CCPC Annual Report 2025

The Mergers and Acquisitions Report for 2025 was recently published by the Competition and Consumer Protection Commission (CCPC).  The report provides details of the enforcement of competition law in Ireland in 2025 as well as providing details on the notifications received by the CCPC throughout the year and offering a snapshot of merger control in Ireland.  A number of key points from the report are outlined below.

Enforcement

In what the report describes as a “landmark moment for competition enforcement in Ireland”, five school bus operators were convicted by a jury at the Central Criminal Court for engaging in bid-rigging in respect of a tender competition. This followed an investigation and legal preparations by the CCPC.

In 2025, the CCPC carried out nine unannounced searches across businesses and private residences in relation to ongoing cartel investigations. The CCPC also carried out a further dawn raid at the premises of an Irish-based distributor of home appliances.

Reflecting enhanced powers conferred on the CCPC under the Competition (Amendment) Act 2022, the CCPC issued three formal requests for information to several businesses as well as four witness summonses requiring individuals to attend before the CCPC and provide evidence, in the context of the CCPC’s administrative competition law investigations.

In 2025, the CCPC appointed its first Chief Adjudication Officer and 17 adjudication officers under the CCPC’s administrative enforcement regime for breaches of competition law. The role of adjudication officers is to make determinations in relation to alleged infringements of competition law, procedural requirements, commitments, structural or behavioural remedies or prohibition notices.

Merger Control in Ireland:  2025 in Review

Number of Notifications

The CCPC issued 91 determinations for the calendar year 2025.  This reflects a year on year increase in the number of determinations issued by the CCPC, with 82 determinations issued by the CCPC in 2024 and 68 in 2023.

Simplified Merger Procedure

Approximately 63.7% of the 91 determinations were made under the Simplified Merger Notification Process. The simplified procedure, introduced in 2020, allows for a quicker turnaround time in the CCPC’s assessment of the merger and helps to expedite the process.

Sectoral Breakdown

The professional services field was the most prominent sector of merger control activity followed by manufacturing and construction. Professional services was also the leading sector in 2024, reflecting continued consolidation trends.

Determinations

• The CCPC issued 91 determinations in 2025, 12 of which related to notifications received in 2024.
• In 2025, the CCPC progressed six Phase 2 investigations. Of these, two were cleared unconditionally, three cleared with remedies, and one carried over to 2026.
• Several transactions were cleared at Phase 1 with remedies with the annual report citing this as “demonstrating that early engagement and constructive solutions can deliver timely outcomes”.
• The CCPC issued 29 requirements for information in relation to notifications received in 2025.

Timeframe

For the year 2025, the CCPC took an average of 17.05 days to issue a Phase 1 decision.  This was an increase on the 2024 figure of 16.3 days. The average time taken to issue a determination for notifications reviewed under the Simplified Notification Procedure was 12.47 working days in 2025, reflecting a decrease on the 2024 average time of 13.3 days.

Media Mergers

In 2025, the CCPC received 8 merger notifications relating to media mergers.

Thoughts

The number of determinations issued in 2025 was the highest since 2018, where 95 determinations were issued. Interestingly, after 2018, the thresholds for mandatory notification were increased resulting in a reduction in the number of notifications received by the CCPC in subsequent years. These thresholds have been increased again, effective as of 1 July 2026. The new thresholds require a notification to be made to the CCPC in respect of a transaction where:

• The combined turnover in Ireland of the undertakings involved is at least EUR100 million.
• The individual turnover in Ireland of two or more of the undertakings involved is each at least EUR15 million.

The above thresholds are significantly higher than those in place since 1 January 2019 and the impact this will have on the number of notifications received by the CCPC for the remainder of 2026 and into the future will be of interest. The CCPC have cited the basis for the increase as wanting to focus its resources on “higher value transactions that are more likely to raise competition concerns and reduce the regulatory burden and costs.” Notably, the CCPC exercised its “call-in” power for sub-threshold mergers for the first time on 20 March 2026 when it directed the parties to the acquisition of TouchStore Limited by healthcare services provider, Uniphar plc, to submit a notification to the CCPC by 17 April 2026. Perhaps, greater use by the CCPC of this “call-in” power is something we may see more of going forward. 

A copy of the 2026 report issued by the CCPC can be found here.

For more information on these updates, please contact Marco Hickey, or Michael Cunningham.

Marco Hickey is the Head of the Competition, Antitrust and Foreign Investment Regulation team at Byrne Wallace Shields. Marco is the author of “Merger Control” published by Thomson Reuters -- the only legal textbook exclusively devoted to merger control in Ireland.

Michael Cunningham is a member of the Competition, Antitrust and Foreign Investment Regulation team at Byrne Wallace Shields.