Competition and Regulated Markets
The CCPC’s increased enforcement activity follows the implementation of the Competition (Amendment) Act 2022 in September 2023.
The Merger Guidelines set out the CCPC’s analytical framework and approach to conducting merger analysis, with the current Merger Guidelines adopted by the CCPC in 2014.
Continued increase in CCPC enforcement activity
2026 is likely to see continued enforcement activity from the Competition and Consumer Protection Commission (CCPC), reflecting a busy 2025 and 2024. Recent CCPC activity shows that dawn raids will remain an important enforcement tool in 2026 as the CCPC continued to conduct dawn raids in 2025, most notably in the betting industry. This follows dawn raids in the home alarm and transport industries in 2024. The CCPC also recently pursued a criminal bid-rigging case in the school bus transport sector with a unanimous guilty verdict issued in the Central Criminal Court in December 2025. Under the Competition (Amendment) Act 2022, bid-rigging is now explicitly recognised as an offence, reinforcing its status as an enforcement priority for the CCPC.
The CCPC’s increased enforcement activity follows the implementation of the Competition (Amendment) Act 2022 in September 2023, which strengthened the power of the CCPC in domestic antitrust enforcement. The recent Government’s Action Plan on Competitiveness and Productivity also noted embedding the CCPC’s administrative enforcement regime as a priority for 2026.
Read our in-depth briefings The Competition (Amendment) Act 2022 and Regulatory Investigations - a guide to dawn raids.
A new media merger regime on the horizon
In mid-2025, the Irish Government approved the General Scheme of the Media Regulation Bill, which proposes a number of changes to the existing media merger regime to give effect to Ireland’s obligations under the European Media Freedom Act (EMFA). While the Government considers Ireland’s current media merger regime largely complies with the EMFA, certain amendments will be needed for Ireland to fully give effect to the EMFA. The proposed changes (if implemented) will widen the scope of Ireland’s existing media merger regime, while excluding certain transactions that are unlikely to impact on media plurality or have a limited connection to Ireland.
Read our in-depth briefing on the upcoming changes to the Irish media merger regime here: A new EMFA-sis on Ireland’s media merger regime.
Anticipated publication of CCPC’s revised merger control guidelines
The CCPC opened a public consultation on the proposed adoption of revised CCPC Guidelines for Merger Analysis (the Merger Guidelines) in October 2024, with the consultation process closing in November 2024. The Merger Guidelines set out the CCPC’s analytical framework and approach to conducting merger analysis, with the current Merger Guidelines adopted by the CCPC in 2014. As approaches to merger review and guidelines develop internationally, the CCPC’s review is intended to ensure the CCPC’s substantive approach to the analysis of notified mergers remains up-to-date and in line with international best practice. We expect the CCPC to publish its revised guidelines for consultation (and maybe even adoption) in 2026, which should provide greater clarity to businesses active in the Irish market.
CCPC seeks increase to merger control thresholds
In November 2025, the CCPC informally confirmed it had asked the Government to raise the financial thresholds for which a transaction must be notified to it for review. The CCPC’s view is that raising the thresholds will ensure the Irish regime keeps pace with the impact of inflation on deal value and companies’ turnover, while also ensuring the regime stays in line with other jurisdictions. If approved, it is anticipated the new regime may come into effect in 2026. In addition to the mandatory merger notification regime, the CCPC also has the power to require mergers and acquisitions which do not meet the financial thresholds to be notified. To date, this call-in power is yet to be used.
Clarity on Irish FDI regime pending
The Irish Foreign Direct Investment (FDI) screening regime commenced operation on 6 January 2025. However, there is currently very limited publicly available information on notifications reviewed under the regime to date. Under the Screening of Third Country Transactions Act, the Minister for Enterprise, Trade and Employment must prepare an annual report outlining the activity and outcomes of the screening mechanism, which will include aggregated data, trends and outcomes. It is also anticipated that the Department of Enterprise, Trade and Employment will update its “Inward Investment Screening Guidance for Stakeholders and Investors” to reflect developments and learnings from the regime’s first year in operation.
Read our in-depth briefing here: Foreign investment screening regime in Ireland to commence on 6 January 2025.
Important agri-food developments on the horizon
2026 will see a number of important developments in the agri-food sector. At a European level, the European Commission has committed to undertaking a formal review of the Unfair Trading Practices (UTP) framework in 2026. The EU also plans to introduce a new Regulation to address the cross-border element of UTPs and to further strengthen enforcement against UTPs prohibited under the UTP Directive. At a national level, additional powers for the Agri-Food Regulator (An Rialálaí Agraibhia) were recently announced in relation to its price and market analysis function, which will take effect on 31 December 2026. Recognising that a regulator alone cannot improve transparency and fairness, the CEO of the Agri-Food Regulator also issued a "call to action" in November 2025 to farmers and businesses to come together and "improve fairness and transparency" in the Irish food supply chain.
Please contact a member of our Competition and Regulated Markets Group or your usual Arthur Cox contact for more information.
Under the Screening of Third Country Transactions Act, the Minister for Enterprise, Trade and Employment must prepare an annual report outlining the activity and outcomes of the screening mechanism, which will include aggregated data, trends and outcomes.
© 2026 Arthur Cox LLP | All rights reserved
