Competition Law Quarterly Asia Pacific

Across the fourth quarter of 2025, competition and merger control authorities in the APAC and Middle East regions accelerated reforms, sharpened procedural tools, and advanced targeted enforcement, setting a more proactive enforcement tone heading into 2026.

Key notable developments include:

• Australia: The government enacted late-stage amendments to the new mandatory merger regime in mid-December 2025, deferring key threshold components, most notably asset and control triggers, until 1 April 2026 while finalising a streamlined waiver framework.
• China: The State Administration for Market Regulation (SAMR) consulted on granular platform compliance guidance which addressed algorithmic collusion, MFNs, and refusal-to-deal risks. It also issued safe-harbour thresholds for vertical agreements effective 1 February 2026 and guidance on review of non-horizontal mergers.
• Hong Kong: The Hong Kong Competition Commission (HKCC) secured voluntary contract changes and a binding commitment from food delivery platform Keeta to remove exclusivity and parity terms that could hinder entry and soften competition.
• Philippines: The Philippine Competition Commission (PCC) deputised the National Bureau of Investigation (NBI) for a dawn raid tied to alleged bid rigging in flood control projects.
• Taiwan: The Taiwan Fair Trade Commission (TFTC) proposed higher merger thresholds and adjusted “monopolistic enterprise” sales criteria to reflect market growth and administrative efficiency, likely reducing mid market filings if adopted.
• Indonesia: The Indonesian Competition Commission (KPPU) issued a failure to file fine for notifying an acquisition under the wrong entity, underscoring strict procedural compliance even where substantive concerns are absent. Parliament also advanced a 2026 reform package that would introduce leniency, shift to pre completion merger control, expand powers, and adopt extraterritorial reach, aligning the regime more closely with OECD practice.
• UAE: The Ministry of Economy & Tourism (MOE) issued its first substantive competition complaint guidelines detailing who may complain, where to file, evidentiary expectations, market harm articulation, and relief parameters, promoting a more transparent and evidence driven enforcement environment.
• Saudi Arabia: Amid robust deal flow, the General Authority for Competition (GAC) maintained an efficient and facilitative regime in 2025, with heavy participation from foreign parties, particularly U.S. investors. The authority handled 427 concentration filings, granted 269 no-objection clearances, issued few conditional approvals, and completed reviews in an average of just 5.4 days.

CLQ Editorial team: Angie Ng, Partner; Kailun Ji, Counsel; Adelle Elhosni, Senior Associate; Candice Upfold, Senior Associate; Chelsea Toner, Associate; Danny Xie, Associate; Dee Dee O'Shannassy, Associate; Yiyun Feng, Associate and Aroon Parthasarathy, Associate.