EU and Irish Competition Law Newsletter April 2026

CCPC Investigations and Enforcement

Criminal Prosecution: Bid-Rigging in School Bus Tenders

In December 2025, five individuals were convicted in the Central Criminal Court in Dublin of engaging in anti-competitiveconcerted practices, contrary to sections 4 and 6 of the Competition Act 2002.

The offences related to bid-rigging in a tender process for publicly funded school bus services in the south-west of Ireland, following dawn raids by the CCPC on businesses in Cork.

Bid-rigging involves coordination between businesses to fix prices or predetermine the outcome of a tender, including through the submission of artificial bids or bid rotation. It undermines competition, increases costs and, as this case demonstrates, carries serious criminal consequences for the individuals involved.

Home Appliances: Cross-Border Dawn Raids and RPM Investigation

The CCPC is investigating an alleged resale price maintenance arrangement involving a manufacturer, a distributor and multiple retailers in the Irish home appliances sector. The investigation is one of the more significant enforcement actions the CCPC has undertaken since its expanded powers came into effect in September 2023.

Resale price maintenance occurs where a supplier restricts a reseller’s ability to set its own prices, typically by imposing minimum resale prices or margins set by the supplier.

The CCPC conducted a dawn raid at an Irish distributor’s premises in June 2025. In November 2025, working alongside the German Competition Authority (the Bundeskartellamt), a further raid was carried out at a manufacturer’s premises in Germany. CCPC authorised officers supported the Bundeskartellamt directly during that operation. Formal information requests have since been issued to several Irish retailers.

Under the Competition Act, the CCPC has the power to impose significant fines for breaches of competition law.

European Commission Investigations

Google: Artificial Intelligence and Publisher Rights

The European Commission is investigating Google for potential anticompetitive conduct in connection with its AI systems. The investigation is one of the most significant competition law developments involving AI to date.

The Commission is examining whether Google has imposed unfair terms on publishers and content creators, or granted itself privileged access to content in a way that disadvantages rival AI developers. The concern is that Google may have used web publishers’ content to power generative AI services, including AI Overviews and AI Mode in Google Search, without appropriate compensation or an effective opt-out. Publishers who refuse risk losing search visibility, which means the choice is far from free in practice.

Separate concerns have been raised about Google’s use of YouTube content. Creators must grant Google broad rights to use their content, but YouTube’s own policies prevent rival AI developers from using that same content to train competing models.

European Commission Merger Control

Music Industry: Universal Music Group / Downtown Music Holdings

The European Commission has approved the proposed acquisition by Universal Music Group N.V. of Downtown Music Holdings LLC, subject to conditions.

The approval required the full divestment of Downtown’s royalty accounting platform, Curve Royalty Systems Ltd. The Commission concluded, after an in-depth investigation, that the transaction would not significantly impede effective competition in recorded music, artist and label services, or music publishing, provided that commitment was honoured.

This case illustrates that even if a transaction is ultimately cleared, specific assets or business lines may need to be divested in order to alleviate potential competition issues. Early identification of those issues is essential to managing the timeline and terms of a deal.

IT Infrastructure: EMK Capital Management / Project Informatica

The European Commission has approved the acquisition of sole control of Project Informatica S.r.l. of Italy by EMK Capital Management Limited of Jersey, under the simplified merger review procedure.

The Commission concluded that the transaction would not raise competition concerns, given the limited combined market position of the parties.

For private equity acquirers, the case is a good example of the simplified EU merger process working as intended where competitive overlap is limited.

Irish Merger Control

Samsung Biologics / Human Genome Sciences

The CCPC cleared the proposed acquisition by Samsung Biologics America Inc., a subsidiary of Samsung Biologics Co. Ltd., of sole control of Human Genome Sciences, a wholly owned subsidiary of GlaxoSmithKline Holdings (Americas) Inc.

Samsung Biologics is a biopharmaceutical manufacturer and part of the broader Samsung conglomerate. Human Genome Sciences operates two manufacturing plants in the United States producing bulk drug substance products. Given the absence of competitive overlaps in Ireland, clearance was achieved under the simplified procedure.

Businesses in the pharma and life sciences sector should note that even large, cross-border transactions can move quickly through the process where the competition analysis is clear.

Vitruvian Partners / Walkers Professional Services

The CCPC cleared the acquisition by VIP V Fund, managed by Vitruvian Partners LLP, of joint control over Walkers Professional Services Limited and related entities. The transaction was notified on 20 January 2026 and cleared following a Phase 1 review on 6 February 2026.

Walkers Professional Services provides corporate administration, fiduciary and compliance services to global asset managers. The CCPC concluded that the transaction would not substantially lessen competition in any market for goods or services in Ireland. The involvement of Funds can give rise to complex merger control considerations. Early assessment remains the most reliable way to avoid delays.

Apleona / Tim Kelly Group

The CCPC cleared the acquisition by Apleona Ireland Limited of sole control of Tim Kelly Mechanical Limited and Tim Kelly (Electrical Contractors) Limited, under the simplified merger notification procedure.

The Apleona Group provides technical and infrastructural facility management services across multiple countries. The Tim Kelly businesses are involved in the design, supply, installation and commissioning of mechanical, electrical and fire protection services in Ireland.

For businesses considering acquisitions in the facilities management or building services sectors, this case is a useful reference point for how the CCPC approaches vertical relationships.

Practice Note: Simplified Merger Notification

Many Irish M&A transactions are now being cleared under the CCPC’s Simplified Merger Notification Procedure. It is worth understanding when it applies and where caution is needed.

In 2025, approximately 70% of CCPC merger notifications were submitted under the simplified regime. Simplified notifications use the same form as standard notifications but require fewer sections to be completed.

When can the simplified procedure be used?

• Where the parties are not active, and are not potentially active, in the same or vertically related markets.
• Where overlapping parties have combined market shares below 15%, or individual shares below 25% in upstream or downstream markets.
• Where an undertaking is acquiring sole control of a company it previously held jointly.

When might a standard notification still be required?

• Transactions in concentrated or novel markets.
• Transactions involving businesses with significant pipeline products, particularly in digital or pharmaceutical sectors.
• Transactions where one party has a market share above 20% in a related or neighbouring market.
• Changes from joint to sole control where the prior arrangements constrained competition.
• Cases involving uncertain market share data or third-party competition concerns.