Global Antitrust Enforcement Report Analysis

JD Supra Trade Law

Published March 12th, 2026

Detected March 13th, 2026

Summary

A&O Shearman has published a global antitrust enforcement report analyzing trends across over 30 jurisdictions. The report highlights a significant increase in cartel fines, reaching USD3.3 billion in 2025, and increased scrutiny of digital markets and investigative powers.

View original document View source feed page

What changed

A&O Shearman's latest Global Antitrust Enforcement Report provides an in-depth analysis of worldwide antitrust enforcement activities in 2025, covering over 30 jurisdictions. Key findings include a substantial rise in global cartel fines to USD3.3 billion, with the EU accounting for USD2.6 billion. The report details the increasing use of investigative tools like dawn raids, the modernization of digital investigation techniques, and a focus on price-fixing and bid-rigging. It also notes a shift in digital market enforcement towards exploitative cases and increased coordination among international regulators.

Multinational companies must develop robust response strategies to navigate the growing risks of both public and private enforcement actions. The report emphasizes the serious threat of sanctions for both individuals and corporations and the strategic importance of understanding differing jurisdictional rules for private collective redress. Companies should be particularly aware of enforcement trends in sectors such as agri-food, energy, transport, life sciences, construction, and digital markets, and the increasing penalties for procedural non-compliance.

What to do next

Review global antitrust enforcement trends and investigative powers
Assess company exposure to cartel conduct (price-fixing, bid-rigging) and digital market scrutiny
Develop or update multinational response strategies for public and private enforcement actions

Penalties

Global cartel fines reached USD3.3 billion in 2025; "Hard" fines are reserved for select cases to signal deterrence, punish egregious behavior, or set legal precedent. Sanctions for individuals and corporates are a serious threat.

Source document (simplified)

March 12, 2026

Global Antitrust Enforcement Report Published

Emily Bourne, Imogen Carr, Laura Harvey, Thomas Masterman A&O Shearman + Follow Contact LinkedIn Facebook X Send Embed

Our latest Global antitrust enforcement report offers an insightful analysis of the current state and future trajectory of antitrust enforcement worldwide, based on analysis of enforcement data from over 30 jurisdictions.

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.

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

[View source.]

Send Print Report

Latest Posts

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
Attorney Advertising.

Written by:

A&O Shearman Contact + Follow Emily Bourne + Follow Imogen Carr + Follow Laura Harvey + Follow Thomas Masterman + Follow more less

PUBLISH YOUR CONTENT ON JD SUPRA

✔ Increased readership
✔ Actionable analytics
✔ Ongoing writing guidance Join more than 70,000 authors publishing their insights on JD Supra

Start Publishing »

Published In:

Agribusiness + Follow Algorithms + Follow Antitrust Investigations + Follow Antitrust Provisions + Follow Antitrust Violations + Follow Bid Rigging + Follow Cartels + Follow Competition Authorities + Follow Dawn Raids + Follow Energy Sector + Follow Enforcement Actions + Follow European Commission + Follow Fines + Follow Multinationals + Follow Price-Fixing + Follow Technology + Follow White Collar Crimes + Follow Antitrust & Trade Regulation + Follow General Business + Follow Consumer Protection + Follow International Trade + Follow more less

A&O Shearman on:

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: Sign Up Log in ** By using the service, you signify your acceptance of JD Supra's Privacy Policy.* - hide - hide