Global antitrust enforcement report published

The report discusses the significant increase in fines, use and development of investigative tools, the impact of digital market scrutiny, and emerging trends in public and private enforcement practices. 

On investigative and enforcement tools:

• Of the 31 jurisdictions surveyed, 22 (71%) confirmed that the regulator had carried out dawn raids during 2025.
• Regulators have been pushing for increased investigative powers, including to effectively search business records in a digital age where relevant information could be held in the cloud.
• Domestic dawn raids are now a permanent feature as post-Covid working patterns have remained more flexible.
• Authorities are modernizing their investigative toolkits to identify anticompetitive conduct, including through combining data science with classic investigatory powers and by widening available channels for the provision of whistleblower evidence. Most obviously, authorities are targeting bid-rigging in public tenders. 
• Regulators, including in the EU, China, and the U.S., are stepping up their enforcement of procedural non-compliance.

On outcomes:

• Last year, global cartel fines reached USD3.3 billion, the highest annual figure since 2021 (USD4bn). Enforcement by the European Commission (EC) and EU member states accounted for USD2.6bn of the total. 
• Price-fixing remained the most enforced form of cartel conduct in 2025, closely followed by bid-rigging. Authorities are also targeting the use of algorithms and public communications to facilitate anticompetitive outcomes. 
• Agri-food, energy, transport, life sciences, construction, and digital markets are in the spotlight as authorities align with government policies to protect essential consumer spend and encourage economic growth. 
• In digital markets, there appeared to be a shift in focus from pure exclusionary cases towards exploitative cases, together with complementary enforcement under the antitrust and digital markets regimes.
• Authorities showed an increasing appetite to use “soft” enforcement tools such as commitments, settlement and guidance.
• "Hard” fines often reserved for select cases where it is deemed necessary to firmly signal deterrence, punish particularly egregious behavior or set an important legal precedent.
  Access to private collective redress is expanding, but the gatekeeping rules differ sharply between jurisdictions. These differences make forum choice strategic, and they require claims to be tailored to each system’s specific certification logic.

Investigations are frequently carried out simultaneously across different jurisdictions and regulators increasingly coordinate approaches. Sanctions (both for individuals and corporates) are a serious threat. More than ever, any multinational needs to have a response strategy in place to meet the potential risks of public and private enforcement actions.

We represent clients on complex cross-border and national investigations and have been involved in the majority of high-profile cartel cases over the past 20 years. We helped shape current U.S. and EU leniency and enforcement policies and our team covers every aspect of government investigations and enforcement. 

For more details see the A&O Shearman Global antitrust enforcement report 2026.