No deal too small: CCPC uses “call-in” power for the first time

The CCPC has called in a below-threshold transaction for the first time, sending a clear message to dealmakers across Ireland: size is not a shield from regulatory scrutiny.

On 20 March 2026, the CCPC called in Uniphar plc’s proposed acquisition of TouchStore Limited for review. The deal fell below the mandatory notification thresholds, which meant there was no obligation to notify the CCPC. The CCPC stepped in anyway, exercising the call-in power it has had since 2022.

For anyone involved in M&A in Ireland this is a moment worth paying attention to. It is the first time the CCPC has used this power, and it confirms what many in the market had been anticipating: certain below-threshold transactions will be on the CCPC’s radar.

Sean Ryan, Partner and Head of EU, Competition and Regulatory at Whitney Moore, sees this as a turning point. “The call-in power has been there since 2022, but until now it had not been used. This changes the conversation. If you are doing a deal in Ireland, you should not assume that falling below the thresholds means you are automatically outside the CCPC’s reach.”

What the CCPC did

Uniphar announced its proposed acquisition of TouchStore in January 2026. Because the transaction fell below the relevant thresholds, no mandatory notification was required. But the CCPC had been monitoring the market. It issued information requests, carried out its own research and engaged with third parties. Having gathered enough information to form a view, it exercised its call-in power.

If a transaction that has not completed is called in, standstill obligations apply. The transaction cannot complete until it has been formally notified to, and cleared by, the CCPC. In addition, the CCPC has the power to impose wide ranging interim measures, including requiring the parties to reverse steps already taken.

The commercial reality

For dealmakers, this goes to the heart of deal certainty. A transaction that sits comfortably outside the mandatory notification process can nonetheless be subject to full CCPC review. Conditions could be imposed after signing. Timelines could move. The terms agreed by the parties at signing may not be the terms they end up with.

Sean explains the practical impact: “This creates a risk that needs to be factored into every transaction. Buyers and sellers both need to consider: could this transaction attract the CCPC’s attention, even if we are not required to notify? That question now has real consequences. Carrying out an early competition law risk assessment is critical. Build time for a competition law review into your timetable. The worst position to be in is finding out that there may be competition law issue after you have already committed to a timeline that does not allow for it; or having terms imposed by the CCPC post signing that were not envisaged by the parties.”

If you would like to discuss

If you would like more information, please contact:

Sean Ryan, Partner, Corporate
Head of EU, Competition and Regulatory
Sean.Ryan@WhitneyMoore.ie

Roisin Caulfield, Senior Associate
EU, Competition and Regulatory
Roisin.Caulfield@WhitneyMoore.ie

Dean Power, Associate
EU, Competition and Regulatory
Dean.Power@WhitneyMoore.ie

Hannah Bergin, Associate
EU, Competition and Regulatory
Hannah.Bergin@WhitneyMoore.ie