue the dialogue with stakeholders. The topics discussed were as follows: single and collective dominance; capability to produce exclusionary effects; evidentiary burden and substantive legal standard; departure from competition on the merits (notion and practical application); objective necessity and efficiencies; predatory pricing and margin squeeze; exclusive dealing and conditional rebates; tying; self-preferencing, and refusal to supply and access restrictions.

The review of the draft Guidelines is ongoing, incorporating feedback from stakeholders and recent developments in the case-law of the EU Courts. The Commission aims to adopt the Guidelines in 2026.

1.3.3.    Revision of rules on technology transfer agreements ongoing 

In 2025, the Commission launched the impact assessment phase of the review of the Technology Transfer Block Exemption Regulation (TTBER) 17 and the accompanying Guidelines (TTGL) 18 . This builds on the results of the evaluation completed on 22 November 2024 with the publication of a staff working document.

The evaluation showed that the TTBER and TTGL have been largely successful in ensuring the effective, efficient and uniform application of EU competition rules to technology transfer agreements. Specifically, both instruments have successfully assisted companies in self-assessing the compliance of their technology transfer agreements with EU competition rules.

However, the evaluation also indicated areas for improvement to increase legal certainty (for example, to address stakeholders’ practical difficulties in calculating market shares on technology markets) and that the rules could be updated to reflect recent market developments (for example, in relation to the growing importance of the licensing of certain types of data, which are not addressed by the current rules).

In light of the results of the evaluation, the impact assessment seeks to review possible policy options for those areas of the rules that could be improved to ensure that the framework remains fit for purpose in light of evolving technologies and market dynamics.

In 2025, the Commission gathered evidence through several means, including an external expert study on data licensing, a call for evidence, and a public consultation on the proposed options for revising the rules. A public consultation on drafts of a revised TTBER and Guidelines was held in September and October. A reality check was organised on 12 November 2025 to test the practical implications of proposed changes regarding data licensing, licensing negotiation groups and technology pools. More than 80 stakeholders participated in the reality check. Their feedback will inform the finalisation of the revised TTBER and Guidelines, which are expected in 2026.

1.4. Significant judgments by EU Courts in antitrust and cartels

1.4.1.    Antitrust

In 2025, the EU Courts adopted significant judgments and preliminary rulings on various aspects of antitrust enforcement.

1.4.1.1. Anticompetitive agreements under Article 101 TFEU

The Court of Justice’s preliminary ruling of 8 May 2025 in Beevers Kaas 19 clarified the conditions under which an exclusive distribution system could benefit from an exemption under the 2010 Vertical Block Exemption Regulation 20 . The Court confirmed for the first time that one of the conditions for an active sales ban imposed to protect an exclusive distribution system to benefit from the 2010 Vertical Block Exemption Regulation is that the supplier must obtain the (express or implicit) acceptance of the sales ban by all its other distributors in the European Economic Area (EEA). That condition is included in the definition of exclusive distribution systems in the 2022 Vertical Block Exemption Regulation 21 .

On 23 October 2025, the Court of Justice dismissed the appeal lodged by Teva and Cephalon against the General Court’s judgment 22 upholding a Commission decision which fined those companies for having entered into an anticompetitive pay-for-delay agreement 23 . On 26 November 2020, the Commission established that Teva and Cephalon had infringed Article 101 TFEU by concluding a settlement agreement under which Teva agreed to delay the entry of its generic product in exchange for a value transfer from Cephalon 24 . Unlike in previous pay-for-delay cases (Fentanyl 25 , Lundbeck 26 and Servier 27 ), the payment (value transfer) to Teva was made predominantly through a package of commercial deals, which were all very lucrative for Teva, rather than as a straightforward cash payment. By establishing that these side deals would not have been concluded (or at least not on the same terms) under normal market conditions, i.e. had Teva not agreed to the non-compete and no-challenge clauses in the settlement agreement, the Commission concluded that the side deals indeed represented an illegal value transfer. The Court rejected the appeal in its entirety thus confirming the Commission’s decision that the settlement agreement constituted an infringement of Article 101 TFEU by both object and effect.

1.4.1.2. Abuses of dominance under Article 102 TFEU

On 25 February 2025, the Court of Justice delivered a preliminary ruling in Alphabet/Autoritá Garante della Concorrenza e del Mercato (Android Auto) 28 . The Court clarified that, where a dominant company has developed a digital platform intended for use by third parties, refusing to grant interoperability between that platform and a third-party app may constitute an abuse of dominant position. The Court also emphasised that this refusal can be an abuse even if access to that platform is not indispensable for the commercial operation of the third-party app, but is such as to make that app more attractive to consumers. Furthermore, the Court of Justice clarified that the fact that the third-party app and other competitors remained on the market or even grew their position despite not having access to the dominant company’s platform does not mean that the refusal of interoperability did not have anti-competitive effects and was therefore not abusive. Such refusal can still be considered abusive if it has the potential to hinder competition on the market. This judgment is significant as it provides clarity when a refusal to grant interoperability may be abusive under Article 102 TFEU.

In Cluj Airport 29 , the Court of Justice clarified on 27 February 2025 in a preliminary ruling that the Council Directive 96/67/EC on access to the ground handling market at Union airports does not exclude the application of EU competition law’s prohibition of abusive conduct in situations where the airport provider refuses access to the airport infrastructure necessary for the provision of ground handling services at EU airports. The judgment confirms that the mere existence of sectoral rules does not mean that the conduct in question is exempted from the competition rules laid down by the Treaties, irrespective of whether or not those sectoral rules are applicable to that conduct.

On 10 December 2025, the General Court dismissed Intel’s 30  application for annulment of the Commission’s 2023 decision imposing on Intel a fine of EUR 376 million for infringing Article 102 TFEU by imposing so-called naked restrictions on HP, Acer and Lenovo concerning the use of AMD processors. The 2023 decision followed a legal battle between Intel and the Commission regarding a 2009 decision by which the Commission fined Intel EUR 1.06 billion for infringing Article 102 TFEU by means of exclusivity rebates and payments granted to certain customers (so-called naked restrictions). Together, those two types of conducts were considered to form a single and continuous infringement as part of a strategy aimed at excluding a competitor from the market for microprocessors. In 2022, the General Court annulled the Commission’s 2009 decision as regards the part of the single and continuous infringement relating to exclusivity rebates but annulled the fine in full, since it was not in a position to identify the amount of the fine relating solely to the naked restrictions part of the decision that was upheld. Consequently, in 2023, the Commission re-adopted a decision imposing a fine on Intel of EUR 376 million only for the naked restrictions. Intel again challenged that decision. In its judgment of 10 December 2025, the General Court fully endorsed the Commission’s decision to re-adopt a fine for the naked restrictions but, at the same time, reduced that fine by 37% to EUR 237 million in view of the lower gravity of the naked restrictions in the exercise of its unlimited jurisdiction.

1.4.1.3. Antitrust procedure

On 30 January 2025, the Court of Justice delivered a preliminary ruling in Caronte & Tourist 31 . It concluded that the ECN+ Directive 32 and Article 102 TFEU, read in light of the principle of effectiveness of EU law, preclude national legislation from imposing a 90-day time limit on a national competition authority to initiate proceedings concerning a competition law infringement in a case such as the one pending before the referring court. The underlying national legislation provides such a 90-day time limit starting from the moment the competition authority gained knowledge of the essential elements of the alleged infringement, and sanctions the failure to observe that period with the annulment of that authority’s final decision and the revocation of the authority’s power to initiate new infringement proceedings regarding the same practice.

1.4.2.    Cartels

In 2025, the EU courts dealt with several actions for annulment of cartel decisions and appeals and clarified the Commission’s inspection powers.

In Replacement Tyres 33 , the General Court upheld on 9 July 2025 the Commission’s inspection decision as regards the ‘main period’ of the suspected infringement. The Court confirmed that the Commission can launch inspections purely based on information obtained through the screening of publicly available information, and that the inspection decision was sufficiently reasoned. It also noted that the Commission can use its inspection powers even in a scenario where the evidence may be limited to publicly available information - in the present case, regular public calls with investors (so-called earnings calls) - and rejected the claim that a request for information would have been more appropriate in such a scenario. The Court however annulled the part of the decision regarding to the ‘earlier period’ of the suspected infringement, finding that the Commission did not show sufficiently serious indicia to support the suspicions for those few years in the more distant past. The judgment is final.

On 30 April 2025 in Symrise 34 , the General Court fully upheld the legality of the inspection in the ex officio Consumer Fragrance investigation. The Court confirmed that the Commission had sufficient indicia of a possible infringement to justify its actions. Importantly, the Court also upheld the Commission’s right to protect the confidentiality of its sources and investigation methods at this stage of the proceedings, recognizing that disclosing their identity or the precise origin of the information could undermine the effectiveness of cartel detection. The judgment is final.

In EGB (European Government Bonds), the General Court dismissed all six actions for annulment of the Commission’s decision on 26 March 2025 35 . In particular, the Court confirmed that the conduct constituted a single and continuous infringement. It further held that the exchanges of commercially sensitive information, price-fixing arrangements, market sharing and customer allocation - on both the primary and secondary market for EGBs - were particularly harmful to competition. Furthermore, the Court confirmed the Commission’s legitimate interest in finding an infringement with regard to Bank of America and Natixis, both of which were not fined because their infringement fell outside the limitation period. The Court also upheld the Commission’s methodology for calculating the fines but made marginal corrections. Five investment banks have since appealed against the judgment 36 .

In FOREX, the General Court partly upheld the application for annulment by Credit Suisse - now UBS - of the Commission’s decision of 2 December 2021 that imposed a fine of EUR 83 million on Credit Suisse for its participation in 2012 in one of the FOREX cartels 37 . All other banks had settled their case with the Commission for a total of EUR 1.4 billion. The Court confirmed that Credit Suisse participated in the cartel and rejected all arguments in that regard but reduced the amount of the fine to EUR 28.9 million. The Commission had calculated the value of sales on the basis of a proxy that contained a uniform reduction factor, while Credit Suisse had provided the Commission with more granular individual data. The Court found that the Commission was obliged to use this ‘best available data’ when it applied its own Fining Guidelines 38 . Neither the Commission, nor UBS, have appealed the judgment and the Commission has adapted and further individualised its fining methodology in financial cartel cases.

The judgments above are in line with previous case-law predominantly upholding the Commission’s decisions sanctioning investment banks for the anticompetitive conduct of their traders through the exchange of commercially sensitive information in a network of contacts between competitors, and endorsing - albeit sometimes with corrections - the fines calculations in the Commission’s financial cartel cases.

1.4.3.    Private enforcement of EU competition law

In 2025, the Court of Justice issued several significant rulings regarding private enforcement in EU competition law.

The Court of Justice’s preliminary ruling of 28 January 2025 in ASG 2 39  concerned a stand-alone action where several sawmills, which allegedly suffered losses following an infringement of Article 101 TFEU, assigned their damages claims to a legal person that brought a bundled action for damages on behalf of the sawmills. The Court clarified that the principles of effectiveness and effective judicial protection preclude national law which has the effect of preventing persons allegedly harmed by competition law infringements from assigning their claims for compensation on a fiduciary basis to a provider of legal services, provided that: (i) there are no equivalent legal or contractual possibilities for consolidating claims; and (ii) the bringing of individual actions for damages is, having regards to all the circumstances, impossible or excessively difficult. The judgment is significant as it states that national legislation preventing a group action to claim damages may infringe EU law.

In its preliminary ruling of 13 February 2025 in Athenian Brewery and Heineken 40 , the Court of Justice clarified that a parent company and its subsidiary can be jointly sued at the place where one of them is domiciled if the parent company exercises decisive influence on the economic activity of the subsidiary. Where the parent company holds all or almost all the shares of its subsidiary, a rebuttable presumption applies that the parent exercises such decisive influence over that subsidiary for the purpose of determining jurisdiction.

In its preliminary ruling of 4 September 2025 in Nissan Iberia 41 , the Court of Justice found that Article 101 TFEU, read in the light of the principle of effectiveness and the Damages Directive 42 , must be interpreted as meaning that the limitation period under national law for bringing an action for damages - allegedly arising from an infringement of EU competition law found in a decision by a national competition authority - cannot begin to run until that decision is no longer susceptible to appeal. The Court also emphasised that judgments in which such a decision has been definitively upheld must be officially published, freely accessible to the public, and have a clearly specified date of publication.

The Court of Justice’s preliminary ruling of 30 October 2025 in FL und KM Baugesellschaft and S 43 clarified that EU law does not grant an absolute protection to leniency statements and settlement submissions (i.e. the voluntary self-incriminating statements made by parties subject to a competition law investigation to obtain immunity or a fine reduction). In particular, the Court held that EU law does not preclude mechanisms for administrative assistance that would require a national competition authority to transmit its files, including leniency statements and settlement submissions and the information obtained from them, to the national criminal authorities, upon request, provided that such mechanisms do not jeopardize the effectiveness of leniency programs and settlement procedures as tools to detect and establish competition law infringements. The Court however clarified that once leniency statements and settlement submissions end up in criminal files, pursuant to Article 31(3) of the ECN+ Directive 44 , access to these statements and submissions can only be granted to persons under investigation for the purposes of exercising their rights of defence, in particular where complaints against those persons are based on information contained therein. Access cannot be granted to other parties, in particular injured parties who seek compensation for the harm caused by the competition law infringement. The Court further clarified that this access limitation does not extend to documents and information provided in order to explain, specify in detail and prove the content of leniency statements or settlement submissions.

1.5. Cooperation within the European Competition Network (ECN) and with national courts

1.5.1.    Cooperation with the national competition authorities (NCAs) within the ECN

Along with the Commission, NCAs and national courts enforce EU antitrust rules (Articles 101 and 102 TFEU) within their respective jurisdiction. The cooperation with NCAs takes place through the ECN 45 ensuring effective and consistent application of these rules. This unique joint enforcement has not only significantly contributed to fair competition in the Single Market, but also reinforced the relevance and credibility of EU law.

Two key mechanisms safeguard the effective and consistent application of Articles 101 and 102 TFEU: (i) the NCAs’ obligation to inform the Commission of a new investigation at the stage of the first formal investigative measure, and (ii) the NCAs’ obligation to notify the Commission of their envisaged national decisions applying those provisions. In 2025, the Commission and the NCAs launched 154 new investigations, and the NCAs notified 71 envisaged decisions to the Commission.

In addition to these formal cooperation mechanisms, the ECN members meet regularly to inform each other of new investigations, and to discuss ongoing investigations, case-law developments and various competition policy-related issues. For instance, the Commission and several NCAs pooled their data scientists to work on common detection projects within the ECN Digital Investigations and AI working group. In 2025, 37 ECN meetings took place.

1.5.2.    ECN+ Directive 

The ECN+ Directive aims to ensure that NCAs have effective enforcement tools and the necessary resources to detect and sanction companies infringing EU antitrust rules. It also aims to ensure that the NCAs can take their decisions in full independence.

In March 2025, the Commission closed the infringement proceedings which had been opened against 15 Member States for the late transposition of the Directive 46 . On 23 January 2025, the Court of Justice imposed a lump sum and periodic penalty payment on Estonia for lack of transposition 47 . Early July 2025, Estonia notified to the Commission the full transposition of the Directive. The Commission closed the infringement proceeding against Estonia on 11 December 2025 48 .

1.5.3.    Cooperation with national courts

In addition to cooperating with the NCAs within the ECN, the Commission also cooperates with national courts. The Commission supports national courts in enforcing the EU competition rules in an effective and consistent manner by providing case-related information or opinions on matters of substance, or by intervening as amicus curiae in proceedings pending before national courts.

1.5.4.    Private enforcement

The Damages Directive aims to simplify the process for those harmed by an infringement of EU antitrust rules to exercise their right to compensation before national courts. Since its adoption in 2014, the number of damages actions before national courts increased significantly, and such actions have become much more widespread across the EU. In light of this trend, DG Competition launched a study in summer of 2024 to examine the development of antitrust damages actions in the EU. This study, which is being conducted by an external consortium, seeks to take stock of the quantitative and qualitative development of private antitrust damages actions across various EU jurisdictions, including their interplay with public competition law enforcement. Work on the study is currently ongoing.

EU merger control ensures that companies active on EU markets can compete on fair and equal terms. Proposed transactions which are likely to distort competition are subject to close scrutiny by the Commission. If necessary to protect competition, the Commission can give merging companies the opportunity to dispel competition concerns by offering commitments. If sufficient commitments cannot be found or agreed upon, the Commission may prohibit the transaction. In its assessment, the Commission considers the efficiencies brought about by mergers. Such efficiencies may have positive effects on costs and innovation, provided they are verifiable, merger-specific, and likely to be passed on to consumers.

2.1. Recent enforcement trends

In 2025, the Commission received 384 notifications and adopted 370 decisions. This represents a slight decrease compared to the previous year and is broadly in line with the ten-year average. Moreover, in 2025 the Commission received 31 reasoned submissions from notifying parties during pre-notification, requesting the referral of a case either from the Commission to an NCA or vice versa. The Commission agreed to examine one transaction following a referral pursuant to Article 22 EUMR 50 and did not refer any transaction to NCAs for examination under Article 9 EUMR 51 .

The vast majority of mergers notified in 2025 did not raise competition concerns and were reviewed speedily. The simplified procedure was applied in 88% of all decisions: the Commission adopted 325 merger decisions under this procedure. Nevertheless, merger enforcement remained intensive due to the complexity of a significant number of cases. The Commission intervened in nine cases, all of which were approved subject to conditions. The Commission did not prohibit any transaction in 2025.

A significant number of non-simplified transactions concerned already concentrated industries. Reviewing these required the Commission to assess their potential impact on competition carefully, employing sophisticated quantitative techniques and comprehensive qualitative investigative tools.

In 2025, the Commission opened in-depth investigations (Phase II) in four cases, concerning the wholesale markets for branded food 52 , the wholesale market for the distribution of recorded music 53 , the market for low-carbon ferronickel 54 , and the market for container terminal services 55 . 

Figure 4: Merger outcome 2016-2025

All remedies accepted by the Commission in 2025 consisted of divestitures of tangible or intangible assets. This confirms the Commission’s general preference for structural remedies in merger cases, as they are best suited to address competition concerns arising from a concentration in a durable manner.

In the nine instances where the Commission cleared transactions subject to remedies, the notifying parties offered comprehensive remedy packages already in Phase I. This includes transactions in which the divestment business from a previous transaction once again constituted the remedy package, as seen in Safran’s acquisition of part of Collins Aerospace 56 . In this case, clearance was conditional upon Safran’s divestment of its North American trimmable horizontal stabiliser actuator systems business, which fully addressed the competition concerns identified by the Commission.

2.2. Modernising and simplifying the Merger Guidelines

In 2025, DG Competition launched the review of the EU Merger Guidelines, a key policy initiative in line with the Executive Vice-President Ribera’s Mission Letter 57 . 

Both a public and a targeted consultation were held simultaneously and ran from 8 May until 3 September 2025. The Commission received 243 responses in total, out of which 106 were replies to the public consultation. On 29 October 2025, the Commission published a factual summary of the feedback received from the public consultation 58 showing that a majority is in favour of updating the Guidelines and to replace the currently separate Guidelines by one single document. The Commission also published an overview of the main trends from the consultation 59 . 

On 4 December 2025, DG Competition organised the first stakeholder workshop on the review of the Guidelines. Around 120 participants discussed topics such as scale, market power, resilience, competitiveness and efficiencies in six interactive break-out sessions. The second workshop will be held in January 2026. The revised EU Merger Guidelines are expected in 2026.

2.3. Significant judgments by EU Courts in merger control

In E.ON 60 , on 26 June 2025, the Court of Justice dismissed the appeal of five German public sector undertakings against judgments of the General Court 61 upholding a Commission decision that authorised a transaction between German energy companies RWE and E.ON 62 . E.ON and RWE announced in March 2018 a complex asset swap by means of three transactions. One of the questions addressed before the Court of Justice was whether those three transactions formed part of a ‘single concentration’ and that, therefore, they ought to have been examined in the context of a single merger control procedure and not through three separate procedures as was the case here 63 . The Court of Justice dismissed this ground of appeal on the basis that the concept of a ‘single concentration’ does not apply where independent undertakings gain control of different targets, as is the case with this asset swap.

In Brasserie Nationale and Munhowen, the General Court dismissed an action for annulment of a Commission decision on 2 July 2025. The contested decision had granted a referral request under Article 22 EUMR, submitted by the Luxembourgish Competition Authority, regarding the acquisition of Boissons Heintz by Brasserie Nationale 64 . The action for annulment was brought, in particular, on the grounds that the applicants considered the referral request to be submitted out of time. They argued this constituted a breach of the second subparagraph of Article 22(1) EUMR, which states that a referral request must be submitted within 15 working days of the date on which the concentration was ‘made known’ to the Member State. The General Court ruled that the ‘making known’ of a concentration must consist of an active transmission - by the undertakings concerned, third parties or any other source - of relevant and sufficient information to the competent authority of the Member State concerned.

In the area of State aid control, several policy initiatives advanced the EU economy on its route to competitiveness, growth and resilience. Most significantly, the Commission adopted the Clean Industrial Deal State Aid Framework (CISAF) 65  to accompany the Clean Industrial Deal (CID) 66 , the EU’s plan for competitiveness and decarbonisation launched on 26 February 2025. The Commission also adopted a new Services of General Economic Interest (SGEI) Decision, introducing important new rules for affordable housing SGEIs (see below Part II, section 8.2.1.1), and published guidance on how Strategic Projects - as defined in the Critical Medicines Act proposal - can receive financial support from Member States while complying with State aid rules 67 (see below Part II, section 7.2.1).

3.1. Recent enforcement trends in State aid control

Figure 5: State aid decisions 2016-2025

2025 saw several Commission decisions approving aid measures in key policy areas, such as investments in the transition towards a net-zero economy, and in digital infrastructure and technologies.

Under the new CISAF, the Commission adopted eight decisions approving nine national measures notified by five Member States. The total budget notified by Member States under these State aid measures amounted to approximately EUR 18.43 billion. In particular, the Commission approved six investment aid schemes to support investment projects adding manufacturing capacity for clean technologies, key components, and related critical raw materials, based on section 6.1 CISAF, with a total budget of around EUR 6.68 billion (see below Part II, section 1.2.11). It also approved one EUR 11.3 billion scheme, under section 4.1 CISAF regarding the rollout of renewable energy (see below Part II, section 1.2.4), as well as a EUR 408 million scheme under section 5 CISAF (decarbonisation) (see below Part II, section 1.2.9).

Under the Temporary Crisis and Transition Framework (TCTF) 68 , which remained applicable until 25 June 2025 69 , the Commission adopted eight decisions (including two amendment decisions), approving six national measures notified by seven Member States 70 . The overall budget that Member States notified to the Commission under such State aid measures amounted to around EUR 2.78 billion. In particular, the Commission approved strategic investment aid schemes based on sections 2.5 and 2.8. For example, aid was approved for the deployment of large-scale energy storage to foster the transition to a net-zero economy (see below Part II, section 1.2.4). 

Additionally, based on Article 107(2)(b) TFEU, the Commission adopted two decisions related to the COVID-19 crisis in 2025 71 . It also adopted decisions in at least 13 cases for which the Member States had indicated that RRF 72 funding will be used 73 .

3.2. Modernising and simplifying State aid rules and guidance

The developments outlined below relate to rules of horizontal nature (for developments on sectoral rules and guidance, see below Part II).

3.2.1.    New State aid framework supporting the CID (CISAF) adopted

On 25 June 2025 the Commission adopted the CISAF to enable Member States to accelerate the development of clean energy, industrial decarbonisation and clean technology. The CISAF will be in place until 31 December 2030, replacing the TCTF which had been in place since 2022.

CISAF simplified State aid rules in five main areas:

I.the roll-out of renewable energy and low-carbon fuels and new rules on non-fossil flexibility measures and on capacity mechanisms following a target model;

II.temporary electricity price relief for energy-intensive users to ensure the transition to low-cost clean electricity;

III.the decarbonisation of existing production facilities;

IV.the development of clean tech manufacturing capacity in the EU, and

V.the de-risking of investments in clean energy, decarbonisation, clean tech, energy infrastructure projects and projects supporting the circular economy.

Other State aid rules relevant to the CID, such as the Climate, Environmental protection and Energy Aid Guidelines (CEEAG) 74 , continue to apply in parallel and may be used by Member States for different and more complex support measures. Member States will also continue to implement State aid measures in this field under the General Block Exemption Regulation (GBER) 75 without the need for prior notification to the Commission. On 4 November 2025, the Commission published a staff working document accompanying the CISAF, which outlines policy rationale and the evidence base considered when adopting the CISAF 76 .

3.2.2.    State aid for horizontal and other objectives

As in previous years, Member States continued to award a substantial part of aid under block-exempted measures in 2025. The block exemption regulations – the GBER, the Agriculture Block Exemption Regulation (ABER) 77 , and the Fisheries Block Exemption Regulation (FIBER) 78 ) - allow Member States to implement a wide range of public support measures without prior notification to the Commission. This reduces the administrative burden for public authorities and accelerates the delivery of public support.

While the ABER and FIBER are sector-specific, measures can be implemented under the GBER in various areas, such as research and development, environmental protection, broadband connectivity, regional development, employment, or support for small and medium-sized enterprises (SMEs). As illustrated by the figures below, the vast majority of horizontal aid falls under the GBER.

Figure 6: State aid expenditure 2014-2024, in EUR billion, in constant prices

Figure 7: GBER State aid expenditure by objective in the EU 2019-2024, in EUR billion, in constant prices

3.2.2.1. Evaluation of aid schemes

The ex post evaluation of aid schemes was introduced by the 2012 State Aid Modernisation (SAM) 79 . The aim is to gather the necessary evidence to identify the impact - both positive and negative - of the aid and to provide input for future policy-making by the Member States and the Commission. Since 1 July 2014, ex post evaluation has been required for large block-exempted aid schemes in certain aid categories under the GBER, as well as for a selection of notified schemes approved by the Commission under State aid guidelines 80 . Under the ABER and FIBER, evaluation has also been required for certain aid categories since 1 January 2023 81 .

For an aid scheme subject to the evaluation obligation, Member States must first notify an evaluation plan and subsequently submit an evaluation report in line with the plan approved by the Commission. By the end of 2025, the Commission had in total approved 163 evaluation plans, covering 20 Member States 82 and the United Kingdom (the UK).

Most of the approved plans concerned notified energy and broadband schemes, alongside large regional aid and research, development, and innovation projects under the GBER. In total, these schemes account for over EUR 130 billion in annual State aid budgets 83 . By the end of 2025, the Commission services had reviewed a total of 67 interim and 57 final evaluation reports, which were considered to be of average to good quality - particularly the final reports 84 .

By assessing these reports, the Commission seeks to: (i) provide appropriate feedback to Member States; (ii) make sure that results are used for more effective policy-making; and (iii) provide evidence to assist Member States when considering future legal developments.

3.2.2.2. Review of the State aid GBER ongoing

On 14 July 2025, the Commission launched a call for evidence and public consultation 85 seeking input on the scope and content of the review of the GBER. The review aims at reducing the administrative burden of Member States and undertakings, resolving implementation difficulties or errors, and providing Member States with greater flexibility in designing support measures.

This includes a review of the current rules for social enterprises, training and employment aid, following up on the ‘Action Plan for the Social Economy’ (2021) 86 and the ‘Union of Skills’ (2025) 87 , as well as a review of aid rules for affordable and energy-efficient housing. The latter is intended to be complementary to the new State aid rules on the SGEI adopted on 16 December 2025 88 (see below, Part II, section 8.2.1.1). 

Both the questionnaire-based public consultation and the call for evidence closed on 6 October 2025. In essence, respondents to the public consultation found that the GBER aligns, to some extent, with certain policy objectives, such as legal certainty, promoting green and digital transitions, fostering resilience, promoting R&D, and economic and social cohesion. However, they emphasised the need to reduce administrative burden, improve user-friendliness and legal certainty, simplify compatibility conditions, and adapt to current political, economic, technical, and social changes. Contributions to the call for evidence also expressed keen interest in simplifying the GBER, reducing administrative burdens, and ensuring alignment with current EU policy priorities.

Overall, the Commission received 217 replies to the public consultation and 282 contributions to the call for evidence from a wide variety of stakeholders, including public authorities, business associations, individual companies, NGOs, trade unions, academic and research organisations, and citizens 89 . The adoption of the revised GBER is planned for the end of 2026, before the current GBER expires on 31 December 2026. 

3.2.2.3. Aid for research, development, and innovation (R&D&I)

R&D&I is a key driver of economic growth and is necessary to achieving a variety of policy objectives, including those of the European Green Deal and the Digital Strategy. Where there is a market failure due to a high risk related to investment, and this market failure leads to suboptimal R&D&I activities, State aid for such activities can be necessary and appropriate.

The vast majority of all R&D&I State aid measures are implemented under the GBER, which does not require prior notification to the Commission. Prior authorisation under the framework for State aid for research, development and innovation (R&D&I Framework) 90  is, however, possible for large aid amounts.

3.2.2.4. Important Project of Common European Interest (IPCEI)

In 2025, the Commission approved one new IPCEI: the IPCEI Tech4Cure 91 . This is the second health-related IPCEI and it supports cross-border research, innovation, and the first industrial deployment of a new generation of medical devices. These devices incorporate advanced and novel digital/AI solutions to support the concept of predictive, preventive, and personalised medicine (‘3P medicine’) (see below Part II, section 7.2.4). 

Throughout 2025, the Commission also continued to work in close partnership with Member States through the Joint European Forum for IPCEIs (JEF-IPCEI). The JEF-IPCEI provides a platform for close and flexible cooperation between Commission services and Member State authorities; where relevant, they may also invite representatives from candidate countries, industry, academia, and other stakeholders. Jointly led by DG Competition and the Directorate General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW), the JEF IPCEI covers the entire IPCEI life cycle, from identification of areas of strategic interest for potential future IPCEIs, to the design, assessment and implementation of IPCEIs at national level. Its objectives include improving speed and efficiency of the IPCEI process by streamlining procedures and aligning potential new IPCEIs with the EU industrial strategy and other relevant EU strategies.

The dedicated JEF-IPCEI website 92 provides regular updates on the forum's activities, including technologies currently being identified as potential new IPCEI candidates as well as those currently in the design phase, thus ensuring visibility and transparency of efforts and results. By publishing streamlined IPCEI templates, factsheets, reports and recommendations, the website also provides guidance to Member States and interested stakeholders. There are currently two ongoing working groups identifying potential future IPCEI: clean, connected, and autonomous vehicles, and critical raw materials. 

Since its creation in 2023, the JEF-IPCEI’s work has enabled eight IPCEI candidates to enter the design phase, including four in 2025 (innovative nuclear technologies, biobased chemicals, biobased materials, biotechnologies for food and feed), and has led to the publication of 12 recommendations covering the entire IPCEI life-cycle and enabling Member States to streamline, simplify and speed up the set-up and the implementation of IPCEIs.

Following the adoption of the CID, the Commission launched the IPCEI Design Support Hub 93  on 9 April 2025. The Hub aims to provide dedicated support to the Member States involved in the design phase, streamlining the process, increasing efficiency and better preparing the subsequent assessment phase. It comprises a team led by DG Competition, in close collaboration with relevant experts across the Commission, including, whenever relevant, the Joint Research Centre (JRC). Currently, all eight IPCEI candidates in the design phase are being supported by the Hub 94 .

3.2.2.5. Aid to support EU semiconductor ecosystem

Since outlining the principles of support for capacity building in the semiconductor industry in the Chips Act Communication 95 , the Commission has approved 11 cases, authorising up to EUR 13.8 billion in public support. Of the measures supporting new semiconductor manufacturing facilities, six were approved in 2025 96 , with a combined budget of approximately EUR 2.3 billion.

3.2.2.6. Regional aid

In 2025, the Commission adopted several decisions concerning regional investment aid

Specifically, it approved aid to: PCC for the setting up of a chemical plant in Poland 97  (see below Part II, section 5.2.5.); Envision for the construction of an electric vehicle battery factory in France 98  (see below Part II, section 1.2.11); Sunwoda for the construction of an electric vehicle battery factory in Hungary 99  (see below Part II, section 1.2.11); and to Vetter Pharma for the construction of a production facility in the pharmaceutical sector in Germany 100  (see below Part II, section 7.2.4). 

The Commission also approved an amendment to a tax scheme that aims at supporting investments in French outermost regions 101 . In another instance, the Commission found that aid granted by Germany to Abalon Hardwood Hessen was, at least in part, incompatible with State aid rules because the aid granted exceeded the maximum allowed in that specific assisted area and called for recovery of this part of the aid 102 . Furthermore, the Commission opened a formal investigation into planned aid by Poland to Man Trucks. In this case, the Commission expressed doubts as to both the incentive effect of the aid and its proportionality 103 .

           3.2.2.7. Infrastructure support measures 

In 2025, the Commission dealt with several infrastructure support measures. In particular, it approved a Greek support measure for the construction of two sections of the motorway on the island of Crete, called BOAK, under Article 107(3)(c) TFEU 104 . The Commission also approved changed Lithuanian support for the construction of a multifunctional complex in Vilnius 105 . Moreover, the Commission approved aid for the set-up of an infrastructure dedicated to the gaming industry in a Just Transition area in Poland. This project, co-financed by the Just Transition Fund (JTF), combines the rehabilitation of a former coal mine with the construction of a multifunctional technological facility 106  (see below Part II, section 2.2.3.2). 

3.2.3.    EU environmental and State aid law – access to justice in relation to State aid decisions 

The EU and its Member States are parties to the United Nations Economic Commission for Europe (UNECE) Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (the Aarhus Convention). To address the findings of the Aarhus Convention Compliance Committee in case ACCC/C/2015/128 107 , the Commission established an internal review mechanism covering certain State aid decisions. This mechanism was introduced by an amendment of the Implementing Regulation 108 and of the Best Practices Code 109 adopted on 12 May 2025.

This mechanism enables eligible non-governmental organisations (NGOs) to request an internal review of certain Commission final State aid decisions that close a formal investigation procedure under Article 108(2) TFEU, on the grounds that the activity subject to State aid and/or any of the aspects of the State aid measure approved by that decision that are indissolubly linked to the object of the aid, contravene a specific rule or rules of Union environmental law.

The first Aarhus review request concerned the 2024 Commission’s decision on the PALLAS project, which involved aid for the construction of a research reactor and of an isotope processing facility in Petten for cancer diagnosis and treatment 110 . The Dutch NGO Stichting Laka requested the Commission to review the compliance with EU environmental law of its decision which found the Dutch authorities’ measures in favour of the PALLAS project compatible with the internal market. The request was rejected as inadmissible 111 .

3.3. Significant judgments by EU Courts in State aid

In 2025, the EU Courts adopted several important judgments in the field of State aid, concerning in particular the notions of ‘advantage’ and ‘selectivity’, the assessment of other provisions of EU law, damages actions, as well as the national implementation of aid schemes.

3.3.1.    Notions of advantage and beneficiary

In European Gaming and Betting Association (EGBA) 112 , the Court of Justice confirmed the annulment by the General Court of the Commission’s decision approving the extension of lottery licences in the Netherlands. The Court of Justice held that the Commission could not have excluded serious difficulties in its assessment that the measure at issue was no aid without looking into whether it conferred an indirect advantage to some of the charitable entities that would be remitted funds from certain licence holders. Given that the remittance of part of the proceeds generated by the activity of the licence holders to bodies designated by those licences constituted one of the main features of the legislation at issue, the Commission could not have excluded the existence of serious difficulties in this case.

3.3.2.    Selectivity 

In Prezydent Miasta Mielca 113 , the Grand Chamber of the Court of Justice delivered a preliminary ruling considering that general and abstract tax exemptions are presumed to be inherent to the normal tax system (i.e. the reference system) and do not - as a general rule - confer a selective advantage unless a consistent category of beneficiary undertakings is formed. Accordingly, the Court of Justice considered that the Polish real estate tax exemption for land and structures forming part of railway infrastructure in question did not appear to confer a selective advantage. 

3.3.3.    Assessment of other provisions of EU law

In its judgment of 23 January 2025 in Neos v Ryanair 114 , the Court of Justice set aside the judgment by which the General Court had annulled the Commission’s 2020 decision approving an Italian damage compensation scheme for airlines during the COVID-19 pandemic for lack of reasoning as regards certain requirements (for example minimum remuneration). The Court of Justice noted that given the extremely large number of provisions and principles of EU law that could have been infringed by the grant of aid in question, the Commission could not be required to provide specific reasoning concerning each one of them, but could disregard those provisions and principles that were either not relevant with respect to the measure at hand or, in any event, had not been infringed. On this basis, the Court of Justice considered that the Commission had sufficiently explained its assessment of the minimum remuneration requirement.

On 11 September 2025, in Paks II 115 , the Court of Justice (Grand Chamber) annulled the Commission’s 2017 decision approving aid for two nuclear reactors in Hungary. The Court held that the Commission should have ascertained whether the direct award of the contract for the construction of the nuclear reactors to a Russian undertaking complied with EU public procurement rules. The Court of Justice considered that the public procurement procedures for the construction of the nuclear reactors in question were inextricably linked to the State support of the electricity production from these reactors, and that the direct award was a pre-condition for the financing of the construction project.

3.3.4.    State aid in the aviation sector

On 13 February 2025, the Court of Justice annulled the General Court's judgment of 8 February 2023 in Carpatair 116 . This judgment concerned a Commission decision finding that agreements signed between Wizz Air and Timisoara airport for the use of the airport infrastructure were in line with the Market Economy Operator (MEOP) test, based on an ex post reconstruction of the financial analysis with the information available to the airport prior to the conclusion of the contracts. In its judgment, the General Court had considered that the Commission could not demonstrate the compliance with the MEOP test based on evidence reconstructed entirely after the conclusion of the agreements, even if that evidence is based on information that was available and on developments foreseeable at the time when the agreements were signed. The Court of Justice annulled the General Court's judgement, finding that the General Court had not substantiated its conclusion that Carpatair’s action for annulment of the Commission’s decision was admissible. The Court of Justice did not take a position on the application of the MEOP test but referred the case back to the General Court.

On 2 April 2025 in Ryanair (LOT) 117 , the General Court upheld the Commission’s decision of 22 December 2020, which had approved a Polish State aid measure to the airline LOT under the Temporary Framework for State aid measures to support the economy during the COVID-19 pandemic. Two points of particular interest were addressed: (i) the identification of the beneficiary of the aid measure. Specifically, the necessity to assess the respective roles of a parent undertaking and its affiliates within a group; and (ii) the issue of eligibility for aid, since the Temporary Framework established that, for recapitalisation measures, the beneficiary must be unable to find financing on the markets at affordable terms.

In its judgment of 25 June 2025 in Condor II 118 , the General Court confirmed the 2021 Commission’s decision approving approximately EUR 145 million of damage compensation to the airline Condor for the damage suffered between March and December 2020 due to the COVID-19 pandemic.

In a judgment of 10 December 2025 in Restructuring aid for TAP 119 , the General Court dismissed in full Ryanair’s challenge of the legality of the Commission’s decision of 21 December 2021, which approved a EUR 2.55 billion restructuring aid for TAP. The Court confirmed the Commission’s findings relating to the eligibility of TAP to receive the restructuring aid and the role the company plays in the connectivity of Portugal and in the Portuguese economy. The Court also confirmed that the restructuring plan presented by Portugal for TAP was realistic, coherent, far-reaching and that it ensured company’s return to long-term viability. The Court confirmed the proportionality of the aid amount. It rejected Ryanair’s arguments that the compensatory measures proposed by Portugal were insufficient or inadequate to limit distortive effects of the restructuring aid on competition and internal market. Those measures included a divestiture of 18 daily slots at the Lisbon airport, a limitation of the size of TAP’s fleet until end 2025 and a divestiture of TAP SGPS’s stakes in Cateringpor and Groundforce.

3.3.5.    Damages actions

In Kargins 120 , the General Court confirmed the lawfulness of the possibility for the Commission to submit amicus curiae in national proceedings concerning State aid 121 . The Court also clarified that an invitation by one of the parties to intervene does not affect the Commission’s impartiality. On this basis, the General Court dismissed the action seeking damages from the EU in relation to an allegedly unlawful intervention by the Commission as amicus curiae within the context of a national dispute.

3.3.6.    National implementation of an aid scheme

In Toode 122 , the Court of Justice delivered a preliminary ruling on the effect of an unlawful refusal of an aid application by the Latvian authorities. The Court considered that, in the case at hand, the right to an effective remedy under Article 47 of the European Charter of Fundamental Rights precluded an interpretation of national law whereby the date of the grant could not correspond to the date of the unjustified refusal. This applies specifically where the refusal occurred within the time-limit set by the Commission’s decision, but a judicial finding of unlawfulness was only reached after that time-limit had expired.

3.4. Monitoring, recovery and cooperation with national courts

3.4.1.    Increased monitoring of existing State aid to ensure competition on fair and equal terms

As in previous years, the majority of the new State aid measures implemented in 2025 were covered by a block exemption regulation, such as the GBER 123 . It is essential for the Commission to verify that Member States apply State aid schemes correctly and that they only grant aid when all conditions are met. 

The Commission monitoring consists of regular ex post controls based on a sample of existing aid schemes, both block-exempted and approved measures. This serves as a necessary complement to the approval of State aid schemes by the Commission, and acts as a counterweight to the ‘self-assessment’ performed by Member States resulting from the exemption from the notification obligation.

As part of the monitoring process, the Commission follows up on irregularities and uses the tools at its disposal to address the competition distortions that those irregularities may have caused. In some instances, Member States offer to rectify detected problems voluntarily, for example by amending national legislation or recovering aid granted in excess of the permitted levels. In other cases, the Commission may need to take formal action.

In 2025, the Commission launched a new monitoring cycle of block exempted and approved aid granted in 2022 and 2023. The selected sample includes aid granted to support the economy during the COVID-19 pandemic, as well as aid schemes introduced in response to the Russian war of aggression against Ukraine.

3.4.2.    Restoring competition by recovering State aid granted in breach of the rules

To ensure the integrity of the Single Market, Member States must take all necessary measures to recover unlawful and incompatible aid. The purpose of recovery is to restore the situation that existed in the internal market prior to the granting of the aid. This is necessary to maintain effective competition.

In 2025 the Commission adopted three new recovery decisions 124 . By the end of the year, 25 recovery cases - resulting from previously adopted negative decisions with recovery - were pending.

As of 31 December 2025, the total amount of unlawful and incompatible aid recovered from beneficiaries stood at EUR 39.8 billion 125 . At the same point in time, the outstanding amount pending recovery was EUR 6.2 billion.

Figure 8: Recovery Decisions in 2025 

In 2025, the Commission imposed penalties on Greece and Italy based on Court judgments condemning these two Member States for having infringed EU State aid rules 126 .

3.4.3.    Cooperation with national courts to ensure the effectiveness of State aid rules

The Commission cooperates with national courts under Article 29 of Regulation 2015/1589 127 and in accordance with the Notice on the enforcement of State aid rules by national courts (the Notice) 128 . This cooperation includes direct case-related assistance, where national courts and tribunals may request information from the Commission or seek an official opinion on the application of State aid rules. Additionally, the Commission may submit amicus curiae observations on its own initiative. To ensure transparency, the Commission publishes these opinions and amicus curiae observations, as well as observations to other bodies, such as arbitration tribunals, on its website 129 .

The Commission also reaches out to national judges by providing training on State aid rules and on the practical implications of the Notice. In this context, the Commission encourages national judges to utilise the Notice to promote the coherent enforcement of State aid rules at national level across the EU. Past studies on the enforcement of State aid law at national level indicate a relatively limited number of State aid cases being brought before national courts 130 . 

Since national courts can play a crucial and complementary role in enforcement of State aid rules, the Commission has recently stepped up its efforts to reach out to judges with more tailored training sessions. For instance, following a general tender for the training of national judges 131 , the Commission is cooperating with the Vrije Universiteit Brussel (VUB) to provide trainings through the SUNAJUST programme. This programme is designed to: (i) develop accessible and engaging course materials; and (ii) organise numerous training events for judges, prosecutors, apprentice national judges, and national court staff. On 3 December 2025, the Commission hosted a reality check on State aid private enforcement and the use of State aid rules in national courts to gather insights from judges, lawyers, academics and other stakeholders on the practical challenges and opportunities in enforcing State aid rules at national level.

The FSR is a Single Market legislation that aims at addressing possible distortions of competition in the Single Market when subsidies granted by non-EU governments benefit economic activities in the EU. It started to apply in July 2023.

4.1. Context

The FSR fills a regulatory gap by tackling distortive effects created in the EU Single Market in situations where undertakings benefitting from foreign subsidies have an advantage when acquiring undertakings active in the Single Market, participating in public procurement processes or more generally when they invest and make commercial decisions in the EU Single Market. Such distortive foreign subsidies, including below-market interest rate loans, unlimited State guarantees, favourable tax agreements or dedicated State funding, would be problematic if granted by an EU Member State when assessed under EU State aid rules.

Considering the challenge to find a multilateral solution to subsidies within a reasonable timeframe, the Commission committed, as part of the New Industrial Strategy for Europe, to explore how best to strengthen the EU’s anti-subsidies mechanisms and tools. As a result, the FSR was adopted on 14 December 2022. This set of rules enables the Commission to address distortions caused by foreign subsidies and allows the EU to ensure a level playing field for all companies operating in the Single Market, while remaining open to trade and investment.

Under the FSR, the Commission has the power to examine any foreign subsidy granted to an undertaking engaging in an economic activity in the Single Market. It may act on its own initiative (ex officio) or through the review of compulsory notifications for large concentrations and large public procurement procedures. Within the Commission, DG Competition is in charge of concentration notifications and ex officio investigations, while DG GROW deals with public procurement procedures and related ex officio cases.

4.2. Developments on rules and guidance

To provide legal clarity regarding the implementation of the FSR and ensure transparency on the Commission’s action, DG Competition’s and DG GROW’s websites provide regularly updated Q&As providing clarifications on a number of procedural, jurisdictional and implementation issues 132 . In 2025, clarifications were added regarding: (i) which foreign financial contributions should be taken into account for the purpose of calculating the relevant notification thresholds (Q9); (ii) whether a third country’s collateral to a loan granted to it by a financial institution constitutes a separate foreign financial contribution (Q18); (iii) which parts of a loan need to be reported where such a loan is provided by a third country or to a third country or both (Q19); and (iv) how passive investments by limited partners attributable to a third country should be notified in case of acquisitions of control or creation of joint ventures by a private investment fund (Q26).

In 2024, the Commission provided initial clarifications on several key concepts of the Regulation, including the distortion caused by a foreign subsidy on the internal market (Article 4(1) FSR), the application of the balancing test (Article 6 FSR), and the assessment of a distortion in a public procurement procedure (Article 27(1) FSR) 133 .

In 2025, the Commission worked on additional clarifications provided as Guidelines to be adopted by 13 January 2026 as laid down in Article 46 FSR. In this context, the Commission launched a call for evidence in March 2025. Following a pre-consultation phase with targeted stakeholders, a public consultation on the draft guidelines was held between 18 July 2025 and 12 September 2025. Around 60 stakeholders provided input, ranging from EU industry associations (20%), consultants (27%), EU public authorities (16%), undertakings (14%), third countries’ authorities and associations (14%), academia (2%) 134 . These Guidelines intend to cover the: (i) application of the criteria for determining the existence of a distortion (Article 4(1)); (ii) application of the balancing test (Article 6); (iii) application of the Commission’s power to request the prior notification of any concentration (Article 21(5)) or of foreign financial contributions received by an economic operator in a public procurement procedure (Article 29(8)); and (iv) assessment of a distortion in a public procurement procedure (Article 27).

In parallel, the Commission launched the FSR Review in August 2025. The process started with the publication of a call for evidence and a public consultation 135 . The review focuses on the: (i) assessment of foreign subsidies that distort the internal market; (ii) application of the balancing test (that is to say whether positive effects of the foreign subsidy counterbalance its distortive effects); (iii) review of foreign subsidies with a possible distortive effect in the internal market on the Commission's own initiative; (iv) notification thresholds; and, (v) level of complexity of the rules and the costs incurred by businesses. Interested stakeholders submitted their views until November 2025. An external study has also been commissioned to provide a factual overview of the Commission’s case practice and identify potential aspects of the FSR implementation for simplification. The FSR Review report is scheduled for publication by 14 July 2026, as set out in the Regulation. 

On 15 October 2025, the Directorate-General for Trade & Economic Security (DG TRADE), DG GROW and DG Competition held a joint reality check. This event sought technical feedback from practitioners on the implementation of the trade anti-dumping and anti-subsidies regime 136 (TDI) and the FSR. The Commission services presented the various activities under these instruments and answered questions from stakeholders.

4.3. Enforcement

Under the FSR, the Commission reviews notified proposed concentrations and participation in public procurement procedures. It also carries out ex officio investigations if information suggests a foreign subsidy is distorting the internal market. DG Competition is tasked with concentration notification cases and ex officio procedures: those activities are described below. FSR enforcement benefits from the support of the intelligence and digital forensic teams of the Chief Technology Officer (CTO) Unit in DG Competition.

In 2025, 99 concentrations were notified under the FSR.

In the case of the acquisition by Abu Dhabi National Oil Company PJSC (ADNOC) of sole control of Covestro AG (Covestro), ADNOC notified the transaction on 15 May 2025. ADNOC, headquartered in the UAE, is a State-owned oil and gas producer and the national oil company of Abu Dhabi. Covestro (formerly Bayer MaterialScience AG), a publicly listed company incorporated in Germany, is a chemical producer that focuses on the supply of high-performance polymers and components for such polymers. The Commission opened the in-depth investigation on 28 July 2025. ADNOC offered commitments in the early phase of this investigation, in the interest of addressing the Commission’s concerns. Therefore, while carrying out a detailed in-depth investigation, the Commission was able to adopt the decision well ahead of the legal deadline, without needing to formalise its concerns in a Statement of Grounds. On 14 November 2025 137 , the Commission adopted a decision with commitments. This is the second final Commission decision under the FSR.

The Commission identified foreign subsidies in the form of an unlimited State guarantee and tax benefits to ADNOC, as well as a committed capital increase by ADNOC into Covestro. It assessed the possible distortive effects of the foreign subsidies both in the acquisition process and, looking forward, in the activities of the combined entity. The decision concludes that, in view of the unduly favourable conditions - including the capital increase which directly facilitated the acquisition, and the seemingly unduly inflated price - offered by ADNOC for the acquisition of Covestro, which may have deterred other investors from making an offer, the foreign subsidies could have potentially led to negative effects on competition in the acquisition process. As to distortions in the activities of the combined entity in the internal market, the decision concludes that the foreign subsidies would have artificially improved the capacity of the combined entity to finance its activities in the internal market and increased its indifference to risk. In the specific context of the chemical sector, this would likely have affected its investment strategies - such as capital expenditures, future acquisitions, etc. - to the detriment of competition and other market players. The commitments offered by ADNOC provide that ADNOC will adapt its articles of association so that they no longer deviate from ordinary UAE insolvency law, thereby removing the unlimited State guarantee. They also provide that Covestro’s sustainability patents will be shared within the internal market at transparent terms and conditions set in advance, benefitting those companies that are particularly reliant on Covestro’s sustainability technology. ADNOC appointed a trustee who will monitor compliance with the commitments.

In 2025, the Commission also continued working on its ex officio investigations in the fields of security equipment for airports and ports and wind energy.

In the field of security equipment, the Commission adopted a decision on 11 December 2025 to open an in-depth investigation into Nuctech. This was based on sufficient indications that the company had been granted foreign subsidies distorting the internal market 138 . These subsidies reportedly take the form of grants, preferential tax measures or loans on preferential terms. The Commission holds preliminary concerns that the foreign subsidies may have improved Nuctech's competitive position in the internal market, allowing it to offer prices and conditions that cannot be reasonably matched by other market players, thereby distorting competition in the internal market. The Commission will investigate these concerns in detail during the in-depth investigation. Should they be confirmed, the Commission may impose redressive measures or accept commitments from the company to effectively address the concerns.

Regarding the court proceedings related to this case, on 21 March 2025, the Vice-President of the Court of Justice upheld the order of the President of the General Court, which had rejected Nuctech’s application for interim measures concerning the Commission’s inspection decision 139 . In his order, the Vice-President of the Court of Justice confirmed that the Commission is entitled to address an inspection decision to an undertaking incorporated outside the EU, provided it operates within the EU, and may inspect the EU premises of such undertaking. It was further confirmed that Commission must be able to inspect information accessible from a business’ EU premises, even when that information is stored outside of the EU. Nuctech’s appeal against the Commission’s decision to carry out unannounced inspections at its two EU entities on 23 April 2024 remains pending 140 .

Furthermore, the Commission continued its preliminary review into the conditions for the development of a number of wind parks in some Member States. This review is based on indications that some wind manufacturers and other companies active in the internal market may benefit from foreign subsidies, granting them an unfair competitive advantage 141 . This investigation followed the ‘European Wind Power Action Plan’ 142  through which the Commission committed to closely monitoring potential foreign subsidies that create distortions of competition. The preliminary review is based on Articles 9 and 10 FSR, which empower the Commission to examine information from any source regarding alleged distortive foreign subsidies on its own initiative. Under these provisions, where the available information indicates the possibility of a distortive foreign subsidy, the Commission may seek all information necessary to assess, on a preliminary basis, whether the financial contribution constitutes a foreign subsidy and whether it distorts the internal market.

The DMA is a Single Market legislation that harmonises the obligations of gatekeepers - large digital platforms that provide services that are an important gateway for business users to reach end users - across the EU. It contributes to a well-functioning Single Market by laying down rules that ensure contestability and fairness in digital markets. The DMA therefore opens ecosystems, creates real opportunities for businesses to enter and expand into new markets, and provides end users with more and genuine choice. As one of the centrepieces of the European Digital Strategy 143 , the DMA complements EU competition rules, which continue to apply to digital platforms. The DMA entered into force on 1 November 2022 and became applicable on 2 May 2023.

5.1. Context

The DMA is the first regulatory tool in the world to comprehensively regulate the gatekeeper power of the largest digital companies. Currently, the DMA applies to seven gatekeepers together operating 23 regulated platforms. The Commission (with DG Competition and DG Communications Networks, Content and Technology (DG Connect) in the lead) is the sole enforcer of the DMA. It works in close cooperation with the NCAs within the ECN in accordance with Articles 37 and 38 DMA.

Following the first designation decisions in September 2023, which triggered the six-month deadline for gatekeepers’ compliance, the Commission moved into the implementation and enforcement stage in March 2024. Throughout 2025, the Commission continued an intense regulatory dialogue with all designated gatekeepers to implement the DMA obligations effectively. It organised public compliance workshops to provide a forum for third parties to engage with the gatekeepers on their compliance solutions. The Commission also continued the non-compliance investigations opened in March 2024 and concluded three of them. Moreover, the Commission issued two specification decisions, the first-of-their-kind, which provide guidance to gatekeepers on how to comply with certain obligations.

The Commission’s efforts have led to very tangible changes to the benefit of both businesses active in Europe as well as European consumers. These include for example: opening up mobile ecosystems by allowing developers to offer alternative app stores on iOS and iPadOS to contest Apple’s own App Store, allowing eSIMs transfer from an Android phone to an iPhone and vice versa, enabling greater interoperability across services and devices (for instance by granting device manufacturers and app developers improved access to iPhone features that interact with such devices), and offering a choice screen for users to select their preferred default browser on iOS devices. These changes, which directly benefit consumers, were acknowledged by the European consumer organisation, BEUC, in its November 2025 report, ‘First Bloom: Increased Consumer Choice After Eighteen Months of the DMA’ 144 . The report underscores that these outcomes represent early but meaningful progress under the DMA.

5.2. Enforcement

5.2.1.    Gatekeeper designations

In 2025 no new Core Platform Services (CPSs) were designated by the Commission.

On 23 April 2025, following a market investigation, the Commission concluded that Meta’s online intermediation service Facebook Marketplace should no longer be designated as a CPS under the DMA 145 . The decision follows a request submitted by Meta on 5 March 2024 to reconsider the designation in September 2023 of Facebook Marketplace as an online intermediation service. Following an assessment of Meta’s arguments and market investigation, the Commission found that the changes Meta brought to the service resulted in a reduction of business users in Facebook Marketplace below the designation thresholds.

5.2.2.    Formal proceedings

On 19 March 2025, the Commission adopted two decisions specifying the measures that Apple must take to comply with its interoperability obligation (Article 6(7) DMA) for hardware and software features controlled by its operating systems iOS and iPadOS 146 . The first case concerns nine iOS connectivity features, predominantly used for connected devices. This covers for example the display of iPhone notifications on a smartwatch. The second case concerns request process put in place by Apple, which developers must follow to obtain interoperability with iOS and iPadOS. The measures implemented are based on technical input from Apple as well as feedback from third parties gathered during the public consultations and bilateral exchanges. The first measures have been implemented in the iOS 26 version and are already delivering concrete improvements for users. Apple has appealed both specification decisions 147 .

On 23 April 2025, the Commission concluded its investigation into Apple’s anti-steering practices by finding that Apple breached Article 5(4) DMA and imposing a EUR 500 million fine on Apple 148 . The Commission imposed a cease and desist order, forcing Apple to remove all technical and commercial restrictions on steering within 60 days subject to periodic penalty payments. The decision has been appealed by Apple. On 26 June 2025, Apple rolled out updated terms for the App Store and revised contractual terms for app distribution on iOS. The Commission continues monitoring Apple’s compliance with its decision of April 2025.

On 23 April 2025, the Commission also concluded its investigation into Meta’s ‘consent or pay’ advertising model finding that Meta breached Article 5(2) DMA and imposing a EUR 200 million fine 149 . In addition, the Commission imposed a cease and desist order, forcing Meta to bring the non-compliance of its ‘consent or pay’ model effectively to an end within 60 days subject to periodic penalty payments. The decision has been appealed by Meta. Following a close dialogue with Meta, the Commission took note on 8 December 2025 of Meta’s undertaking to offer users in the EU an alternative, free version of its social networks using less personal data for an experience with less targeted advertising, based on a specific choice interface and flow for users. Following its implementation, the Commission will seek feedback and evidence from Meta and other relevant stakeholders on the impact and uptake of this new ad model.

On 23 April 2025, the Commission closed the investigation into Apple’s user choice architecture and its compliance with the obligations to easily uninstall software applications and change default settings on iOS 150 . This closure follows a constructive dialogue between the Commission and Apple. Among the results, Apple changed its browser choice screen, streamlining the user experience of selecting and setting a new default browser on iPhone.

On 6 November 2025, the Commission launched proceedings into potential breach by Google of Article 6(12) and 6(5) DMA obligations through demoting media publishers’ content in search results 151 . The Commission’s investigation focuses specifically on Google’s ‘site reputation abuse policy’ and the extent to which its application complies with the obligations set out in Articles 6(12) and 6(5) DMA to ensure transparent, fair and non-discriminatory conditions to Google Search’s ranking.

On 18 November 2025, the Commission opened three market investigations in relation to cloud computing services. Two market investigations seek to assess whether Amazon and Microsoft should be qualitatively designated as gatekeepers for their cloud computing services, Amazon Web Services and Microsoft Azure 152 . The third market investigation will examine if the existing DMA obligations can effectively tackle practices that may limit competitiveness and fairness in the cloud computing sector in the EU 153 . The investigations opened on 25 March 2024, against Alphabet with regard to its anti-steering rules 154 and self-preferencing on Google Search 155 are still ongoing.

The investigation opened on 23 April 2024 against Apple concerning Apple’s contract terms 156 in relation to third party app stores is also ongoing.

5.3. Developments on rules

In addition, as required by Article 53 DMA, the Commission initiated the first review of the DMA in 2025.

The Commission consulted a broad set of stakeholders to gather input that will feed into its report. On 3 July, the Commission launched a public consultation, seeking feedback from any interested parties, including citizens, SMEs, business organisations, and other stakeholders, on the impact and effectiveness of the DMA and its readiness to face emerging challenges, such as the rollout of Artificial Intelligence (AI)-powered services 157 .

In June 2025, the Commission also invited the members of the Digital Markets Act Advisory Committee (DMAC) 158 to reflect on their possible contribution to this exercise and provide their input for the purposes of the first DMA review. Member States have also been informed of this process at a meeting of the Council Working Party on Competition in June 2025. Based on the input received, the Commission will prepare a review report assessing the impact of the DMA so far, which will also be shared with Member States. The Commission is required to complete its review of the DMA by 3 May 2026. The resulting report will be presented to the European Parliament (Parliament), the Council and the European Economic and Social Committee. 

5.4. Regulatory cooperation and transparency

The DMA provides for close cooperation between the Commission, as the sole enforcer, and NCAs. It also established a High-Level Group comprising the European bodies and networks identified within the Regulation. The primary objective of the High-Level Group is to support the coherent and effective implementation of the DMA alongside other sector-specific regulations applicable to gatekeepers. The Group convenes several times a year to discuss and coordinate on current topics of regulatory relevance 159 . On 7 March 2025, the High-Level Group held its fourth plenary session in Brussels. Additionally, three sub-group meetings took place in 2025, focusing on data-related obligations, Article 7 (interoperability), and AI.

The Commission also cooperated regularly with NCAs under the DMA’s specific mechanism to coordinate the complementary application of the DMA and national competition law, as well as by participating in multilateral fora such as the G7 Competition Summit 160 .

In accordance with its transparency obligations, the Commission publishes a DMA annual report 161  which details the state of implementation and the progress made towards achieving the DMA’s objectives.

Finally, in 2025, the Commission received information about 36 transactions pursuant to Article 14 DMA, which requires gatekeepers to inform the Commission of intended acquisitions within the digital sector. The summaries of these transactions are regularly published on the DMA website 162 .

Given the current geopolitical challenges and the fact that many markets extend far beyond the EU, the Commission - as a competition policymaker and enforcer - is committed to remaining a leading and respected international actor. Through global cooperation, the Commission contributes to a ‘Global Europe’ that leverages the EU’s power and partnerships. Fostering a level playing field and the rule of law abroad contribute to advance the interests and competitiveness of EU firms. Such interests can only be safeguarded through a combination of effective trade rules and fair, transparent and non-discriminatory competition regimes in foreign jurisdictions, supported by sustained investment in bilateral and multilateral relations.

6.1. Multilateral relations

In 2025, the Commission continued to engage actively in international competition-related fora, including the Organisation for Economic Cooperation and Development (OECD) Competition Committee, the International Competition Network (ICN), the G7 Competition Summit and the United Nations Conference on Trade and Development (UNCTAD).

At the OECD Competition Committee meeting in June 2025, the Commission participated in exchanges regarding cloud computing services, corporate influence; efficiencies in merger control; mobile payment services; detection tools and on the assessment of the impact of competition authorities’ activities 163 . In December 2025, Executive Vice-President Ribera delivered a keynote speech 164 at the OECD Global Forum on Competition. During this forum, the Commission served as one of the lead examiners in the OECD Peer Review of Kenya’s competition framework and contributed to the roundtable on competition and the healthcare sector 165 . Additionally, the Commission intervened in roundtables held by the Competition Committee and its Working Parties No. 2 and No. 3. These discussions focused on market studies and other market analysis tools; cooperative antitrust in remedy design; competition in AI infrastructure, and experiences with the use of AI by competition authorities 166 .

The Commission continued to serve as co-chair of the ICN Merger Working Group until May 2025. In this capacity, it worked on the revision of the chapters on unilateral and coordinated effects for the ICN Recommended Practices for Merger Analysis 167 . These two updated chapters were adopted at the ICN annual conference in May 2025 168 . The unilateral effects chapter was revised to include new theories of harm, additional factors relevant for the assessment, non-price parameters of competition and updated guidance on evidence. The coordinated effects chapter was updated with guidance on the various dimensions and forms of coordination, factors to assess the incentives to coordinate as well as potential disruption. In May 2025, the Commission was appointed co-chair of the ICN Unilateral Conduct Working Group. In that capacity, it organised a webinar in November 2025 on the use of evidence in antitrust enforcement against unilateral conduct. In May 2025, the Commission also participated in the ICN annual conference, with the Deputy-Director General for mergers speaking on the Merger Working Group plenary panel, and other Commission speakers contributing to several breakout sessions 169 . Throughout the year, the Commission moderated and facilitated sessions at several key international workshops: (i) the ICN unilateral conduct workshop which took place in March 2025 in Brazil 170 ; (ii) the ICN merger workshop held in October 2025 in Mauritius 171 ; and (iii) in the ICN cartel workshop in November 2025 in South Korea 172 . In October 2025, the Commission was appointed co-chair of the Interest Group Use of AI by Competition Agencies within the ICN Technologist Working Group. In this context, it hosted a knowledge sharing event on applied AI tools in competition enforcement.

At the October 2025 G7 Competition Summit in Ottawa 173 , the discussions focused on digital competition concerns, specifically algorithmic pricing, and their impact on competition and the economy. Participating authorities and agencies exchanged views on enforcement experiences and detection strategies, alongside emerging policy issues related to conduct in digital markets. At the request of Canada, the OECD presented a new scoping note focusing on algorithmic pricing and competition 174 . The summit culminated in the publication of an updated version of the compendium of approaches to improve competition in digital markets 175 , reflecting the shared views of competition authorities 

In July 2025, the Commission attended the 9th UN Conference on Competition and Consumer Protection 176 . Participants discussed competition and consumer protection issues at the national, regional and international levels, to continue enhancing consumers welfare through open, fair, dynamic and inclusive markets. The Commission intervened in sessions on ‘Competition and regional economic organisations’ and ‘Investigative techniques and digital tools in a modern enforcement world’. 

6.2. Bilateral relations

In 2025, the Commission continued cooperate bilaterally with the UK as provided for in the EU/UK Trade Cooperation Agreement (TCA) 177  and the Withdrawal Agreement 178 . The Commission’s work focused on controlling potentially competition distorting subsidy schemes in the UK; this includes monitoring and reporting on subsidy, competition legislation and enforcement. The Commission also represented the EU in the formal committees established under the TCA and Withdrawal Agreement. In addition, following the joint announcement by the EU and UK of a ‘New Strategic Partnership’ at the Summit on 19 May 2025 179 , the Commission engaged in discussions with the UK on several topics, including State aid and energy cooperation. In May 2025, the Commission also adopted proposals for Council decisions to sign and conclude the competition cooperation agreement between the EU and the UK 180 .

In 2025, the Commission continued the negotiations on a competition cooperation agreement between the EU and Canada, which is intended to replace the current agreement of 1999 181 .

Moreover, the Commission continued its cooperation on competition policy with the Korean and the Japanese Fair Trade Commissions and China's State Administration for Market Regulation. DG Competition's multilateral technical cooperation continued as well with an activity with the Association of Southeast Asian Nations  (ASEAN) competition authorities. DG Competition and DG Connect signed a Cooperation Arrangement with the Japan Fair Trade Commission regarding cooperation in the field of digital platform regulation 182 .

The Commission aims to include provisions on competition and subsidy control when negotiating Free Trade Agreements (FTAs). In 2025, the Commission concluded FTA negotiations with Indonesia and continued FTA negotiations with India, Malaysia, Philippines, Thailand and ESA5 183 . The Commission increasingly engaged with the Middle East and started negotiations with the United Arab Emirates on a FTA, which includes a chapter on competition.

As regards (potential) 184 candidate countries 185 , the Commission's primary objective regarding competition law is to support the setting up of legislative frameworks ensuring well-functioning and operationally independent competition and State aid authorities that will build up solid enforcement records in these countries. In 2025, the Commission continued to monitor national reforms, enforcement of competition rules and the overall compliance of the (potential) candidate countries with their commitments under the Association Agreements to ensure the legal alignment of their national rules with the EU acquis. The Commission also followed and assessed the progress made in relation to the implementation of support facilities for Ukraine and Moldova and for the Western Balkan countries that aim to assist the candidate and potential candidate countries with their legal, administrative and economic integration with the EU internal market. In 2025, the screening meetings and consequent screening reports including about competition policy were conducted and concluded for Ukraine and Moldova. This compulsory step in the EU accession negotiations process paves the way for further alignment and formal negotiations under the chapters relating to competition policy 186 .

In 2025, the Commission also engaged actively with several African national and regional authorities to strengthen their policy frameworks and support continental and regional economic integration. The Commission cooperated with three African regional economic communities - the West African Economic and Monetary Union (WAEMU); the East African Community (EAC); and the Common Market for Eastern and Southern Africa (COMESA) - and the authority supporting the implementation of the African Continental Free Trade Area (the AfCFTA Secretariat) at continental level, to support competition and consumer welfare in Sub-Saharan Africa. The Commission also cooperated on a bilateral basis with few competition authorities on the continent (for instance Egypt, Kenya, South Africa) and has assisted Gambia in setting up its merger control rules.

7.1. Benefits of EU competition for consumers and citizens

The Commission’s enforcement in the fields of antitrust and mergers generate direct benefits for citizens. DG Competition measures the impact of its enforcement activities in the areas of antitrust (cartels and non-cartel antitrust) and merger control in several complementary ways.

An important measure is ‘direct customer savings’, that is to say likely direct price effects for customers in markets where the Commission has intervened. Based on a simplified OECD method, the estimated direct customer savings from Commission interventions in 2025 were in the range of EUR 12.4 - 21.9 billion. This amounted to EUR 12 - 20 billion on average per year over the period 2012-2025. In relative terms, this corresponded to savings of around EUR 60 - 100 per EU household per year.

Figure 9: Customer savings by instrument (2012-2025) in billion EUR (midpoints)

The Commission is not the only enforcer of the EU competition rules. Its partners in the ECN also play an active role. In 2025, DG Competition and participating NCAs within the ECN continued to work on measuring additional customer savings generated by enforcement action taken by these NCAs. For the period 2020-2024, the analysis indicates that the combined customer savings (Commission and NCAs) sum up to a range of EUR 18 - 30 billion per year. This means that the NCAs contribute at least another 50% of direct savings on top of those generated by the Commission. The total amount of direct customer savings (Commission and NCAs) corresponds to some EUR 100 - 160 per household per year for this period.

Interventions by competition authorities not only aim to stop anticompetitive behaviour by market participants in specific cases (‘direct effects’), they also deter future anticompetitive behaviour by other market participants (‘deterrent effects’). It is well known that this type of indirect effects is difficult to measure, which is why the Commission has launched a survey study to obtain further knowledge on the magnitude and main drivers of deterrence effects.

Beyond direct and indirect price effects, the Commission’s enforcement activities also have positive effects on innovation and quality. Economists tend to agree that such ‘dynamic effects’ are significant and important for productivity growth and competitiveness, but they also agree that their magnitude is very difficult to measure. In 2025, the Commission and the OECD continued their collaborative effort to gain further insights into the impact of innovation on competition and competition enforcement 187 . In addition, DG Competition commissioned and published two studies for this purpose 188 .

Competition policy enforcement does not only have a positive economic impact at microeconomic level; it also serves as an important driver of welfare and growth at macroeconomic level. Estimated price reductions resulting from competition policy interventions (both directly and indirectly, via deterrence effects) can be used to improve economy-wide performance indicators on investment, employment, prices, productivity and ultimately on gross domestic product (GDP) 189 . The impact of competition and competition enforcement was the subject of the OECD Working Party meeting on 16 June 2025 190 , where DG Competition contributed to the update of the OECD Factsheet on Competition and Macroeconomic Outcomes of 2014.

Figure 10: Competition enforcement contributing to economic growth

Using QUEST III, the Commission’s basic macro-economic forecasting tool modelling by the JRC, suggests that the Commission’s competition enforcement activities may trigger an increase of real EU GDP relative to the baseline in the range of 0.6% - 1.1% in the medium to long term (the equivalent of an uplift of EUR 100-180 billion in GDP), a 0.3% - 0.7% reduction in the overall price level and an increase in consumption (0.5 - 1.0%) and investment (1.1 - 1.7%) 191 . These results indicate that competition policy directly supports GDP growth, investment and consumption across the EU economy.

7.2. Ex post evaluation

On 20 February 2025, DG Competition published a first-of-its-kind study assessing the effectiveness of antitrust remedies imposed or accepted by the Commission over the past 20 years under Articles 7 and 9 of Regulation 1/2003 192 . While the effectiveness of the Commission’s antitrust remedies seems to have improved over the last 20 years, the study also shows that: (i) past antitrust remedies have not always been implemented; moreover, fewer than half in the selected sample were fully effective in achieving their goal; (ii) purely behavioural remedies were less likely to be both fully implemented and effective, than other forms of remedies; and (iii) implementation and effectiveness seem to have improved over time. On 27 March 2025, DG Competition hosted an expert online workshop with the authors of the study and leading experts. 193

Also in 2025, the findings of the ex post evaluation study into ‘killer acquisitions’ in the pharma sector were discussed with economic and legal experts in a workshop 194 .

II.SECTORAL OVERVIEW

1.    Energy & Environment 

1.1. Overview of key challenges in the sectors

The European electricity market - the largest integrated market in the world - has become a cornerstone of the clean energy transition. The continued integration of the EU electricity market enhances resilience, reduce consumer costs, and supports investment in renewable generation 195 . 

In 2025, the situation in the energy markets continued to stabilise across both electricity and gas sectors following the energy crisis of 2021-2023. This stability, although at levels above historical averages, was achieved thanks to the rapid deployment of clean energy, the diversification of supply, the availability of energy interconnections and the solidarity demonstrated across Member States. However, price volatility persists, and energy prices are still significantly higher than outside the EU, and they vary considerably across EU Member States. These high prices and the disparity remain a major concern for European consumers and many industries. As highlighted in the Draghi report, high energy costs are at the core of the challenges currently facing the European economy.

On 26 February 2025, the Commission published the CID to support industry and companies through the transition towards a carbon-neutral economy. The CID outlines a series of actions to lower energy prices and create quality jobs and the right conditions for companies to thrive. In parallel and as part of the ClD, the Commission presented the ‘Action Plan for Affordable Energy’ (AEAP) 196 , introducing both short-term and structural measures to deliver stable and predictable energy costs, increase energy efficiency, and expand renewable generation, ensuring that businesses can remain competitive while consumers benefit from affordable energy. Together the CID and the AEAP underline how a cleaner and independent energy system helps boost the economy while also contributing significantly to Europe's decarbonisation ambitions. Complementing these strategies, the Commission presented a Roadmap towards ending Russian energy imports in May 2025 197 . This plan aims to fully eliminate dependence on Russian energy by stopping the import of Russian gas and oil and phasing out Russian nuclear energy, while simultaneously ensuring stable energy supplies and prices across the EU. 

In this context, competition and State aid policy play a crucial role in shaping a conducive environment for green investments, driving efficiency in public support for a competitive European economy. To achieve the ambitions of the CID and assist Member States in designing measures that support its objectives, the Commission adopted the CISAF on 25 June 2025 (see above Part I, section 3.2.1).

The CISAF also introduces simplified compatibility criteria for aid schemes making use of the ‘Grants-as-a-service-tool’ under the Innovation Fund ‘regular’ grants calls (GaaS) 198 . This mechanism builds upon the synergies existing between Innovation Fund requirements and State aid rules. A guidance on the GaaS possibility has been published in November 2025 199 and notification forms for CISAF, including GaaS are available on the Commission website 200 . 

1.2. Contribution of EU competition policy to tackling the challenges in the green economy

In 2025, competition policy and enforcement continued to contribute to the EU environmental objectives through the application of the State aid, antitrust and merger rules.

1.2.1.    Revised State aid EU Emission Trading System (ETS) Guidelines adopted 

On 23 December 2025, the Commission adopted targeted amendments of the ETS State aid Guidelines 201 .

The ETS Guidelines aim at reducing the risk of ‘carbon leakage’ - where companies move production to countries outside the EU with less ambitious climate policies - leading to less economic activity in the EU and no reduction in greenhouse gas emissions globally. They enable Member States to compensate companies in at-risk sectors for part of the higher electricity prices resulting from the carbon price signals created by the EU ETS (so-called indirect emission costs). Hence, the ETS Guidelines also contribute to the competitiveness of European industries. They are complementary to the measures allowed under CISAF, if overcompensation is excluded.

The ETS Guidelines were adopted for the full duration of the current EU ETS phase - running from 2021 until 2030 - to ensure predictability, with a possible update of certain technical parameters in 2025 to be in line with the most recent available data, if deemed necessary. Against this background, the Commission has adopted the following amendments to the current ETS Guidelines:

I.the extension of the list of industrial sectors eligible for compensation to include 20 new sectors and two new subsectors. This includes the manufacture of organic chemicals and certain activities in the ceramic, glass, and batteries sectors;

II.an increase in the aid intensity from 75% to 80% for sectors that were already eligible before the amendment to cater for their increased risk of carbon leakage;  

III.the option for Member States to notify sectors or subsectors that are not included in the amended list of eligible sectors, if they can demonstrate these are at genuine risk of carbon leakage;

IV.the requirement for large beneficiaries to contribute to the green transition by, among others, investing a share of the aid in projects that contribute to reducing the costs of the electricity system.

The CO2 emission factors and geographic areas are also updated for 2026-2030, based on the most recent data available. The CO2 emission factors reflect the CO2 emission content of fossil fuels used for electricity production in a given geographic area and are used to determine the amount of compensation. The amendment allows Member States to apply a gradual transition from 2026 to 2030, where the decrease in the applicable maximum regional CO2 emission factor compared to the previous factor for 2021-2025 is particularly large.

The ETS Guidelines are expected to be further supplemented with electricity efficiency benchmarks for the newly eligible sectors.

1.2.2.    Guidance on two-way contracts for difference and other guidance

On 10 December 2025, the Commission adopted the Guidance on the design of two-way contracts for difference (2w-CfD) 202 . The ‘2w-CfD’ are defined as contracts between a power-generating installation operator and a counterpart, usually a public entity, that provides both minimum remuneration protection and a limit to excess remuneration. The Electricity Regulation 203 mandates that direct price support for certain types of renewable electricity generation facilities 204 and for new nuclear electricity generation facilities, take the form of ‘2w-CfD’. The Guidance provides interpretation and clarification on the design principles to help Member States design their support schemes in line with the Electricity Regulation. It also provides examples of best practices that can be applied by Member States in the ‘2w-CfD’ support schemes. 

In parallel, the Commission continued to provide guidance to stakeholders to facilitate the interpretation and application of the rules and guidelines as well as to harmonise their application among the Member States. For instance, the Commission participated in several sectoral conferences to present the CISAF (see above Part I, Section 3.2.1) and provide explanations on its scope and provisions. The Commission also participated in several technical presentations and meetings, for example a webinar for Member States and national regulatory authorities (NRAs) on non-fossil flexibility support schemes co-organised by DG ENER and DG Competition on 1 December 2025.

Furthermore, the Commission provided hands-on support to Member States regarding the interpretation of the Net-Zero Industry Act (NZIA) Regulation 205 and the implementation of the NZIA criteria. These criteria will become mandatory for a minimum of 30% in terms of volume, or 6 GW, of renewable energy source auctioned each year per Member State, as from 30 December 2025. Specifically, the Commission provided guidance to several Member States on the design of the NZIA non-price criteria related to the supply chain resilience within the Renewable Energy Sources (RES) schemes.

These communication and outreach activities aim to enhance transparency and provide greater legal certainty in the implementation of the State aid rules across the EU.

1.2.3.    Supporting hydrogen production

In 2025, under the CEEAG, the Commission approved three State aid schemes totalling EUR 836 million to support the production of renewable hydrogen through the European Hydrogen Bank 206 's ‘Auctions-as-a-Service’ 207 tool.

These three measures include a EUR 400 million Austrian State aid scheme 208 and a EUR 36 million Lithuanian State aid scheme 209 , both approved in March 2025, as well as a EUR 400 million Spanish State aid scheme 210 approved in April 2025. The schemes support the production of up to 112 000 tonnes of renewable hydrogen in Austria, 13 000 tonnes in Lithuania, and 221 000 tonnes in Spain, potentially avoiding up to 1.6 million tonnes of CO2 emissions in total. The companies planning to construct new electrolysers in Austria, Lithuania and Spain must comply with EU criteria for producing renewable fuels of non-biological origin (RFNBOs), including contributing to the deployment or financing of additional renewable electricity needed to support hydrogen production under the scheme 211 . The ‘Auctions-as-a-Service’ model provides several advantages, notably in terms of cost-efficiency in awarding support, unlocking private investment and combining national and European support schemes, while supporting the CID's goal of accelerating EU industry decarbonisation and bolstering competitiveness. 

1.2.4.    Encouraging the deployment of renewable energy sources

In 2025, the Commission approved several State aid schemes supporting the deployment of renewable energy sources, having assessed their compatibility under specific State aid guidelines, in particular section 2.5 TCTF, section 4.10 CEEAG, and section 4.1 CISAF. These approved measures include investment aid for constructing new renewable energy production capacity or storage, as well as direct price support schemes providing aid for the production of electricity or heat from renewable energy sources.

For instance, on 28 February 2025, the Commission approved under section 4.10 CEEAG, a EUR 103 million Czech State aid scheme to support the production of heat from biomass in existing district heating installations 212 . The scheme promotes the use of renewable energy sources in heat production, in line with the objectives of the REPowerEU Plan 213 . The aid will take the form of a green bonus, which consists of a subsidy granted for each gigajoule of heat from biomass supplied to the heat distribution system. The bonus will be determined by the Czech Energy Regulatory Office on an annual basis. The aid amount will be equal to the cost difference of producing heat from biomass compared to producing heat from coal. Eligible beneficiaries are owners of existing heat installations using biomass with a heat output above 1 MW.

On 17 March 2025, the Commission approved, under section 2.5 TCTF, a EUR 699 million Spanish State aid scheme to support investments in energy storage to facilitate the transition to a net-zero economy 214 . The objective of the scheme is to provide investment aid for the deployment of large-scale energy storage, which will reduce reliance on fossil fuel imports and allow for a higher penetration of variable renewable energy sources in the Spanish electricity system. The aid - provided as direct grants and partially financed by the European Regional Development Fund (ERDF) - supports the construction of 1.8 GWh of new electricity storage capacity. The aid is granted through a competitive bidding process open to all storage technologies connected to either the transmission network or distribution network.

On 5 August 2025, the Commission approved, under section 4.1 CISAF, a EUR 11 billion French scheme to support offshore wind energy and boost this clean tech industry in the EU in line with the objectives of the CID 215 . This aid measure will support the construction and operation of three floating offshore wind farms of 500 MW capacity each, that will generate around 2.2 TWh of electricity, equivalent to the annual consumption of 450 000 French households. The support will be provided as direct price support, through a ‘2w-CfD’ over a 20-years period, awarded via a transparent and non-discriminatory competitive bidding process. Resilience has been included as tender prequalification and award criterion to diversify wind turbine and main specific components supply chains, to reduce dependency on imports from China, in line with the NZIA criteria.

1.2.5.    Consolidating nuclear-based energy

For some Member States, nuclear energy is an important component of decarbonisation, industrial competitiveness, and security of supply strategies. Acknowledging Member States’ right to determine their energy mix, the Commission continued in 2025 to assess the compatibility of State aid for nuclear energy generation under Article 107(3)(c) TFEU, which enables Member States to support the development of certain economic activities. Several significant measures were approved or were under investigation in 2025.

On 21 February 2025, following an in-depth investigation, the Commission approved a Belgian support measure for the lifetime extension of two nuclear reactors, Doel 4 and Tihange 3 216 . In June 2024, Belgium notified the Commission of its plan to extend the lifetime of these two nuclear reactors - which have a combined capacity of approximately 2 GW - to reduce Belgium’s dependency on fossil fuels and preserve the security of electricity supply in Belgium and neighbouring countries. In July 2024, the Commission opened an in-depth investigation to assess the compatibility of the proposed aid measure with the internal market, with a focus on the assessment of the financial arrangements and the proportionality of the nuclear waste liabilities. The reactors are majority-owned by Engie's Belgian unit Electrabel with 89.9% share, while Luminus (an EDF subsidiary) holds a 10.1% minority share. A new 50-50 joint-venture between the Belgian State and Electrabel, BE-NUC, was created to cover the necessary capital cost of the extension. A ‘2w-CfD’ ensures stable revenues for a period of 10 years and limits excess remuneration. Additional financial protective mechanisms, such as a loan and an operating cashflow guarantee, are also part of the financial set-up. To address the Commission’s concerns, Belgium clarified that those financial arrangements are complementary, covering different risks related to the project, and thus necessary to ensure its long-term financial viability. The measure also includes Electrabel transferring liabilities related to the storage and disposal of nuclear waste and spent fuel, to the Belgian state for a lump sum payment of EUR 15 billion which will be managed and controlled by a dedicated national body, Hedera. Moreover, the measure ensures risk-sharing and legal protection in the event of future legislative changes.

On 9 December 2025, following an in-depth investigation, the Commission approved aid measures for the first nuclear power plant in Poland 217 . In September 2024, Poland notified the Commission of its plan to support State-owned company Polskie Elektrownie Jądrowe sp. z o.o (PEJ) in the construction and operation of a new nuclear power plant in Lubiatowo-Kopalino. The project consists of three new nuclear reactors, each with a capacity of 1250 MW. Under the aid measures, the beneficiary will benefit from direct price support in the form of ‘2w-CfD’’ running for 40 years to provide stable revenues to the nuclear power plant. In addition to the CfD, the support package includes an equity injection covering approximately 30% of the project’s costs and State guarantees covering 100% of the debt taken by PEJ to finance the investment project. The plant is expected to increase the security of electricity supply for Poland and its neighbouring countries, contributing to the decarbonisation of the energy sector and the diversification of the Polish energy mix. This decision followed the opening of a formal investigation in 2024, which focused on the appropriateness and proportionality of the aid, potential distortions in electricity markets, and the measure's compliance with relevant provisions of EU law. To address the Commission’s concerns raised during the investigation, Poland adjusted the measures, notably by changing the design of the CfD and shortening its duration.

On 22 December 2025, the Commission opened a formal investigation regarding the support for the construction and operation of two new nuclear units at the Dukovany site 218 . In April 2024, the Commission approved aid for the construction and operation of a single new nuclear reactor in Dukovany 219 . In October 2025, Czechia notified the Commission of its plan to extend the investment in nuclear capacities and support the construction and operation of two new nuclear units in Dukovany, with an electricity generation capacity of up to 976 MWe each. This project serves Czechia’s plan to decarbonise its electricity sector and address an identified gap in electricity supply. The beneficiary of the aid measure is Elektrárna Dukovany II (EDU II), owned by the Czech state (80%) and ČEZ (20%), the only nuclear power plant operator in Czechia. Under the aid measure, the beneficiary will benefit from direct price support in the form of a ‘2w-CfD’ with a duration of 40 years. The beneficiary will also benefit from a low-interest repayable State loan of an initial amount currently estimated between EUR 23 billion and EUR 30 billion, which will cover the full construction costs, and of a protection mechanism against unforeseen events or policy changes that may make the realisation of the project impossible. Based on its preliminary assessment, the Commission has doubts on the compatibility of the aid measure with the internal market, namely regarding its appropriateness and proportionality, its impact on competition in the market, as well as its compliance with other provisions of EU law (in particular with the design principles set out in Article 19d(2) of the Electricity Regulation as regards the CfD).

Following the annulment by the Court of Justice of the Commission’s decision declaring the State aid for the construction of two new reactors on the Paks site in Hungary compatible with the State aid rules (see above Part I, section 3.3.3), the Commission is again assessing the compatibility of the measure following its decision to initiate the formal investigation procedure under Article 108(2) TFEU.

1.2.6.    Ensuring security of supply

On 29 July 2025, the Commission approved, under section 4.8 CEEAG, a EUR 300 million Swedish strategic electricity reserve to safeguard security of electricity supply in emergency situations 220 . On 28 October 2025, also under section 4.8 CEEAG, the Commission approved a EUR 750 million Estonian strategic reserve to support security of electricity 221 . The strategic reserves 222 in Sweden and Estonia will be in place until 2035 and must be open to all projects that can contribute to achieving the security of supply objective, including electricity generation, demand-side response and storage. The projects that will benefit from the aid in both these cases will be selected through a transparent, non-discriminatory competitive bidding process. Capacity funded through these measures will not participate in electricity markets while held in the reserve. This restriction is designed to minimise the distortion of competition within these markets.

On 6 October 2025, the Commission approved, under section 4.8 CEEAG, an Austrian scheme to safeguard security of electricity supply and network stability 223  for a period of 5 years. This scheme is an extension and update of the existing network reserve that was approved in 2021 and that will end in 2026 224 . Several technical changes were introduced to, among other things, increase the participation of smaller resources, in particular electricity consumers that can provide demand response by reducing energy use. The scheme will also be open to electricity storage facilities and demand-response providers. The subsidised capacity must remain available and be located in parts of Austria or neighbouring countries where it can help manage transmission congestion. The aid will take the form of direct grants paid per MW of available capacity held in the reserve, as well as payments to cover operating costs when capacity is activated. The costs of the aid scheme will be recovered from consumers in locations where there is a capacity shortfall, via network charges on consumer bills. 

On 22 December 2025, the Commission approved a French capacity mechanism 225  with an estimated budget of EUR 20 billion. The scheme, approved for a period of 10 years under section 4.8. CEEAG, represents an extension and update of the capacity mechanism originally approved in 2016. Various design changes were introduced to simplify its functioning (from a decentralised to a market-wide design) and to promote the development of a sufficient amount of non-fossil flexibilities. The scheme will also be open to all technologies emitting less than 550gCO2/kWh of electricity produced, and fossil fuel technologies will not be granted long-term contracts under the aid measure. The subsidised capacity must remain available during the delivery periods (November to March) and be located in France or in interconnected Member States having signed a cross-border agreement with France (for instance Belgian capacities may participate as of the first auction). The aid will take the form of direct grants paid per MW of available capacity. The costs of the scheme will be recovered from consumers based on their consumption during hours when a risk on security of supply exists. 

1.2.7.    Addressing electricity costs for energy-intensive industries 

On 24 April 2025, the Commission approved, under section 4.11 CEEAG, a Portuguese scheme providing aid for energy intensive users (EIUs) 226 . The scheme concerns a reduction for EIUs in the payment of levies aimed at financing: (i) electricity production from renewable energy sources; (ii) support for energy efficiency; and (iii) social tariffs and promotion of electricity generation in isolated regions. The scheme will run until 22 April 2035 and has an estimated budget of EUR 612 million. The beneficiaries are required to conduct energy audits, as defined by Article 8 of Directive 2012/27/EU 227 . They also must commit to at least one of the following actions: (i) implement certain energy audit recommendations; (ii) cover at least 30% of electricity consumption with renewable energy sources; or (iii) invest at least 50% of the aid in projects leading to significant reductions of the installation's greenhouse gas emissions. The scheme intends to reduce the risk that activities, in certain economic sectors particularly exposed to international trade and relying heavily on electricity for their value creation, will relocate outside the EU where environmental policies are absent or less ambitious. In parallel, it maintains incentives for an effective decarbonisation. The scheme is in line with the CID, which recognises that European industries need urgent support to decarbonise, electrify, to confront high energy costs, unfair global competition, and complex regulations, harming their competitiveness. 

1.2.8.    Supporting the shift to clean mobility 

In 2025, the Commission continued to provide guidance to Member States on the use of Articles 36a and 36b GBER on clean mobility. A growing number of schemes for clean mobility are implemented by Member States under those GBER provisions.

On 29 July 2025, the Commission approved, under the CEEAG, a EUR 36 million (DKK 268 million) Danish measure aimed at reducing greenhouse gas emissions in the domestic aviation sector 228 . The scheme is designed to incentivise the use of sustainable aviation fuel (SAF) for domestic flights. The primary objective of the scheme is to support at least one domestic air route using 40% SAF, which approaches the current technical limit of 50%. This exceeds the minimum set by the ReFuelEU Aviation Regulation 229 , which requires fuel suppliers to achieve a minimum share of 2% during the scheme period. The aid level will be determined through a competitive bidding process, ensuring cost-effectiveness and efficiency. The scheme also includes rules to prevent overcompensation, namely by ensuring that supported SAF is excluded from parallel support measures under the ReFuelEU Aviation regulation and the EU ETS Directive 230 , and by prohibiting the use of SAF that has already received subsidies from Denmark, other EU Member States, or third countries.

On 17 December 2025, the Commission approved, under the CEEAG, a German EUR 1.6 billion scheme to support the deployment of publicly accessible fast-charging stations for electric heavy-duty vehicles (e-HDVs) at non-serviced rest sites along the German motorways 231 . This measure contributes to the objectives of the European Green Deal and the ‘Fit for 55’ package 232 . In particular, it supports the development of a cross-border charging network and facilitates the shift from diesel trucks or buses to electric ones, providing them with the recharging infrastructure at spots where this infrastructure is not yet supplied by the market. The beneficiaries will be companies with experience in the construction and operation of recharging infrastructure, to be selected following a competitive bidding process. All participating charging point operators will offer different pricing options: an ad hoc pricing model (without the need for a subscription), a contract-based pricing model, and a ‘pass-through’ pricing mode (where the drivers can use the pricing of their own energy supplier). These models increase choice at charging points, which ensures sufficient price competition. 

1.2.9.    Reducing industrial emissions 

In 2025, under the CEEAG, section 2.6 TCTF and section 5 CISAF, the Commission approved almost EUR 12 billion of aid for the decarbonisation of the industry, either through aid schemes or aid to specific projects 233 . 

One Finnish aid scheme 234 took the form of a tax credit assessed under section 2.6 TCTF to support (next to the production of renewable energy and the production of strategic equipment assessed respectively under sections 2.5 and 2.8 TCTF) the decarbonisation of industrial production processes by helping companies reduce greenhouse gas emissions from their production processes by at least 40% and/or reduce their energy consumption by at least 20%. Three additional German, Danish and French aid schemes presented similarities with carbon CfDs and were based on competitive bidding processes. While the German scheme focused on undertakings subject to the ETS 235  and was open to all technologies, including Carbon Capture and Storage (CCS), the Danish scheme focused more specifically on incentivising the switch to cleaner fuels by industries 236 . The French scheme was focusing on undertakings subject to the ETS and open to all technologies, except those already subsidised through already existing support schemes such as support for renewable energy generation, including support for renewable hydrogen 237 .

On 15 December 2025, the Commission approved, under section 5 CISAF, a Spanish aid scheme for the decarbonisation of manufacturing industry 238 . The scheme will support investments into technologies such as electrification, shifting to renewable or low-carbon hydrogen, recovery of waste heat, carbon capture, storage and utilisation, in a wide range of sectors including chemicals, ceramics, paper and metallurgy. Under the scheme, the aid will take the form of direct grants determined based on pre-defined aid intensities. The measure will be open to enterprises of all sizes, and to installations and sectors within and outside of the Emission Trading System.

1.2.10.    Stimulating the circular economy

       1.2.10.1. State aid enforcement

The Commission also approved aid schemes aimed at incentivising projects promoting a more circular economy in 2025.

On 3 February 2025 the Commission approved, under section 4.4 CEEAG, a EUR 500 million French scheme to support the chemical recycling of certain types of plastic waste, such as trays, films, non-beverage bottles and textile materials with a certain amount of polyester content 239 . The scheme aims to support chemical recycling technologies that convert mixed and/or contaminated plastic waste back into ‘virgin-like’ raw materials. The maximum amount of aid is 40% of the extra investment costs calculated by comparing the total investment costs of a project of chemical recycling of plastic waste with those of less environmentally friendly projects. 

On 20 May 2025, the Commission approved a EUR 1.2 billion Dutch scheme to support companies in their efforts to improve resource efficiency and the circular economy by using secondary or bio-based raw materials instead of primary or fossil-based raw materials 240 . Given that such projects can reduce lifecycle greenhouse gas emissions - in addition to the environmental benefit of a more circular economy - they will compete within the same bidding process as decarbonisation projects (reducing direct emissions). However, they will be evaluated and compared on the basis of their total emission reductions.

           1.2.10.2 Antitrust enforcement

On 1 April 2025, the Commission fined 15 major car manufacturers and one association a total of EUR 458 million for participating in a long-lasting cartel concerning end-of-life vehicle recycling 241 . Mercedes-Benz was not fined as it revealed the cartel to the Commission under the leniency programme. For over 15 years, these car manufacturers coordinated their behaviour to avoid paying for recycling services. Furthermore, they agreed not to compete on advertising, the extent to which their cars could be recycled, and to remain silent on the recycled materials used in their new cars. High quality recycling in key sectors such as the automotive plays a crucial role for meeting the EU’s circular economy objectives, not only to cut waste and emissions, but also to reduce dependencies, lower production costs and create a more sustainable and competitive industrial model in Europe. This decision illustrates the Commission’s readiness to investigate novel types of anticompetitive conduct that may have an adverse impact on the clean transition. This case also marks a new record for the settlement procedure, with all 17 parties involved agreeing to acknowledge their participation in exchange of a 10% reduction in fines.

Furthermore, the Commission continued its investigation into the synthetic turf industry in several Member States to determine whether the companies active in this sector have infringed EU competition rules. In this context, the Commission imposed fines on Eurofield SAS and Unanime Sport SAS, the ultimate parent of Eurofield at the time of the infringement, of a total of around EUR 172 000 for providing an incomplete reply to a request for information issued in the context of the Commission's investigation 242 . This is the first time that the Commission used its powers under Article 23(1)(b) of Regulation 1/2003 to ensure that companies do not compromise its antitrust investigation by not providing full and complete replies to information requests. 

The Commission also finalised its ex officio preliminary investigation initiated in 2024 into possible anti-competitive conduct in breach of Articles 101 and 102 TFEU by the Irish Farm Film Plastics Group (IFFPG), a non-profit association operating the only licenced extended producer responsibility (EPR) scheme for farm plastic waste recovery in Ireland. The Commission’s preliminary investigation under Article 102 TFEU focused on whether the design and remunerative structure of IFFPG’s EPR scheme is capable of producing exclusionary effects towards independent waste collectors and whether certain elements of IFFPG’s constitutive documents and its contracts with authorised waste collectors may be contrary to Article 101 TFEU and the ‘polluter pays’ principle. Following the Commission’s preliminary investigation, IFFPG made modifications to its EPR scheme. These modifications will lead to a shared responsibility for the financing of IFFPG’s EPR scheme between IFFPG’s members and Irish farmers. They will also increase competition on the level of collectors of farm plastic waste, as well as on each level of the farm plastics supply chain. The Commission’s investigation has now been closed.

Moreover, the Commission continued its investigation into the collection and recovery of packaging waste in Czechia under Article 106 in conjunction with Article 102 TFEU following up on the Letter of Formal Notice addressed to Czechia in June 2024 243 .

1.2.11.    Investments in clean tech manufacturing

In 2025, the Commission approved six schemes based on section 6.1 CISAF, incentivising investment projects that add manufacturing capacity in clean technologies. On 22 October 2025, the Commission approved a EUR 61 million aid scheme for Emilia Romagna 244  and on 3 November 2025, a EUR 219 million aid scheme for Lazio 245 . On 6 November, the Commission approved a EUR 700 million aid scheme for Spain 246 . On 9 December 2025, the Commission approved a EUR 1 500 million aid scheme for Italy 247 and on 12 December 2025, a EUR 100 million aid scheme for Austria 248 . On 17 December 2025, the Commission approved a EUR 4 100 million aid scheme for Hungary 249 .

The Commission also approved State aid for individual projects adding manufacturing capacity in clean technologies under the Regional Aid Guidelines (RAG) 250 . On 31 January 2025, the Commission approved a EUR 48 million French State aid measure to support Envision AESC France’s production of batteries for electric vehicles 251 in Douai, Hauts-de-France, which is an area eligible for regional aid under Article 107(3)(c) TFEU. The project will create about 1 000 direct jobs, as well as additional indirect jobs. On 14 August 2024, the Commission approved a EUR 264 million Hungarian State aid to support the electric vehicles battery plant of Sunwoda in Nyíregyháza 252 . The project is eligible for regional aid under Article 107(3)(a) TFEU. It is expected that 2 500 direct and 470 indirect jobs will be generated.