This month has seen the entry into force of lower notification thresholds in the UK for additional markets impacting national security, legislation passed in Aruba to introduce a new merger control regime and the publication of revised guidelines in France, which include an extension of the scope of the simplified procedure. UK—revised notification thresholds for additional national security sectors enter into force The lower notification thresholds in the UK for certain additional sectors impacting national security have entered into force. The lower thresholds cover transactions in sectors involving the developing, producing development, production or research into: • artificial intelligence, • cryptographic authentication, and • advanced materials. For these sectors: • the 25% share of supply threshold has been amended so that it can be met solely by the activities of the target, and • the target’s turnover threshold has been reduced to £1m (from £70m). This change follows a similar change in 2018 for other sectors impacting national security, namely (i) military or dual-use goods which are subject to export control, or (ii) quantum technology,

Monthly round-up of international merger control developments for July/August 2021. This month has seen ‘warning letters’ in the US where investigations have not been able to be completed in the 30-day waiting period, proposals published to amend the UK merger control regime and the introduction of another gun-jumping amnesty in Ukraine. United States—FTC to issue ‘warning letters’ where investigation incomplete after 30 day waiting period On 3 August 2021, Holly Vedova, Acting Director of the FTC’s Bureau of Competition, announced that the FTC has begun to send standard form letters to merging parties involved in deals that the FTC has not been able to fully investigate within the 30-day waiting period of the HSR Act. The ‘warning letter’ tells the parties that the FTC has not yet completed its investigation and that, if the parties complete the transaction, they do so at their own risk. Separately, On 15 July 2021, the FTC rescinded its 1995 policy statement that had disfavored prior approval or prior notice provisions in FTC merger consent decrees. Since 1995, such provisions,

This monthly round-up (July 2022) has seen the publication of preliminary results regarding Luxembourg’s public consultation on the creation a new merger control regime and an announcement in China of a delegated review of certain simplified merger filings to start on 1 August 2022. Luxembourg—preliminary results published of public consultation regarding merger control On 13 July 2022, the Internal Market and Competition Department of the Ministry of Economy published the first results of its public consultation in relation to the creation of a national merger control regime in Luxembourg. The report highlights the following points: • 88% of the respondents are in favour of a mandatory system (or one with mandatory components). Other stakeholders expressed a preference for a voluntary system, especially in the years following implementation of the new regime • 60% of the respondents argued that the notification thresholds should be based on turnover, potentially mirroring the French and Belgium approach with both aggregate and individual domestic turnover thresholds applied to at least two undertakings. Only a few stakeholders were in favour of market share thresholds

This monthly round-up (June 2022) has seen amendments (including changes to the merger control regime) passed on China’s Anti-Monopoly Law, as well the launch of a new consultation on further proposed changes to China’s merger control thresholds, the publication of a draft bill to lower the merger control thresholds in Finland, the introduction of revised notification thresholds in Kosovo and the resumption of the merger control review process in Ukraine. China—amendments passed on Anti-Monopoly Law including in relation to merger; new consultation launched proposing changes to merger control thresholds On 24 June 2022, the 35th session of the 13th National People’s Congress Standing Committee passed the decision to amend the Anti-Monopoly Law (AML). In relation to merger control, the main amendments are as follows: • higher fines for gun-jumping. For an unreported merger that does not lead to competition concerns, the maximum fine is increased from RMB 500,000 to RMB 5m. When anti-competitive effects are found, the maximum fine will be further increased to up to 10% of the notifying party’s group turnover in the last financial year

This month has seen the Belgian Competition Authority impose a standstill and hold separate order on Proximus under abuse of dominance rules to a non-notifiable acquisition, amendments to the merger control thresholds in Morocco, the publication of draft legislation including (amongst other things) a new exemption from the notification obligation in Switzerland, and the Federal Trade Commission proposing changes to the pre-merger notification form and process in the USA. Belgian—BCA imposes standstill and hold separate order under abuse of dominance rules In our March 2023 monthly merger update, we highlighted that the Belgian Competition Authority (BCA) announced an ex-post investigation under the abuse of dominance rules in relation to Proximus’, the incumbent Belgian telecom operator, recent acquisition of EDPnet. The transaction did not meet the Belgian merger control thresholds because of EDPnet’s turnover. This action takes place following the Court of Justice’s judgment in Towercast on 16 March 2023, which held that concentrations falling below merger control thresholds can be subject to ex-post review for abuse of dominance. The Towercast judgment therefore recognises an additional

This month has seen competition law changes (including in relation to merger control) come into force in Canada, and the Korean Fair Trade Commission launch a consultation on draft amendments to the merger notification process and its guidelines in South Korea. Canada—competition law changes now in force In our monthly merger updates for March 2023 and December 2023, we mentioned that the Canadian Government had proposed significant and wide-ranging amendments (including in relation to merger control) to the Competition Act, which were set out in Bill C-59, The Fall Economic Statement Implementation Act 2023 (the Bill). On 20 June 2024, the Bill came into force. In relation to merger control, the key amendments are as follows: • Allowing the Competition Tribunal (Tribunal) to conclude that a merger will result in a substantial prevention or lessening of competition (SPLC) solely based on market concentration or market share, and introducing a rebuttable structural presumption that a merger will result in an SPLC if it results in an increase in market share above the 30% threshold. • Expressly

This month has seen the Competition and Markets Authority (CMA) launch a consultation on proposed changes to its merger control guidance on jurisdiction and procedure. CMA launches consultation on proposed changes to its merger control guidance on jurisdiction and procedure On 20 June 2025, the CMA launched a consultation on proposed changes to its merger guidance on jurisdiction and procedure (CMA2) and to the merger notice template. The proposed changes are designed to embed the CMA’s new ‘4P’s’ (pace, predictability, process, and proportionality) framework into its mergers process. The proposed changes consist of: • clarifications to the CMA’s approach to the ‘material influence’ and ‘share of supply’ tests • changes relating to the CMA’s approach to global mergers • changes in relation to the pre-notification and phase 1 merger process and to the current merger notice template Clarifications to the CMA’s ‘material influence’ and ‘share of supply’ tests The CMA can assert jurisdiction to review a transaction whenever a buyer acquires ‘material influence’ over a target company. This is notably lower than most merger regimes globally,

This month has seen the German government propose reforms to the merger control thresholds and transaction value test, Ireland raise its merger control thresholds with effect from 1 July 2026, and UK’s Competition and Markets Authority launched a consultation on its revised approach to merger efficiencies. Germany—government proposes reforms to merger control thresholds and transaction value test On 4 June 2026, the German government published a proposal to amend the German Competition Act, including several changes to the merger control regime. The proposed reforms would increase the jurisdictional thresholds, requiring notification where the parties’ combined worldwide turnover exceeds €750 million, one party generates more than €75 million in German turnover and a second party generates more than €20 million in German turnover. The proposal would also amend the transaction value threshold, particularly the local nexus requirement. Under the proposed rules, transactions may be notifiable where the target is not yet active in Germany but is likely to become active there in the future. This appears intended to address recent case law concerning the scope of activities

This month has seen the announcement of lower notification thresholds in the UK for additional markets impacting national security, the introduction of lower notification thresholds in Zimbabwe, the entry into force of the new simplified notificiation procedure in the Republic of Ireland and the reversion in Guernsey and Jersey to separate competition authorities. UK—revised notification thresholds for additional national security sectors to be introduced The UK is to introduce amendments to the notification thresholds for certain additional sectors impacting national security, namely the developing, producing or research into: • artificial intelligence • cryptographic authentication, and • advanced materials For these sectors only, the 25% share of supply threshold will be amended so that it can be met solely by the activities of the target and the alternative target’s turnover threshold will be reduced to £1m (from £70m). It is expected that the amendments will come into force within the next two to three months. The UK government has also introduced the power to intervene on public interest grounds in relation to transactions that impact the

This month has seen amendments to the notification thresholds in Slovakia, the start of the parliamentary process to amend the notification thresholds in Ukraine, and more fines imposed for breaches of merger control rules. Slovakia—amendments to notification thresholds introduced Amendments to the merger control regime in Slovakia have entered into force, including a change to the notification thresholds. In relation to the thresholds, the separate notification threshold for joint ventures (JVs) has been removed (this threshold required a notification if one party had turnover in Slovakia of at least €14m (approximately US$16.9m) and another party had worldwide turnover of at least €46m (approximately US$55.5m)). Instead, now JVs will be assessed through the general notification threshold and the notification threshold for the acquisition of control. Other amendments that have entered into force today include: • the phase II deadline will now begin on the last day of the phase I investigation (ie when referred to phase II), rather than when the parties are informed • notifying parties are required to inform the Antimonopoly Office of the Slovak Republic

This month has seen the temporary suspension of merger reviews in Ukraine due to Russia’s invasion, significant amendments to the merger control thresholds in Turkey and Belgium’s Parliament introducing a filing fee for merger notifications. This monthly round-up has also seen Antimonopoly Committee of Ukraine clarify its merger control procedures in light of Russia’s invasion of Ukraine, annual amendments to thresholds in Italy, revised merger control thresholds entering into force in Israel and the Indian government extending the de minimis exemption for mergers until March 2027. Ukraine—AMC ceases operations and temporarily suspends merger reviews On 24 February 2022, the Antimonopoly Committee (AMC) moved from Kyiv to Lviv after the imposition of martial law, following Russia’s invasion of Ukraine. On 7 March 2022, the AMC announced it had suspended (amongst other submissions) all of its merger reviews that had not been resolved by 24 February 2022. Companies do not have to comply with existing information request deadlines during this period, but they must still file merger notifications. The changes are expected to last until the end of martial

This month has seen clarifications regarding the merger thresholds and notification procedures in Cambodia, publication of the Canadian Competition Bureau’s recommended merger control reforms as well as an increase to the merger filing fee, the Indonesian Competition Authority consulting on plans to revamp its merger control regime, the annual amendments to thresholds in Italy taking effect, an increase to the notification thresholds in Saudi Arabia, and the Taiwan Fair Trade Commission broadening the scope of transactions subject to the simplified merger review procedure. Cambodia—CCC issues new regulations for merger notifications On 6 March 2023, the Cambodia Competition Commission (CCC) issued Sub-decree No. 60 which clarifies the procedure for filing a merger notification to the CCC. Furthermore, on 14 March 2023, the CCC also published Decision No. 95 which clarifies the merger thresholds under the Cambodian merger control regime. It should be noted that it is currently unclear when Sub-decree No. 60 and Decision No. 95 will enter into force. The main aspects of Decision No. 95 and Sub-decree No. 60 are set out below. Decision