Competition Law Quarterly Asia Pacific
23 April 2025
Welcome to the first quarter edition of our Competition Law Quarterly for 2025. In this edition, we cover the latest developments in competition law across key Asia Pacific jurisdictions in the beginning of 2025, with a focus on enforcement trends, merger control, enforcement actions and legislation development.
Salient developments covered by this edition include:
- looking back at the major legislative developments and enforcement trends in China for 2024;
- enforcement priorities released by the Australian Competition and Consumer Commission (ACCC) for 2025-26;
- merger control reform in Australia and the UAE, respectively.
- In Australia, in preparation for the shift towards to the new mandatory merger control regime effective in January 2026, the ACCC has published guidance on the transitional arrangements that will affect businesses from 1 July 2025 and a draft merger assessment guidelines for public consultation. The guidance and draft guidelines clarify timing, process issues, and substantive analysis for the merger review process.
- In the UAE, the new merger control thresholds have been announced and will apply to transactions involving parties active in the UAE. While this has clarified the turnover and market share thresholds, further clarifications are required for the definitions of certain key concepts, such as control and relevant markets.
- active enforcement actions taken by the competition authorities in China, Hong Kong, Indonesia, and Malaysia against various forms of anti-competitive conduct.
- In China, Shanghai Administration for Market Regulation fined three pharmaceutical firms for horizontal monopoly agreements. Notably, an employee of one of the companies was fined CNY 500,000 (c. USD 70,000), marking the first instance of the individual liability under the 2022 Anti-Monopoly Law.
- In Hong Kong, the first criminal conviction for obstruction of an investigation by the Hong Kong Competition Commission (HKCC) underscores the seriousness of non-compliance with the HKCC's investigative powers and highlights the potential personal liability for employees involved in such violations.
- In Indonesia, the Indonesian Competition Commission fined a company for submitting a notification 13 working days late after the filing deadline which is 30 working days post-closing.
- In Malaysia, the Malaysian Competition Commission fined eight companies for rigging road construction bids, demonstrating its active enforcement of bid rigging cartel conduct.
- continuous development of legislations to tackle novel competition concerns in each of China, Taiwan and Thailand.
- In China, the State Administration for Market Regulation issued guidelines to analyse anti-monopoly rules in the pharmaceutical sector, including on key topics such as product hopping, pay-for-delay, resale price maintenance, and excessive pricing.
- In Taiwan, the Taiwan Fair Trade Commission published guidelines on concerted actions in the context of environmental sustainability, aiming to help businesses achieve Taiwan's net-zero emissions target by 2050 while complying with the Fair Trade Act.
- In Thailand, the official draft of the Platform Economy Act (PEA) was released for public comment. Digital platforms in Thailand should be preparing for the obligations that will be imposed under the PEA, particularly if they are likely to be classified as a "gatekeeper" or a Very Large Online Platform.
The interactive map was last updated on 23 April 2025.
CLQ Editorial team: Angie Ng, Partner; Adelle Elhosni, Senior Associate; Kailun Ji, Senior Associate; Chelsea Toner, Associate; Danny Xie, Associate; Dee Dee O'Shannassy, Associate; Aroon Parthasarathy, Associate and Yiyun Feng, Associate.
