Regulatory Scrutiny of Procedural Compliance and Penalties in 2025

JD Supra Trade Law

Filed March 12th, 2026

Detected March 13th, 2026

Summary

In 2025, regulators in the EU, China, and the US increased enforcement of procedural non-compliance. The European Commission fined Eurofield approximately USD194,000 for incomplete information, and the Italian AGCM fined Ryanair USD1.47 million for similar issues. These actions highlight a growing trend of penalties for procedural missteps.

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What changed

In 2025, regulatory bodies globally, including the European Commission (EC) and the Italian Competition Authority (AGCM), significantly increased scrutiny and penalties for procedural non-compliance during investigations. The EC imposed a fine of approximately USD194,000 on Eurofield for providing incomplete information during an antitrust probe, a penalty reduced due to cooperation. Similarly, the AGCM fined Ryanair USD1.47 million for failing to provide complete and correct information, specifically internal strategic documents, during an abuse of dominance investigation. These cases underscore a trend where regulators are actively pursuing and penalizing companies for procedural missteps, such as incomplete responses to information requests, even after dawn raids.

Companies operating in jurisdictions with heightened regulatory oversight, particularly in antitrust matters, must ensure robust internal processes for responding to information requests. This includes verifying the completeness and accuracy of all submitted documents and information. Failure to do so can result in substantial fines, as demonstrated by the Eurofield and Ryanair cases. The UK's Competition and Markets Authority (CMA) also now has enhanced powers to impose significant fines for non-compliance. Regulated entities should review their compliance procedures to mitigate the risk of penalties related to procedural breaches, especially in light of the increasing assertiveness of enforcement agencies worldwide.

What to do next

Review internal procedures for responding to regulatory information requests to ensure completeness and accuracy.
Verify that all requested documents and information are provided promptly and truthfully.
Stay informed about evolving procedural compliance expectations and potential penalties in relevant jurisdictions.

Penalties

Eurofield fined approximately USD194,000 (reduced from a potential 1% of turnover); Ryanair fined USD1.47 million.

Source document (simplified)

March 12, 2026

Spotlight On Procedural Compliance

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

Incomplete responses, inaccurate information, obstruction and other procedural missteps attracted significant regulatory attention and penalties in 2025. We saw regulators, including in the EU, China, and the U.S., step up their enforcement of procedural non-compliance.

Scrutiny of responses to information requests intensifies across Europe

Information requests are a vital tool for authorities attempting to uncover antitrust infringements. Failure to fully and accurately comply with these requests will compromise and potentially lengthen and increase the costs of investigations. Authorities are therefore likely to actively look out for and investigate potential misdemeanors and ensure sanctions have a deterrent effect.

2025 saw two significant cases where companies were penalized for failing to provide full responses to information requests. Both breaches came to light following dawn raids.

In September 2025, the European Commission (EC) imposed an unprecedented fine on Eurofield for providing incomplete information during an antitrust investigation in the synthetic turf sector. The authority was alerted to the possible incompleteness of Eurofield’s reply to an informal request for information after comparing it with documents collected during dawn raids carried out as part of the investigation. Eurofield and Unanime Sport (Eurofield’s ultimate parent at the time of the infringement) ultimately agreed to cooperate and submitted the missing documents after the EC informed them that it was investigating the suspected procedural breach. The EC settled on a fine amounting to 0.3% (of a possible 1%) of the parties’ combined total turnover, which it considered to be “both proportionate and deterrent.” This was reduced by 30% to around USD194,000 as a reward for the companies’ cooperation.

On announcing the penalty, EC competition commissioner Teresa Ribera noted that the EC “will not hesitate to pursue similar cases in the future.”

Summer 2025 saw another notable enforcement case when the Italian antitrust authority (AGCM) fined Ryanair USD1.47 million for failing to provide complete and correct information during its abuse of dominance probe. Specifically, the AGCM found the airline had failed to provide internal strategic documents (i.e., business plans and other relevant presentations) that were in its possession. Ryanair had claimed that it did not prepare business plans for Italy or other countries and that strategic decisions were taken informally and not documented. The fine was the authority’s highest-ever penalty for such an infringement and Ryanair has announced that it will appeal the decision.

It will be interesting to see whether the UK's Competition and Markets Authority (CMA) follows suit in pursuing similar breaches, in accordance with its new powers under the UK’s Digital Markets, Competition and Consumers Act (in force since January 1, 2025) to impose fines of up to 1% of annual turnover for non-compliance with investigations (a sharp rise from a previous maximum fine of GBP30,000).

Beyond Europe: regulators worldwide toughen up on procedural breaches

Other national regulators have also clamped down on procedural breaches.

In March 2025, the Turkish antitrust authority imposed a monetary fine of 0.1% of its gross turnover on Novonesis A/S and its subsidiaries due to the provision of incomplete, incorrect, and misleading information. In addition, it imposed additional daily fines of 0.05% of its gross turnover for every day after the deadline date that it failed to provide the missing information.

In July 2025, China’s Shangdong AMR fined Weifang Zhongyuan Pharmaceuticals in excess of USD5.3m for abusing its dominant position in the supply of an active pharmaceutical ingredient. The investigation also uncovered that four pharmaceutical companies had obstructed the investigation by providing false information, denying profit-sharing, and providing inconsistent statements. Each of the four companies was fined (separately to the abuse of dominance investigation) approximately USD28,000.

Significantly, in January 2026, the U.S. Federal Trade Commission and a coalition of states sued Amazon and asked a federal judge to impose spoliation sanctions for Amazon’s alleged failure to retain relevant business records. It claims that Amazon has been “deliberately deleting unedited “raw” notes from business meetings” in contravention of its document preservation obligations.

Enforcement has also caught individuals.

In April 2025, in the U.S., a military contractor pleaded guilty to destroying evidence relating to the bid-rigging of U.S. Army operation and maintenance contracts in South Korea. He deleted text messages after receiving a litigation hold notice from his employer requiring him not to destroy or delete communications and later covered up the deletion.

The U.S. Department of Justice noted that it “will not hesitate to prosecute individuals who unlawfully impede our investigations by destroying or covering up evidence.”

Rising penalties for dawn raid obstruction

Over recent years, we have seen numerous fines for non-compliance with dawn raids. 2025 was no exception.

In Hong Kong, 2025 saw the first criminal prosecution and conviction for non-compliance with investigation powers. An employee at a commercial cleaning company was sentenced to two months in prison for destroying and concealing documents during a dawn raid conducted by Hong Kong’s Competition Commission.

In Hungary, Volvo Hungária Kereskedelmi was fined a record amount of USD619,000 for an apparent delay in providing encryption keys to data obtained during a dawn raid, while fines were also levied in Türkiye (retailer BIM fined USD36m for deleting data) and Poland (automotive wholesale and retail sale company Landcar fined for failing to provide information).

In addition, in China, a pharmaceutical company and individual employees were fined for reportedly forcibly entering a meeting room being used by the authorities and violently seizing a laptop that had been prepared for inspection.

See our section on strengthening investigative powers signifies a continued appetite for enforcement where we discuss the volume and location of antitrust inspections carried out in 2025.

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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.
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