Competition Law Quarterly Asia Pacific

In the third quarter of 2025 several key themes in competition law emerge across the APAC and Middle East - heightened cartel enforcement, evolving merger regimes, and an ongoing growing focus on digital-platform conduct.

Among the most notable developments

• Australia – Record-breaking cartel fines against a flat steel manufacturer and a distributor of building management systems are upheld in the Full Federal court while the Australian Competition and Consumer Commission (ACCC) issues two fresh civil cartel suits. Meanwhile, first clearances under the forthcoming mandatory merger regime are obtained and a draft waiver form for non-problematic deals is published for consultation as the ACCC prepares for the formal commencement of the new mandatory merger regime on 1 January 2026.
• Brunei – Full commencement of abuse-of-dominance and anti-competitive merger provisions means all three pillars of the Brunei Competition Act are now operative and while the merger regime in Brunei remains voluntary, the new prohibition against anti-competitive mergers introduces a new level of scrutiny for merger and acquisition activity.
• China – The State Administration for Market Regulation (SAMR) ordered its first ever unwinding of a below-threshold merger in the pharmaceutical sector and imposed remedies on two below-threshold tech acquisitions underscoring the authority's strong “call-in” policy for mergers in sensitive industries.
• Hong Kong – Three multi-sector dawn-raid operations covering twenty-five premises and a second review of the vessel-sharing block exemption highlight the Hong Kong Competition Commission's (HKCC) twin priorities of cartel deterrence and calibrated industry carve-outs.
• Indonesia – The Indonesian Competition Commission (KPPU) issued its largest fine to date (c. USD 27 million) against several entities for anti-competitive truck-sales practices - capping a year that also saw a sizeable abuse-of-dominance penalty in the tech sector.
• Malaysia – The Malaysia Competition Commission (MyCC) released a near-final Digital Economy Ecosystem market-study report that flags dominance and transparency concerns across mobile operating systems, e-commerce, ad-tech and online travel.
• Thailand – The Trade Competition Commission of Thailand (TCCT) draft guidelines on unfair trading by multi-sided digital platforms propose ex-ante rules on pricing, self-preferencing, data leveraging and algorithmic manipulation, dovetailing with the contemplated Platform Economy Act.
• UAE – The revamped merger-control thresholds have been in force for six months and forthcoming implementing regulations are expected to help clarify their practical application. As we reflect on key learnings on the new regime, it is clear that early filing assessments are becoming indispensable for dealmakers in the region.

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