On 30 April, the UAE adopted Cabinet Decision No. (59) of 2026 (“the 2026 Executive Regulations”), setting out the executive regulations for Federal Decree-Law No. (36) of 2023 on the Regulation of Competition. The 2026 Executive Regulations replace the previous implementing regulations adopted in 2014 under the former UAE competition law. They are expected to enter into force on 30 July 2026.

Taken together, the adoption of Federal Decree-Law 36 on Regulating Competition of 2023, Cabinet Resolution No. (3) of 2025 establishing the new filing thresholds, and the subsequent adoption of the 2026 Executive Regulations complete a long-anticipated overhaul of the UAE merger control framework. These measures mark a decisive shift towards a fully operational and modern merger control regime. The 2026 Executive Regulations significantly streamline the notification process, introduce enhanced timing certainty, and create a clear pathway for third parties to engage with the Competition Department of the Ministry of Economy & Tourism (“Competition Department”) to influence the outcome of merger reviews.

More broadly, the 2026 Executive Regulations introduce important changes to various aspects of UAE’s competition law framework, including measures relating to behavioural competition enforcement and procedures. In combination with other recent competition policy and enforcement actions, the 2026 Executive Regulations signal the UAE’s ambition to bring its competition and merger control framework in line with international best practice.

This article focuses on the main revisions to the UAE merger control framework, before briefly outlining the wider changes introduced to the UAE’s behavioural competition regime by the 2026 Executive Regulations.

Continue Reading The UAE’s New Merger Control Framework: What the 2026 Executive Regulations Mean for Dealmakers

On 10 February 2026, the EU released the agreed compromise text of the new Regulation on the screening of foreign investments in the EU (the “New FIR Regulation”).  The three EU institutions (Commission, Parliament and Council) reached the compromise on the text in December 2025 (see our blog) following several months of…

Continue Reading New Foreign Investment Screening Regulation – Key Takeaways from the Agreed Compromise Text

On 9 January 2026, the Commission adopted its Guidelines on the application of certain provisions of Regulation (EU) 2022/2560 of the European Parliament and of the Council on foreign subsidies distorting the internal market (the “FSR Guidelines”). The FSR Guidelines explain how the Commission assesses whether foreign subsidies distort the internal market, and, if so, whether their potential positive effects outweigh their potential negative impacts. They also explain how the Commission may exercise its call-in powers to request the prior notification of any concentration or any foreign financial contributions (“FFCs”) in the context of a public procurement procedure that falls below the notification thresholds.

This blogpost describes the FSR Guidelines. The FSR Guidelines were adopted after a little more than two years of application of the FSR, on which the Commission will report in July 2026, potentially leading to its revision. While they crystallize the Commission’s practice thus far, they do not address the frequently voiced concern that they are overbroad and, consequently, too many unproblematic concentrations or tenders must undergo a cumbersome reporting process. For more details on the FSR, please see our previous blogpost.

Key takeaways

  • The FSR Guidelines offer detailed guidance on how the Commission will conduct its assessment of distortions. While the responsibility for this assessment lies with the Commission, companies under investigation may need to demonstrate that the foreign subsidies they have received are not linked to their economic activities in the EU. If they are unable to do this successfully, they must then provide a comprehensive analysis of the impact those foreign subsidies have on the internal market.  
  • In balancing the potential negative impact of foreign subsidies with their potential positive effects, the FSR Guidelines rely on an approach similar to State aid assessment. However, unlike in State aid, they do not provide any presumption that certain categories of subsidies are on balance positive when defined conditions are met. Instead, they require a case-by-case assessment.  
  • Regarding the Commission’s approach to requesting notification of concentrations or FFCs in the context of a public procurement procedure, the FSR Guidelines leave the Commission broad discretion when it determines that those activities merit prior review given their impact on the EU. As a result, companies may need to consider their FSR risks even if they do not engage in large concentrations or public procurement procedures in the EU.   
Continue Reading The European Commission adopts the Foreign Subsidies Regulation Guidelines

On 20 January, the UK Government announced a consultation on planned reforms to the UK’s merger and markets regime. Key proposed changes include narrowing certain jurisdictional thresholds, centralising Phase II decision-making within the Competition and Markets Authority (CMA) Board through removal of the Phase II independent panel (CMA Panel), and the introduction of a new “single-phase” market investigation review process.

Whilst reform may be welcome to businesses in some respects, the proposals are likely to further centralise decision-making power within the CMA, as well as increasing the oversight of Government in the administration of key aspects of the UK’s antitrust regime. For merger decisions in particular, the removal of the CMA Panel, combined with the Government’s commitment to retain the judicial review standard of appeal, may reignite calls for a full merits review standard to be introduced alongside the proposed reforms.

Why now? 

Having gained a reputation for taking bold stances on global mergers with arguably limited nexus to the UK (e.g., Facebook/Giphy and Sabre/Farelogix), the CMA has sometimes been accused of deterring some transactional investments in the UK economy. As part of a wider Regulatory Action Plan, the Government in January 2025 replaced the incumbent CMA Chair, Marcus Bokkerink, with Doug Gurr (formerly a global VP and the head of Amazon UK). The Government also committed to reviewing and narrowing the UK’s notoriously broad jurisdictional thresholds under the Enterprise Act 2002.

A resulting flurry of activity has already seen the CMA prioritising cases that have a direct impact on UK consumers or businesses; adopting a more neutral stance towards behavioural remedies in suitable cases; and promising to increase the pace, predictability, and proportionality (the “4Ps”) of its enforcement activities, in particular for merger reviews.  

The proposed reforms consolidate and entrench this direction of travel.

Continue Reading “Operational transformation” at the CMA -What the latest announcements mean for UK antitrust enforcement

On 11 December 2025, the Council and European Parliament reached political agreement to revamp the EU’s Foreign Investment Screening Regulation.  The revamp aims at responding to perceived growing risks to national and economic security in the EU. It forms part of the EU’s recently unveiled Economic Security Doctrine. While the full text has not…

Continue Reading The EU adopts revamped regime to screen foreign investment

The figures are fresh off the press: the European Commission published its Fifth Annual Report on the screening of foreign direct investments (“FDI”) into the European Union (“EU”) just a few days ago.[1] Like the previous editions, the Fifth Annual Report offers a statistical overview of the EU FDI framework’s…

Continue Reading EU’s Fifth FDI Annual Report: Five trends in Europe’s screening activities

The war in Ukraine, and other recent geopolitical conflicts, has underscored the need for EU-based defence capabilities to scale up to face these challenges. Several EU initiatives which have sought to stimulate investment are starting to bear fruit, as the European Defence Agency recently reported record high defence spendings in the EU (€350bn for 2024…

Continue Reading Five Key Points on FDI Screening in the EU Defence Sector

On June 25, 2025, the European Commission adopted the Clean Industrial Deal State Aid Framework (CISAF) to promote the EU’s goals for decarbonization and competitiveness. CISAF makes permanent the relaxed State aid compatibility rules adopted under the Temporary Crisis and Transition Framework (TCTF). It will be in effect from June 25, 2025 until December 31…

Continue Reading The European Commission adopts the Clean Industrial Deal State Aid Framework

On 2 June 2025, the European Commission (“Commission”) fined the food delivery companies Delivery Hero and Glovo EUR 329 million for engaging into cartel conduct through agreeing not to poach each other’s employees, exchanging competitively sensitive information, and allocating geographic markets.

The decision signals increased antitrust scrutiny of labour-related arrangements between rivals  and…

Continue Reading European Commission issues first no-poach decision in labour markets, warning against the collusive risks of minority shareholdings

Introduction

On Thursday 8 May 2025, the EU took another important step towards revamping its framework to screen foreign investment, with the European Parliament adopting an amended version of the bill (the “EP Bill”, available here). That vote has now cleared the way for the next step in the legislative process: the tri-partite negotiations between the European Commission, the Council of the EU, and the European Parliament (aka “trilogue”) to arrive to a final text that will become law.

The EP Bill endorses the Commission proposal[1] that sought to bring more harmonisation/oversight over Member States, but also goes further and makes several ambitious additions to the Commission proposal in particular, the EP Bill would: (i) give new decision-making powers to the Commission in an area where such powers previously have squarely rested in the hands of the EU Member States, (ii) expand the list and scope of sectors in which foreign investments could undergo screening, and (iii) require reporting and screening of greenfield investments above a certain amount in many sectors.

This post explains these key proposed changes for non-EU investors and sets out how we see the prospects of these changes surviving the remainder of the legislative process.

Continue Reading EP Approves Draft FDI Regulation Giving Extensive Powers to EC